RIPPLES LTD.

PRIVACY POLICY

This website is operated by Ripples Ltd. (“Ripples”)

This Privacy Policy explains our privacy practices for processing Personal Information on our Website, application and services. We process Personal Information as described in this Policy.

We are committed to protecting your privacy and processing your Personal Data fairly and lawfully in compliance with applicable data protections laws. You can access our full Privacy Policy below to help you better understand how we collect and use Personal Data pertaining to each of our Users. In it, we explain in more detail the types of Personal Data we collect, how we collect it, what is the legal basis of collection, what we may use it for, who we may share it with, what our retention periods are and what are your rights in relation to the Personal Data we collect.

Within the Privacy Policy you will find some specific examples of why and how we use your Personal Data.

Read this policy and make sure you fully understand our practices in relation to your Personal Data, before you access or use the Website or application.  If you read and fully understand this Privacy Policy, and remain opposed to our practices, you must immediately leave this Website, application or service, and avoid or discontinue all use of the Website and application. If you have further questions or concerns regarding this policy please contact us at: info@drinkripples.com

FULL PRIVACY POLICY

Ripples Ltd. (“Ripples”, “we, our” or “us”) provides this Privacy Policy, as will be updated from time to time (our “Policy” or “Privacy Policy”) to inform the visitors of our Website and application (“you” or “User”) of our policies and procedures regarding the collection, use and disclosure of information we receive when you use the Website and application.

  1. Definitions:

Personal Data” means individually identifiable information, namely information that identifies an individual or may with reasonable efforts cause the identification of an individual.

Non Personal Data” means information that does not personally identify you and does not reveal your specific identity as an individual, such as anonymized information.

 

Visitor” or “User” or “you” means visitors and users of our Website and application.

Services” means use of our Platform by Users.

Website” means our public website available at www.drinkripples.com providing details regarding the Services we provide for Users.

Platform” means the platform accessible through the “Log In” tab in the Website and application providing access for registered Users to the platform.

This Policy was originally written in English. If you are reading a translation and it conflicts with the English version, please note that the English version prevails.

  1. WHEN DOES THIS PRIVACY POLICY APPLY

This Privacy Policy applies to Personal Data that we collect about you, use or otherwise process regarding your relationship with us as a visitor of our Website and application.

This Privacy Policy does not apply to services that may have separate privacy policies that do not incorporate this Policy.

  1. THE TYPES OF PERSONAL DATA THAT WE COLLECT

PERSONAL DATA THAT YOU PROVIDE US

While browsing our Website and application and in the course of using the Services, you or others will provide us with Personal Data as part of the Services and information related to you that is added to the services through any interface or mechanism, such as content you upload to our application, registration information and any other means. This information may include your contact details such as: name, email, phone number, country and technical details of the site the user manages and for whom he wants to enquire more information about our Services.

THE PERSONAL DATA THAT WE COLLECT OR GENERATE

If you browse our Website and application, we may collect Personal Information. This includes (by way of a non-exhaustive list): your computer’s Internet Protocol address and your location through the use of “cookies”. A cookie is a small data file that we transfer to your computer’s hard disk for record-keeping purposes. We use cookies to enable certain features of the Services, to better understand how you interact with the Website and application and to monitor web traffic routing and aggregate usage of the Services. You can instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from the website you visit. If you do not accept cookies, however, you may not be able to use all portions or all functionality of the Services.

We may use GIFs in order to collect information. Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web pages.

We may use automated devices and applications, such as Google Analytics, to evaluate usage of our Service. We use these tools to help us improve our Services, performance and user experience. We may also engage third parties to track and analyze Service data or provide other services on Our behalf. Such third parties may combine the information that We provide about you with other information that they have collected. This Policy does not cover such third parties’ use of the data.

Other websites and applications may also place or read cookies on your computer’s browser.

  1. NON PERSONAL DATA

In addition to the categories of Personal Data described above, we will also process further anonymized information and data that is not processed by reference to a specific individual. We may collect this Non-Personal Data through the Website and application in the following ways:

  1. Information that your browser or application sends when you visit a website or online service (“Log Data”). This Log Data may include, but is not limited to, non-identifying information regarding the User’s device, operating system, internet browser type, screen resolution, language and keyboard settings, internet service provider, referring/exit pages, date/time stamps, the web page you were visiting and information you search, etc.
  2. We may use automated devices and applications to evaluate usage of our Service. We use these tools to help us improve our Services, performance and user experience. We may also engage third parties to track and analyze data or provide other services on our behalf. Such third parties may combine the information that we provide about you with other information that they have collected from other sources. This Policy does not cover such third parties’ use of the data and such use is governed by such third parties’ privacy policies.
  3. Other websites and applications may also place or read cookies on your computer’s browser. Please see below Section 7.
  4. HOW WE USE PERSONAL DATA

Personal Data is used for the following primary purposes (as may be updated from time to time): to (i) provide and operate the Services; (ii) monitor and analyze use of the Services and study and analyze the functionality of the Services; (iii) to provide ongoing customer assistance, technical support and maintain the Services; (iv) provide service announcements and notices, promotional messages and market our Services; (v) enforce our Terms of Use, policies and other contractual arrangements, to comply with court orders and warrants, and prevent misuse of the Services, and to take any action in any legal dispute and proceeding.; (iv) better understand your needs, both on an aggregated and individualized basis, in order to further develop, customize and improve our Services based on Users’ preferences, experiences and difficulties; (vi) communicate with you and contact you to obtain feedback from you regarding the Services; (vii) disclose to third party vendors, service providers, contractors or agents who perform functions on our behalf with respect to the Services; (viii) to create aggregated statistical data and other aggregated and/or inferred Non-Personal Data, which we or our business partners may use to provide and improve our Website; and (x) as otherwise authorized by you.

We may use your email address you provided us to contact you when necessary, including in order to send you reminders, offers and to provide you information and notices about the Services. At any time, you may choose (opt out) whether your Personal Data is to be used for sending such marketing materials which are not an essential part of the Services. You may exercise your choice by contacting us at: info@drinkripples.com

  1. HOW WE USE NON PERSONAL DATA

We may use information that is Non Personal Data for the same purposes we use Personal Data (where applicable) and in addition in order to (i) compile anonymous or aggregate information, (ii) disclose to third party vendors, service providers, contractors or agents who perform tasks on our behalf in connection with the Services, (iii) monitor and analyze use of the Services and for the technical administration and troubleshooting of the use of the Services, and (iv) provide us with statistical data.

We may use analytics tools. These tools help us understand users’ behaviour on our Website, including by tracking page content, and click/touch, movements, scrolls and keystroke activities. The privacy practices of these tools are subject to their own policies and they may use their own cookies to provide their services.

From time to time, we may use additional or alternative analytics services. We will provide a notice of these changes on our Website and application.

We use anonymous, statistical or aggregated information, which may be based on extracts of your Personal Data, for legitimate business purposes including for testing, development, improvement, control and operation of the Services. We may share such information with our third party providers. It has no effect on your privacy, because there is no reasonable way to extract data from the aggregated information that can be associated with you. We will share your Personal Data only subject to the terms of this Policy, or subject to your prior informed consent.

We use the following types of “cookies” to collect information:  analytics cookies, session cookies, functionality cookies, authentication cookies, ‘strictly necessary’ cookies and targeting or advertising cookies .A cookie is a small data file that we transfer to your computer’s hard disk for record-keeping purposes. We use cookies to enable certain features of the Services, to better understand how you interact with the Services and to monitor web traffic routing and aggregate usage of the services. You can instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from the website and application you visit. If you do not accept cookies, however, you may not be able to use all portions or all functionality of the Services.

  1. SHARING INFORMATION WITH OTHERS

We do not sell, rent or lease your Personal Data. We may share your Personal Data with service providers and other third parties, if necessary to fulfil the purposes for collecting the information, such as cloud vendors, subcontractors providing us processing services, etc., provided that any such third party will commit to protect your privacy as required under the applicable laws and this Policy.

Additionally, a merger, acquisition or any other structural change may require us to transfer your Personal Data to another entity, provided that the receiving entity will comply with this Policy.

  1. SHARING INFORMATION WITH AUTHORITIES

We may need to disclose Personal Data in response to lawful requests by public authorities or law enforcement officials, including meeting national security or law enforcement requirements. We cooperate with government and law enforcement officials to enforce and comply with the law.

  1. TRANSFER OF DATA OUTSIDE YOUR TERRITORY

We may store, process or maintain information in various sites worldwide, including through cloud-based service providers worldwide. Where the GDPR applies and we transfer Personal Data to another country outside the EEA, we will ensure that it is protected and transferred in a manner consistent with legal requirements. In relation to data being transferred outside of the EEA, for example, this may be done in one of the following ways:

  1. the country that we send the data to might be approved by the European Commission as offering an adequate level of protection for Personal Data (Israel is an approved country);
  2. the recipient might have signed up to a contract based on “model contractual clauses” approved by the European Commission, obliging them to protect your Personal Data;
  3. where the recipient is located in the US, it might be a certified member of the EU-US Privacy Shield scheme; or
  4. in other circumstances the law may permit us to otherwise transfer your Personal Data outside the EEA.

You can obtain more details of the protection given to your Personal Data when it is transferred outside the EEA (including a copy of the standard data protection clauses which we have entered into with recipients of your Personal Data) by contacting us as described the Section 7 below.

If you are located in a jurisdiction where transfer of your Personal Data to another jurisdiction requires your consent, then you provide us your express and unambiguous consent to such transfer or the storage, processing or maintenance of the information in other jurisdictions by using the Services.

  1. YOUR RIGHTS

In all of the above cases in which we collect, use or store your Personal Information, you may have the following rights and, in most cases, you can exercise them free of charge.

At any time, you may contact us at: info@drinkripples.com and request to know what Personal Data we keep about you. We will make good-faith efforts to locate the data that you request to access.

Under your right of access, you may obtain confirmation from us of whether we are processing Personal Data related to you, receive a copy of that data, so that you could verify its accuracy and the lawfulness of its processing, request the correction, amendment or deletion of the data if it is inaccurate, incomplete, outdated or processed in violation of applicable law.

However, we may retain certain information as deemed required by us in accordance with applicable laws, or for legitimate business reasons, for the duration as required under applicable laws.

In addition, we may delete any Personal Data pursuant to our policies, as in effect from time to time.

  1. RESPONSE TO REQUESTS

When you ask us to exercise any of your rights under this Policy and the applicable law, we may need to ask you to provide us certain credentials to make sure that you are who you claim you are, to avoid disclosure to you of Personal Data related to others and to ask you questions to better understand the nature and scope of data that you request to access.

We may redact from the data which we will make available to you, any Personal Data related to others.

  1. DATA SECURITY

We take the safeguarding of the Personal and Non Personal Data very seriously, and use a variety of systems, applications and procedures to protect the information from loss, theft, damage or unauthorized use or access when it is in our possession or control, including reasonable physical, technical and organizational measures which restrict access to the information. These measures provide sound industry standard security. However, although we make efforts to protect your privacy, we cannot guarantee that the Services will be immune from any wrongdoings, malfunctions, unlawful interceptions or access, or other kinds of abuse and misuse.

We also regularly monitor our systems for possible vulnerabilities and attacks, and regularly seek new ways and for further enhancing the security of our Services and protection of our Users’ privacy.

You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private. In addition, you should take steps to protect against unauthorized access to Personal Data stored on your premises as well as defining limited access rights to such information on a need to know basis.

If you receive an e-mail asking you to update your information with respect to the Website, do not reply and please contact us at info@drinkripples.com

  1. DATA RETENTION

We retain different types of information for different periods, depending on the purposes for processing the data, our legitimate business purposes as well as pursuant to legal requirements under the applicable law. We may retain Personal Data for as long as necessary to support the collection and the use purposes under this Policy and for other legitimate business purposes, for example, for storing data, for documentation, for cyber-security management purposes, legal proceedings and tax issues. We may store aggregated Non Personal Data without time limit. In any case, as long as you use the Services, we will keep information about you, unless we are legally required to delete it, or if you exercise your rights to delete the information. However, we do not keep any images sent from the application (e.g. selfies).

  1. CHANGES TO THIS PRIVACY POLICY

We may change the terms of this Privacy Policy from time to time by posting notice on our Website, with a seven (7) day advance notice. However, substantial changes will be effective thirty (30) days after the notice was initially posted. We will make an effort to inform you of substantial changes through the channels of communication generally used in such circumstances, and subject to the requirements of applicable laws – to obtain your consent.

If we need to adapt the Policy to legal requirements, the amended Policy will become effective immediately or as required.

Your continued use of the Services following such notice shall constitute your consent to any changes made and a waiver of any claim or demand in relation to such changes. If you do not agree to the new or different terms, you should not use and are free to discontinue using the Services.

  1. APPLICABLE LAW AND DISPUTE RESOLUTION

This Privacy Policy shall be governed by and construed in accordance with the laws of the State of Israel, without regard to its conflict of law provisions.

The courts of the Tel Aviv – Jaffa district shall have exclusive jurisdiction in all disputes and proceedings arising from this Privacy Policy.

  1. CONTACT US

For further information about this Policy, please contact us at info@drinkripples.com

We work hard to handle your information responsibly. If you are unhappy with the way we do this, please contact us and we will make good-faith efforts to address your concerns. We are usually able to resolve privacy questions or concerns promptly and effectively. If you are not satisfied with the response you receive from us, you may escalate concerns to the applicable privacy regulator in your jurisdiction. Upon request, we will provide you with the contact information for that regulator.

 

Ripples Ltd. All rights reserved.

Last Updated: August 19, 2019