(Last Update: December 2022)
DrGraduate is an online magazine (“Website”) owned and operated by Kueez Entertainment Ltd. (“Company”, "we" or “us” or “our”). We respect your privacy and recognize that your privacy is important.
For California and Colorado residents, please review our CCPA Privacy Notice
We reserve the right to amend this Policy from time to time, at our sole discretion. The most recent version of the Policy will always be posted on the website. The updated date of the Policy will be reflected in the “Last Modified” heading. We will provide notice to you if these changes are material and, where required by applicable law, we will obtain your consent. Any amendments to the Policy will become effective within 30-days upon the display of the modified Policy. We recommend you to review this Policy periodically to ensure that you understand our most updated privacy practices.
Kueez Entertainment Ltd, is incorporated under the laws of Israel, and it is the controller of your Personal Data.
You may contact us via one of the following:
By the “contact us” page available here;
By Mail: Itzhak Sade 8, Tel-Aviv, Israel, 6777508
By Email for general inquiries: firstname.lastname@example.org.
By Email to our Data Protection Officer (DPO): email@example.com
By Email to our EU and UK Data Protection Representative (DPR): Kueez has designated Dr. Andreas Mätzler as its representative in the European Union for data protection matters, pursuant to Article 27 of the GDPR. Inquiries regarding Kueez’s EU privacy practices may be sent to Dr. Mätzler at Schellinggasse 3/10, Vienna 1010, Austria, or by e-mail to firstname.lastname@example.org (please add the following subject to all correspondences: 14102729). If you are a GDPR-protected individual, you also have the right to lodge a complaint with an EU supervisory authority.
DATA SETS WE COLLECT AND FOR WHAT PURPOSE:
You can find here information regarding the purposes for which we process your personal data as well as our lawful basis for processing, the definition of “personal” and “non-personal” data, and how it is technically processed.
We may collect aggregated, non-personal non-identifiable information, for example, technical information transmitted by the device you are using and certain aggregated data, which may be made available or gathered via your access to and use of the Services (“Non-Personal Data “). We are not aware of the identity of the user from which the Non-Personal Data is collected. The Non-Personal Data being collected may include your aggregated usage information and technical information transmitted by your device, such as: the type of browser or device you use, language preference, time and date stamp, country location, etc.
We may also collect from you, during your access to the website or interaction with the Services, individually identifiable information, namely information that identifies an individual or may, with reasonable effort, be used to identify an individual (“Personal Data”). The types of Personal Data that we collect as well as the purpose for processing such data are specified in the table below. For the avoidance of doubt, any Non-Personal Data connected or linked to any Personal Data shall be deemed as Personal Data as long as such connection or linkage exists.
The table below details the processing of Personal Data, the purpose, lawful basis, and processing operations:
|DATA SET||PURPOSE AND OPERATION||LAWFUL BASIS|
|Website Interaction and Marketing
When you interact with our website, we may collect your online identifiers, such as Internet Protocol (IP) address and Cookie ID, unique identifiers (“Online Identifiers”).
|First, Online Identifiers and cookies are used, in particular to operate the website and enable its proper functionality, for example to automatically recognize you by the next time you enter the website or to confirm you are a real person.
||Strictly necessary cookies which are required for the proper and basic operation of the website will be processed in our legitimate interest.
Other cookies, including any targeting and marketing cookies, will be processed based on your consent which we will obtain through our cookie notice and consent management.
Please note that if you reset your advertising settings or opt-out of interest-based advertising, you may still see advertisements on our website, but those ads will not be targeted for you. Please note that such actions may result in a less enjoyable user experience.
If you voluntarily contact us, through any means of communications we make available (for example, “contact us” page) for support or other general inquiries you will be required to provide us with certain information such as your name, your organization name (i.e., on behalf of which you contact us), email address, and any additional information you decide to share with us (“Contact Information”).
|We process such data to respond to your inquiry, and provide you with the support, materials and information you have requested.
The correspondence and its contents with you may be processed and stored by us in order to improve our customer service and in the event, we believe it is required to continue to store it, for example, in the event of any claims or in order to provide you with any further assistance (if applicable).
|We process Contant Information subject to our legitimate interest.|
|Profiling and Ad Targeting:
In an effort of delivering relevant advertising to the end users, third party partners with whom we have engaged with, collect consumer interest segments (“Behavior Data”) for use in targeted advertising online (“Interest-Based Advertising” or “IBA”).
Further, ad calls, which is a code shared with advertisers, may include zip code, advertiser ID, the webpage the end user came from, the IP address, approximate location which assists the advertiser to determine which ads to place. The ad call will also include the end user’s preference regarding profiling and targeted advertising (“Ad Call”)
|We share this data with our partners as further detailed below, so that they can deliver more relevant advertising to the end user browsing our website. Please note, we do not use, collect or have access to Behavior Data, however, we enable our partners collect it and display targeted ads.||We process this data solely upon receiving consent from the end user directly through the consent management and cookie notice. You may withdraw your consent at any time by opting out of IBA as further detailed below. Please note that if you reset your advertising settings or opt-out of interest-based advertising, you may still see advertisements on our website, but those ads will not be targeted for you. Please note that such actions may result in a less enjoyable user experience.|
When you sign up to our newsletter or other marketing materials, you will be requested to provide your name and email address.
|We will use your email address in order to send you our newsletter and other marketing materials.||We process such data subject to your consent. You may withdraw consent at any time through the “unsubscribe” link within the email or by contacting us directly at: email@example.com.|
Please note that, the actual processing operation per each purpose of use and lawful basis detailed in the table above, may differ. Such processing operation usually includes set of operations, made by automated means, such as collection, storage, use, disclosure by transmission, erasure or destruction. Transfer of Personal Data to third party countries as further detailed in the Data Transfer section is based on the same lawful basis as stipulated in the table above.
In addition, we may use certain Personal Data to prevent potentially prohibited or illegal activities, fraud, misappropriation, infringements, identity thefts and any other misuse of the Services and to enforce the Terms, as well as to protect the security or integrity of our databases and the Services, and to take precautions against legal liability. Such processing is based on out legitimate interests.
We may collect different categories of Personal Data and Non-Personal Data from you, depending on the nature of your interaction with the Services provided through the website and Platform, as detailed above.
HOW WE COLLECT YOUR INFORMATION:
Depending on the nature of your interaction with us, we may collect the above detailed information from you, as follows:
• Provided by you voluntarily choose to provide us with information, such as when you contact us, all as detailed in this Policy.
COOKIES AND SIMILAR TECHNOLOGIES:
Cookies can be used for various purposes, including allowing you to navigate between pages efficiently, for statistical purposes, as well as for advertising purposes.
DATA SHARING – CATEGORIES OF RECIPIENTS WE SHARE PERSONAL DATA WITH:
We share your data with third parties, including our service providers that help us provide our Services. You can find here information about the categories of such third-party recipients.
|CATEGORY OF RECIPIENT||DATA THAT WILL BE SHARED||PURPOSE OF SHARING|
||All types of Personal Data.||We may disclose Personal Data to our service providers, contractors and third parties, including, but not limited to, our cloud and hosting provider, analytics and marketing providers, CRM systems, etc., the service providers are limited by contracts which limit their use of the data, and requires implementing security measures. The service providers process the data solely to provide the needed services. These entities are prohibited from using your Personal Data for any purposes other than providing us with requested services.|
|We share this data with our advertising partners, so they will be able to place ads hat best suit such web-page, as a part of our Services.|
|Consent Manager (“CMP”)||Online Identifiers and the user’s preference.||When you browse our site for the first time, depending on your location, a cookie banner will appear, in this banner you will be able to choose if you allow us to share Personal Data (e.g., Online Identifiers) with third party for one or all of the aforesaid purposes (“Preference”). These Preference are different depending on your jurisdiction. The CMP receives the Online Identifiers from us.|
|Media Buyers||Cookie ID
|In some cases when we buy media online, we may submit unique identifier. The unique identifier provided to the media owner, may become personally identifiable when such media owner combines our parameters with its own existed information about you, to which you gave your consent when first interacting with such media owner’s services (for example social media Services).|
|Any acquirer of our business||All types of Personal Data||We may share Personal 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 Policy.|
|Legal and law enforcement
||Subject to law enforcement authority request.||We may disclose certain data to law enforcement, governmental agencies, or authorized third parties, in response to a verified request relating to terror acts, criminal investigations or alleged illegal activity or any other activity that may expose us, you, or any other user to legal liability, and solely to the extent necessary to comply with such purpose.|
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.
We acknowledge that different people have different privacy concerns and preferences. Our goal is to be clear about what information we collect so that you can make meaningful choices about how it is used. We allow you to exercise certain choices, rights, and controls in connection with your information. Depending on your relationship with us, your jurisdiction and the applicable data protection laws that apply to you, you have the right to control and request certain limitations or rights to be executed.
For California and Colorado residents, please review our CCPA Privacy Notice.
You may exercise any or all of your above rights in relation to your Personal Data by filling out the Data Subject Request Form (“DSR”), and send it upon completion to: firstname.lastname@example.org.
You can exercise certain rights independently without filling out the DSR Form:
- You can opt-out from receiving our marketing emails by clicking “unsubscribe” link;
- You can use the cookie settings tool on our website to change your preferences;
- you can withdraw consent for processing Personal Data for analytics or marketing purposes, by using the cookie settings on the website, or as detailed below.
You may opt-out directly from third party retargeting cookies or other ad-technology trackers through self-regulatory services. For more information, please visit:
- Network Advertising Initiative (NAI) here;
- Digital Advertising Alliance (DAA) here;
- European Inter Active Digital Advertising Alliance (EDAA) here;
- For California residents can opt-out from having your data used for IBA here;
- You can also opt out of interest-based advertising with some of the service providers we use, such as Google here, Google Analytic here.
Ad choices settings and options will vary depending on your browser and device settings, and this is not an exhaustive list. Please note that such opt-out choices will only apply to the specific browser or device from which you opt-out. We encourage you to explore your device and browser settings to understand your choices better.
Please note that, if you opt out of interest-based advertising, some information will still be collected for other purposes, such as research, analytics, and internal operations. You will also continue to receive contextual advertisements, but they may be less relevant to your interests.
In general, we retain the Personal Data we collect for as long as it remains necessary for the purposes set forth above, all under the applicable regulation, or until you express your preference to opt-out (where applicable), or terminate your use of the Services, or you request to delete your Personal Data.
Other circumstances in which we will retain your Personal Data for longer periods of time include: (i) where we are required to do so in accordance with legal, regulatory, tax, or accounting requirements; (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 Data. Please note that except as required by applicable law, we may at our sole discretion, delete or amend information from our systems, without notice to you, once we deem it is no longer necessary for such purposes
We work hard to protect the Personal Data we process from unauthorized access, alteration, disclosure, or destruction. We have implemented physical, technical, and administrative security measures for the Services that comply with applicable laws and industry, such as encryption using SSL, we minimize the amount of data that we store on our servers, restricting access to Personal Data to Kueez employees, contractors, and agents, etc. Note that we cannot be held responsible for unauthorized or unintended access beyond our control, and we make no warranty, express, implied, or otherwise, that we will always be able to prevent such access.
INTERNATIONAL DATA TRANSFER:
Our data servers in which we host and store the information are located in the EU and the USA. The Company’s HQ are based in Israel in which any information you provide us may be transferred to and processed in countries other than the country from which you accessed our Services. When Personal Data that was collected within the EEA is transferred outside the EEA, we will take necessary steps to ensure that sufficient safeguards are provided during the transferring of such Personal Data. You may exercise your rights, where applicable, to receive information regarding the transfer mechanism that was used during such transfer. Personal Data transferred outside the EEA is transferred, in all cases pursuant to standard contractual clauses approved by the European Union ("SCCs"). Additionally, following the withdrawal of the United Kingdom (“UK”) from the European Union on January 31, 2020, the UK is no longer considered to be a part of the EEA and therefore, the transferring of Personal Data from the EEA to the UK will also be subject to the SCCs or other contractual clauses that will ensure the security of the Personal Data (pending an adequacy decision from the European Commission).
INTERACTION WITH THIRD PARTY WEBSITES:
ELIGIBILITY AND CHILDREN PRIVACY:
Our website and Services are not intended for use by children and we do not knowingly collect or maintain information about anyone under the age of 16. Please contact us at: email@example.com if you have reason to believe that a child has shared any information with us.