TYPES OF DATA WE COLLECT & LAWFUL BASIS
Before we will detail the types of data collected through our Services, we would like to explain the lawful basis on which we process and share data: (i) In the event a user voluntarily signs up for our Services, we will process Personal Data (as defined below) in order to perform a contract; (ii) When a visitor accesses our website, we may collect IP address under the lawful basis of our legitimate interest; (iii) we will process Personal Data based on the user’s consent, subject to applicable law requirements.
The information we process can be classified into two categories: (i) “Personal Data” meaning information that identifies an individual or may with reasonable effort identify an individual which we process in order to provide the Services; (ii) “Non- Personal Data” meaning non-identifiable information, which is gathered via the use of the Services.
The Personal Data we process includes the following data sets:
Online Identifiers - IP address, cookies or agents;
Contact us - information you voluntarily provide us such as when you communicate with us via email or the website, etc.;
Registration - information provided by you when you sign up for our Services, for example your name and email address. In addition, in the event you choose to register or sign-in using your social network account we will have access to your social network account’s basic information, for example your name, email address and information which you made publicly available or agreed to share with us;
Contacts - in order to provide the Services you will be requested to share with us your full contact list, phone number as well as details saved by you under your contact application.
Backup- as part of the Services and in order to enable you to back up your contact list or synchronize such list between your devices, we will store your contact list in our database. Note that, you and your contacts shared with us, have the right to opt-out from having their contact information enhanced, managed, organized or otherwise shared by us, as well as stored in our database, as detailed in the “OPT OUT” Section below and available here: https://www.lobsterapps.io/opt-out;
Mailbook- to enable the Mailbook App or feature, as part of the Services, we will request that you provide us access to your email account (i.e., Gmail account) solely in order to extract the information included in the signatures of the individuals and companies that you have interacted with. We will not review or access any of the content and will only access the signatures in such emails.
The Non-Personal Data we process includes the following data sets: (i) analytic related information collected and processed either by us or by third parties on our behalf (e.g., Google Analytic). This information may include information with regards to your use of the Services, for example, the amount of time spent using the Services, click stream, etc. We use this data in order to improve and enhance our Services and the way we offer them, as well as for internal analytics and research purposes; (ii) we will process technical information such as your device’s type of operating system, language preference, browser type, the directing domain, time and date you access the Services, etc.; (iii) information we anonymize or de-identify, meaning – it cannot identify an individual.
We do not combine Personal Data you may provide voluntarily with the Non - Personal Data. However, if we do so, we will treat the combined information as Personal Data.
HOW DO WE COLLECT YOUR DATA
SDK AND COOKIES
When you use the App and Services, we may use tracking technologies known as “cookies” and SDKs (or similar technologies). Cookies are small text files that are placed on your hard drive by a web server when you access our Services. Cookies are used in purpose of improving the interaction between you and the Services, by, for example, enabling automatic activation of certain features, efficient navigation between pages, remembering your preferences etc. More information about cookies is available at: www.allaboutcookies.org.
We may use third parties cookies or other technology to collect information about your online and Services usage activities, as follows:
Google Analytics and Fabric. These cookies are placed in order to track and analyze the use of our Services and website, for internal purposes, and may include the collection of your IP address. Additional information with respect to Google’s use of the data from our use of Google Analytics cookies is available in Google’s policies located at: www.google.com/policies/privacy/partners and https://policies.google.com/technologies/partner-sites. We also recommend you to read about Google Analytics’ currently available opt-outs available at: https://tools.google.com/dlpage/gaoptout/. For additional information of our use of Google products, click here.
DISCLOSURE OF INFORMATION
DATA RETENTION, SECURITY AND DATA TRANSFER
We will retain the data we collect solely for as long as required to fulfil the purposes for which it was collected, as well as to comply with our legal, tax and accounting requirements. In addition, we may also retain your Personal Data for longer periods if we reasonably believe, at our discretion, that we need to obtain an accurate record of your correspondence or any dealing with us, for example, in the event of any complaints, all, in compliance with applicable laws.
Further, in the event of a security incident, in which we discover your Personal Data may be at risk, then we will take reasonable efforts to notify you and the applicable authority (if required, subject to applicable laws).
We may process your Personal Data in countries outside your jurisdiction. If we do so, we will take the needed steps to ensure your Personal Data will receive the required level of protection.
YOUR RIGHTS AND OPT OUT
Data protection and privacy laws provide you with the ability to exercise some rights regarding your Personal Data that we hold (which might be different in each jurisdiction) such as; (i) you may request to access your Personal Data that we hold; (ii) you may request the rectification of your Personal Data that we hold; (iii) you may request the erasure of your Personal Data that we hold (as long as we do not have a legitimate reason for retaining the data); (iv) you may request to restrict processing of your Personal Data; (v) you may object to processing of your Personal Data by us; (vi) you may request to exercise your right of data portability; (vii) you may exercise your right to file a complaint to a supervisory authority in your jurisdiction; and (viii) you have the right to withdrew consent (in the event the Personal Data is processed subject to your consent).
If you wish to submit a request to exercise your rights, please contact us. When you contact us and request to exercise your rights regarding your Personal Data, we will require certain information from you in order to verify your identity and locate your data and that the process of locating and deleting the data may take reasonable time and effort, however not more than one (1) month, unless otherwise required or permitted under applicable law.
Opt-Out: You may also opt-out of the data collection related to our Services, as follows: (i) you may set your browser to block all cookies, including cookies associated with our Services, or to indicate when a cookie is being set, by adjusting the privacy and security settings of your web browser. Please refer to the support page of the browser you are using. For your convenience, see more information about your controls in this regard, within the following links: Google Chrome ; FireFox ; Internet Explorer ; Safari ; Edge ; Opera ; (ii) you may opt out of certain data collection related to our Services at any time including, but not limited to the data collection associated with the Mailbook App; and (iii) you may opt out at any time of your use of the Mailbook App. Please click HERE for instructions.
Data privacy and related laws in your jurisdiction may provide you with different or additional rights related to the data we collect from you, which may also apply.
We do not use the Services to knowingly solicit data from or market to children under the age defined under applicable law, and specifically US residents under the age of 13 and EEA residents under the age of 16. We reserve the right to request proof of age at any time, and we request that individuals under the age detailed above will not provide us with Personal Data. Please contact us if you believe that a child has provided us with Personal Data, and we will make best efforts to delete such information.
[Last Revised: March 17, 2019]