AIO Privacy Policy

AIO Me Ltd. (”AIO”, “we“, “us” or “our”) respects your privacy.


This AIO Service User Privacy Policy (the “Policy”) explains our privacy practices while performing AIO Services to you including through (i) our mobile application developed, created, branded, customized and/or supported by AIO (“App”); (ii) web service and/or website; and/or (iii) other digital services offered by or on behalf of AIO.


This Policy is incorporated in AIO User Terms of Use, available at: www.aio.network/terms (the “Terms”). Capitalized terms that are defined in the Terms will have the same meaning when used herein.


AIO provides a service which enables you to (i) store your Documents at your Private Storage; (ii) share any of your Documents with third parties (“Recipient(s)”), upon your explicit order to us, together with our Document Meta Data and Review Data, which refers to that Document (the “Service”).


This Policy describes the ways your personal information and data is collected, used and shared throughout the Service and the rights and options available to you with respect to your information.


AIO is a data processor. It is your decision which Documents to upload to the Storage and which Documents (including the Documents Meta Data and Review Data) to share with third parties (the “Recipients”), which may be controllers of your data. We encourage you to review Recipients’ data collection and privacy policies, in addition to this Policy. 


You hereby agree to the use of: (a) electronic means to consent to and complete this Policy and to provide you with any notices given pursuant to this Policy; and (b) electronic records to store information related to this Policy and your use of the Service.

Privacy Policy Summary


1. Personal Information that you Voluntarily Provide. upon registration to the Service you will be requested to provide your email address, mobile phone number and other personal information such as first name and family name. You may choose not to share your personal information with us, nor to use the Service thereof.


2. Processing of Documents. We will process, store and share with Recipients the Documents Meta Data and Review Data. We will enable you to share the Documents you store in the Storage by using the Service with Recipients.


3. Other Information Collected by Us. We collect other information such as: mobile device identifier and/or account identifier (Advertising ID), IP, geo-location (if enabled), device type and its operating system version, features, content, services or websites accessed, clicked or interacted with through the Service.

 

4. Collection of your Location. Your location will be available to us via your mobile phone, mobile web or web services, if you provide permission to share it with us.


5. Use of Collected information. The information we collect, and which is shared with us will be used inter alia to provide you with the Service’s functionalities and features, prove delivery of Documents, Documents Meta Data and Review Data, interact with you, and provide you with the specific and/or personalized activity.


6. Sharing and Transferring Collected Information. In addition to sharing your information with Recipients we may share it with competent authorities if you breach this Policy and the Terms, our affiliates and upon merger or transfer of our major assets.


7. Third Parties Services. If you provide information of Third Parties Services, we will not collect any information used by you to access these Third Parties Services. We collect the Document Meta Data received through the process of generating Documents or other information from these Third Parties and storing them in your Storage.


8. Process of Sensitive Information. AIO does not require its Users to provide sensitive information nor does it intentionally collect or process otherwise sensitive information.


9. Age limit; Children’s Privacy. You must not use the Service if you are younger than 18 years old.


10. Aggregated or Anonymized Information. anonymized or aggregated information may be used by us for any purpose.


11. Use of Automated Decision-Making. You hereby agree to the use of automated decision-making, based on the information you provide us and your usage of the Service, including interactions with Recipients.


12. Use of Cookies. We may use “cookies”, “web beacons” and other similar information-gathering technologies throughout the Service.


13. Transfer of Data Outside Your Territory. You hereby provide your express and unambiguous consent to transfer of your personal information to another jurisdiction.


14. California End Users – CCPA. The categories of personal data collected by StartApp are elaborated in Section 1, 3 and 4; AIO usage of the data (including sharing of data) is elaborated in Sections 1-6 and 10; your opt out right and other rights are elaborated in Section 16.


15. Legal Basis for Processing of Data. Process of information you provide us through the Registration Form is based on your consent. Information we process about you which is not based on your consent, is processed on the basis of (i) fulfillment of contract to provide you the Services; and/or (ii) our legitimate interests of in order to perform services requested by you.


16. Your Rights with the Data. You have the right to exercise any of the following rights: consent withdraw; right to object; right to erasure; and right of access / right to data portability.


17. Information Security. It is not guaranteed and you cannot reasonably expect that the Service and its related databases will be immune from any wrongdoings, malfunctions, unauthorized interceptions or access, or other kinds of abuse and misuse.


18. Changes to this Policy. This Policy may be changed from time to time by posting a new version at: www.aio.network/privacy.

19. Contact Us. At any time, you may contact us with any question, claim or complaint that you may have with respect to this Policy or the Service, by sending an email to: support@aio.network.

1.    Personal Information that you Voluntarily Provide

1.1.    Upon registration to the Service you will be requested to provide your email address, mobile phone number and other personal information such as first name and family name, as will be requested within the registration form (“Registration Form” and “Registration Form Information”).


1.2.    We will use your email address and/or mobile phone number for (i) authentication and validation of your registration; (ii) connecting your Storage to our Service; (iii) validating your identity when you ask us to share Documents (including Documents Meta Data) with Recipients; and (iv) validating your identity when you ask to opt out or disconnect from the Service; and (v) communicating with you in regard of the Service.


1.3.    We will share your Registration Form Information with Recipients in order to identify you.


1.4.    In addition to the above, we will collect information regarding (i) receipt of SMS text messages, push notifications and/or emails sent to you through the Service; (ii) your participation in or use of the Service, such as any engagement with Recipient(s) you make by using the Service.


1.5.    Although in order to perform the Service we need your personal information, you may choose not to share your personal information with us, nor to use the Service thereof.


2.    Processing of Documents (including Documents Meta Data and Review Data)


2.1.    We will process, store and share with Recipients the Documents Meta Data and Review Data. We will enable you to share the Documents you store in the Storage by using the Service with Recipients. We will process and use any requests for Documents or data sent to you by Recipient(s) through our Service, and the information and meta data in regard of your engagement with these Recipient(s). 


2.2.    Documents Review and Review Data. Other than Document Meta Data, we will not access the content of your Documents, nor will we review them, unless we are requested by the Recipient otherwise. In such case, our review will be performed subject to the following terms: (i) it will be performed only in regard of information requested by the Recipient and with respect to the Documents actually shared by you with that Recipient only (i.e.: upon or together with submission or sharing these Documents); (ii) the deliverables of such review (“Review Data”) will be shared with that Recipient only and shall be owned by it; and (iii) the Review Data of the review shall deem to be Confidential Information of the Recipient and you, and will not disclosed by use to any third party, other than if such disclosure is ordered by competent authorities or pursuant to any applicable law.


2.3.    By sharing your Document(s) with (or submitting to) Recipient(s) you hereby agree to:


(a)    grant that Recipient your consent to access, review and analyze the content of the Document together with the Document Meta Data and Review Data, which we will share with it; and 


(b)    agree that we will review the Documents pursuant to Section 2.2 (Documents Review and Review Data) above.


3.    Information Collected by Us from all Users of the Service


The following section will apply to our data collection practices which apply to all users who accessed or used the Service (including users which do not voluntarily share their personal information with us):


3.1.    We collect from all App Users information about the mobile device, such as mobile device identifier and/or account identifier (Android UDID, iOS UUID; Advertising ID: IDFA for iOS devices and AAID for Android devices, or their equivalent), the Internet protocol (IP) address of the device used to access the Internet, geo-location (if enabled), device type and its operating system version. 


3.2.    We also collect information regarding the features, content, services or websites accessed, clicked or interacted with through the Service as well as information regarding the interactions made with the Service’s interface and features such as logging info, tabs, banners, or pages that are clicked on or accessed, ads and/or promotions viewed through the Service and receipt of notifications sent through the Service.


4.    Collection of Your Location


4.1.    Your location will be available to us via your mobile phone, mobile web or web services, if you provide permission to share it with us.


4.2.    We will process your location information, whenever your location is made available to us, for the following purposes: [(i) validate your identity; (ii) fraud prevention; and (iii) to provide you with offers and/or promotions which are based on your location.


4.3.    By disabling your location, certain features which require your location information may not function or may be interrupted.

 

5.    Use of Collected Information


In addition to the above, the information we collect, and which is shared with us will be used for the following purposes:


5.1.    To provide you with the Service’s functionalities and features;


5.2.    To prove delivery of Documents, Documents Meta Data and Review Data;


5.3.    To send you, from time to time, emails, push notifications, SMS text messages, which may be commercial notifications, from us, Recipients and/or other third parties relevant to the Services;


5.4.    To provide you with the specific and/or personalized activity, promotions, advertisements, features and/or service via the Service;


5.5.    To provide you with services based on your location;


5.6.    To remotely update the Service on your mobile device or otherwise when a new version or update is released;


5.7.    To improve and customize the experience of using the Service and the offerings made through the Service;


5.8.    To develop new services update or upgrade existing services;


5.9.    To manage the administrative and operational aspects of the Service;


5.10.    To enforce this Policy and the Terms and prevent unlawful activities and misuse of the Service;


5.11.    To comply with any applicable law and assist law enforcement agencies when we have a good faith belief that our cooperation with them meets the applicable legal standards; and


5.12.    To take any action in any case of dispute involving you with respect to the Service.


6.    Sharing and Transferring Collected Information


In addition to the above, the information outlined in the preceding sections, may be shared with, or transferred to others, as the case may be, in any of the following instances:


6.1.    If you have breached the Terms or this Policy, abused your rights to use the Service, or violated any applicable law, or in any other case of dispute, or legal proceeding of any kind involving you with respect to the Service, your information may be shared with competent authorities and with any third party, as may be required;


6.2.    We may share information that we collect or obtain through the Service with the relevant authorities, entities or persons if we reasonably believe that we are required by law to share or disclose your information;


6.3.    Personal identifiable information may be shared with, or transferred to, our affiliated corporate group entities (entities controlled by, under common control with, or controlling us, directly or indirectly), but their use of such information must comply with this Policy; and


6.4.    Upon bankruptcy, dissolution or other liquidation or insolvency events or in the event of merger, sale or transfer of all or a portion of our assets or shares or other reorganization or reconstruction in our ongoing business, the information that we receive, collect or obtain, as outlined in the preceding sections, may be shared with or transferred to, that respective entity, provided that it will undertake to be bound by the provisions of this Policy, with reasonably necessary changes taken into consideration. Upon such transfer or sharing of information, that entity will assume full and exclusive responsibility for all subsequent use and processing it makes of the information and we will be released from any liability to you, regarding the succeeding entity’s use and processing of the information by it.
In any case other than the above mentioned in this Policy, your personally identifiable information will be shared with others only if you provide your consent.


7.    Third Parties Services


7.1.    You may provide information through certain areas, features, frames or sections of the Service, that are operated by third parties. Those third parties may include, government or official authorities, your bank account, payment services providers or payment processors (“Third Parties” and “Third Parties Services”).


7.2.    We do not have access to, nor do we collect any information used by you to access these Third Parties Services. We collect the Document Meta Data received through the process of generating these Documents or other information from these Third Parties and storing them in your Storage. 


7.3.     It is those Third Parties, and not AIO, that are responsible for their data collection practices associated with such Third Parties Services. We encourage you to read the privacy policy of each Third Party.


7.4.    Third Parties Services may share with us information they collect from you or you voluntarily provide to them which is related to or within the scope of the Service.


8.    Process of Sensitive Information


AIO does not require its Users to provide sensitive information nor does it intentionally collect or process otherwise sensitive information. Please note that it is your responsibility if your sensitive information is included within your Documents. Upon review of the Documents, pursuant to Section 2.2 above (Documents Review and Review Data) we will not knowingly filter, copy or make available any sensitive information. 


9.    Age limit; Children’s Privacy


You must not use the Service if you are younger than 18 years old, and AIO does not intentionally or knowingly collect any information from Users below that age.


10.    Aggregated or Anonymized Information


AIO Service collects anonymized as well as aggregated information, which does not identify you personally. In addition, we may anonymize your information and/or aggregate it with other Users’ information. Such anonymized or aggregated information may be used by us for any purpose, including by posting, disseminating, transmitting, sharing or otherwise communicating or making it available to third parties.


11.    Use of Automated Decision-Making


You hereby agree to the use of automated decision-making, based on the information you provide us and your usage of the Service, including interactions with Recipients.


12.    Use of Cookies


We may use “cookies”, “web beacons” and other similar information-gathering technologies (collectively, “Cookies“) to collect non-PII automatically as you access and browse the Service through your web browser, mobile browser or when you are directed to mobile browsing pages from the App. This Policy covers the use of Cookies by AIO only and does not cover the use of Cookies by any other third party, including the Recipients of your Documents.


Cookies (which may be HTML files, Flash files or other technology) are text files that help store data including user preferences and activity. “Web beacons” (also known as image tags, gif or web bugs) are small pieces of code used to collect data, such as counting page views or promotion views. 


We may use both session ID Cookies and persistent Cookies, for the purpose of making it easier for you to navigate through the Service. A session ID Cookie expires when you close your browser; a persistent Cookie remains for an extended period of time. You may remove persistent Cookies by following directions provided in your web browser or mobile browser’s “help” file. We set a persistent Cookie for such uses as to store your name and/or user name so you don’t have to enter it more than once. Persistent Cookies also enable us to track and target the interests of our users to enhance the users’ experience through the Service. If you reject Cookies, you may still use the Service.
By using the Service, whether as a registered user or otherwise, you acknowledge, understand and hereby agree that you are giving us your consent to gather information about your use of the Service through Cookies, when applicable.


13.    Transfer of Data Outside Your Territory


The Service, by its nature as an online service, may store and process information in Europe, the United States and in other various locations throughout the globe. If you are a resident in a jurisdiction where transfer of your personal information to another jurisdiction requires your consent, then you hereby provide your express and unambiguous consent to such transfer.


If you are a resident of the European Economic Area (“EEA“) we will take appropriate measures to ensure that your personal data receives an adequate level of data protection upon its transfer outside of the EEA. Any transfers, whether to third parties or internally, of personal information from the EEA to countries not deemed to provide an adequate level of data protection are governed by European Union (EU) Standard Contractual Clauses, which are incorporated herein by reference, and/or equivalent data transfer regulations to protect the security and confidentiality of personal information.


14.    California End Users – CCPA


Without derogating from the provisions of this Policy, please note that: (a) the categories of personal data collected by StartApp are elaborated in Section 1, 3 and 4; (b) our usage of the data (including sharing of data) is elaborated in Sections 1-6 and 10; and (c) your opt out right and other rights are elaborated in Section 16.


15.    Legal Basis for Processing of Data


Process (including: collection, use and share) of information you provide us through the Registration Form is based on your consent, granted through submission of the Registration Form. Your consent is personal. You must not provide other person’s information or register on behalf of another person.


Information we process about you in accordance with this Policy, which is not based on your consent, is processed on the basis of (i) fulfillment of contract to provide you the Services; and/or (ii) our legitimate interests of in order to perform services requested by you.


16.    Your Rights with the Data


16.1.    You have the right to exercise any of the following rights, as well as other rights granted to you in accordance with the laws apply to you (“User Right(s)”): (a) Consent Withdraw: you may withdraw your consent granted to us to collect and process your personal information pursuant to the terms of this Policy; (b) Right to object: you may object to the processing of your personal data; (c) Right to erasure (right to be forgotten): you have the right to request us to delete or remove the personal information collected through your use of the Service; and (d) Right of access / Right to data portability: you have a right to receive a copy of the data collected about you in the course of using the Service.


16.2.    You can exercise any of these rights by sending us a request to: privacy@aio.network. Your email subject shall include the User Right(s) you would like to exercise (such as: “Right to Object”). The email message must be sent from your Registered Email (email used for registration to the Service). We may have to communicate with you in order to process your request, including to verify your identity. By sending us an email you hereby agree that we will communicate with you for that purpose.


16.3.    If you chose to exercise of any End User Right(s) (a)-(c), our Service to you will terminate pursuant to section: “Termination by User” of the Terms with the effect detailed in the section “Effect of Service Termination”. Please review these sections of the Terms (at: www.aio.network/terms). In addition, we will anonymize the data collected about you (i.e.: deletion or making the data which may identify you personally unavailable), provided that, some personal information may still reside in our systems in archived form in such areas which we do not access for using such information. All other data will not be deleted. Exercise of your rights, will not affect the lawfulness of processing based on consent before they were exercised. We may continue to process information which your consent is not required for, subject to any applicable law.


16.4.    If you chose to exercise of any End User Right(s) (d), we will send your data to the Registered Email within fourteen (14) days from receipt of your request (or verification of your identity). After receiving a copy of the data that we collected about you, you may ask us to rectify or erase the data collected about you in the course of using the Service. We will notify you in writing if rectification or erasure of portion of the data is not feasible. In such case you shall have the option to erase the entire data, by exercising End User Right (c) above.


16.5.    Please note that exercising any of the above rights in connection with data collected by or shared with Recipient(s), has to be communicated directly to the Recipient(s). 


16.6.    In addition to the above you have the right to lodge a complaint with a supervisory authority.


17.    Information Security


Security measures are implemented to reduce the risks of damage, loss of information and unauthorized access or use of information. However, these measures are unable to provide absolute information security. Therefore, although efforts are made to secure your personal information, it is not guaranteed and you cannot reasonably expect that the Service and its related databases will be immune from any wrongdoings, malfunctions, unauthorized interceptions or access, or other kinds of abuse and misuse.


18.    Changes to this Policy


18.1.    This Policy may be changed from time to time by posting a new version at: www.aio.network/privacy. Substantial changes will take effect 30 days after their initial posting and other changes will take effect 7 days after their initial posting. If the Policy is amended to comply with legal requirements, the amendments will become effective immediately upon their initial posting, or as required. The most up-to-date Policy is available at: www.aio.network/privacy.


18.2.    You agree to be bound by any of the changes made to this Policy. Your continued use of the Service after the changed take effect will indicate your acceptance of the amended Policy. If you do not agree with the amended Policy, you must avoid any further use of the Service and/or uninstall the App.


19.    Contact Us


At any time, you may contact us with any question, claim or complaint that you may have with respect to this Policy or the Service, by sending an email to: support@aio.network.

Last Update: September 24, 2020

 

 


 

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