Last modified on: [April] [20], 2022
Tedooo Privacy Policy
MA Tedooo group Ltd.,(the “Company”, and also in this policy "we", "us", "our") offers, through [name
of Application] web and application (the "Application"), a marketplace for buyers and sellers for various
products (“Products”),Products (“Services”).
This Privacy Policy is intended to explain how we collect, use and otherwise process information
collected from users, whether these are buyer or sellers (buyers and sellers collectively "User/s"; and
also "you") through the Application and website and during the provision of Services. This policy is a
part of the Terms [https://www.tedooo.com/eula] and is incorporated therein. Capitalized terms
used in this Policy but not defined herein are defined in the Terms.
The Application and Services are intended for adults. Users under the age of eighteen (18), or of legal
age at their place of residence, are not permitted to use the Application and Services without the
consent of a parent or legal guardian. We have the right to implement age verification measures, and
to subject the right to download and use the Application to pass such verification. Data privacy is
important to us. This means that we process data with due care, while adopting and combining industry
standard data collection, storage, and processing practices with security measures to protect against
unauthorized access, alteration, disclosure, or destruction of a User's personal information and always
in accordance with applicable data protection laws.
Contents:
1. What personal data we collect (“Personal Data”)
2. How we collect your Personal Data
3. How we use your information
4. How we share your information
5. Data transfers and global processing
6. How long we hold your Personal Data
7. Marketing Messages
8. Data Subject Rights
9. Changes to This Privacy Policy
10. How to Contact Us
1. What Personal Data We Collect
1. We may collect different categories of personal information depending on your activities on the
Application and depending also on whether you are a buyer or a seller:
1. When registering to the Application: name, postal address, email address, telephone
number, username, password. If you choose to register trough an existing account of
yours in a different platform, such as Google account, Apple account or Facebook
account- your user name and password to such a platform will be used to enter the
Application, but be saved in an external service.
2. When you use the Application: the personal data that may be contained in any video,
photo, free text, comment or other submission you upload or post to the Application;
audio, visual data, GPS location, information collected from devices GPS, camera and
microphone, such as location, sounds and images. We strongly advise you not to
include any sensitive information in the free text you insert to Application, for
example to your profile, Chat or Feed.
3. your entries in the various fields. Some of this data may be inserted in the form of
free text. We strongly advise you not to include any payment data in such content
(i.e. credit card numbers).
4. When payments are made by you, your payment information is processed by third
party payment processing services – we do not collect or store this information.
5. When you interact with us outside the Application, we may also collect details of
other interactions that you have with us, together with any other information that
you choose to provide us with, for example, through your interactions with our
customer and technical support teams.
2. We also anonymize and aggregate personal information (so that it does not identify you) and use it for
purposes including testing our IT systems, research, data analysis, improving the Application, and
developing new products and services. Such anonymized information includes technical information
transmitted by User's device regarding the hardware specifications (e.g. operating system type, version
and device) and language preferences, as well as User's country.
3. You are not obligated to provide us with any of the above information under any applicable law.
However, we will not be able to operate the Application and/or provide you with the Services or part
of them, as applicable, if you do not agree, or if you withdraw your consent, or request to object (all as
detailed under section 8 with respect to your rights) to our processing of these data items. Therefore,
if you do not agree to us collecting the above Personal Data, please do not use the Application or
Services.
2. How We Collect Your Information
1. We collect Personal Data Directly: from Users- when they register on the Application or website and
through their continuous use of the Application or website.
2. We collect Personal Data Automatically-
We automatically log information about Users when they access our App and/or Website. For example,
when visiting our Application and/or Website, we log Users Device operating system name and version,
manufacturer and model, browser type, browser language, how long they spent on a our application
or website… most of the data that is collected is deleted within 24 hours after collection.
3. We collect Personal Data from Social Networking Site or other platforms or websites-
Our Application and/or Website includes interfaces that allow Users to connect with social networking
sites (each a “SNS”). If you connect to a SNS through our Application and/or Website, you authorize us
to access, use and store the information that you agreed the SNS could provide to us based on your
settings on that SNS. We will access, use and store that information in accordance with this Policy. You
can revoke our access to the information you provide in this way at any time by amending appropriate
settings from within your account settings in the applicable SNS.
3. How we Use Your Information
Here is what we do with your Personal Data that we collect as described above:
1. We use all of the above personal data to operate, maintain, and provide to you with the Application
features and functionality and to provide you with the Services as requested by you.
2. We use your information to send you emails with regards to your operation of the Application (e.g.,
account verification, notify you of changes/updates to features, credentials change, technical and
security notices), as well as to send you marketing communications (please see more details regarding
this under “Marketing Communications”).
3. We may use the above information to respond to your requests and messages, including with respect
to your rights as data subject, as well as to initiate contact with you on issues related to the Application
or Services or support and maintenance issues.
4. We may use the information you provide to allow certain functions to perform as intended.
5. To prevent, detect and fight fraud or other illegal or unauthorized activities
6. We use anonymized, aggregate data, in order to gain insight on how you and other users use the
Application and Services and try and improve our Application and Service, as well as to plan our
marketing and advertisements.
7. To ensure legal compliance – from our side (to legal requirements that apply to us and to our obligations
under the Terms) and from your side (Compliance with laws applicable to you and with the Terms)
8. We will not use your Personal Data for any personal profiling and automated decision making based on
such profiling.
9. We limit access by our employees to your information only to those who were specifically authorized
by us to access your information, as part of their job description.
4. Our Legal Bases for Processing:
With respect to such activities we will conduct as Controllers, we will only process your personal
information where we have a legal basis to do so.
The following are the legal bases under which we process your information in the manners specified
above:
1. Performance of a contract to which we and you, the data subject, are parties. Many of the uses
described above are actions that involve processing of your information in order to meet our
undertakings to you and respond to your requests and indications within the Services.
2. Legitimate interests: We may use your information where we or our customers have legitimate
interests to do so. For instance, we analyze users’ behavior on our services to continuously improve our
offerings, and we process information for administrative, fraud detection and other legal purposes.
3. Consent – some of the information you provide is based on your consent and will to provide it. In
addition, we may ask you from time to time, through the Service or Application interface, to provide
your consent for specific uses (for example, to add you to our newsletter or send marketing
communications to you in case we have never had any commercial relations regarding the products or
services subject matter of such communication).
5. How we Share Your Personal Data
1. No Sale to Third Parties. We do not, and will not, sell any of your personal data to any third party for
advertising, marketing or any other purpose – including your name, address, email address or credit
card information. We want to earn and maintain your trust, and we believe this is absolutely essential
in order do that.
2. Service Providers: we employ other companies services and technology to perform tasks on our behalf
and need to share some of your information with them in order to provide the Services. The categories
of third party recipients of the Personal Data from us are as follows:
● Cloud and hosting – Amazon servers
● Translations service provider- Google, Microsoft
● DB – Mongo
● Signup and log in authentication- TWilio
● Analytics and attribution provider – Adjust
● Billing, processing payments – Google Pay and Apple Pay
● Sending push notifications – Pushi, Google and apple [yes]
● clearing service provider- Google, Apple [yes]
Our agents do not have any right to use your personal information collected from our Services beyond
what is necessary for the purpose of facilitating our provision of the Application and Services.
3. Compliance with the Law: We may disclose your information if we believe it’s necessary in order to
comply with the law, such as to comply with a subpoena, regulation or legal request, respond to a
government request, to address fraud or security issues, to protect the safety of any person, to enforce
our agreements with you; to investigate, prevent, or take other action regarding illegal activity,
suspected fraud or other wrongdoing or to protect our own rights or property. If you are located in the
EU, we may only do so based on legal requirements specified above of EU authorities. This includes
sharing such information with our legal counsels.
4. Business Transfers: If we are in a bankruptcy, merger, acquisition, reorganization or sale of assets, your
information may be transferred as part of that transaction to a successor in interest and to the
applicable legal authorities as well as legal counsels and other professional counsels involved such as
accountants, and other officers of the government or of the applicable judiciary instance.
5. Anonymized Information: We may provide third parties (for their needs, including advertising and
tracking) with aggregated but anonymized information and analytics about our customers however,
before we do so, we will make sure that it does not identify you.
6. Data Transfers and Global Processing
Why is Personal Data Transferred?
As we operate globally, we may on occasion allow your personal data to be accessed and/or processed
and from and/or transferred to countries other than your own location. We may do this where data is
accessed/processed:
1. By our service providers, for the purposes we specified above under the chapter “How we Share Your
Personal Data”.
2. By consenting to the collection and use of your personal information, you agree to your personal
information being transferred and stored in this manner and for the specified purposes.
Our Legal Basis for performing such transfers across boundaries (when we act as Controllers):
1. Model Clauses. With some of our processors, we use standard contractual clauses that are binding
standards of processing of personal data committed contractually by third parties processing
information for us and on our behalf, such standard clauses are approved by the European Commission.
2. Consent. In the absence of Model Clauses, Your consent. By using the Application and/or Services, you
agree and understand that your information may be transferred from the EEA or other countries in
which you may be using the Services, to other countries outside your own location (including outside
the EEA), and specifically to the USA. The transfer will be to such third parties as described under “How
we Share Your Personal Data”. You agree to such transfer, and you understand that data processed in
these countries/regions is subject to different data protection laws, which may sometimes grant a
lesser degree of protection than the privacy laws and regulations applicable within the EEA for example.
7. How long we hold your Personal Data
We retain the personal information that we collect from and about you for as long as it is needed to
provide access to the Application or to manage your account. We take reasonable steps to delete the
personal information we collect if your registration to use our Application lapses, if you opt out of
receiving further communications from us, or if you ask us to delete your information. We may however
retain and use personal information as necessary to comply with our legal and regulatory obligations,
to resolve disputes and to enforce our agreements, and we may retain and use anonymous and
aggregated information for performance reporting and analytic purposes and for product and service
improvement.
You can request that your personal information be deleted by contacting us at [info@tedooo.com]
8. Security of Personal Data
We are committed to protecting the security of any personal data on our database and network. We
use a variety of security technologies and procedures to help protect all personal data from loss, misuse,
unauthorized use, access, inadvertent disclosure, alteration and destruction. However, no network,
server, database or Internet or e-mail transmission is ever fully secure or error free. Therefore, you
should take special care in deciding what information you disclose.
9. Marketing Messages
1. If you have said we can, we will send you marketing messages by email to keep you aware of what
we’re up to and to help you see and find our products and services.
2. You can stop receiving marketing messages from us at any time. You can do this by clicking on the
‘unsubscribe’ link in any email or by contacting us.
10. Data Subject Rights
You, as a data subject have a few rights relating to your personal data held or processed by us:
1. The right to be informed about how your personal information is being used.
2. The right to access the personal information we hold about you.
3. The right to request the correction of inaccurate personal information we hold about you.
4. In some circumstances, the right to request that we delete your data
5. The right to Restrict processing your personal data
6. The right to object to processing activities, if the processing is based on our legitimate interest;
7. The rights to withdraw consent at any time, if the processing is based on consent
8. The right to object to processing of personal data for direct marketing purposes
9. In some circumstances, the right to request that we transfer or port elements of your data either to
you or another service provider – if the processing is based on your consent, and is made by automated
means.
10. The right to file a complaint with your Supervisory Authority.
11. Links to Other Websites
Our Application may contain links to third party applications, websites and features. This Privacy Policy
does not cover the privacy practices of such third parties. These third parties have their own privacy
policies and we do not accept any responsibility or liability for their applications, websites and features
or policies. Please read their privacy policies before you submit any data to them.
12. Changes to This Privacy Policy
We may change this privacy policy from time to time, to reflect how we are processing your data,
including following any regulatory changes or our internal policies.
If we make significant changes, we will make that clear on the Application or by some other means of
contact such as email, so that you are able to review the changes before you continue to use
Application.
13. How to Contact Us
We always want to hear from you!
Please don’t hesitate to contact us at info@tedooo.com, and we will be happy to answer any questions
you may have concerning this privacy policy, deal with your complaint, or help you exercise any of your
rights as set out above.
