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Privacy Policy

METROLINK.AI LTD. PRIVACY POLICY

Last Updated: November 1, 2021

This privacy policy (“Privacy Policy”) governs how we, METROLINK.AI LTD. (together, “METROLINK.AI” “we”, “our” or “us”) use, collect and store Personal Data we collect or receive from or about you (“you”).

Please read this Privacy Policy carefully, so you can understand our practices and your rights in relation to personal data. “Personal Data” or “Personal Information” means any information that can be used, alone or together with other data, to uniquely identify any living human being and any information deemed as Personally Identifiable Information by privacy laws. Important note: Nothing in this Privacy Policy is intended to limit in any way your statutory right, including your rights to a remedy or means of enforcement.

This Privacy Policy can be updated from time to time and, therefore, we ask you to check back periodically for the latest version of this Privacy Policy.  If we implement significant changes to the use of your Personal Data in a manner different from that stated at the time of collection, we will notify you by posting a notice on our Website or by other means.

  1. WHAT INFORMATION WE COLLECT, WHY WE COLLECT IT, AND HOW IT IS USED

 

Specific Personal Data we collect

 

Website Visitors – individuals who visit our Website www.metrolink.ai and who may volunteer certain contact data (such as their email address) to receive communications from Metrolink.

Customers– those who register on their own or on behalf of an entity or organization to use any product(s) or service(s) within Metrolink’s Platform, including administrators of an Metrolinks Account. For the purposes of this Privacy Policy, “Services” shall refer to all product(s), service(s) or offering(s) made available by Metrolink.

End Users– individuals who visit our Customers’ websites and whose information we process (on behalf of our Customers) in order to provide the Services to our Customers pursuant to our agreements with them (“End Users”). All personal data about End Users will be solely collected on behalf of our Customers. Metrolink may use the data collected for analytics and customization of ads only in an aggregated and anonymized form. Metrolink  will not collect or process any Sensitive Data of End Users.

 

Why is the Personal Data collected and for what purposes?

 

Depending on which features of the Platform you use, we collect different kinds of information (including Personal Information) about or from you. This Personal Information is necessary for the performance of our contractual obligations towards you and providing you with our Services, to protect our legitimate interests, as well as for compliance with regulatory obligations to which we are subject. If this information will not be provided, you may not be able to use our Platform (such as opening an Metrolink account), or certain features of our Platform. In certain instances, we will obtain your consent to the collection of your Personal Information, as appropriate (in which case, you can revoke your consent at any time by approaching us).

 

Finally, please note that some of the abovementioned Personal Data will be used for detecting, taking steps to prevent, and prosecution of fraud or other illegal activity, to identify and repair errors, to conduct audits, and for security purposes. Personal Data may also be used to comply with applicable laws, with investigations performed by the relevant authorities, law enforcement purposes, and/or to exercise or defend legal claims. In certain cases, we may or will anonymize or de-identify your Personal Data and further use it for internal and external purposes, including, without limitation, to improve the services and for research purposes. “Anonymous Information” means information which does not enable identification of an individual user, such as aggregated information about the use of our services. We may use Anonymous Information and/or disclose it to third parties without restrictions (for example, in order to improve our services and enhance your experience with them).

  1. HOW WE PROTECT AND RETAIN YOUR INFORMATION

 

  • Security. We have implemented appropriate technical, organizational and security measures designed to protect your Personal Data. However, please note that we cannot guarantee that the information will not be compromised as a result of unauthorized penetration to our servers. As the security of information depends in part on the security of the computer, device or network you use to communicate with us and the security you use to protect your user IDs and passwords, please make sure to take appropriate measures to protect this information.

 

  • Retention of your Personal Data. We retain your Personal Data as follows: (i) where we are required to do so in accordance with legal, regulatory, tax or accounting requirements, or (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, or (iii) if we reasonably believe there is a prospect of litigation relating to your Personal Data or dealings.

 

  1. HOW WE SHARE YOUR PERSONAL DATA

 

In addition to the recipients described above, we may share your Personal Data as follows:

 

  • With our business partners with whom we jointly offer products or services. We may also share Personal Data with our affiliated companies. We may also share Personal Data with our affiliated companies about you. They may combine this Personal Data with other details they hold about you. Unless they provide you with their own privacy policy, they may use your Personal Data for the purposes explained in this Privacy Policy. We are part of the Metrolink.AI group, which is a global organization. For the purposes explained in this Privacy Policy, we may transfer your Personal Data to Metrolink.AI group companies (including service providers operating on their behalf) and other third parties in countries which do not have the same level of data protection laws as those in the country where you are located. AI uses several legal mechanisms, including EU Standard Contractual Clauses, to help ensure that your rights and protections are respected by all companies of the Company Name group. We use efforts to ensure that each Metrolink.AI group company will comply with the key data protection principles of fair handling of Personal Data and ensuring adequate level of protection of Personal Data.
  • To the extent necessary, with regulators, courts or competent authorities, to comply with applicable laws, regulations and rules (including, without limitation, federal, state or local laws), and requests of law enforcement, regulatory and other governmental agencies or if required to do so by court order;
  • If, in the future, we sell or transfer, or we consider selling or transferring, some or all of our business, shares or assets to a third party, we will disclose your Personal Data to such third party (whether actual or potential) in connection with the foregoing events;
  • In the event that we are acquired by, or merged with, a third party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer, disclose or assign your Personal Data in connection with the foregoing events, including, in connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or to another company; and/or
  • Where you have provided your consent to us sharing or transferring your Personal Data (e.g., where you provide us with marketing consents or opt-in to optional additional services or functionality).

 

  1. YOUR PRIVACY RIGHTS. HOW TO DELETE YOUR ACCOUNT

 

  • You can exercise your rights by contacting us at [email protected]
  • You may use an authorized agent to submit a request on your behalf if you provide the authorized agent written permission signed by you.
  • When processing your request, we may ask you for additional information to confirm or verify your identity and for security purposes, before processing and/or honoring your request.
  • Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly in accordance with applicable law or inform you if we require further information in order to fulfil your request. In the event that your request would adversely affect the rights and freedoms of others (for example, would impact the duty of confidentiality we owe to others) or if we are legally entitled to deal with your request in a different way than initial requested, we will address your request to the maximum extent possible, all in accordance with applicable law.
  • We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive.
  • Deleting your account: Should you ever decide to delete your account, you may do so by emailing [email protected] If you terminate your account, any association between your account and Personal Data we store will no longer be accessible through your account. However, given the nature of sharing on certain services, any public activity on your account prior to deletion will remain stored on our servers and will remain accessible to the public.

                                                                             

  1. USE BY CHILDREN

 

We do not offer our products or services for use by children and, therefore, we do not knowingly collect Personal Data from, and/or about children under the age of eighteen (18). In the event that we become aware that you provide Personal Data in violation of applicable privacy laws, we reserve the right to delete it. If you believe that we might have any such information, please contact us at [email protected]

  1. INTERACTION WITH THIRD PARTY PRODUCTS


We enable you to interact with third party websites, mobile software applications and products or services that are not owned or controlled by us (each a “Third Party Service”). We are not responsible for the privacy practices or the content of such Third Party Services. Please be aware that Third Party Services can collect Personal Data from you. Accordingly, we encourage you to read the terms and conditions and privacy policies of each Third Party Service.

 

  1. LOG FILES

We use log files. We use such information to analyze trends, administer the Website, track users’ movement around the Website, and gather demographic information.

 

  1. ANALYTIC TOOLS
  • Google Analytics. The Website uses a tool called “Google Analytics” to collect information about use of the Website. Google Analytics collects information such as how often users visit this Website, what pages they visit when they do so, and what other websites they used prior to coming to this Website. We use the information we get from Google Analytics to maintain and improve the Website and our products. We do not combine the information collected through the use of Google Analytics with Personal Information we collect. Google’s ability to use and share information collected by Google Analytics about your visits to this Website is restricted by the Google Analytics Terms of Service, available at https://marketingplatform.google.com/about/analytics/terms/us/, and the Google Privacy Policy, available at http://www.google.com/policies/privacy/. You may learn more about how Google collects and processes data specifically in connection with Google Analytics at http://www.google.com/policies/privacy/partners/. You may prevent your data from being used by Google Analytics by downloading and installing the Google Analytics Opt-out Browser Add-on, available at https://tools.google.com/dlpage/gaoptout/.
  • FullStory. The Website uses FullStory in order to better understand our users’ needs and to optimize this service and experience. FullStory is a technology service that helps us better understand our users experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables us to build and maintain our service with user feedback. FullStory uses cookies and other technologies to collect data on our users’ behavior and their devices. This includes a device’s IP address (processed during your session and stored in a de-identified form), device screen size, device type (unique device
    identifiers), browser information, geographic location (country only), and the preferred language used to display our website. FullStory stores this information in a
    pseudonymized user profile. FullStory is contractually forbidden to sell any of the data collected on our behalf. For further details, please see FullStory’s privacy policy at https://www.fullstory.com/legal/privacy-policy/ You can opt-out to the creation of a user profile, FullStory’s storing of data about your usage of our Website and FullStory’s use of tracking cookies on other websites on this link https://www.fullstory.com/optout/.
  • Facebook Pixels and SDKs. We use Facebook pixels or SDKs, which are tools that provide help to website owners and publishers, developers, advertisers, business partners (and their customers) and others integrate, use and exchange information with Facebook, as such the collection and use of information for ad targeting. Please note that third parties, including Facebook, use cookies, web beacons, and other storage technologies to collect or receive information from your websites and elsewhere on the internet and use that information to provide measurement services and target ads. Facebook’s ability to use and share information is governed by the Facebook Tools Terms, available at: https://www.facebook.com/legal/technology_terms/. You can prevent your data from being used by Facebook Pixels and SDKs by exercising your choice through these mechanisms: http://www.aboutads.info/ choices or http://www.youronlinechoices.eu/.
  • Google Signals. The Website uses a tool called “Google Signals” to collect information about use of the Website. When we activate Google Signals, some existing Google Analytics features are updated to also include aggregated data from Google users who have turned on “Ads Personalization” (Ads Personalization available at https://support.google.com/ads/answer/2662856/). Audiences that we create in Google Analytics and publish to Google Ads and other Google Marketing Platform advertising products can serve ads in cross device-eligible remarketing campaigns to Google users who have turned on Ads Personalization. Google Analytics collects additional information about users who have turned on Ads Personalization, base across device types and on aggregated data from users who have turned on Ads Personalization. The data is user based rather than session based. The Cross Device reports include only aggregated data. No data for individual users is ever exposed. You can modify your interests, choose whether your Personal Data is used to make ads more relevant to you, and turn on or off certain advertising services in the Ads Personalization link above.
  • Google API. Our website and platform uses Google API in order to interact with user’s search results for marketing campaigns  For further details please see the Google API terms of service at https://developers.google.com/terms  and the Google privacy policy at https://policies.google.com/privacy
  • Advertising Partners.  Through our services, we allow third party advertising partners to set technologies and other tracking tools to collect information regarding your activities and your device (e.g., your IP address, mobile/website identifiers, page(s) visited, location, time of day). We also combine and share such information and other information (such as demographic information and past purchase history) with third party advertising partners. These advertising partners will use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit third party websites within their networks. This practice is commonly referred to as “interest-based advertising” or “online behavioral advertising. We allow access to other data collected by the services to share information that may be useful, relevant, valuable or otherwise of interest to you. If you prefer not to share your Personal Information with third party advertising partners, you may let us know.

We reserve the right to remove or add new analytic tools.

  1. SPECIFIC PROVISIONS APPLICABLE UNDER CALIFORNIA PRIVACY LAW

 

  • California Privacy Rights: California Civil Code Section 1798.83 permits our customers who are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please send an email to [email protected] Please note that we are only required to respond to one request per customer each year.

 

  • Deletion Of Content From California Residents: If you are a California resident under the age of 18 and a registered user, California Business and Professions Code Section 22581 permits you to remove content or Personal Information you have publicly posted. To remove, please send an email to [email protected] Please be aware that after removal you will not be able to restore removed content. In addition, such removal does not ensure complete or comprehensive removal of the content or Personal Information you have posted and that there may be circumstances in which the law does not require us to enable removal of content.

 

 

  1. CONTACT US

 

If you have any questions, concerns or complaints regarding our compliance with this notice and the data protection laws, or if you wish to exercise your rights, we encourage you to first contact us at [email protected]