Last Revised: June 18, 2024
Addressable Ltd. (“Addressable”, “our”, “we” or “us”) respects the privacy of its users (“User(s)”, “your” or “you”), and is committed to protecting the information that you share with us in connection with your use of our website, available at: https://www.addressable.io/ (the “Website”), and our online Software-as-a-Service (SaaS) platform and solutions, intended for digital marketing and market analytics (the “Solution”), and through our own marketing and advertising activities and any other services we may provide to you from time to time (together with Website and Solution, the “Services“).
1. Scope and Applicability.
This privacy policy (“Privacy Policy”) governs and is intended to describe our practices regarding information (including Personal Information as defined below) that we may collect from you or about you when you use or access the Services, the ways in which we may use such information, and the choices and rights available to you.
Users of our Services (referred to, unless otherwise specifically indicated, as “Users” or “You” collectively) may include (i) individuals who use our Solution in their capacity as employees, service providers and consultants or other personnel of our business customers (our business customers hereafter “Customer(s)”) including individuals identifying as a Customer “admin” users or Customer’s end-users, using or accessing the Services under Customer’s account or on Customer’s behalf (each, a “Customer End-User”); (ii) individuals to whom we have served marketing campaigns on behalf of our Customers in the scope of the provision of the Services or otherwise individuals who accessed or interacted with our Customers online assets with respect to which our Services are provided to Customer (each, a “Customer Audience Member” and collectively, the “Customer Audience”); (iii) visitors of the Website and of our other digital and online assets (each, a “Visitor”); and (iv) Candidate(s) (as defined below).
This Privacy Policy supplements and shall be read in conjunction with the Addressable Website Terms of Use (“Website TOS”) and the Addressable Platform Terms of Service (the “PlatformTOS”) or if a commercial agreement was entered into by Addressable and the applicable Customer concerning Customer’s access and receipt of the Services (the “Addressable Services Agreement” or “ASD”), such applicable ASD; and it may be supplemented by additional privacy statements, terms or notices provided to you. Capitalized Terms not defined herein shall have the meaning ascribed to them under our TOU, the Platform TOS or the ASD (as applicable). In case of any conflict between the terms of the Platform TOS or the ASD and the TOU and/or this Privacy Policy, the terms of the Platform TOS or the ASD as applicable, shall prevail and govern.
IMPORTANT NOTE: where we process Personal Information contained in data, works and materials: (i) inputted by the Customer into the Platform; (ii) collected by Addressable’s access to Customer’s social network advertising account, that were obtained by Customer independently of the Services or (iii) about Customer End-Users ; we do so on behalf of and under the instruction of the respective Customer (which Customer may be your employer, or other corporation on behalf of which you perform services, or otherwise are using our Services) in our capacity as a “data processor” on behalf of such Customer and in accordance with the Data Protection Agreement we have in place with the relevant Customer (“DPA”).
The provisions of this Privacy Policy as they relate to Addressable’s independent privacy and data processing activities as a “data controller” – with respect to Users who are Visitors, Customer Audience, or Candidates do not apply to the processing of Customer Data or any other data with respect to which Customer and Addressable agreed that Addressable shall serve as data processor on behalf of Customer. If you are using our Services as a Customer End-User, of if otherwise, you have any questions or requests regarding Customer End-Users’ Personal Information , please contact the Customer on behalf of which you use the Solution (usually this will be your employer or corporation for which you provide a service).
2. Your Acceptance of this Privacy Policy.
Please read this Privacy Policy before accessing and/or using our Services or any part thereof. By accessing or using the Services or any part thereof, you confirm that you are aware of, and agree to the terms and conditions set forth in this Privacy Policy, including to the collection and processing of your Personal Information (as defined below).
You are not legally obligated to provide Personal Information to us. You hereby acknowledge and agree that you are providing us with Personal Information of your own free will and volition. You hereby agree that we may collect and use such Personal Information pursuant to this Privacy Policy and any applicable laws and regulations.
TO THE EXTENT THAT YOU PROVIDE US WITH ANY PERSONAL INFORMATION RELATED TO ANY THIRD PARTY OR ANY OTHER PERSON OR ENTITY WHICH IS NOT YOU, INCLUDING INFORMATION RELATED TO ANY OF YOUR PERSONNEL, COLLEAGUES, OR CUSTOMERS, OR ANY OTHER THIRD PARTY, YOU ARE SOLELY RESPONSIBLE TO RECEIVE AND HEREBY REPRESENT THAT YOU HAVE AND UNDERTAKE THAT YOU SHALL HAVE AT ALL TIMES, MAINTAINED AND RECEIVED, THE CONSENT, AUTHORITY, PERMISSION, AND APPROVAL OF SUCH PERSONS AND PROVIDED THEM WITH SUFFICIENT DISCLOSURES, TO ALLOW US TO ACCESS, STORE, COLLECT, ANALYZE AND PROCESS SUCH PERSONAL INFORMATION AS DETAILED HEREIN.
3. What information do we collect from our users?
Non-personal Information: Non-personal Information is unidentified and non-identifiable information pertaining to Users, which may be made available to us, or collected automatically via their use of the Website and/or Solution. Such Non-personal Information does not enable us to identify the person from whom it was collected, and mainly consists of technical and aggregated usage information which is not linked to an identifiable individual, such as the operation system and browser version, duration of usage of the Website, User's 'click-stream' activity, keyboard language, etc.
Personal Information: Personal Information is information that pertains or relates to a specific individual, where such individual is identified or may be identified with reasonable efforts or together with additional information, we have access to.
Personal Information does not include information that has been anonymized or aggregated; provided that such information can no longer be used to identify a specific natural person. Addressable collects personal information in certain instances of interaction with its Users as follows:
When you visit our Website, use our Solution or access and visit our other digital and online assets or otherwise directly communicate with us, we may collect certain information automatically and certain information that is actively provided or made available to us:
Automatic Collection of data such as your IP address and device identifier, technical information with respect to the devices and software you use to access our Website, Solution or assets such as operating system, browser type, and version, type of device, crypto wallet address, time-zone, platform, language, technical configuration, usability information with respect to your use of the Website, Solution and other digital assets, and your engagement therewith, such as clickstream, event and log data, page visits, and different segmentation we apply when we consider your engagement with our Website and/or Solution; and
Actively provided Information – such as information that you actively input or otherwise communicate to us during such visit or communication such as (a) contact information such as full name, email address, company and any other information you actively input through our Website’s online forms and text fields and as part of your correspondence with us through various channels of communication, including when you address our support services, register for an account with us or when you update your account details; (b) the contents of your interaction with our customer support or sales teams which may include text/video/audio recordings and transcripts of such communications;
Impression and attribution information which mainly includes information concerning your navigations from and to our Website, Solution or other digital assets such as http referrals, IP address, advertiser ID.
We collect and process information concerning Customer Audience Members in the scope of our provision of Services to the relevant Customer. Such Customer Audience data may be obtained through access permissions to the Customer digital assets, granted to us by the relevant Customer, or otherwise in the scope of our services through various advertising attribution technologies such as cookies and similar tracking technologies.
Candidates’ Information (as defined below) that is submitted to us by candidates via email, by HR agencies or that we collect from generally available publications.
We do not collect any Personal Information from you or related to you without your approval or pursuant to the approvals provided to us by your organization or otherwise any approvals provided by our Customers, which are obtained, inter alia, through active acceptance of this Privacy Policy. Personal Information that we obtain and process as part of our Customers’ use of our Services (including without limitation, any trial use of our Solution), is processed by us pursuant to our Customer’s assurance that they have the right to allow us to have such access. Our access and use of any such data may also be subject to an applicable service agreement and/or data processing agreement between us and our Customer (e.g., Addressable Services Agreement), and in the event of a conflict between such agreement and this Privacy Policy, such specific agreement shall prevail.
Automatic collection of data is performed through the use of cookies, web beacons, and similar technologies
Personal Information collected from other sources: We may collect personal information concerning you, from third parties who have assured us that they have obtained your consent for such provision of information.
For the avoidance of doubt, any Non-Personal Information connected or linked to any Personal Information shall be deemed as Personal Information as long as such connection or linkage exists.
We do not collect any Personal Information from you or related to you without your approval, which is obtained, through various means, including through your acceptance of this Privacy Policy.
4. Why Do We Collect Information on Our Users?
We may use the information that we collect and receive about you for the following purposes:
To provide and operate our Website and/or Solution and related services.
To allow users to access certain components of our Website and/or provide our Solution or related services to our Customers.
To allow users who are Candidates to apply for work with us.
To be able to contact users who requested such contact to be made, for the purpose of providing them with further information on Addressable and its Services or to respond to such contact request or other voluntary submission of data by the users.
To prevent, detect, mitigate, and investigate fraud, security breaches, or other potentially prohibited or illegal activities, whether suspected or actual.
To market our Services to users or potential users, and to be able to track and evaluate our marketing activities and their results and attribute different marketing achievements to the respective marketing efforts.
To display or send to you marketing and advertising material including general and personalized content.
To be able to deliver and enhance the Website and/or Solution, and provide the users with technical assistance and support.
To send you updates, notices, notifications, announcements, and additional information related to the Website and/or Solution and related services.
To act upon and comply with requests you may make pursuant to this Privacy Policy and the privacy laws that apply to you.
To perform functions or services as otherwise described to you at the time of collection of the relevant information.
To create cumulative statistical data and other cumulative information and/or other conclusive information that is non-personal, in which we and/or our business partners might make use of in order to operate and improve our Website and/or Solution and provide related services.
To comply with any applicable rule or regulation and/or response or defend against legal proceedings versus us or our affiliates.
5. Lawful Grounds for Collecting Information on Our Users.
We collect and process your information for the purposes described in this policy, based at least on one of the following legal grounds:
With your consent: We ask for your agreement to process your information for specific purposes and you have the right to withdraw your consent at any time. For example, in order to provide you with personalized content and advertisements, we ask for your consent to use certain cookies;
Providing the requested services: we collect Personal Information to provide our users with the Website and/or Solution and access to the services available through our Website and/or Solution.
Legitimate interests: We process your information for our legitimate interests while applying appropriate safeguards that protect your privacy. This means that we process your information for things like detecting, preventing, or otherwise addressing fraud, abuse, security, usability, functionality or technical issues with our services, protecting against harm to the rights, property or safety of our properties, or our users, or the public as required or permitted by law; Enforcing legal claims, including investigation of potential violations of this Privacy Policy; in order to comply and/or fulfill our obligation under applicable laws, regulation, guidelines, industry standards and contractual requirements, legal process, subpoena or governmental request, as well as our commercial agreements with our Customers.
6. Where do we store user’s personal information?
Information regarding the Users (unless otherwise mandated by our Customers with respect to their respective Customer End-Users) will be maintained, processed, and stored by us and our authorized affiliates and service providers in the EU, US, and in Israel, and as necessary, in secured cloud storage, provided by our third-party service provider.
Where Addressable processes Personal Information on behalf of a Customer (including without limitation, Personal Information of Customer End-Users), such Personal Information will be processed in the locations as permitted and required by the Customer.
While the data protection laws in the above jurisdictions may be different from the laws of your residence or location, please know that we, our affiliates, and our service providers that store or process your Personal Information on our behalf are each committed to keeping it protected and secured, pursuant to this Privacy Policy and industry standards, regardless of any lesser legal requirements that may apply in their jurisdiction.
You hereby accept the place of storage and the transfer of information as described above.
7. Who Do We Share User Information with And Why?
We keep the information processed by us in strict confidence and we may only share information with third parties (or otherwise allow them access to it) in very limited circumstances and for very specific purposes, as described below:
Internally – We may share information with our family of companies, as well as our employees or other personnel, for the purposes described in this Privacy Policy. In addition, should Addressable or any of its affiliates undergo any change in control, including by means of merger, acquisition or purchase of substantially all of its assets, your information may be shared with the parties involved in such event under strict security conditions, for the purpose of evaluating such event and in accordance with the terms of this Privacy Policy. If we believe that such change in control might materially affect your Personal Information then stored with us, we will notify you of this event and the choices you may have, either through a prominent notice on our Website or by contacting you directly through contact details you have provided us.
Protecting Rights and Safety – We may share your information to enforce this Privacy Policy and/or any other agreement between Addressable and you, including investigation of potential violations thereof; to detect, prevent, or otherwise address fraud, security or technical issues; or otherwise, if we believe in good faith that this will help protect the rights, property or personal safety of any of our users, or any member of the general public.
Third Parties & Business Partners – When using our Services as a Customer End-User we will share your Personal Information with the applicable Customer with which you are affiliated (on behalf whom we process your information), in accordance with this Privacy Policy and any contractual obligations to such Customers. We partner with certain third parties to provide selected services that are used to facilitate and enhance the Website and/or Solution, your use thereof, or otherwise to facilitate us in our exercise of rights under this Privacy Policy (“Service Providers"). Such Service Providers may have access to, or process on our behalf personal information which we collect, hold, use, analyze, process and/or manage. These Service Providers include, among others, hosting, database and server co-location services (e.g. AWS, GCP), cookie and pixel vendors (e.g., Adform), CRM service providers (e.g. Hubspot) authentication services and our business, legal and financial advisors. We remain responsible for any personal information processing done by the Service Provider on our behalf, except for events outside of our and/or their reasonable control, and except with respect to Service Providers with whom you are contractually engaged, either through a prior separate contractual engagement and/or through acceptance of their privacy policy and terms of use if such are referenced below and/or in our data processing agreement with our Customers.
Law Enforcement – We may cooperate with government and law enforcement officials to enforce and comply with the law. We may therefore disclose any information to the government or law enforcement officials as we believe necessary or appropriate to respond to claims and legal processes (including but not limited to subpoenas), to protect our or a third party’s property and legal rights, to protect the safety of the public or any person, or to prevent or stop any activity we may consider to be, or to pose a risk of being, illegal, unethical, inappropriate or legally actionable.
Specifically, each of our Service Providers which store or process your Personal Information either: (i) assured us that they provide adequate safeguards to protect your rights to privacy including where applicable, by undertaking to comply with the EU Standard Contractual Clauses; (ii) where applicable, hold and process such information on our behalf in jurisdictions which have been determined to ensure adequate level protection by the EU Commission; (iii) perform such processing pursuant to your consent and acceptance of their privacy policy as further detailed in this Privacy Policy.
For avoidance of doubt, we may share anonymized/de-identified information with any other third party, at our sole discretion.
8. Your Rights.
If you are a user of our Services and to the extent that the law applicable to you grants you such rights, you may provide us with certain requests with respect to your Personal Information that is stored in our systems, and in the event of requests by Users who are Customer End-Users, subject to and as set out in Section 15. You may also ask for our confirmation as to whether or not we process your Personal Information. In some jurisdictions, you may request to exercise rights concerning your Personal Information as follows:
Right of access. You may have a right to know what information we hold about you and, in some cases, to have the information communicated to you. We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any information.
Right to correct Personal Information. We endeavor to keep the information that we hold about you accurate and up to date. Should you realize that any of the information that we hold about you is incorrect, please let us know and we will use our best efforts to correct it as soon as we can.
Data deletion. In some circumstances and under certain laws and regulations, you may have a right to request that some portions of the Personal Information that we hold about you be deleted or otherwise anonymized/de-identified.
Data portability. In some circumstances and under certain laws and regulations, you may have the right to request that the data that you have provided to us be provided to you, so you can transfer or port it elsewhere.
If you wish to exercise any of these rights, contact us at: info@addressable.io. When handling these requests, we may ask for additional information to confirm your identity and your request. Please note, upon request to delete your Personal Information, we may retain such data in whole or in part to comply with any applicable rule or regulation and/or response or defend against legal proceedings versus us or our affiliates.
To find out whether these rights apply to you and on any other privacy-related matter, you can contact your local data protection authority if you have concerns regarding your rights under local law.
9. Using Cookies And Other Tracking Technologies.
When you access or use the Website, we may use industry-wide monitoring and tracking technologies such as "cookies" or “pixel tags” (or similar technologies), which store certain information on your computer ("Local Storage"), and which will allow us to enable automatic activation of certain features and make your service experience much more convenient and effortless. The Local Storage is created per user and may be deleted by you, or you may configure your browser to not accept any such local storage items.
For example, these technologies enable us to: (i) provide you with the Website and/or Solution, (ii) keep track of our users’ preferences and authenticated sessions, (iii) secure our Website by detecting abnormal behaviors, (iv) identify technical issues and improve the overall performance of the Website and/or Solution, and (v) deliver targeted advertisements that are more tailored to their audience and track ad performance (For more information about this practice, click here: https://www.aboutads.info/choices/).
Such tracking technologies may include Pixel tags (also commonly known as web beacons), transparent images, iFrames, cookies, or Java script placed on our Website and/or Solution or our advertisements and emails, that are used to understand how you interact with the Website and/or Solution, with such advertisements and emails. To learn more about our use of Cookies and other tracking technologies, please see our Cookie Policy. It is important to note that some of these tracking technologies are provided to us by our Services Providers who collect and process personal information in the scope of the services that they provide us.
Please note – in certain cases such Services Providers may collect and process personal information, in a scope that is broader than the scope of collection and processing required for the purposes set forth above. This means that sometimes these Services Providers have access to more of your personal information than we do. In such cases, all such excess collections and processing are performed pursuant to and under a direct contractual relationship you have with such Service Providers, as detailed below, and any rights you may have with respect to such information, collected by such Services Providers, shall be governed by such contractual relationship. Otherwise, the terms of this Privacy Policy shall fully apply.
We may also use Google, X, and Reddit functionality of re-marketing tracking cookies and pixel-based retargeting. This means that if you provide your consent to Google, X, and Reddit , (the “Social Ad Platforms”) to be provided with personalized commercial offers, you may be served with ads based on your use of the Website, outside of the Website, and across the internet. In such an event the Social Ad Platforms, will place cookies or pixels on your web browser and use such technologies to serve you ads based on past visits to our Website.
Please visit the Social Ad Platforms’ individual privacy policy to find out how they use such information:
X, Reddit, Google
If you wish to opt-out of such re-targeting and tracking functionality of the Social Ad Platforms, you may do so at the following links:
Google, X
Specifically, to provide our some of the functionalities available through our Solution, we utilize the Adform Pixel, to learn more about how Adform processes your Personal Information, the Adform privacy notice is available under https://site.adform.com/privacy-center/platform-privacy/product-and-services-privacy-policy/. If you wish to opt out of the use of any Adform cookies, pixels, or similar tracking technologies you can opt out through this link.
In addition, if you wish not to receive ads from us based on your use of the Website, please send us an e-mail to info@addressable.io and we will respond within a reasonable timeframe and in accordance with applicable laws.
Learn more about your choices and how to opt-out of tracking technologies: In order to delete or block any tracking technologies, please refer to the “Help” area on your internet browser for further instructions, or You may also opt out of third-party tracking technologies by following the instructions provided by each third-party service provider in its privacy policy listed above or visiting www.youronlinechoices.eu or https://www.aboutads.info/choices/. Please note however that deleting any of our tracking technologies or disabling future tracking technologies may prevent you from accessing certain areas or features of our Website, or may otherwise adversely affect your user experience.
10. Direct Marketing.
You hereby agree that we may use your contact details provided during the filling of a registration form on the Website for the purpose of informing you regarding our products and services which may interest you, and to send to you other marketing material. You may withdraw your consent via sending us written notice by email to the following address: info@addressable.io or by pressing the “Unsubscribe” button in the mail.
Please note that the Company may also contact you with important information regarding our Website and/or Solution. For example, we may notify you (through any of the means available to us) of changes or updates to our Website and/or Solution, payment issues, service maintenance, etc. You will not be able to opt out of receiving such service messages.
11. Minors.
To use our Services, you must be over the age of eighteen (18). Therefore, we do not knowingly collect Personal Information from minors under the age of eighteen (18) and do not wish to do so. We reserve the right to request proof of age at any stage so that we can verify that minors under the age of eighteen (18) are not using the Website and/or Solution.
Without derogating from the above, certain personal information of persons under the age of eighteen (18) might be included as part of the data provided to us or made available by our Customers in relation to the Services, who have assured us it has the right to do so. Our access and use of any such data is as set forth in this Privacy Policy.
12. Information Security.
We take great care in implementing and maintaining the security of the Website, Solution, and Personal Information. We have implemented administrative, technical, and physical safeguards to help prevent unauthorized access, use, or disclosure of Personal Information. Your information is stored on secure servers and is not publicly available. We limit access to your information only to those employees, third-party service providers, or partners on a “need to know” basis, and strictly in order to enable us to perform the agreement between you and us or the agreement between us and your organization (in its capacity as our Customer).
Despite these measures, we cannot provide absolute information security or eliminate all risks associated with Personal Information, and security breaches may happen. If you have any questions about our Personal Information security, please contact us at info@addressable.io.
13. Data Retention.
If you are a visitor of our Website, we will retain your Personal Information only for as long as necessary to achieve the purposes for collection and processing set forth above. Retention periods will be determined taking into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time. If you withdraw your consent to our processing of your Personal Information, we will delete your Personal Information from our systems (except to the extent retaining such data in whole or in part is necessary to comply with any applicable rule or regulation and/or to respond to or defend against legal proceedings brought against us or our affiliates).
14. Job Candidates.
We welcome all candidates (“Candidates”) to apply to any of the open positions posted on our Website, or that we otherwise publish on Facebook or LinkedIn. We may be provided with certain Personal Information which may include your full name, email address, phone number, curriculum vitae, and other information such Candidates may elect to share with us over the course of their candidacy (“Candidates Information”). We are committed to keeping Candidates’ Information private and using it solely for our internal recruitment purposes (including for identifying Candidates, evaluating their applications, making hiring and employment decisions, and contacting Candidates by phone or in writing).
Please note that Addressable may retain Candidates Information submitted to us even after the applied position has been filled or closed. This is done so we could: re-consider Candidates for other positions and opportunities at Addressable; use their Candidates Information as references for future applications submitted by them; and in case the Candidate is hired, for additional employment and business purposes related to their work.
If you previously submitted your Candidates Information to Addressable, and now wish to access it, update it, or have it deleted from our systems, please contact us at info@addressable.io.
15. Data Controller/Processor.
Our Customers are solely responsible for determining whether and how they wish to use our Services, and for ensuring that all individuals using the Services on the Customer’s behalf or at their request, as well as all individuals whose personal information may be included in any Personal Information processed through the Services, have been provided with adequate notice and given informed consent to the processing of their personal information, where such consent is necessary or advised, and that all legal requirements applicable to the collection, use or other processing of data through our Services are fully met by the Customer. Our Customers are also responsible for handling data subject rights requests under applicable law, by their Customer End-Users and other individuals whose data they process through the Services (and accordingly, if you are a Customer End-User or other individual whose Personal Information was provided to us in connection with Customer’s use of the Services, Addressable does not provide to you the rights set forth in Section 8 above).
If you would like to make any requests or queries regarding personal information we process as a data processor on our Customer’s behalf, including accessing, correcting, or deleting your data, please contact the Customer and/or an applicable Customer End-User directly.
16. Updates To This Privacy Policy.
We reserve the right to change this policy at any time, so please revisit this page frequently. We will notify you regarding substantial changes to this Privacy Policy by changing the link to the Privacy Policy on the Website and/or Solution and/or by sending you an e-mail regarding such changes to the e-mail address that you provided during registration. Such substantial changes will take effect seven (7) days after such notice was provided on our Website or sent by email. Otherwise, all other changes to this Privacy Policy are effective as of the stated “Last Revised” date, and your continued use of the Website and/or Solution after the Last Revised date will constitute acceptance of, and agreement to be bound by, those changes.
17. General.
This Privacy Policy, its interpretation, and any claims and disputes related hereto, shall be governed by the laws of the State of Israel, without respect to its criminal law principles. Any and all such claims and disputes shall be brought in, and you hereby consent to them being litigated in and decided exclusively by a court of competent jurisdiction located in Tel-Aviv, Israel.
This Privacy Policy was written in English and may be translated into other languages for your convenience. If a translated (non-English) version of this Privacy Policy conflicts in any way with the English version, the provisions of the English version shall prevail.
If you have any questions (or comments) concerning this Privacy Policy, you are welcome to send us an email at: info@addressable.io and we will make an effort to reply within a reasonable timeframe.
