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PRIVACY POLICY

Last Revised: May, 2020

This privacy policy ("Privacy Policy") provides details on how we Sherlock Tech Ltd ("we", "us" or "our") collect, process and use data from users ("user" or "you"), of our Search Product and Search Services (as defined in our End User License Agreement ("EULA")), as required, among others, according to the EU General Data Protection Regulation ("GDPR") and the California Consumer Privacy Act ("CCPA") where applicable.

This Privacy Policy is an integral part of our EULA. Capitalized terms not defined in this Privacy Policy shall have the meaning set forth therein.

AT THE OUTSET, PLEASE NOTE:

You are not required by law to provide us your Personal Data (as defined below), however, some of the Search Services, may require the processing of certain Personal Data, as shall be detailed herein.
Children (as defined under applicable law, and specifically under the age of 16) are not permitted to use the Search Services nor provide us with any Personal Data.
Applicable laws in your jurisdiction may provide you with certain rights regarding your Personal Data, for example, amend, erase or restrict the processing of your Personal Data, or have access to certain Personal Data. Please review the “YOUR RIGHTS AND CONTROLS” paragraph below for more information.
We may share Personal Data with third parties in connection with the provision of the Search Services, or other limited circumstances as specified herein.
If you have any questions or requests regarding the processing of your Personal Data, or would otherwise like to contact us in connection with this Privacy Policy, please send us an email to: support@sherlocktechltd.com

AMENDMENTS

This Privacy Policy may be updated from time to time, and every 12 months in the event required under applicable laws. Therefore, we ask you to check back periodically to read the most updated Privacy Policy. The last and updated version is reflected in the "Last Revised" heading above. In the event of a material change we will make best efforts to provide a notice, subject to applicable laws requirements.

DATA WE COLLECT

When you install our Search Product and use the Search Services, we will collect certain information about you and your use as follows:

"Personal Data" or "Personal Information" (subject to applicable law definitions) - meaning information that identifies an individual or may with reasonable effort identify an individual. This may include online identifiers such as IP address, name, emails, etc.,

"Non-Personal Data" - meaning technical and aggregated data about you that is non-identifiable and non-personal (i.e., cannot identify you).

If we combine Personal Data with Non-Personal Data, we will treat the combined data as Personal Data.

EU General Data Protection Regulation ("GDPR") & Lawful Basis for Data Processing

We have included below information about which data is processed, how we process and use your data, but before, we would like to explain the lawful basis for which we do so subject to the GDPR:

Where you download the Search Product and use our Search Services, we process certain Personal Data where we have a legitimate interest in processing such data.
In the event you contact us, we will process your contact details and other information you choose to provide us with in order to perform our contract with you.
We will also process certain Personal Data where you have provided us with consent to do so, if applicable.

As defined under the GDPR, we act as a Controller of the Personal Data we collect and detailed below.

DATA WE COLLECT	PURPOSE OF COLLECTION AND USE
Technical Data and Internet Protocol Address: When you download Search Product and use the Search Services, we will collect your Internet Protocol address ("IP"). In addition, we will collect technical data transmitted from your device such as your aggregated use of the Search Service, statistics, type of browser and default search language preference, operating system type, time and date you access and use the Search Service, approximate geographical location, etc.	We are using industry common practices to anonymize IP address immediately following collection, and store it in an ammonized manner (i.e., as Non Personal Data). Collection of the IP address is necessary for providing the Search Services. Thus, we will use this data for the purpose of operating, providing, maintaining, protecting and managing our Search Services. In addition, we will use this data under our legitimate interests of auditing and tracking usage statistics as well as security and fraud detection, and business operation such as calculating our business partners considerations.
Contact Us & Customer Support: If you voluntarily contact us through any means of communication we provide (e.g., send us an email, etc.), you will be requested to provide us with your contact information such as your name and email address.	We will use your contact details and save your contact history with us in order to respond to your inquiry, provide you with support, assistance or any other service requested by you. We will retain our contact history and correspondence, in the event we find it applicable (e.g., in the event of future claim, to provide you with support, or to improve our services).
Search Queries We, or our third-party partners (advertisers or feed providers included in the Search Product) may collect search queries related data. It is important to note that this data is deleted shortly following collection.	This data is processed in order to provide you with advertisments based on previous searches.

DATA WE COLLECT

PURPOSE OF COLLECTION AND USE

Technical Data and Internet Protocol Address:

When you download Search Product and use the Search Services, we will collect your Internet Protocol address ("IP").

In addition, we will collect technical data transmitted from your device such as your aggregated use of the Search Service, statistics, type of browser and default search language preference, operating system type, time and date you access and use the Search Service, approximate geographical location, etc.

We are using industry common practices to anonymize IP address immediately following collection, and store it in an ammonized manner (i.e., as Non Personal Data).

Collection of the IP address is necessary for providing the Search Services. Thus, we will use this data for the purpose of operating, providing, maintaining, protecting and managing our Search Services. In addition, we will use this data under our legitimate interests of auditing and tracking usage statistics as well as security and fraud detection, and business operation such as calculating our business partners considerations.

Contact Us & Customer Support:

If you voluntarily contact us through any means of communication we provide (e.g., send us an email, etc.), you will be requested to provide us with your contact information such as your name and email address.

We will use your contact details and save your contact history with us in order to respond to your inquiry, provide you with support, assistance or any other service requested by you. We will retain our contact history and correspondence, in the event we find it applicable (e.g., in the event of future claim, to provide you with support, or to improve our services).

Search Queries

We, or our third-party partners (advertisers or feed providers included in the Search Product) may collect search queries related data. It is important to note that this data is deleted shortly following collection.

This data is processed in order to provide you with advertisments based on previous searches.

California Consumer Privacy Act 2018 ("CCPA") & Categories of Personal Information Collected and Shared

Please note that, under the CCPA, Personal Information does not include: Publicly available information from government records; Deidentified or aggregated consumer information.

As required under the CCPA, please see below a table specifying the categories of Personal Information we collect:

Category	Examples	Collected
A. Identifiers.	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.	Yes
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.	No
C. Protected classification characteristics under California or federal law.	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).	No
D. Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	No
E. Biometric information.	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	No
F. Internet or other similar network activity.	Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.	Yes
G. Geolocation data.	Physical location or movements.	No
H. Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information.	No
I. Professional or employment-related information.	Current or past job history or performance evaluations.	No
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	No
K. Inferences drawn from other personal information.	Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	No

As required under the CCPA, please see below information regarding disclosures of Personal Information for a business purpose:

In the preceding twelve (12) months, Company has disclosed the following categories of Personal Information for a business purpose: (A) Identifiers and (F) Internet or other similar network activity.

We disclose your Personal Information for a business purpose to the following categories of third parties: Data aggregators; Service providers, Business Partners.

Personal Information disclosed by us for a business purpose, is subject to contractual obligations on behalf of the service provider to not use this data for any purpose except performing its obligations under our engagement.

Sale of Personal Information

In the preceding twelve (12) months, Company has not sold Personal Information.

HOW WE COLLECT DATA

We may collect Personal Data either through the use cookies (as elaborated in the "Cookies" section below), and other tracking technologies when you interact with the Search Product and Search Services; or when you directly provide us with information (for example send us an email).

COOKIES

When using our Search Service, we or our business partners assign your device with a log file, a cookie (session or persistent), web beacons or other related technologies, to collect information with respect to your activity in connection with our Search Service.

A "cookie" is a small piece of information that a website assign to your device while you are viewing a web site. Cookies can be used for various different purposes. These purposes include allowing you to navigate between pages efficiently, enable automatic activation of certain features, remembering your preferences and making the interaction between you and the services you are using quicker and easier. Cookies are also used to help customize your experience (i.e., provide you with search results and advertisements based on your searches).

As part of the Search Product, the following third-party cookies are used:

Facebook – this cookie is used for analytic, measurement & performance purposes. Please review Facebook’s privacy policy available here, and cookies policy available here, in order to learn more.
Google Analytics – this cookies is used for analytic and measurement. Please review Google’s privacy policy available here, opt out available here, in order to learn more. For information of our use of Google products, click here.
Jeeng – this cookies is used for targeting and advertising. Please review Jeeng’s privacy policy available here, in order to learn more.

Cookies Opt-Out:

You may opt-out of data collection and sharing process made through cookies. Most browsers will allow you to erase cookies, block cookies, or receive a warning before a cookie is stored. However, if you choose to disable cookies, some features of our Search Services may not operate properly. For more information about cookies and your controls in this regard, please review your browser settings. You may find applicable information here:

WITH WHOM WE SHARE DATA

We do not sell, trade, or rent users' Personal Data to other parties. We may share data solely in the following events:

we will share your information, solely to the extent needed to comply with any applicable law or regulation (including our policies and agreements), solely to the extent needed to establish or exercise our rights to defend against legal claims or to prevent harm to the rights, property or safety of us, our users, yourself or any third party or for the purpose of collaborating with law enforcement agencies or in case we find it necessary in order to enforce intellectual property or other legal rights.
we may share your data, in the event of a corporate transaction (e.g. sale of a substantial part of our business, merger, consolidation or asset sale). In the event of the above, our affiliated companies or acquiring company will assume the rights and obligations as described in this Privacy Policy.
we may share Personal Data with our trusted service providers only to the extent required to fulfill the purposes of providing the services.
we may disclose or share IP address collected by us (as detailed above), for the purpose of operating our business and providing the Search Services, as well as to calculate payments and detect fraud, security or technical issues in connection with the Search Service;

YOUR RIGHTS AND CONTROLS

Privacy laws differ from jurisdiction to jurisdictions, each of which may provide you with different rights regarding your Personal Data, such as the right to access your Personal Data; the right to erase Personal Data; the right to opt out of Personal Data processing, etc.

Particularly, if you are a resident of the European Economic Area ("EEA") or California, the provisions of the GDPR and the CCPA, respectively, provide you with the following rights: The right to be informed: in order to ensure fair and transparent processing, you have the right to be provided with information regarding our data collection and privacy practices, as detailed in this Privacy Policy. The right to access data: you have the right to request a confirmation from us that we process your Personal Data, and in some cases, be provided with a copy of the Personal Data we process. The right to be forgotten: you have the right to require us to erase certain Personal Data, if particular conditions are satisfied (if the personal data is no longer needed for the original purpose and there is no new lawful basis for continued processing; if you have exercised your right to withdrawn consent (if applicable), or to object to the processing and we have no overriding grounds for the continued processing; the personal data is processed unlawfully; or erasure of personal data is necessary to comply with applicable legislation. This right is not absolute. We may reject your request in some circumstances, including where we must retain the data in order to comply with legal obligations or defend against legal claims, etc. The right to object: you have the right to object to processing of Personal Data, in the event the basis for processing is our legitimate interests, however, we will be permitted to continue the processing if our legitimate interests override your rights, or when processing is necessary to establish, exercise or defend a legal claim or right, etc.; The right to restrict processing: you may limit the purposes for which we process your Personal Data, when: the accuracy of the data is contested; processing is unlawful and you requests restriction instead of erasure; the Personal Data is no longer needed for the original purpose it was collected, however the data is still required to establish, exercise or defend legal rights; or there are overriding grounds in the context of an erasure request; Rectification (in the event you are an EEA resident): you have the right to require to update Personal Data which is not correct; Portability: you have the right to have your Personal Data "port" to a third-party, subject that: the Personal Data was provided by you; the Personal Data is processed automatically; and the Personal Data was processed on the legal bases of contract or consent; The Right to Non-Discrimination (in the event you are California resident): you have the right not to be discriminated against for having exercised your rights under the applicable laws. In particular, the business may not: deny the consumer goods or service, charge the consumer different prices for goods or services, whether through denying benefits or imposing penalties provide the consumer with a different level or quality of goods or services to the consumer.

We provide you with the ability to exercise certain choices and controls in connection with our treatment of your Personal Data, depending on your relationship with us. If you wish to exercise any or all of the above rights, please download our applicable form available at: Privacy Rights Request and send it to our privacy team at: support@sherlocktechltd.com

Where we are not able to provide you with the information for which you have asked, we will endeavor to explain the reasoning for this and inform you of your rights, including the right to complain to the supervisor authority (in the event you are EEA resident). We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any such information in accordance with applicable law.

THIRD PARTY SERVICES

This Privacy Policy does not cover third-party services, third party providers or third party websites content. These third party’s data protection practices may be different from ours, and is not under our control. Give the above, we will not be responsible or liable to such privacy practices and you are advised to carefully review the applicable third-party’s privacy policy.

CHILDREN INFORMATION

The Search Product and Search Services are not directed or intended for children, as defined under applicable law, and specifically under the age of 16. We do not knowingly collect or solicit information from children. If we later obtain actual knowledge that we process child’s Personal Data, we will take steps delete the applicable data.

SECURITY AND DATA RETENTION

Your privacy is very important to us and therefore we are committed to protecting your Personal Data from unauthorized access, use or disclosure. We have implemented physical, technical and administrative security measures that comply with applicable laws and industry standards.

As described in the table below, we minimize the Personal Data that it stored on our servers in the first place. In the event of a data breach, 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 rectify, replenish or remove incomplete or inaccurate information, at any time and at our own discretion. We retain the data we have collected for as long as needed to provide the Search Services, carry out our business purpose and to comply with our legal obligations, resolve disputes and enforce our agreements, in accordance and compliance with applicable laws, or until an individual request us to delete its Personal Data, as detailed above.

TRANSFER OF DATA

We may process or store Personal Data within the European Economic Area ("EEA"), US, and internationally, therefore you hereby accept and agree that by accessing and using our Search Services from outside the United States, your information may be transferred to, stored, and processed in the United States. If you are a resident of the EEA we will take appropriate measures to ensure that your Personal Data receives an adequate level of data protection as required under the GDPR.

DO NOT TRACK DISCLOSURE

Do Not Track signals are not responded. See: http://www.allaboutdnt.com/, for more information.

CONTACT INFORMATION

If you have any questions about this Privacy Policy, or the practices of our Search Services, please contact us at:

Via e-mail: support@sherlocktechltd.com