Privacy Policy

(1) DATA CONTROLLER INFORMATION & CONTACT INFORMATION

Playright Ltd., incorporated under the laws of the State of Israel, is the “data controller” (as such term is defined under the GDPR or equivalent privacy legislation) of your Personal Data collected through this website. This basically means that when you access our website or otherwise use its Services, we determine the types of Personal Data to be collected, the purposes for which we collect and use it and the means by which Personal Data is processed.

For any question, inquiry or concern related to this Privacy Policy or the processing of your Personal Data, you may contact as follows:

Data Protection Officer:
By Mail:
Playright Ltd.
Yitzchak Sade 8, Tel Aviv, IL
By Email:
dpo@playright.ai

Data Protection Representative - For Data Subjects in the EU and UK:

We value your privacy and your rights as a data subject and have therefore appointed Prighter Group with its local partners as our privacy representative and your point of contact.

Prighter Group provides you an easy way to exercise your privacy-related rights (e.g., requests to access or erase personal data). If you want to contact us via our representative, Prighter Group, or exercise your data subject rights, please visit the following website

(2) THE DATA COLLECTED BY US AND PURPOSE OF USE

We may collect two types of information from you, depending on your interaction with us and our website:

The first type of information is non-identifiable and anonymous information (“Non-Personal Data”). We are not aware of the identity of the individual or other identifiers of the individual from which the Non-Personal Data is collected. Non-Personal Data which is being gathered via access or interaction with the Websites, consist of aggregated usage information, as well as technical information transmitted by your device, such as the type of operating system, browser, or device.

The second type of information is individually identifiable information, namely information that identifies an individual or may with reasonable effort identify an individual (“Personal Data”).

For the avoidance of doubt, any Non-Personal Data connected or linked to Personal Data shall be deemed as Personal Data as long as such connection or linkage exists.

We do not knowingly collect or process any Personal Data constituting or revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data, data concerning a person's health or data concerning a person’s sex life or sexual orientation (“Special Categories of Personal Data”).

The table below details the types of Personal Data we process, the purpose, lawful basis, and our processing operations:

Please note that the actual processing operation per each purpose of use and lawful basis detailed in the table above may differ. Such processing operation usually includes a set of operations made by automated means, such as collection, storage, use, disclosure by transmission, erasure, or destruction. The transfer of Personal Data to third-party countries, as further detailed in the Transfer of Data section below, is based on the same lawful basis as stipulated in the table above.

In addition, we may use certain Personal Data to prevent potentially prohibited or illegal activities, fraud, misappropriation, infringements, identity thefts, and any other misuse of the Services and to enforce the Terms, as well as to protect the security or integrity of our databases and the Services, and to take precautions against legal liability. Such processing is based on our legitimate interests.

(3) HOW WE COLLECT INFORMATION

Depending on the nature of your interaction with the website and Services, we may collect information as follows:

Automatically – we may use third party cookies (as elaborated below) or similar tracking technologies to gather some information automatically when you interact with our website.

Provided by you voluntarily – we will collect information if and when you choose to provide us with the information, such as through the Services, contact us communications, registration, etc.

(4) COOKIES & TRACKING TECHNOLOGIES

We use “cookies” (or similar tracking technologies) when you access the website or interact with the Services we offer. The use of cookies is a standard industry-wide practice. A “cookie” is a small piece of information that a website assigns and stores on your computer while you are viewing a website. Cookies can be used for various purposes, including allowing you to navigate between pages efficiently, for statistical purposes, as well as for advertising purposes. You can find more information about our use of cookies here: www.allaboutcookies.org.

In addition, please see our Cookies Settings page which details the cookies we use on are website, as well as enabling you to change your settings and preferences ant any time.

Most browsers will allow you to erase cookies from your computer’s hard drive, block acceptance of cookies, or receive a warning before a cookie is stored. You may set your browser to block all cookies, including cookies associated with our website and Services, or to indicate when a cookie is being used by us, by adjusting the privacy and security settings of your web browser. Please refer to the support page of your browser to learn more about how you can adjust your privacy and security settings. Additionally, you may opt out of certain advertisers’ cookies and browser-enabled, interest-based advertising.

Please note that once you choose to opt out or disable cookies, some features of the Services may not operate properly and your online experience may be limited. In addition, even if you do opt-out, you may still receive some content and advertising, however, it will not be targeted content or advertising.

Please note that, where we use third-party advertising cookies, such third-party may independently collect, through the use of such tracking technologies, some or all types of Personal Data detailed above, as well as additional data sets, including to combine such information with other information they have independently collected relating to your online activities across their network of websites, for the purpose of enhanced targeting functionality and delivering personalized ads, as well as providing aggregated analytics related to your use and interaction with our website (for example, by using Microsoft cookie which will be also subject to Microsoft Privacy Statement), and the performance of our advertising campaign you interacted with. These third parties collect and use this information under their own privacy policies, and are responsible for their practices.

For additional information, please see the Your Rights Related to Your Personal Data & Opt-Out section below.

(5) SHARING PERSONAL DATA WITHTHIRD PARTIES

We share your Personal Data with third parties, including our service providers that help us provide our Services. You can find in the table below information about the categories of such third-party recipients.

(6) YOUR RIGHTS RELATED TO YOUR PERSONAL DATA & OPT-OUT

Under applicable data protection and privacy laws, individuals have certain rights and controls regarding their Personal Data we process and store. The rights you may exercise depends on the purpose of collection, your relationship with us, and your jurisdiction and the privacy laws that apply to the processing of your Personal Data. The principal rights that may apply to your Personal Data (subject to your jurisdiction and additional conditions) may include:

• The Right to Be Informed – you have the right to be provided with information regarding our Personal Data collection and privacy practices – all as detailed under this Privacy Policy. If you have any additional questions, please contact us at: dpo@playright.ai

• The Right to Access/Inspect Your Personal Data – you have the right to ask us to confirm whether or not we collect and use your Personal Data, the right to know which Personal Data we specifically hold about, and to ask for a copy of your Personal Data or access it.

• Right to Correct/Rectify Your Personal Data – you have the right to ask us to correct or update your Personal Data we hold that is incorrect or request deletion for inaccurate Personal Data, after verifying the accuracy of the data and further taking into account the nature of the processing and the purposes.

• Right to Erase Your Personal Data (the Right “To Be Forgotten”) – you have the right to request the erasure of certain Personal Data we process, if specific conditions are satisfied, for example, if you think we no longer need to use it for the purpose we collected it; in the event that the collection was based on your consent; where we have used it unlawfully, or; where we are subject to a legal obligation to delete your Personal Data. Request for erasure will be subject to our rights and obligations under applicable law (for example, our legitimate interests such as record keeping, completing transactions, providing a service that you have requested, taking actions reasonably anticipated within the context of our ongoing business relationship with you, fulfilling the terms of a written warranty, detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, or prosecuting those responsible for such activities; debugging products to identify and repair errors that impair existing intended functionality; exercising right provided for by law; engaging in public or peer-reviewed scientific, historical, or statistical research in the public interest, etc.). You are not required to create an account with us to submit a deletion request.

• Right to Restrict Processing Of Your Personal Data – you have the right to ask us to restrict or limit the purpose for which we process your Personal Data, where certain conditions are satisfied (for example, where you contest the accuracy of the Personal Data, for a period enabling us to verify its accuracy; where the processing is unlawful and you oppose the erasure of the Personal Data; where we no longer need the Personal Data for the purposes of the processing).

• Right to Object – you have the right to object to any use of your Personal Data which we have justified by our legitimate interest if you believe your fundamental rights and freedoms to data protection outweigh our legitimate interest.

• Right to Withdraw Consent/Opt-Out – when the lawful basis for our processing of your Personal Data is your consent, you may withdraw such consent at any time. You have the right to opt-out from receiving our direct marketing, if applicable, by unsubscribing through the email received. We do not profile you in a manner that has a significant effect on you or other individuals, therefore we do nor provide an opt-out option from such use of Personal Data.

• Data Portability – you have the right to ask us to provide a copy of your Personal Data in a portable format and, to the extent technically feasible, readily usable format that allows you to transmit the Personal Data to another entity without hindrance. We will select the format in which we provide your copy.

• Right to Appeal or Lodge a Complaint – If we decline to take action on your request to exercise your rights related to your Personal Data, we will inform you without undue delay as required under applicable data protection and privacy laws. Our notice will include a justification for declining to take action and instructions on how you may appeal, if applicable. Under the GDPR you have the right to lodge a complaint with the applicable Data Protection Authority in the EU or the Information Commissioner in the UK.

Note that, not all those rights apply in every jurisdiction.

For California Residents, please further review our CCPA Privacy Notice, and for US residents, please further see the “– Additional Information for US Residents paragraph below – to learn more about your rights under applicable US laws.

For detailed information on how to exercise your rights, please see the Data Subject Request Form (“DSR”) form available HERE and send it to our privacy team at: dpo@playright.ai.

Certain rights can be easily executed independently by you without the need to fill out the DSR Form:

• If you have a User Account, you can correct certain data provided therein (such as contact information) through the account settings;
• You can you can opt-out from receiving our marketing emails by clicking “unsubscribe” link;
• You can use the cookie settings tool on our website to change your preferences;
• You may opt-out directly from third party retargeting cookies or other ad-technology trackers through self-regulatory services. For more information, please visit: Digital Advertising Alliance (US) HERE; Digital Advertising Alliance (Canada) HERE; Digital Advertising Alliance (EU) HERE; Network Advertising Initiative HERE; Use the Global Privacy Control (“GPC”) signals. You can also opt out of interest-based advertising with some of the service providers we use, such as Google HERE, Google Analytic HERE.

(7) DATA RETENTION

We retain Personal Data we collect as long as it remains necessary for the purposes set forth above, all in accordance with applicable laws, or until an individual expresses a preference to opt-out.

In certain circumstances, we will retain your Personal Data for longer periods of time and mainly:

• Where we are required to retain Personal Data in accordance with legal, regulatory, tax, or accounting requirements;
• Where we deem retention is necessary to obtain an accurate record of your dealings with us in the event of any complaints or challenges (e.g., Product adverse event); or
• If we reasonably believe there is a prospect of litigation relating to your Personal Data.

Please note that except as required by applicable law, we may at our sole discretion, delete or amend information from our systems, without notice to you, once we deem it is no longer necessary for such purposes.

(8) DATA SECURITY

Data security is of high priority to us. We make efforts to protect Personal Data we process from unauthorized access or unauthorized alteration, disclosure or destruction. We have implemented physical, technical and administrative security measures for the website that comply with applicable laws and industry such as restricting access to Personal Data to our personnel, minimize the data that we store on our servers, etc. Note that, we cannot be held responsible for unauthorized or unintended access that is beyond our control, and we make no warranty, express, implied or otherwise, that we will always be able to prevent such access.

Please contact us at: dpo@playright.ai if you feel that your privacy was not dealt with properly, in a way that was in breach of our Privacy Policy or if you become aware of a third party's attempt to gain unauthorized access to any of your Personal Data. We will make a reasonable effort to notify you and the appropriate authorities (if required by applicable law) in the event that we discover a security incident related to your Personal Data.

(9) CROSS BORDER DATA TRANSFER

Due to our global business operation, we may store or process your Personal Data in several territories, including, for example in Israel, the UK, EU, US or in other countries. Thus, any information you provide us may be transferred to and processed in countries other than the country from which you accessed our Websites or otherwise the country of your jurisdiction. We will take appropriate measures to ensure that your Personal Data receives an adequate level of data protection upon its transfer. Where Personal Data collected from within the EU or UK, is being transferred outside such territories to countries which didn’t receive an adequacy decision on behalf of an authorized authority (such as the EU Commission), we will take necessary steps in order to ensure that sufficient safeguards are provided during the transferring of such Personal Data, in accordance with the provision of the standard contractual clauses approved by the European Union or the UK Information Commissioner’s Office . Thus, we will obtain contractual commitments or assurances from the data importer to protect your Personal Data, using contractual protections that EEA and UK regulators have pre-approved to ensure your data is protected (known as standard contract clauses), or rely on adequacy decisions issued by the European Commission. Some of these assurances are well-recognized certification schemes.

(10) POLICY AMENDMENTs:

We reserve the right to amend this Privacy Policy from time to time, at our sole discretion. The most recent version of this Privacy Policy will always be posted on the website and the update date will be reflected in the “Last Revised” heading. We will provide notice if these changes are material and, where required by applicable law, we will obtain your consent. Any amendments to the Privacy Policy will become effective within 30-days upon the display of the modified Privacy Policy. We recommend you to review this Privacy Policy periodically to ensure that you understand our most updated privacy practices

(11) ELIGIBILITY AND CHILDREN PRIVACY:

Our website and Services are not intended for use by children (the phrase "child" shall mean an individual that is under the age defined by applicable law which with respect to the EEA is under the age of 16 and with respect to the US, under the age of 13). Furthermore, some of our websites are restricted for use for minors (as defined under applicable law). Thus, we do not knowingly process children’s information. We will discard any information that we receive from a user that is considered a "child" immediately upon our discovery that such a user shared information with us. Please contact us at: dpo@playright.ai if you have reason to believe that a child has shared any information with us, and we will take reasonable steps to ensure that such information is deleted from our files.

(12) JURISDICTION-SPECIFIC NOTICES:

A. ADDITIONAL NOTICE TO CALIFORNIA RESIDENTS

This section applies only to California residents, pursuant to the California Consumer Privacy Act of 2018 (“CCPA”) effective November 2020, and as amended by the CPRA, effective January 1, 2023.

Please see the CCPA Privacy Notice which discloses the categories of personal information collected, purpose of processing, source, categories of recipients with whom the personal information is shared for a business purpose, whether the personal information is sole or shared, the retention period, and how to exercise your rights as a California resident.

B. ADDITIONAL NOTICE TO US RESIDENTS

Residents of certain U.S. states (depending on the applicable state law, acting as an individual or in the household context only and not in a commercial or employment context, as a job applicant or as a beneficiary of someone acting in an employment context or as representative of a business), may have additional rights under applicable privacy laws and be entitled to additional disclosures.

“Personal Data” under applicable US privacy laws, generally means any information that is linked or reasonably linkable to an identified or identifiable individual (and usually does not include publicly available information that is lawfully made available from government records, or that a consumer has otherwise made available to the public; de-identified or aggregated consumer information; or information excluded from the states laws scope, such as: HIPAA, GBPA, non-profit entities, etc.)

“Sensitive Data” means data revealing racial or ethnic origin, religious beliefs, mental or physical health condition or diagnosis, sex life, sexual orientation, citizenship, or immigration status; The processing of genetic or biometric data for the purpose of uniquely identifying an individual; Personal Data collected from a known child; Precise geolocation data.

We are required to provide you with a clear and accessible privacy notice that includes the categories of Personal Data processed, purpose of processing, instructions for exercising consumer rights and appealing decisions, categories of Personal Data shared with third parties, categories of third parties with whom data is shared, and any sale of data or targeted advertising.

Categories of Personal Data & Categories of third parties with whom Personal Data is shared:

In Section 3 to the Privacy Policy, we describe our collection and processing of Personal Data, the categories of Personal Data that are collected or processed, and the purposes for which Personal Data is processed, stored or used. We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated, or incompatible purposes without obtaining your consent, unless we are otherwise entitled, required or permitted under applicable laws.

Additionally, Section 6 to this Privacy Policy details and discloses the categories of third-parties we share for business purposes.

“Sale” of Personal Data:

Under US privacy laws, in principle, the term “sale” is referring to disclosing or making available Personal Data to a third-party in exchange for monetary or other valuable consideration, including for targeted advertising purposes. We do not “sell” information as this term is commonly understood, meaning - we do not, and will not, disclose your Personal Data in direct exchange for money or some other form of payment. However, subject to the definition of the term “sale” under applicable US privacy laws, our practice of using “cookies or other third-party advertising services and sharing Personal Data for such purpose is considered as a “sale”.

Such practice includes the following Personal Data categories shared with these third parties:

Identifiers – online identifiers such as IP and Cookie ID;

Internet and electronic network activity information – such as your engagement with our website and ads.

Geolocation data – derived from IP (country level).

Section 7 to this Privacy Policy details and discloses your rights and Personal Data shared or sold for targeted advertising.

Consumer Rights Related to Their Personal Data:

Residents of certain U.S. states may have additional rights under applicable privacy laws, subject to certain limitations, which may include:

Access – the right to confirm whether we are processing their Personal Data and to obtain a copy of their Personal Data in a portable and, to the extent technically feasible, readily usable format.

Delete – the right to request us to delete their Personal Data provided to or obtained by us.

Correct – the right to request us to correct inaccuracies in their Personal Data, taking into account the nature and purposes of the processing of the Personal Data.

Opt-Out – the right to opt out of certain types of processing, including: (i) to opt out of the “sale” of their Personal Data; (ii) to opt out of targeted advertising by us; and (iii) to opt out of any processing of Personal Data for purposes of making decisions that produce legal or similarly significant effects.

Section 7 to this Privacy Policy provides additional information regarding your principal rights.

Exercising Privacy Rights:

You may submit a request to exercise most of your privacy rights under U.S. state privacy laws by submitting a DSR as available here or contacting us at: dpo@playright.ai. We will take steps to verify your identity and your request by matching the information provided by you with the information we have in our records. In some cases, we may request additional information to verify your identity, or where necessary to process your request. If we are unable to verify your identity after a good faith attempt, we may deny the request and, if so, will explain the basis for denial and how to remedy any deficiencies, where applicable.

Authorized agents may initiate a request on behalf of another individual, provided that such will be required to provide proof of their authorization, and we may also require that the individual directly verify his/her identity and the authority of the authorized agent.

We will respond to your request within the timeframe required under applicable law, and we reserve the right to extend the response time subject to applicable law requirements. If we refuse to take action on a request, we will notify you and our notification will include a justification for declining to take action and instructions on how you may appeal. Within the timeframe set out under applicable law of our receipt of your appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied, you may submit a complaint to the applicable authority or Attorney General of your jurisdiction (including – Colorado AG at https://coag.gov/file-complaint/; Connecticut Attorney General at: https://www.dir.ct.gov/ag/complaint/ or (860) 808-5318; Virginia Attorney General at https://www.oag.state.va.us/consumercomplaintform).