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Triple Space Ltd (“Triple Space” or “us” or “our”) operates a comparison-based website available at: www.triplespace.com and provide to our website’s users (“user” or “you” or “your”) the Services therein (as defined in our Terms of Service). Note that, this Policy is an integral part of the Terms of Service. Definitions herein shall have the same meaning as defined therein.

We have designed this Privacy Policy (“Policy”) to provide transparent and detailed explanation regarding our privacy practice, the data we collect and how we use it, as required under applicable privacy laws andamong others, according to the EU General Data Protection Regulation (“GDPR”) and the California Consumer Privacy Act (“CCPA”) where applicable.

Note to California Residents: please review our designated CCPA Privacy Notice.

We encourage you to carefully review read this Policy before you browse our website or use the Services.

AMENDMENTS

We reserve the right to periodically amend or revise the Policy which will go into effect immediately upon the implementation of the revised Policy on our website. We will make a reasonable effort to notify you in the event that we implement any changes that substantially changes our privacy practices. We recommend that you review this Policy periodically to ensure that you understand our privacy practices and to check for any amendments.

Note to California Residents: notwithstanding the above, as required under the CCPA, this Policy will be reviewed and updated every 12 months.THE TYPES OF DATA COLLECTED

When you access and browse our website or use the Services in an y manner, we collect certain types of data that can be classified as follows:

(i) non-identifiable aggregated data („Non-Personal Data„), for example technical information transmitted by the device you are using and certain aggregated data regarding your use of the Services. We do not use Non-Personal Data in order to identify individuals.

(ii) individually identifiable information (“Personal Data”, or “Personal Information”, subject to applicable law definitions). This may include name, email address and online identifiers, as detailed in the table below.

As required under the GDPR, please see below explanation regarding our lawful basis for processing Personal Data:

(i) If you voluntarily contact us, we will process the information you will provide for the purpose of performing our contract with you and provide you with the service you requested;

(ii) When you access and browse our website, we have a legitimate interest in processing data, such as you IP address.

(iii) We will also process your Personal Data subject to obtaining your consent, where required under applicable law.

It is important to mention that Triple Space will not combine Personal Data you voluntarily provide with Non – Personal Data Triple Space will collect. However, if we will combine these types of data, we will treat the combined data as Personal Data.

Please see the table which details the types of data collected while you browse our website or use the Services offered therein, as well as the purpose of collection and how we use it:

TYPES OF DATA	PURPOSE OF COLLECTION AND HOW DO WE USE IT
Contact Details and Contact History If you voluntarily choose to contact Triple Space for any reason, including support or any questions you may have, through any means of communication available (i.e., online form, email, mail, etc.) we will collect and process the information you provide which may include your name and email address.	We will process your contact details as well asyour contact history for the purpose ofresponding to your inquiries and provide you the service or support you have requested. In addition, we may store this information if we believe it is necessary under our legitimate interests, for example, in order to defend legal claims.
Internet Protocol Address (IP) and Technical Data When you access our website and use the Services, we (directly or by our third part service providers) will collect your IP address. Note that, while IP address is considered personally identifiable information in many jurisdictions (such as the EEA), there are some jurisdictions in which such data sets are not considered as Personal Data. Therefore, we treat such information as Personal Data, in accordance with applicable laws. In addition, we may collect technical Non-Personal Data, including type of operating system, type of device, type of browser, language preference, time and date of accessing the website, click stream in the website, approximate geographical location,etc.;	We will process this data for the purpose of operating, providing, maintaining, protecting, managing, customizing and improving our website and the Services offer through the website, as well as for auditing and tracking usage statistics and traffic flow. This data may also be collected for remarketing purpose, as detailed under the “Cookies” section below, and subject to your consent, where required under applicable law.

HOW THE DATA IS COLLECTED

The data detailed above can be collected if you voluntarily provide it (meaning when you contact us), or, automatically, through the use if of certain tracking technologies, for example, through the use of cookies and pixels.

COOKIES POLICY

Our website includes tracking technologies such as cookies and pixels. These tracking technologies are used for the purpose of gathering some information automatically, by ourselves or by service providers on our behalf.

“Cookies” are small text files that are placed on your hard drive by a web server when you access our website or use the Services. Cookies are used for many purposes, and for example, for making the interaction between you and the Services quicker and easier, enabling automatic activation of certain features, efficient navigation, providing the website in an applicable language in accordance with your country, etc., as well as for remarketing purposes (as detailed below).

You can find comprehensive information about cookies at: www.allaboutcookies.org.

Most browsers will allow you to erase cookies from your computer’s hard drive, block acceptance of cookies, or receive a warning before a cookie is stored. You may remove cookies by following the instructions in your device preferences. However, please note that if you choose to disable cookies, some features of our website may not operate properly and your online experience may be limited.

In addition to our cookies used to operating the website and track performance of our campaigns, we may permit third parties to use cookies or other tracking technologies, as follows:

Cookie Category	Source	Privacy Policy/Opt Out
Analytics and Performance-related cookies	Google.com Google Analytics. This cookie is placed in order to track and analyze the use of our Services, for internal purposes, and may include the collection of your IP.	www.google.com/policies/privacy/partners https://tools.google.com/dlpage/gaoptout. For additional information of our use of Google products, click here.
Targeting and Advertising cookies	Google AdWords. This cookie is placed in order to display relevant ads tailored to you based on the parts of the website you have viewed by placing a cookie on your device.	https://adssettings.google.com/authenticated. For additional information of our use of Google products, click here.
Operation (GEO Location Services)	MaxMind. We use it for geolocation services (country level).	https://www.maxmind.com/en/privacy_policy

Opt-Out

You may control how your browser responds to cookies by adjusting the privacy and security settings of your web browser.

Please refer to the support page of the browser you are using. In this regard, following are some links which you may find useful:

• Google Chrome: https://support.google.com/chrome/answer/95647?hl=en

• Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences

• Internet Explorer: https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies

• Safari: https://support.apple.com/kb/PH21411

• Edge: https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy

• Opera: http://www.opera.com/help/tutorials/security/cookies/

Additionally, you may opt out of certain Advertisers’ cookies and browser-enabled, interest-based advertising at the Network Advertising Initiative’s (“NAI”) website– NAI consumer opt-out and the Digital Advertising Alliance’s (“DAA”) website- DAA opt-out page.

SHARING DATA WITH THIRD PARTIES

We do not share any Personal Data collected from you with third parties except in the following events:

(i) Authorized Disclosures: we may disclose your information to third parties when you consent to a particular disclosure. Please note that once we share your information with another company, that information becomes subject to the other company’s privacy practices;

(ii) Legal Requirement: We may share your information in this situation, only if we are required to do so in order to comply with any applicable law, regulation, legal process or governmental request (e.g., to comply with a court injunction, comply with tax authorities, etc.);

(iii) Third Party Rights: we may share your information in order to prevent harm to the rights (including any legal rights), property (including intellectual property) or other or safety of us, our users or any applicable third party;

(iiii) Affiliated Companies and Corporate Transactions: We may share your information with our parent company, any of our subsidiaries, joint ventures, or other companies that are under common control with the Company (“Affiliated Companies”) solely if and when applicable or necessary for the purposes described in this Policy, as well as 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, we will make our best efforts to ensure that our Affiliated Companies or acquiring company assumes the rights and obligations as described in this Policy.

(v) Service Providers. We may share your information with third parties that perform services on our behalf (e.g., analytic services).

(vi) Online Identifiers. We may share IPs collected by us (as detailed above), for the purpose of operating and improving our business, providing the Services and remarketing, calculating payments and auditing our business partners, as well as to detect fraud, security or technical issues in connection with the website.

We reserve the right to use, disclose or transfer (for business purposes or otherwise) aggregated and processed Non-Personal Data to third parties, including, inter alia, affiliates, for various purposes including commercial use. This information may be collected, processed and analyzed by us and transferred in a combined, collectively and aggregated manner (i.e., your information is immediately aggregated with other users) to third parties.

YOUR RIGHTS

Data protection and privacy laws may provide you with the ability to exercise some rights regarding your Personal Data that we hold (which might be different in each jurisdiction) such as;

* The right to access your Personal Data;

* The right to ensure your Personal Data is accurate, complete and up to date;

* The right to have your Personal Data amended (by correcting, deleting or adding information);

* The right to object to the processing of your Personal Data;

* The right to send or “port” your Personal Data;

* The right to file a complaint with a supervisory authority in your jurisdiction; and

* The right to withdraw consent, subject to legal or contractual restrictions and reasonable notice;

Please review our Privacy Rights Policy to learn more. In addition, if you wish to submit a request to exercise your rights, please download our form and send it to: admin@triplespace.com.

When you contact us and request to exercise your rights regarding your Personal Data, we will require certain information from you in order to verify your identity and locate your data and that the process of locating and deleting the data may take reasonable time and effort, asrequired or permitted under applicable law.

Data privacy and related laws in your jurisdiction may provide you with different or additional rights related to the data we collect from you, which may also apply.

THIRD PARTY

The Service and website includes links to websites and services not owned or operated by us (“Third Party”). These Third Parties’ privacy practices may differ from ours. Since those Third Parties’ websites, including any content, products or services therein, are provided by us solely as suggestions, we are not, and won’t be held responsible to such Third Parties’ privacy practices. Thus, we recommend you to carefully review the applicable Third-Party privacy policy once you leave our website via any link directing to Third Parties’ websites.

DATA RETENTION

We retain the Non-Personal Data we collect for as long as needed to provide the Service, carry out our business purpose, perform our contract with you, 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.

We are entitled to rectify, replenish or remove incomplete or inaccurate information, at any time and at our sole discretion.

SECURITY

We use physical, technical and administrative security measures for the Services that we believe are in compliance with applicable laws and industry standards in order to prevent your information from being accessed without the proper authorization, improperly used or disclosed, unlawfully destructed or accidentally lost. It is important for you to remember however, that unfortunately, the transmission of information via the internet cannot be 100% secure. As such, although we will do our best to protect your Personal Data, we cannot guarantee the security of data transmitted via our Website or our Services and any transmission of your data shall be done at your own risk.

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

CHILDREN

You represent and warrant that: (i) You are above the age of 18; and (ii) you are of legal competence to enter into this Policy. The Service are not directed or intended for individuals under the age of 18 and we do not knowingly collect or solicit information from them. If we obtain actual knowledge that a user is under 18, we will take steps to immediately delete such user’s Personal Data. If you become aware or have any reason to believe that an individual that is under the age of 18 has shared any information with us, please contact us at: admin@triplespace.com.

TRANSFER OF YOUR DATA

We may store or process your information in the United States or in other countries. If you are a resident of the European Economic Area („EEA“) we will take appropriate measures to ensure that your information receives an adequate level of data protection upon its transfer outside of the EEA. If you are a resident of a jurisdiction where transfer of your data requires your consent, then your consent to this Policy includes your express consent for such transfer of your Personal Data.

DO NOT TRACK DISCLOSURE

Our website does not respond to Do Not Track signals. For more information about Do Not Track signals, please see: http://www.allaboutdnt.com/.

By sending an email to our Data Protection Officer at: admin@triplespace.com.

If you have any questions or comments about this Policy, please contact us via mail:

Triple Space Ltd.

Har Sinai 5 Tel Aviv , Israel

You can also contact us via email at: admin@triplespace.com

[Last Revised: February 09, 2020]