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プライバシーポリシー

Effective Date: January 1, 2020

Welcome to the KADS website (the "Site"). 

As we are committed to protect your rights to privacy, we are providing this Privacy Policy (the "Privacy Policy") in order to describe our practices regarding the information we may collect or to which we may have access, through your use of our Website, App and Services (together the Platform) and the manner in which we may use such information, and the choices and rights available to you.

Please note: you are not obligated by law to provide us with any Personal Information.

1.WHAT INFORMATION DO WE COLLECT?

a.First - What is personal information?

Personal information is individually identifiable information, namely information that identifies an individual or may with reasonable efforts or together with additional information we have access to, enable the identification of an individual, or may be of private or sensitive nature information relating to an identified or identifiable natural person. Identification of an individual also includes association of such individual with a persistent identifier such as a name, an identification number, persistent cookie identifier etc.

Personal information does not include information that has been anonymized or aggregated so that it can no longer be used to identify a specific natural person.

b.We collect personal information from you when you use or interact with our Platform

We collect personal information from you and any devices (including mobile devices) you use when you: use or access our Platform, register for an account with us, provide us information on a web form or other text field, update or add information to your account, or through correspondence you and we conduct with each other.

More specifically we collect and use the following categories and types of information:

>Personal information you provide us when you use our Platform

Generally, this category refers to any information, data or content you actively and voluntarily create or provide through our Platform.

*Contact information such as your name, email and physical addresses, or telephone number when you fill our online form or register for an account with us or when you update your accounts details.

*Information you provide during a transaction, or other transaction-based content that you generate or that is connected to your use of the Platform as a result of a transaction you are involved in such as your eyeglasses prescription.

*Other content that you generate, or your actions in your use of your account (such as adding items to your shopping cart, adding items to your saved items list etc.

*The contents of your interaction with our customer support or sales departments, which may include text/video/audio recording and transcripts of such communications.

*Financial information (such as credit card or bank account numbers), which is processed by our third party services providers as further detailed below and to which we have no access.

*Shipping, delivery, postage, billing and other information used to transact and deliver through the Platform, as well as, where applicable, information required to clear customs (such as Tax ID or other identification numbers).


*Information you voluntarily provide to the Platform for the purpose personalization of your interface with the Platform such as age, preferred language, preferences etc.

*You may also provide us information through your use of certain functionalities we make available to you through the Platform such as chats with support representatives,

*Information we are required or authorized by applicable national laws to require you to provide us in order to authenticate or identify you or to verify the information we have collected or otherwise provide you with our Platform.

>>Personal information you provide us when you use our Platform
 

*We collect information about your interaction with our Platform, in certain cases about your impressions of and reactions to our advertisements, and information related to our communications with you. This is information we receive from devices (including mobile devices) and software you use when you access our Platform. This information could include the following: Device ID or unique identifier, device type, ID for advertising, unique device token, operating system, information regarding your clicks, views and engagement with our advertisement and Services, information concerning your traffic to and from the Platform, your referral URL, ad data, your IP address, your web log information, and your location information, including location information from your mobile device or as can be derived from your IP address.

We perform such automatic collection through use of cookies, web beacons, unique identifiers, and similar technologies which allow us to collect information about the pages and screens you view, the links you click, and other actions you take when using our Platform, within our advertising or email content, as further detailed in section 5.

Please take into consideration that certain portions of such abovementioned information may also be collected from your device or software, when the Platform is running in the background, i.e. when they have been launched but are not used.

For more information about our use of these technologies, and how to control them, see our Cookies Policy


Please keep in mind - that most mobile devices and auxiliary software, allow you to control or disable the use of certain collectable information including location services, by any application, in the device's settings menu.

 

>>Personal information collected from other sources


*We may also collect personal information concerning you, from third parties who have assured us that they have obtained your consent for such provision of information or that you have freely and publicly provided. For example, we may collect and use demographic and other information that is publicly available in an applicable jurisdiction, additional contact information, credit/check information, and information from credit bureaus, as allowed by applicable national laws.


*Social Media: We allow you to share information with social platforms, or use social platforms to create your account or to connect your account with the respective social platforms. Those social platforms may give us automatic access to certain personal information retained by them about you (e.g., content viewed by you, content liked by you, and information about the advertisements you have been shown or have clicked on, etc.). You control the personal information you allow us to have access to through the privacy settings on the applicable social platforms and the permissions you give us when you grant us access to the personal information retained by the respective social platforms about you.


By associating an account managed by a social platform with your account and authorizing us to have access to this information, you agree that we can collect, use and retain the information provided by these social platform in accordance with this Privacy Policy.


*If you give us personal information about someone else, you must do so only with that person’s express authorization. For example, we may enable you to invite your friends and family to use our Platform, by providing us with their contact details in order for us to contact them on your behalf, or by providing you with our URL link or other code, to be used by such friends and family. You should inform such friends and family how we collect, use, disclose, and retain their personal information according to this Privacy Policy prior to sharing such information with us.


1.What are the Purposes of the Collection and Processing of Personal Information
 

Legal basis for use.
 

We collect, process and use your information for the purposes described in this Privacy Policy, based at least on one of the following legal grounds:  
 

*When Performing the Services: We collect and process your Personal Information in order to provide you with the Services, following your acceptance of this Privacy Policy; to maintain and improve our Services; to develop new services and features for our Users; and to personalize the Services in order for you to get a better user experience. For example, we may display to you offers and products which we think will be more relevant to your taste, based on your browsing habits on our Website.
 

*Legitimate interests:We process your information for our legitimate interests while applying appropriate safeguards that protect your privacy. This means that we process your information for things like detecting, preventing, or otherwise addressing fraud, abuse, security, usability, functionality or technical issues with our services, protecting against harm to the rights, property or safety of our properties, or our users, or the public as required or permitted by law; enforcing legal claims, including investigation of potential violations of this Privacy Policy; in order to comply and/or fulfil our obligation under applicable laws, regulation, guidelines, industry standards and contractual requirements, legal process, subpoena or governmental request, as well as our Terms of Service.

*With your consent: We ask for your agreement to process your information for specific purposes and you have the right to withdraw your consent at any time. For example, we ask for your consent to send you our marketing offers and communications.

Purpose of Use.

We may use personal information that we collect about you for the following purposes:

*To provide and improve our Platform and its various functions and features and to manage our business;

*To send you updates, notices, notifications, announcements, and additional information related to the Platform;

*To be able to manage your account and provide you with customer support and technical assistance;

*To display or send to you marketing and advertising material and general and personalized content and advertisement via the Platform, email, postal mail, telephone, mobile devices and/or when you visit other sites, and to track and analyze the effectiveness and relevance of such material;

*To create cumulative statistical data and other cumulative information and/or other conclusive information that is non-personal, in which we might make use, in order to operate and improve our Website and provide our Services;

To verify your eligibility and deliver prizes in connection with promotions and referral programs we may hold from time to time;

*To prevent, detect, mitigate, and investigate fraud, security breaches or other potentially prohibited or illegal activities, including any breaches of this Privacy Policy or of our Terms of Use

*To comply with any applicable rule or regulation and/or response or defend against legal proceedings versus us or our affiliates.

1.WHERE DO WE PROCESS AND STORE USER’S PERSONAL INFORMATION?

Information regarding the Users will be maintained, processed and stored by us and our authorized affiliates and service providers in various locations around the world, including, without limitation, the United States. Any and all personal information that we collect from our users is maintained in secured cloud storage environments provisioned by third party cloud providers.

It’s our policy, irrespective of the jurisdictions wherein our Users are located, to maintain all User-supplied data in secure environments provisioned by third parties that : (i) have assured us of the safeguards which they implement to protect your privacy, or (ii) hold and process such information on our behalf either in jurisdictions which have been determined to ensure an adequate level protection by the EU Commission, and in the case of U.S., includes certification under the EU-US Privacy Shield framework.

We utilize standard contract clauses , rely on the European Commission's adequacy decisions about certain countries, as applicable, and obtain your consent for these data transfers to the United States and other countries.

2.TO WHOM WE SHARE PERSONAL INFORMATION

We may share your personal information with third parties (or otherwise allow them access to it) only in the following manners and circumstances:

Third Party Services: We partner with a number of selected service providers, whose services and solutions complement, facilitate and enhance our own. These include hosting, data and cyber security services, fraud detection and prevention services, merchant processing, shipping, postal and delivery services, website and mobile app functionality, manufacturing services, e-mail and text message distribution and monitoring services, advertising, affiliation and related analytics services, customer support and call center services, as well as our business, legal and financial advisors, and others (collectively, "Third Party Service Providers"). Each such Third-Party Service Provider may receive or otherwise have access to your personal information through your use of our Services, and may only use your personal information for such purpose(s) as expressly authorized by us. Such disclosure or access is strictly subject to the recipient's or user's undertaking of confidentiality and appropriate safeguards obligations, as well as the prevention of any independent right to use your personal information, subject to applicable law.

Governmental/Law Enforcement Agencies and Legal Requests or Duties: We may disclose or otherwise allow access to Personal Information pursuant to a legal requirement or request, such as a subpoena, search warrant or court order, or in compliance with applicable laws and regulations. Such disclosure or access may occur with or without notice to you, if we have a good faith belief that we are legally required to do so, or that disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing.

Protecting Rights and Safety: We may share your personal information with others, with or without notice to you, if we believe in good faith that this will help protect the rights, property or personal safety of our Company, of any of our Users, or any members of the general public.

Our Affiliated Companies: We may share personal information internally within our affiliates for the purposes described in this Privacy Policy. In addition, should we or any of our affiliates undergo any change in control, including by means of merger, acquisition or purchase of substantially all of our assets, your personal information may be shared with the parties involved in such event. If we believe that such change in control might materially affect your personal information then stored with us, we will notice you of this event and the choices you may have via e-mail and/or prominent notice on our Platform.


3.YOUR RIGHTS

You can make choices regarding our collection and use of the personal information you share with us. You can control your personal information that we have obtained by emailing the Company at [email protected]. By way of example, you may request (i) access to the personal information we’ve collected from/about you, (ii) that updates are made to your personal information, (iii) that we cease using your personal information to contact you, and (iii) we delete the personal information about you in our records. We will undertake to respond to your request within 30 days of receipt thereof. In some cases, your ability to access or control your personal information will be limited, as required or permitted by applicable law. If that should happen, the Company will notice you accordingly. How you can access or control your personal information will also depend on which Services you use. For example, if you ask us to delete your personal information, we may not be permitted to do so if you’ve made a purchase via our Platform. We will retain your information for as long as your account is active or as needed to provide you access to the Services. We will also retain and use your information as necessary to comply with our legal obligations, resolve disputes, and to enforce our agreements.

For the removal of doubt, we expressly reserve the right to transfer, share or otherwise use non-personally identifiable information (e.g., anonymous, aggregated information) in our sole discretion and without the need for further approval.

4.DIRECT MARKETING

By registering to our Services and/or providing us with your e-mail address or any other contact information (including without limitation through any form on our Website), you hereby agree that we may contact you for the purpose of informing you regarding our products and services which may interest you, and in order to send to you other marketing material. You may withdraw your consent by sending us written notice by email to the following address: [email protected] or by pressing the "Unsubscribe" button contained in the promotional communications you receive. Please note that the Company may also contact you with important information regarding your use and interaction with our Services. For example, we may notice you (through any of the means available to us) of changes or updates to our Services, payment issues, service maintenance, etc. You will not be able to opt-out of receiving such service messages.

5.MINORS

To use our Platform, you must be over the age of sixteen (16). Therefore, we do not knowingly collect personal information from minors under the age of sixteen (16) and do not wish to do so. Any purchase of products through our Properties that is intended for a child under sixteen (16) years of age, must be carried out by his/her legal guardian within such legal guardian’s account, and without providing us any personal information of such child.

We reserve the right to request proof of age at any stage so that we can verify that minors under the age of sixteen (16) are not using the Services. If we learn that we have collected personal information from a child under sixteen (16) years, we will delete that information as quickly as possible. If you believe that we might have any such information, please contact us at [email protected].

6.INFORMATION SECURITY

We take great care in implementing and maintaining the security of our Platform. We employ industry standard procedures and policies to ensure the protection of personal information, and to prevent unauthorized use of any such information. Among other means we use Secure Socket Layer (SSL) technology, which creates an encrypted link between our web server and your browser, and provides a secured path of communication to ensure the information remains protected and private. Please note however, that regardless of the measures we take and the efforts we make, we cannot and do not guarantee the absolute protection and security of any personal information.

7.UPDATES TO THIS PRIVACY POLICY

From time to time, we may change the terms of this Privacy Policy. Changes will take effect once they are posted online and by accessing and/or using the Services after we make any such changes to this Privacy Policy, and you are deemed to have accepted such changes. If you do not agree with any of the amended terms, you must avoid any further use of the Properties and/or the Services provided thereon.

8.GENERAL INFORMATION

This Privacy Policy, its interpretation, and any claims and disputes related hereto, shall be governed by the laws of the State of Israel. Any and all such claims and disputes shall be brought in, and you hereby consent to them being litigated in and decided exclusively by a court situated in Israel.

Our Properties may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites may have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal information to these websites

9.HAVE ANY QUESTIONS?

If you have any questions (or comments) concerning this Privacy Policy, you are welcome to send us an email at: [email protected] and we will make an effort to reply within a reasonable timeframe.

By contacting us, and accessing the Platform, you warrant and agree that you are free to do so, and that you are not providing us with information which violates any third party intellectual or privacy rights.

COOKIE POLICY

We use certain monitoring and tracking technologies, including ones offered by third party service providers to collect and process the personal information we specified above. These technologies are used in order to maintain, provide and improve our Platform on an ongoing basis, in order to provide a better experience to our Users and to provide our customers and potential customers with more relevant advertisements of our Services. For example, these technologies enable us to: (i) keep track of and apply our Customer's and Potential Customers’ Services and Website preferences and authenticated sessions, (ii) better secure our Services by detecting abnormal behaviors, (iii) identify technical issues and improve the overall performance of our Services, (iv) monitor and analyze our ads’ performance (v) create and monitor analytics relating to use of our Services, and (v) deliver to you targeted advertisements that are more tailored to you based on your browsing activities and inferred interests.

Based on the foregoing, we’ve adopted this policy ("Cookie Policy") to explain how we use cookies and your related choices and options. In this policy we use the term "cookies" to refer to any applicable tracking technologies described herein.


>>WHAT ARE COOKIES

*Cookies are a small text file that is stored on your device to help websites and mobile apps remember things about you. Session-based cookies last only while your browser is open and are automatically deleted when you close your browser. Persistent cookies last until you or your browser delete them or until they expire. To learn more about cookies, visit http://www.allaboutcookies.org/

*Pixel Tags (also known as web beacons or clear GIFs) are transparent images, iFrames, or JavaScript placed on a website or in marketing emails that are used to understand how you interact with such websites or emails.

*Social Media Features, such as the Facebook "like" button, may collect your IP address and which page you are visiting on a website, and may set a cookie to enable the feature to function properly. Your interactions with these features are governed by the privacy policy of the company providing the relevant Social Media Features.

*Single Sign-on allows you to log in to certain websites or mobile applications using sign-in services provided by third parties, such as Facebook or Google. These services will authenticate your identity and provide you the option to share certain personal information with us such as your name and email address to pre-populate our sign-up form.

>>HOW WE USE COOKIES

The cookies we use can be classified in one of the following categories:
 
Strictly Necessary cookies We use these cookies to enable you to use our Platform’s features, such as enabling movement between pages and remembering information you enter on forms.
Without these necessary cookies, services and functions on our Website will not be possible and our Website will not perform as it should.
Security cookies We use these cookies to help identity and prevent security risks.
Authentication cookies We use these cookies to help us show you the right information and settings when you are logged-in to our website.
Performance and Analytics cookies We use these cookies to collect information about Users’ use of our Platform to help improve the way the Platform works. An example is counting the number of different people coming to our website or using a particular feature, rather than the total number of times the site or feature is used. Without this cookie, if you visited the website once each week for three weeks we would count you as three separate users. We would find it difficult to analyze how well our website was performing and improve it without these cookies.
Functionality and Preference cookies We use these cookies to remember the choices you make such as which language you prefer and to provide you with personalized features.
Targeting and Advertising cookies We use these cookies to deliver you with ads when you browse the web that are more relevant to you and your interests, by remembering information such as what you looked at on our Platform and to track the performance of these ads.
Social Sharing cookies We use these cookies to allow you to share content directly on the social network/sharing sites, like Facebook, Twitter or Google+ on which you have a user account. Examples would be if you wanted to "like" or "tweet" about a service or product advertised on our website

>>YOUR CHOICES

*Strictly Necessary Cookies: Because these cookies are essential to operate our website, there is no option to opt out of these cookies.

*Targeting and Advertising Cookies:

*You can opt out of interest-based targeting provided by participating ad servers through the Network Advertising Initiative at www.networkadvertising.org/managing/opt_out.asp or the Digital Advertising Alliance at www.aboutads.info/

*You may be able to change your device settings (on your iPhone, iPad or Android) to control whether you see online interest-based ads

*You can opt out of some (but not all) of third party tracking technologies by following the instructions provided by the applicable third party service providers listed in the table below in their privacy policy.

*You can learn more about your options by visiting www.youradchoices.com or www.youradchoices.eu

*Other Cookies:

*You can follow the instructions provided by your website or mobile browser (usually located within the "Help", "Tools" or "Edit" facility) to modify your cookie settings.

*You can opt out of some (but not all) of third party tracking technologies by following the instructions provided by the relevant third party service providers listed in the table below, in its privacy policy:
 
Third party & Type of cookies Service provided
Google Optimize - Analytics This cookie allows us to test and evaluate the best ways to present our website to our users.
https://policies.google.com/technologies/cookies
Google - Analytics Google provide anonymized data about the visits made to our website.
https://policies.google.com/privacy?hl=en&gl=uk
Google - Social Sharing Google store cookies which allow the "Google +"social sharing" functionality.
https://policies.google.com/privacy?hl=en&gl=uk
Facebook - Social Sharing Facebook store cookies which allow the Facebook "Like" social sharing functionality but only if you click on the Facebook "Like" button on our website or log in using your Facebook account.
https://www.facebook.com/about/privacy/
Twitter - Social Sharing Twitter also store cookies which allow their social sharing functionality including the "Tweet" function and to generate usage information during your visit to our website.
https://twitter.com/en/privacy
Google Adwords - Analytics This cookie allows us to measure performance to improve the relevancy of advertising and to reduce the number of ads you receive.
https://policies.google.com/privacy?hl=en&gl=uk
Google Double Click - Analytics This cookie allows us to measure performance to improve the relevancy of advertising and to reduce the number of ads you receive.
https://policies.google.com/privacy?hl=en&gl=uk
Facebook - Analytics This cookie allows us to measure performance to improve the relevancy of advertising and to reduce the number of ads you receive.
https://www.facebook.com/about/privacy/
Twitter - Analytics This cookie allows us to measure performance to improve the relevancy of advertising and to reduce the number of ads you receive.
https://twitter.com/en/privacy
OATH - Yahoo – Gemini - Analytics This cookie allows us to measure performance to improve the relevancy of advertising and to reduce the number of ads you receive.
https://gemini.com/privacy-policy/
Microsoft – Bing - Analytics This cookie allows us to measure performance to improve the relevancy of advertising and to reduce the number of ads you receive.
https://advertise.bingads.microsoft.com/en-us/resources/policies/microsoft-bing-ads-privacy-policy

>>DELETING ALL WEB BROWSER COOKIES

All of the Web browser cookies we use are stored on Users’ browser local memory. Therefore, by deleting such cookies from your local memory, we will not be able to associate any information we have about you, unless you login to our Platform as a registered user.

>>DO NOT TRACK

We do not currently commit to responding to your browsers’ ‘Do Not Track’ signals with respect to our Platform, in part, because no common industry standard for ‘Do Not Track’ has been adopted by regulators, including no consistent standard of interpreting a user’s intent. We are committed to monitoring the developments around ‘Do Not Track’ and the implementation of a standard.

>>CHANGES TO THIS COOKIE POLICY

We may update this Cookie Policy from time to time. We encourage you to periodically review this Cookie Policy to stay informed about our use of cookies, the information we collect via cookies, and any updates in relation thereto. If we make any changes to this Cookie Policy that significantly impact the way we use cookies, we will endeavor to provide you with notice in advance of such change by highlighting the change on our Website. Your continued use of our Platform constitutes your agreement to this Cookie Policy and any updates.

>>CONTACT US

If you have any questions about our use of cookies, please contact us at [email protected].
 
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