Sync.Me Privacy Policy

Last Revised: November 10, 2020

INTRODUCTION

Sync.Me Technologies Ltd. (“Sync.Me”, “our”, “we”, “us” or the “Company”) is

committed to respect the privacy and Personal Information of the users

(“user” or “you”) in connection with the use of our mobile application and/or

by accessing our website https://sync.me (collectively the “Service”).

• Our Service is primarily designed to empower consumers to make

informed decisions and deter illegal and fraudulent calling activities.

• Our Service plays a key role in enhancing connectivity and thwarting

intrusive and fraudulent calls, by introducing a variety of smart features

that empower consumers to make informed decisions and reduce the

risks of the user community from being targeted by malicious or

misleading activities. These features include:

i. Reporting and blocking spam: our users can choose to report and

block numbers to be added to their personal spam call list, and

potentially a regional spam call list. In the event a particular

number was reported as spam by a certain number of users, other

users will be notified if they receive a call from that same number.

ii. Live Caller ID and Spam detection: our Live Caller ID displays the

name of the caller before the consumer answers the call, and flags

if the number was reported as spam.

iii. Number search (reverse lookup): individuals, including those who

are not registered users with Sync.ME, may manually search a

number on Sync.ME's web-based platform in order to ascertain

the identity of the caller and whether a number was reported as

spam. The contact information collected by Sync.ME is used solely

to empower individuals to identify incoming calls from unknown

sources, identify unknown numbers through the use of reverse

numeric lookup, as well as to report and block fraudulent,

intrusive or inappropriate calls.

• We designed our features to better respond to deceptive and abusive

practices aided by anonymity, both in telemarketing as well as in other

abusive or deceptive practices (such as abusive calls).

• Our goal is to promote consumer privacy by allowing them to know who

is calling them, as well as to promote accountability throughout the

industry.

• Important note: Nothing in this Privacy Policy is intended to limit in any

way your statutory rights, including your rights to a remedy or means of

enforcement.


How to withdraw consent? If you would like to remove your Personal

Information from our Service, you may do so by visiting this

link: https://sync.me/unsubscribe

THIS PRIVACY POLICY

This privacy policy (“Privacy Policy”) outlines our practices with respect to the

information we collect from you when you use the Service, and the manners in

which we use such information.

In addition to this Privacy Policy, please also review our Terms of Use, in which

this Privacy Policy is incorporated thereto by reference, along with such other

policies of which you may be notified by us from time to time. The definitions

in our Terms of Use apply to this Privacy Policy unless stated otherwise. We

greatly respect your privacy, which is why we make every effort to provide a

platform that would live up to the highest of user privacy standards. Please

read this Privacy Policy carefully, so you can fully 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. Please note that this is

a master privacy policy and some of its provisions only apply to individuals in

certain jurisdictions. For example, the legal basis in the table below is only

relevant for GDPR-protected individuals

Sync.Me uses, collects, and stores Personal Information that we collect or

receive from or about you such as in the following cases:

1. When you browse or visit our website, https://sync.me/ (“Website”).

2. When you make use of, or interact with, our Website.

a. When you create an account, and when you log in.

b. When you want to find out who called.

c. When you contact us and/or when you submit a request.

3. When you make use of, or interact with, our mobile software

application, and any other software, that we license (each individually,

and collectively, the “App”).

a. When you download our software (or App(s)), create an account,

when you log in and make use of the App.

b. When you download our software (or App(s)), create an account,

when you log in and make use of the App. When you contact us.

In our Privacy Policy you will learn about:

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

IS USED

2. HOW WE SHARE YOUR PERSONAL INFORMATION

3. INTERACTION WITH THIRD PARTY PRODUCTS


4. ADDITIONAL INFORMATION REGARDING TRANSFERS OF PERSONAL

INFORMATION

5. FOR HOW LONG DO WE RETAIN THE INFORMATION WE COLLECT?

6. USER RIGHTS

7. CHILDREN’S INFORMATION

8. HOW DO WE SAFEGUARD YOUR INFORMATION?

9. LOG FILES

10.ANALYTIC TOOLS

11.UPDATES OR AMENDMENTS TO THE PRIVACY POLICY

12.HOW TO CONTACT US

• 1. WHAT INFORMATION WE COLLECT, WHY WE COLLECT IT, AND HOW

IT IS USED?

1. When you browse, or visit, our Website.

i. Specific Personal Information we collect – When you visit

our Website, we collect Personal Information submitted

directly by you, or Personal Information transmitted

automatically from your device using various standard

technologies, such as cookies, analytic tools, digital

identifiers, log files, web beacons or other similar

technologies. For more information, please read our

cookies policy https://sync.me/cookies-policy

ii. Why is the Personal Information collected and for what

purposes? We collect the Personal Information for the

purposes of tracking your activity and use of our Website,

your type of browser, pages you visited, the time and date

of your visits or the links you click on, to improve quality

and design of the Service, including without limitation,

saving you the trouble of re-entering data and queries, to

personalize and customize the Service, and to track your

use of the Service and generate statistics regarding the

Service. In addition, we collect this Personal Information to

enhance and personalize your experience, customize the

advertising content we display, and to perform research,

technical diagnostics, analytics, or statistical purposes.

iii. Legal basis (GDPR only, if applicable) – Consent and

Legitimate interest (e.g., essential cookies).

iv. Third parties with whom we share your Personal

Information – 3rd party platforms such as for the following

purposes: For more information, please read our cookies

policy https://sync.me/cookies-policy


v.


Retention period – For more information, please read our

cookies policy https://sync.me/cookies-policy

vi. Consequences of not providing the Personal Information –

Certain Website features may not be available. Read more

about the purposes of each cookie

https://sync.me/cookies-policy

2. When you make use of, or interact with, our Website

a. When you create an account and when you log in.

i. Specific Personal Information we collect – We will collect

your full name, phone number and email address, and/or

the Google or Microsoft log-in details.

ii. Why is the Personal Information collected and for what

purposes? We collect the Personal Information for the

purpose of: (i) allowing you to create your account, (ii)

allowing you to log in to the services, and (iii) allowing

you to enjoy features available to registered users only

(including, without limitation, the use case Website

features to find our who called you (more information

see below the use case b). To complete the registration,

we may contact you with the number your provided us

(via inbound call or SMS) in order to authenticate your

identity and prevent fraud.

iii. Legal basis (GDPR only, if applicable) – Depending on the

context, processing is necessary for the performance of a

contract to which the data subject is a party, or in order

to take steps at the request of the data subject prior to

entering into a contract, and legitimate interest (e.g. to

sign-up)

iv. Third parties with whom we share your Personal

Information – 3rd party platforms such as for the

following purposes: CRM platform, spam blocking

platform and cloud.

v. Retention period – Your Personal Information will be stored

until we no longer need the information and proactively

delete it or you send a valid deletion request. Please note

that we will retain it for a longer or shorter period in

accordance with data retention laws

vi. Consequences of not providing the Personal Information –

Where we do not process the Personal Information, we

will not be able to: (i) allow you to create your account,


(ii) allow you to log in to the App, and (iii) allow you to

enjoy features available to registered users only.

vii. Marketing communications - We will collect your full name

and email address to send you marketing

communications in accordance with your consent. We

share the Personal Information with 3rd party platforms

such as for the following purposes: CRM platform and

cloud. Your Personal Information will be stored until we

no longer need the information and proactively delete it

or you send a valid deletion request. Please note that we

will retain it for a longer or shorter period in accordance

with data retention laws. If you do not provide us with

the data, we cannot send marketing communications.

b. When you want to find out who called you.

i. Specific Personal Information we collect – We will collect the phone

number provided by you.

ii. Why is the Personal Information collected and for what purposes? We

collect the Personal Information for the purpose of: (i) identifying

(automatically) incoming calls or to perform a manual numeric search

(Caller ID), (ii) enabling you to use our Sync.Me Search feature, (iii)

enabling you to block phone numbers, and/or (iv) reporting phone

numbers as spam and to integrate and update information relating to

you and your contacts with the information stored on your social

platform.

iii. Legal basis (GDPR only, if applicable) – Depending on the context,

processing is necessary for the performance of a contract to which

the data subject is a party, or in order to take steps at the request of

the data subject prior to entering into a contract, and legitimate

interest (e.g., to find our who called you).

iv. Third parties with whom we share your Personal Information – 3rd

party platforms such as for the following purposes: CRM platform,

spam blocking platform and cloud.

v. Retention period – Your Personal Information will be stored until we no

longer need the information and proactively delete it or you send a

valid deletion request. Please note that we will retain it for a longer or

shorter period in accordance with data retention laws.

vi. Consequences of not providing the Personal Information – Where we

do not process this Personal Information, we will not be able to : (i)

automatically identify incoming calls or to perform a manual numeric

search (Caller ID), (ii) enable you to use our Sync.Me Search feature,


(iii) enable you to block phone numbers, and/or (iv) report phone

numbers as spam and to integrate and update information relating to

you and your contacts with the information stored on your social

platform

3. When you make use of, or interact with, our App

a. When you download our software (and/or App(s)), create an account, log

in and make use of the App.

i. Specific Personal Information we collect – We will collect your full

name, phone number and email address, payment information, the

Google or Microsoft log-in details, information stored on your device

phonebook directory (e.g. phone number, email address and name of

your contacts), your approximate geolocation (via Wi-Fi or cellular

technology in your device, including, country), internet protocol (IP)

address and other unique device identifiers and descriptions, and any

other information that you will decide to provide/supply us with.

ii. Why is the Personal Information collected and for what purposes? We

collect the Personal Information for the purpose of: (i) allowing you to

create your account, (ii) allowing you to log in to the App, (iii) allowing

you to enjoy features available to registered users only, (iv) to

complete the registration, we may contact you with the number your

provided us (via inbound call or SMS) in order to authenticate your

identity and prevent fraud, (v) when using our Name Tag feature –

when sufficient number of users indicated that the phone number is

associated with the same name, the name and phone number will be

included in our directory, (vi) to match the information in your phone

and contacts with numbers from the calls you make or receive, as well

as with information in our database. We also store this information

for subsequent data validation for both you and other users of our

App and other products (vii) to send you push notifications, for

example, to remind you and/or suggest you to sync your contacts,

(viii) to enhance and personalize your experience and customize the

advertising content we display, and (ix) to communicate with you (via

email, mobile device, etc.) and to authenticate your identity, (x) to

perform research, technical diagnostics, analytics or statistical

purposes; (xi) to provide you with the most relevant additional

services and offers, and (xii) some information will be processed on

our directory and allow you to perform numeric search and identify

incoming calls against this directory, which contains the contacts’

information of users who permitted the process of this information.


iii. Legal basis (GDPR only, if applicable) – Depending on the context,

processing is necessary for the performance of a contract to which

the data subject is party or in order to take steps at the request of the

data subject prior to entering into a contract, consent and/or

legitimate interest (e.g. to allow the user to sign-up).

iv. Third parties with whom we share your Personal Information – 3rd

party platforms such as for the following purposes:

a. our affiliated companies and our third party professional service

providers, who are allowed to use the information only for the

purposes of providing the Service to you,

b. with our affiliated companies and business partners for

performing services for us (e.g. customer service, marketing

assistance, technical support, analytics, etc.),

c. we share your information, including Personal Information, with

other users in our community. Your name will be displayed in

an incoming call to other users or in a numeric search of your

phone number (Caller ID),

d. Your profile information, including information derived from your

social network, will be available to other users in accordance

with your private settings,

e. Your phone number will not be visible to other users, unless it was

publicly available or if you decided to share it explicitly,

f. If you have activated the Sync.ME Search feature then the contact

details provided by you (e.g., full names, phone numbers and

email addresses) will be processed in our directory and

available to other users registered with this same feature, in an

incoming call or in a numeric search, and

g. If you decided to report a phone number as SPAM, it may be

included in our public SPAM directory, available to the users in

our community.

h. We may also disclose (or permit their access to) your Personal

Information to third party partners via API, mobile carrier, for

the purpose of ensuring that the partners' current data is up to

date, enriching it and allowing our partners to obtain relevant

information for commercial and business opportunities,

including, without limitation, to detect spam calls. If you prefer

that we do not share your Personal Data publicly on our App,

with vendors or business partners, you may opt-out by filling in

your relevant details https://sync.me/unsubscribe


v. Retention period – Your Personal Information will be stored until we no

longer need the information and proactively delete it or you send a

valid deletion request. Please note that we will retain it for a longer or

shorter period in accordance with data retention laws.

vi. Consequences of not providing the Personal Information – Where we

do not process this Personal Information, we will not be able to: (i)

allowing you to create your account, (ii) allowing you to log in to the

App, (iii) allowing you to enjoy features available to registered users

only, (iv) to complete the registration, we may contact you with the

number your provided us (via inbound call or SMS) in order to

authenticate your identity and prevent fraud, (v) when using our

Name Tag feature – when sufficient number of users indicated that

the phone number is associated with the same name, the name and

phone number will be included in our directory, (vi) to enhance and

personalize your experience and customize the advertising content

we display, and (vii) to communicate with you (via email, mobile

device, etc.) and to authenticate your identity, (viii) to perform

research, technical diagnostics, analytics or statistical purposes; (ix) to

provide you with the most relevant additional services and offers, and

(x) some information will be processed on our directory and allow you

to perform numeric search and identify incoming calls against this

directory, which contains the contacts’ information of users who

permitted the process of this information. retention laws.

vii. If you decide to provide us with your social network identifier (e.g.,

Facebook, Google+, LinkedIn, VK) we will be able to retrieve and use

information accessible and/or stored in such service related to your

profile or your contacts (e.g. social identifier, profile link, profile

image, name and emails; collectively “ Social Data ”) to integrate and

synchronize such information with your information and your

contacts’ information, to enhance our users’ experience and update

your information and your contacts’ information. We will retrieve

such information in accordance with the security restrictions and

applicable permissions of the respected approved platform. We do

not store or process password or security related information. Our

legal basis for collecting these Personal Information is consent.

viii. If you voluntarily access or use the “Sync.Me search” feature you will be

asked to provide the names, phone numbers, email addresses and

Social Data about your contacts as contained in your device

phonebook directory, in order to enhance your searchable directory,

for synchronization and to allow us to recommend you people you


may know within our community. Our legal basis for collecting these

Personal Information is that consent.

ix. Marketing communications - We will collect your full name and email

address to send you marketing communications in accordance with

your consent. We share the Personal Information with 3rd party

platforms such as for the following purposes: CRM platform and

cloud. Your Personal Information will be stored until we no longer

need the information and proactively delete it or you send a valid

deletion request. Please note that we will retain it for a longer or

shorter period in accordance with data retention laws. If you do not

provide us with the data, we cannot send marketing communications.

b. When you contact us.

i. Specific Personal Information we collect – We will collect your full

name, phone number, email address, comments and any other

Personal Information that you decide to share/supply us with.

ii. Why is the Personal Information collected and for what purposes? We

collect the Personal Information for the purpose of processing your

request and to assist you with your inquiry. decide to share/supply us

with.

iii. Legal basis (GDPR only, if applicable) – necessary for the performance

of a contract to which the data subject is party or in order to take

steps at the request of the data subject prior to entering into a

contract and legitimate interest (e.g. respond to an inquiry sent by

you). decide to share/supply us with.

iv. Third parties with whom we share your Personal Information – 3rd

party platforms such as for the following purposes: Cloud. decide to

share/supply us with.

v. Retention period – Your Personal Information will be stored until we no

longer need the information and proactively delete it or you send a

valid deletion request. Please note that we will retain it for a longer or

shorter period in accordance with data retention laws.

vi. Consequences of not providing the Personal Information – Where we

do not process this data, we will not be able to process your request

and assist you and respond to your inquiry.

Finally, please note that some of the abovementioned Personal Information

will be used for detecting, taking steps to prevent, and the prosecution of

fraud or other illegal activity, to identify and repair errors, to conduct audits,

and for security purposes. Personal Information 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 Information and

further use it for internal and external purposes, including, without limitation,

to improve the services and for research purposes, we may be shared with

third parties (including ad networks, advertising companies and service

providers) in any of the above circumstances, as well as for the purpose of

developing or delivering tailored or targeted advertising (whether via our

Service or Websites), for the purpose of improving our Service, conducting

business analysis or other business purposes. This information may be

combined with information we collect from other sources, to the extent that

the information remains anonymous. “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).

• 2. HOW WE SHARE YOUR PERSONAL INFORMATION

In addition to the recipients described above, we may share your Personal

Information as follows:

• With our business partners with whom we jointly offer products or

services. We may also share Personal Information with our affiliated

companies.

• 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, including, without limitation, in order

to enforce intellectual property rights or to exercise other legal rights; to

establish or exercise our rights to defend against legal claims; if we

believe it is necessary to investigate, prevent, or take action regarding

illegal activities, suspected fraud or other wrongdoing, safety of person

or property, violation of our policies, to enforce our policies or as

otherwise required in order to comply with the applicable laws and

regulations.

• We may share Information, including Personal Information, with our

parent company, any subsidiaries, joint ventures, strategic alliances, or

other companies under a common control (collectively "affiliated

companies").

• 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 Information 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 Information 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 Information (e.g., where you provide us with marketing

consents or opt-in to optional additional services or functionality).

In the event of the above, our affiliated companies or acquiring company will

assume the rights and obligations as described in this Privacy Policy. If you

want to receive the list of the current recipients of your Personal Data, please

make your request by contacting us to privacy@sync.me.

• 3. INTERACTION WITH THIRD PARTY PRODUCTS

Our Privacy Policy only addresses the use and disclosure of information we

collect from you. 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”). To the extent that you disclose

your information to other parties via our Service (whether our Website or

application; e.g. by clicking on a link to any other website or location or by

providing information via API) or via other sites throughout the internet,

different rules may apply to their use or disclosure of the information you

disclose to them. We are not responsible for the privacy practices or the

content of such Third Party Services. Accordingly, we encourage you to review

the terms and conditions and privacy policies of those sites before providing

your Personal Information to them.

• 4. ADDITIONAL INFORMATION REGARDING TRANSFERS OF PERSONAL

INFORMATION

Access from Israel: Access from Israel is covered by the European

Commission’s Adequacy Decision regarding Israel. You can read more

here: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfersoutside-eu/adequacy-protection-personal-data-non-eu-countries_en

External transfers: Where we transfer your Personal Information outside of

EU/EEA (for example to third parties who provide us with services), we will

obtain contractual commitments from them to protect your Personal

Information.

• 5. FOR HOW LONG DO WE RETAIN THE INFORMATION WE COLLECT?


5.1. Retention of your Personal Information. In addition to the retention

periods mentioned above, in some circumstances we may store your Personal

Information for longer periods of time, for example (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 Information or dealings. We

have an internal data retention policy to ensure that we do not retain your

Personal Information perpetually. Regarding retention of cookies, you can read

more in our cookie policy https://sync.me/cookies-policy

5.2. If your Personal Information was directly volunteered to us, either by

yourself or by another User, we will retain such Personal Information unless

we were instructed by you to delete it. You may approach us at any time with a

request to delete your Personal Information, by sending us an email

at: privacy@sync.me. or you may do so by visiting this

link: https://sync.me/unsubscribe

• 6. USER RIGHTS

Rights: The following rights (which may be subject to certain exemptions or

derogations) shall apply to certain individuals (some of which only apply to

individuals protected by the GDPR):

You can exercise your rights by contacting us at privacy@sync.me. You may use

an authorized agent to submit a request on your behalf if you provide the

authorized agent written permission signed by you. To protect your privacy,

we may take steps to verify your identity before fulfilling 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.

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. We reserve the right to charge a fee where

permitted by law, for instance if your request is manifestly unfounded or

excessive. 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.

Notwithstanding anything to the contrary, you acknowledge that the same

information, including without limitation, the Personal Data provided to

Sync.Me by you may have already been provided, or will be provided, by other

users, or may have already been collected, or will be collected by Sync.Me


independently, or from other sources, or may be available on public sources or

publicly available data sources. For the avoidance of doubt, processing of

information in such cases (e.g., when it was provided the same Personal Data

also by other sources,), including without limitation, the Personal Data shall

not be considered a breach of our Terms of Use and/or your rights (even when

you request to delete the contact details that you had uploaded to the App).

You can opt-out so in an easy manner through our opt-out page, available

here: https://sync.me/unsubscribe

Deleting your account: Should you ever decide to delete your account, you

may do so by emailing privacy@sync.me. If you terminate your account, any

association between your account and Personal Information 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.

• 7. CHILDREN'S INFORMATION

Our Service is not intended for minors below the age of 16 years or otherwise

below the legal age for providing consent that is not subject to authorization

by the holder of parental responsibility, in accordance with the laws in the

jurisdiction your reside (“Age of Consent”), and we will not knowingly collect

personal information from children. If we become aware that a user is under

the age of Age of Consent, we reserve the right to remove the Personal

Information from our files and systems. We reserve the right to request proof

of age at any stage so that we can verify that children are not using the Service.

If you believe that we might have any such information, please contact us

at privacy@sync.me.

• 8. HOW DO WE SAFEGUARD YOUR INFORMATION?

We take great care in implementing and maintaining the security of the Service

and your information and we have implemented appropriate technical,

organizational and security measures designed to protect your Personal

Information. We employ industry standard procedures and policies to ensure

the safety of our users’ information, and prevent unauthorized use of any such

information. Although we take reasonable steps to safeguard information,

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.


If you feel that your privacy was treated not in accordance with our Privacy

Policy, or if any person attempted to abuse our service or acted in an

inappropriate manner, please contact us directly at privacy@sync.me.

• 9. LOG FILES

We use log files. We use such information to analyze trends, administer the

Website/App, track users’ movement around the Website/App, and gather

demographic information.

• 10. 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/.

Firebase Analytics. We also use “Google Analytics for Firebase”. By enabling

this tool, we enable the collection of data about App Users, including

via identifiers for mobile devices (including Android Advertising ID and

Advertising Identifier for iOS), cookies and similar technologies. We use the

information we get from Google Analytics for Firebase to maintain and

improve our App(s). We do not facilitate the merging of personally-identifiable

information with non-personally identifiable information unless we have

robust notice of, and your prior affirmative (i.e., opt-in) consent to, that

merger. Finally, please note that Google Analytics for Firebase’s terms

(available at https://firebase.google.com/terms/) shall also apply.

AppsFlyer. We use a tool called “AppsFlyer”, a mobile attribution and

marketing analytics platform to understand the use of our services. AppsFlyer

is exposed to the following data: (i) unique identifiers and technical data, such

as IP address, User agent, IDFA (Identifier For Advertisers) or Android ID (in


Android devices); and (ii) technical data regarding your operating system,

device attributes and settings, applications, advertising opt-out signals, Google

Advertiser ID, in-app events, device motion parameters and carrier. The use of

this data allows us to analyze our campaigns and performance, as well as your

habits and characteristics. For example, the data AppsFlyer receives includes

downloads, impressions, clicks and installations of their mobile applications,

mobile device use and data regarding in-app events. AppsFlyer’s terms of use

(available at https://www.appsflyer.com/terms-of-use/) and privacy policy

(available at https://www.appsflyer.com/privacy-policy/) also apply to the use

of AppsFlyer.

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

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.

• 11. UPDATES OR AMENDMENTS TO THE PRIVACY POLICY

We reserve the right to change this Privacy Policy at any time, so please re-visit

this page frequently. If we implement significant changes to the use of your

Personal Information in a manner different from that stated at the time of

collection, we will provide notice of such changes of this Privacy Policy on the

Service and/or we will send you an e-mail regarding such changes to the e-mail

address that you volunteered, or by other means. To the maximum extent

permitted by law, such substantial changes will take effect seven (7) days after

such notice was provided on any of the above mentioned methods. Otherwise,

all other changes to this Privacy Policy are effective as of the stated “Last

Revised” date, and your continued use of the Service after the Last Revised

date will constitute acceptance of, and agreement to be bound by, those

changes.


12. HOW TO CONTACT US

If you have any questions (or comments) concerning this Privacy Policy, you

are welcome to send us a contact us request to privacy@sync.me.