Who We Are
Woobi’s registered office is at 9 Ehad Ha’am St. Tel Aviv and we are a company registered in Israel under company number 514234673. We act as the data processor when processing your data. Our designated Data Protection Officer Mr. Ben Lifshits can be contacted at +972-77-21-86536 / DPO@woobi.com.
Information That We Process
Woobi processes your personal information to meet our legal, statutory and/or contractual obligations and to provide you with our products and services. We will never collect nor process any unnecessary personal data from you and do not process your information in any way, other than as specified in this notice.
The personal data that we receive about data subject (whether directly and/or from the data controller) comprises of:
- Cookie IDs
- Device Advertising IDs
- IP addresses
- GPS coordinates
- Browser data
- User agent
- mobile carrier
- User demographic
- User interests
- Website URLs
- App name and bundle ID
- mobile device characteristics(such as OS, Device Make and device model)
- and other non-directly identifiable information which are necessary for the purpose of serving an advertisement
Additionally, When downloading materials or registering on our site, as appropriate, you may be asked to enter your name, email address, mailing address, phone number or other details to help you with your experience.
The information is obtained in the below ways:
We collect information from you when you register on our site, subscribe to a newsletter, respond to a survey, fill out a form, Use Live Chat, Open a Support Ticket, Provide us with feedback on our products or services or enter information on our site.
Within the targeted advertising services we provide, we collect the information through our advertising channels
- RTB (real time bidding) bid request – all data will be provided through the bid request and will be received form one of our controllers
- Woobi Video Player – Data will be provided from a controller, client base data such as IP address and user agent, will be collected directly by Woobi
- Woobi SDK– data will be provided from a controller, device data such as advertising ID OS, OSV, IP address will be collected directly by Woobi.
How We Use Your Personal Data
Social Tokens Ltd. (DBA “Woobi”) takes your privacy very seriously and will never disclose or share your data without your consent; unless required to do so by law. We only process your data for as long as is necessary and for the purpose(s) specified in this notice. Where you have consented to us providing you with promotional offers and marketing, you are free to withdraw this consent at any time. The purposes and reasons for processing your personal data are detailed below: –
- Targeting: for the purpose of serving ads that are more likely to be relevant to you based on the geo, demographic, interest, etc. data collected for this purpose.
- Frequency capping: Making sure that you don’t see the same ad too many times.
- Fraud Identification and Prevention: to ensure our Advertisers’ ads are served to real users, and any measured metrics are not influenced by illegal or fraudulent activities.
- Monitoring and optimization: Monitoring the results and performance of a campaign served on behalf of an Advertiser so that we can measure the result achieved and optimize both during the campaign duration as well as post campaign.
- Reporting: Providing our Advertisers with detailed reports as to the performance of their ads, including various campaign metrics and measurement KPI’s (impressions, click-through-rate, view-through rate, overall completion rate, conversions Reporting is made in aggregated form, not on a per-user basis.
As for information you directly opted into while using our website when you register, sign up for our newsletter, respond to a survey or marketing communication, surf the website, or use certain other site features, this information may be used in the following ways:
- To personalize your experience and to allow us to deliver the type of content and product offerings in which you are most interested.
- To improve our website in order to better serve you.
- To allow us to better service you in responding to your customer service requests.
- To administer a contest, promotion, survey or other site feature.
- To ask for ratings and reviews of services or products
- To follow up with them after correspondence (live chat, email or phone inquiries)
You have the right to access any personal information that Social Tokens LTD. (DBA “Woobi”) processes about you and to request information about:
- What personal data we process about you
- The purposes of the processing
- The categories of personal data concerned
- The recipients to whom the personal data has/will be disclosed
- How long we intend to store/process your personal data for, if any
- If we did not collect the data directly from you, information about the source
If you believe that we hold any incomplete or inaccurate data about you, you have the right to ask us to correct and/or complete the information and we will strive to do so as quickly as possible; unless there is a valid reason for not doing so, at which point you will be notified.
You also have the right to request erasure of your personal data or to restrict processing (where applicable) in accordance with the data protection laws; as well as to object to any direct marketing from us. Where applicable, you have the right to data portability of your information and the right to be informed about any automated decision-making we may use, including:
- Advertisement targeting and optimization
- Real time bidding on ad placements
- Fraud identification and prevention
If we receive a request from you to exercise any of the above rights, we may ask you to verify your identity before acting on the request; this is to ensure that your data is protected and kept secure.
Sharing and Disclosing Your Personal Information
We do not share or disclose any of your personal information without your consent, other than for the purposes specified in this notice or where there is a legal requirement. Social Tokens LTD. (DBA “Woobi”) uses third parties to provide the below services and business functions; however, all processors acting on our behalf only process your data in accordance with instructions from us and comply fully with this privacy notice, the data protection laws and any other appropriate confidentiality and security measures.
- Demand partners– clients purchasing advertisement placements such as DSPs (Demand side platforms), Agencies, Trading Desks and Brand Advertisers.
- Fraud detection, prevention and control partners
- DMPs (data management platforms) – for ad targeting and optimization
Social Tokens Ltd. (DBA “Woobi”) takes your privacy very seriously and takes every reasonable measure and precaution to protect and secure your personal data. We work hard to protect you and your information from unauthorised access, alteration, disclosure or destruction and have several layers of security measures in place, including:
- Access Control (& Firewalls)
- Data Transfer Encryption
- Data Fragmentation & Segmentation
Transfers Outside the EU
Social Tokens Ltd. (DBA “Woobi”) transfers personal data outside of the EU in accordance with our International Data Trasfer Policyץ
This policy is to be read in conjunction with our Data Protection Policy and provides our procedures for transferring personal data outside the EU. We adhere to the Regulation for all non-EU transfers and have robust transfer safeguarding measures and controls in place to protect the personal data and the rights of the data subject in line with the Privacy Shield Framework Principles issued by the U.S. Department of Commerce, located at https://www.privacyshield.gov (“Privacy Shield Principles”) to all Personal Data that Company transfers to processors and/or sub-processors that originates from the European Economic Area or Switzerland (“EEA Data”).
Purposes for such transfer may include:
Region-based data processing on a global scale: our application is a global one and we have a data center in each one of our regions. Data is replicated through all the regions for reasons including processing within the region, fail-over and reduced latency
Where we transfer personal information for the above reasons, we utilise any and all safeguarding measures and mechanisms to ensure that your personal data is always safe and secure. These measures can be found in our International Data Transfer Policy.
Consequences of Not Providing Your Data
You are not obligated to provide your personal information to Social Tokens Ltd. (DBA “Woobi”), however, as this information is required for us to provide you with our services, we will not be able to offer some/all our services without it.
We occasionally process your personal information under the legitimate interests’ legal basis. Where this is the case, we have carried out a thorough Legitimate Interests’ Assessment (LIA) to ensure that we have weighed your interests and any risk posed to you against said interests; ensuring that they are proportionate and appropriate.
How Long We Keep Your Data
Social Tokens Ltd. (DBA “Woobi”) only ever retains personal information for as long as is necessary and we have strict review and retention policies in place to meet these obligations. We keep your basic personal data for a maximum 12 month per processed record after which time it will be destroyed.
Where you have consented to us using your details for direct marketing, or opted in to such service, we will keep such data until you notify us otherwise and/or withdraw your consent.
Occasionally, Social Tokens Ltd. (DBA “Woobi”) would like to contact you with product/service offerings, company news, industry updates, new platform features released, educational posts, promotion offers and more. If you consent to us using your contact details for this purpose, you have the right to modify or withdraw your consent at any time by using the opt-out/unsubscribe options or by contacting Social Tokens Ltd. directly.
If you consent to us contacting you with the above-mentioned marketing and offers, please tick to say how you would like to be contacted:
Post ☐ Email ☐ Telephone ☐ Text Message (SMS) ☐ Automated Call ☐
Additionally, you may be presented with information, marketing material and/or promotion sent to you by email that have been identified as being beneficial to our customers and in our interests. Such information will be relevant to you as a customer and is non-intrusive and you will always have the option to opt-out/unsubscribe at any time.
Lodging A Complaint
Social Tokens Ltd.
Mr. Ben Lifshits, DPO
9 Ehad Ha’am St. Tel Aviv, Israel
firstname.lastname@example.org / +972-77-21-86536
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Ongoing COPPA (Children Online Privacy Protection Act) Compliance
The Children’s Online Privacy Protection Act (COPPA) is a United States federal law that is designed to give parents control over the information collected from their young children online. COPPA prohibits the collection, use, or disclosure of personal information from children under 13 unless given parental consent. The Federal Trade Commission, United States’ consumer protection agency, enforces the COPPA Rule, which spells out what operators of websites, apps and online services must do to protect children’s privacy and safety online.
Social Tokens Ltd. (DBA “Woobi”) operates in full compliance, in addition to GDPR, also with the COOPA requirements, and does not collect nor process data from children under 13
Years of age. Woobi does not enable ads be served on apps / websites that are directed at children under the age of 13, and holds its supply partners and publishers responsible for complying with these restrictions.
9 Ehad Ha’am st.
Tel Aviv, 6525101