Welcome to http://www.atly.com/ (together with its sub domains, Materials ,Marks and services, the “Site”). Please read the following Terms of Use carefully before using this Site so that you are aware of your legal rights and obligations with respect to Steps Solutions Ltd. d/b/a Atly and any of its affiliates ("Atly","we", "our" or "us"). By accessing or using the Site, you expressly acknowledge and agree that you are entering a legal agreement with us and have understood and agreed to comply with, and be legally bound by, these Terms of Use, together with the Privacy Policy (the "Terms").You hereby waive any applicable rights to require an original (non-electronic)signature or delivery or retention of non-electronic records, to the extent not prohibited under applicable law. If you do not agree to be bound by these Terms please do not access or use the Site.
1. Background. The Site is intended to provide information about the platform and the services of Atly.
2. Modification. We reserve the right, at our discretion, to change these Terms at any time. Such change will be effective ten (10) days following posting of the revised Terms on the Site, and your continued use of the Site thereafter means that you accept those changes.
3. Ability to Accept Terms. The Site is only intended for individuals aged thirteen (13) years or older. If you are between the age of thirteen (13) and eighteen (18) years then, prior to visiting or using the Site, you must first review these Terms with your parent or guardian to make sure that you and your parent or guardian understand these terms and conditions and agree to them.
4. Site Access. For such time as these Terms are in effect, we hereby grant you permission to visit and use the Site provided that you comply with these Terms and applicable law.
5. Restrictions. You shall not: (i)copy, distribute or modify any part of the Site without our prior written authorization; (ii) use, modify, create derivative works of, transfer (by sale, resale, license, sub license, download or otherwise), reproduce, distribute, display or disclose Materials (defined below), except as expressly authorized herein; (iii) disrupt servers or networks connected to the Site; (iv) use or launch any automated system (including without limitation, "robots"and "spiders") to access the Site; and/or (v) circumvent, disable or otherwise interfere with security-related features of the Site or features that prevent or restrict use or copying of any Material or that enforce limitations on use of the Site.
6. Subscriptions. Except as expressly set forth in the Terms, your general right to access and use of the Site is free, however some premium features may require a paid subscription. Subscriptions will auto-renew until canceled. Cancelation and applicable refunds are managed expressly through the App Store and Google Play and subject to the terms and conditions specified therein. By subscribing you are also subject to the privacy policy of the App Store and Google Play. For questions about subscriptions, contact support@atly.com
7. Intellectual Property Rights.
7.1. Materials and Marks. The (i) content on the Site, including without limitation, the text, documents, articles, brochures, descriptions, products, software, graphics, photos, sounds, videos, interactive features, and services (collectively, the "Materials"); and (ii) the trademarks, service marks and logos contained therein(“Marks”, and together with the Materials, the “Content”), are the property of Atly and/or its licensors and may be protected by applicable copyright or other intellectual property laws and treaties. “Atly”, the Atly logo are Marks of Atly or its affiliates. All other Marks used on the Site are the trademarks, service marks, or logos of their respective owners. We reserve all rights not expressly granted in and to the Site and the Materials.
7.2. Use of Content. Content on the Site is provided to you for your information and personal use only and may not be used, modified, copied, distributed, transmitted, broadcast, displayed, sold, licensed, de-compiled, or otherwise exploited for any other purposes whatsoever without our prior written consent. If you download or print a copy of the Content you must retain all copyright and other proprietary notices contained therein.
8. Information Description. We attempt to be as accurate as possible. However, we cannot and do not warrant that the Materials available on the Site is accurate, complete, reliable, current, or error-free. We reserve the right to make changes in or to the Materials, or any part thereof, in our sole judgment, without the requirement of giving any notice prior to or after making such changes to the Materials. Your use of the Materials, or any part thereof, is made solely at your own risk and responsibility.
9. Links to Third Party Websites.
9.1. The Site may contain links, and may enable you to post content, to third party websites that are not owned or controlled by Atly ("Third Party Websites").We are not affiliated with, have no control over, and assume no responsibility for the content, privacy policies, or practices of, any third party websites. You:(i) are solely responsible and liable for your use of and linking to third party websites and any content that you may send or post to a third party website; and (ii) expressly release Atly from any and all liability arising from your use of any third party website. Accordingly, we encourage you to read the terms and conditions and privacy policy of each third party website that you may choose to visit.
9.2. Atly permits you to link to the Site provided that: (i) you link to but do not replicate any page on this Site; (ii) the hyperlink text shall accurately describe the Materials as it appears on the Site; (iii) you shall not misrepresent your relationship with Atly or present any false information about Atly and shall not imply in any way that we are endorsing any services or products, unless we have given you our express prior consent; (iv) you shall not link from a Third Party Website which prohibits linking to third parties; (v) such Third party Website does not contain content that (a) is offensive or controversial (both at our discretion), or (b) infringes any intellectual property, privacy rights, or other rights of any person or entity; and/or (vi) you, and your website, comply with these Terms and applicable law.
10. Privacy. We will use any personal information that we may collect or obtain in connection with the Site in accordance with our privacy policy which is available at https://atly.me/privacy-policy/ (“Privacy Policy”). You agree that we may use personal information that you provide or make available to us in accordance with the Privacy Policy.
11. Warranty Disclaimers.
11.1. This section applies whether or not the services provided under the Site are for payment. Applicable law may not allow the exclusion of certain warranties, so to that extent certain exclusions set forth herein may not apply.
11.2. THE SITE IS PROVIDED ON AN "AS IS" AND "AS AVAILABLE" BASIS, AND WITHOUT WARRANTIES OF ANY KIND EITHER EXPRESS OR IMPLIED. ATLY HEREBY DISCLAIMS ALL WARRANTIES, EXPRESS OR IMPLIED, INCLUDING BUT NOT LIMITED TO IMPLIED WARRANTIES OF MERCHANTABILITY,TITLE, FITNESS FOR A PARTICULAR PURPOSE, NON-INFRINGEMENT, AND THOSE ARISING BY STATUTE OR FROM A COURSE OF DEALING OR USAGE OF TRADE. ALTY DOES NOT GUARANTEE THAT THE SITE WILL BE FREE OF BUGS, SECURITY BREACHES, OR VIRUS ATTACKS. THE SITE MAY OCCASIONALLY BE UNAVAILABLE FOR ROUTINE MAINTENANCE, UPGRADING, OR OTHER REASONS. YOU AGREE THAT ATLY WILL NOT BE HELD RESPONSIBLE OR LIABLE FOR THIRD PARTY CONTENT, YOUR DATA, YOUR PERSONAL INFORMATION, AND ANY CONSEQUENCES TO YOU OR ANY THIRD PARTY THAT MAY RESULT FROM TECHNICAL PROBLEMS OF THE INTERNET,SLOW CONNECTIONS, TRAFFIC CONGESTION OR OVERLOAD OF OUR OR OTHER SERVERS. WE DO NOT WARRANT, ENDORSE OR GUARANTEE ANY CONTENT, MATERIALS, PRODUCT, OR SERVICE THAT IS FEATURED OR ADVERTISED ON THE SITE BY A THIRD PARTY.
11.3. YOUR RELIANCE ON, OR USE OF, OR INTERACTION WITH ANY SITE USER OR OWNER, IS AT YOUR SOLE RISK. IF YOU HAVE A DISPUTE WITH ANY SITE USER OR OWNER IN CONNECTION WITH THE SITE, YOU AGREE THAT ATLY IS NOT LIABLE FOR ANY CLAIMS OR DAMAGES ARISING OUT OF OR CONNECTED WITH SUCH A DISPUTE. ATLY RESERVES THE RIGHT, BUT HAS NO OBLIGATION, TO MONITOR ANY SUCH DISPUTE.
11.4. EXCEPT AS EXPRESSLY STATED IN OUR PRIVACY POLICY, ATLY DOES NOT MAKE ANY REPRESENTATIONS, WARRANTIES OR CONDITIONS OF ANY KIND, EXPRESS OR IMPLIED, AS TO THE SECURITY OF ANY INFORMATION YOU MAY PROVIDE OR ACTIVITIES YOU ENGAGE IN DURING THE COURSE OF YOUR USE OF THE SITE.
12. Limitation of Liability.
12.1. TO THE FULLEST EXTENT PERMISSIBLE BY LAW, ATLY SHALL NOT BE LIABLE FOR ANY DIRECT, INDIRECT, EXEMPLARY, SPECIAL,CONSEQUENTIAL, PUNITIVE OR INCIDENTAL DAMAGES OF ANY KIND, OR FOR ANY LOSS OF DATA, REVENUE, PROFITS OR REPUTATION, ARISING UNDER THESE TERMS OR OUT OF YOUR USE OF, OR INABILITY TO USE, THE SITE, EVEN IF ATLY HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES OR LOSSES.
12.2. IN NO EVENT SHALL THE TOTAL AGGREGATE LIABILITY OF ATLY FOR ANY DAMAGES AND LOSSES ARISING UNDER OR IN CONNECTION WITH THESE TERMS OR THAT RESULT FROM YOUR USE OF, OR INABILITY TO USE, THE SITE SHALL NOT IN ANY CIRCUMSTANCE EXCEED THE TOTAL AMOUNT OF FEES, IF ANY, ACTUALLY PAID BY YOU TO ATLY FOR USING THE SITE WITHIN THE THREE (3) MONTHS PRECEDING THE DATE OF BRINGING THE CLAIM.
13. Indemnity. You agree to defend, indemnify and hold harmless Atly and our affiliates, and our respective officers, directors, employees and agents,from and against any and all claims, damages, obligations, losses, liabilities,costs and expenses (including but not limited to attorney's fees) arising from:(i) your use of, or inability to use, the Site; (ii) your violation of any third party right, including without limitation any intellectual property or privacy right; (iii) your interaction with any Site user; and (iv) your violation of these Terms.
14. Term and Termination. These Terms are effective until terminated by Atly or you. Atly, in its sole discretion, has the right to terminate these Terms and/or your access to the Site, or any part thereof, immediately at any time and with or without cause (including, without any limitation, for a breach of these Terms). Atly shall not be liable to you or any third party for termination of the Site, or any part thereof.If you object to any term or condition of these Terms, or any subsequent modifications thereto, or become dissatisfied with the Site in any way, your only recourse is to immediately discontinue use of the Site. Upon termination of these Terms, you shall cease all use of the Site. This Section 15 and Sections 8 (Intellectual Property Rights), 11 (Privacy), 12 (Warranty Disclaimers), 13 (Limitation of Liability), 14 (Indemnity), and 16 (Independent Contractors) to 19 (General) shall survive termination of these Terms.
15. Independent Contractors. You and Atly are independent contractors. Nothing in these Terms creates a partnership, joint venture, agency, or employment relationship between you and Atly. You must not under any circumstances make,or undertake, any warranties, representations, commitments or obligations on behalf of Atly.
16. Assignment. These Terms, and any rights and licenses granted here under, may not be transferred or assigned by you but may be assigned by Atly without restriction or notification to you. Any prohibited assignment shall be null and void.
17. Governing Law. Atly reserves the right to discontinue or modify any aspect of the Site at any time. These Terms and the relationship between you and Atly shall be governed by and construed in accordance with the laws of the State of Israel, without regard to its principles of conflict of laws.
18. General. These Terms shall constitute the entire agreement between you and Atly concerning the Site. If any provision of these Terms is deemed invalid by a court of competent jurisdiction, the invalidity of such provision shall not affect the validity of the remaining provisions of these Terms, which shall remain in full force and effect. No waiver of any term of these Terms shall be deemed a further or continuing waiver of such term or any other term, and a party's failure to assert any right or provision under these Terms shall not constitute a waiver of such right or provision. YOU AGREE THAT ANY CAUSE OF ACTION THAT YOU MAY HAVE ARISING OUT OF OR RELATED TO THE SITE MUST COMMENCE WITHIN ONE (1) YEAR AFTER THE CAUSE OF ACTION ACCRUES. OTHERWISE, SUCH CAUSE OF ACTION IS PERMANENTLY BARRED.
Last updated: 21 June, 2023
Atly PRIVACY POLICYLast Updated: July 23, 2023In order to ensure transparency and give you more control over your personal information, this privacy policy (“Privacy Policy”) governs how we, Steps Solutions Ltd. d/b/a Atly (together, “Atly” “we”, “our” or “us”) use, collect and store Personal Data we collect, disclose, or receive from or about you (“User”, “you”) such as in the following use cases:
1. When you make use of our App Atly ("App")When you create an accountWhen you post content or create content and post it, including any location that is made up of one or more posts ( a “Step”) in our AppWhen you make a comment or otherwise interact with a StepWhen you add content or respond to an existing Step, including by liking, posting, rating, or or adding tagsWhen you make a search of Place in Atly’ AppWhen you share content in our App and/or in social media channelsWhen you create a Map in our App (e.g., Public Map, Restricted Map, Community Map, Secret Map)When you create content and post it in, or otherwise interact with (including by liking, posting, rating, or adding tags), a specific Map in our App AtlyWhen you browse or visit our website, https://www.atly.com (“Website”);When you make use of, or interact with, our WebsiteWhen you subscribe to the email list / newsletters / blogWhen you contact us (e.g. customer support)When you attend a marketing event and/or we exchange business cards and you provide us with your Personal DataWhen you request a demo or a free trialWhen we use the Personal Data of our service providers and suppliersWhen we use the Personal Data of our customersWhen you interact with us on our social media profiles (e.g., Facebook, Instagram, Twitter, LinkedIn)When you import content from your social media platforms to AtlyWhen you export Atly content to your social media platformsWe greatly respect your privacy, which is why we make every effort to provide a platform that would live up to the highest of user privacy standards. Please read this Privacy Policy carefully, so you can fully understand our practices and your rights in relation to Personal Data. “Personal Data” or “Personal Information” means any information that can be used, alone or together with other data, to uniquely identify any living human being. Please note that this is a master privacy policy and some of its provisions only apply to individuals in certain jurisdictions. For example, the legal basis in the table below is only relevant for GDPR-protected individuals.Important note: Nothing in this Privacy Policy is intended to limit in any way your statutory right, including your rights to a remedy or means of enforcement.Table of contents:What Personal Data we collect, why we collect it, and how it is usedHow we protect, store and retain your Personal DataHow we share your Personal DataAdditional information regarding transfers of Personal DataYour Privacy rightsUse by childrenPublic information about your activity on the servicesHow can I delete my account?Links to and interaction with third party productInteraction with third party productsLog filesUse of Analytics ToolsSpecific provisions applicable under California privacy lawContact usThis Privacy Policy may be updated from time to time and therefore we ask you to check back periodically for the latest version of this Privacy Policy, as indicated above. If there will be any significant changes made to the use of your Personal Data in a manner different from that stated at the time of collection, we will notify you by posting a notice on our Website or by other means.WHAT INFORMATION WE COLLECT, WHY WE COLLECT IT, AND HOW IT IS USEDData we collectWhy is the data collected and for what purposes?Legal basis (GDPR only)Third parties with whom we share your dataConsequences of not providing the dataWhen you make use of our AppWhen you create an accountGoogle or Facebook log-inFull nameEmail addressPhone numberBirth dateProfile imageInformation if you choose to upload, sync and/or import it from your device (e.g., pictures)Any other data you decide to provide/supplyTo create an accountTo log-in to your accountTo improve the AppTo allow people to see each otherTo connect with friends in the context of the AppProcessing is necessary for the performance of a contract to which the data subject is party or in order to take Atly at the request of the data subject prior to entering into a contractLegitimate interest (e.g. to create an account)3rd party platforms such as for the following purposes:Amazon (Cloud)Mixpanel (Analyze product usage)Cannot create an accountCannot log-in to your accountCannot improve the AppCannot allow people to see each otherCannot connect with friends in the context of the AppWhen you post content or create content and post it, including any location that is made up of one or more postsUser namePasswordPhoto / PicturesCamera detailsIP AddressLocation of a point of publishing the contentInformation in or about the content you provide (like metadata)Value, subject, description, comments, messagesFlairs Feedback and rating (such as, like)Any other data you decide to provide/supplyTo enable you to create contentTo perform the serviceTo publish your contentTo help you and other users to find points of interestTo view and/or interact with your and other users contentTo enable you to find points of interestTo give you accurate search resultsTo personalize and improve our servicesProcessing is necessary for the performance of a contract to which the data subject is party or in order to take Atly at the request of the data subject prior to entering into a contractLegitimate interest (e.g. to enable you to find points of interest)3rd party platforms such as for the following purposes:Amazon (Cloud)Mixpanel (Analyze user usage)Cannot enable you to create contentCannot perform the serviceCannot publish your contentCannot help you and other users to find points of interestCannot enable you to find points of interestCannot give you accurate search resultsCannot personalize and improve the servicesGeolocationTo enable you to find points of interestTo post your StepImportant note: To create a Step you need to be in the place at the moment of creation, or otherwise select a location on the relevant mapConsentCannot enable you to find points of interestCannot post your StepWhen you make a comment or otherwise interact with a StepFull nameUser nameEmail addressContent of the commentIP AddressRegionDevice model and detailsAny other data you decide to provide/supplyTo process and sharing your commentsTo enable you to comment points of interestTo personalize and improve our servicesProcessing is necessary for the performance of a contract to which the data subject is party or in order to take Atly at the request of the data subject prior to entering into a contractLegitimate interest (e.g. publish your reviews of Atly)3rd party platforms such as for the following purposes:Mixpanel (Analyze user usage)Appsflyer (Online campaign tool)Firebase (Push notifications)Fabric (beta testing and bugs analysis)Cognito (Authentication tool)Google Analytics (Analyze user usage)Cannot process and publish your commentsCannot enable you to comment points of interestCannot personalize and improve our servicesGeolocationTo enable you to find points of interestTo post your comments in the StepConsentCannot enable you to find points of interestCannot post your comments in the StepWhen you add content or respond to an existing Step, including by liking, posting, rating, or adding tagsFull nameUser nameEmail addressHashtagsPhotosContent of the comment (description, title name, value, rating)IP AddressRegionDevice model and detailsAny other data you decide to provide/supplyTo process and sharing your commentsTo enable you to comment points of interestTo personalize and improve our servicesProcessing is necessary for the performance of a contract to which the data subject is party or in order to take Atly at the request of the data subject prior to entering into a contract3rd party platforms such as for the following purposes:Mixpanel (Analyze user usage)Appsflyer (Online campaign tool)Firebase (Push notifications)Fabric (beta testing and bugs analysis)Cognito (Authentication tool)Google Analytics (Analyze user usage)Cannot process and publish your commentsCannot enable you to comment points of interestCannot personalize and improve our servicesLegitimate interest (e.g. publish your reviews of Atly)GeolocationTo enable you to find points of interestTo post your content in an existing StepConsentCannot enable you to find points of interestCannot post your content in an existing StepWhen you make a search of Place in Atly’ AppUser nameEmail addressIP AddressRegionDistinct IDClicked element IDKeywordAny other data you decide to provide/supply usTo enable you to find points of interest in your next searches.To understand user preferences and to improve the servicesTo help you and other users to find points of interestTo view and/or interact with your and other users contentProcessing is necessary for the performance of a contract to which the data subject is party or in order to take Atly at the request of the data subject prior to entering into a contractLegitimate interest (e.g. to enable you to do find points of interest in Atly App)3rd party platforms such as for the following purposes:Mixpanel (Analyze user usage)Appsflyer (Online campaign tool)Firebase (Push notifications)Fabric (beta testing and bugs analysis)Cognito (Authentication tool)Google Analytics (Analyze user usage)Cannot enable you to find points of interestCannot understand user preferences and to improve the servicesCannot help you and other users to find points of interestCannot enable you to find points of interestWhen you share content in our App and/or in social media channelsUser nameEmail addressIP AddressRegionDevice model and detailsContentSocial media channel used to share the contentAny other data you decide to provide/supplyTo process your requestTo share with friend a StepTo share by social media channels a StepTo understand user preferences and to improve the servicesTo help you and other users to find points of interestTo view and/or interact with your and other users contentProcessing is necessary for the performance of a contract to which the data subject is party or in order to take Atly at the request of the data subject prior to entering into a contractLegitimate interest (e.g. to process your request)3rd party platforms such as for the following purposes:Mixpanel (Analyze user usage)Appsflyer (Online campaign tool)Firebase (Push notifications)Fabric (beta testing and bugs analysis)Cognito (Authentication tool)Google Analytics (Analyze user usage)Cannot your requestCannot share with a friend a StepCannot share by social media channels a StepCannot understand user preferences and to improve the servicesCannot help you and other users to find points of interestCannot enable you to find points of interestWhen you create a Map in our App (e.g., Public Map, Restricted Map, Community Map, Secret Map)User name (as the admin name)Name of the map and the brief definition of the MapIP AddressDevice model and detailsContentPermissions settingsAdmin users and co-admin usersAny other data you decide to provide/supplyTo create a Map in our AppTo administrate the MapDepending on the type of Map that the administrator decides to create, to share the Map with the users of the App and allow them to create contentTo understand user preferences and to improve the servicesTo help you and other users to find points of interestTo view and/or interact with your and other users contentProcessing is necessary for the performance of a contract to which the data subject is party or in order to take Atly at the request of the data subject prior to entering into a contractLegitimate interest (e.g. to process your request)3rd party platforms such as for the following purposes:Mixpanel (Analyze user usage)Appsflyer (Online campaign tool)Firebase (Push notifications)Fabric (beta testing and bugs analysis)Cognito (Authentication tool)Google Analytics (Analyze user usage)Cannot create a Map in our AppCannot administrate the MapCannot share by social media channels a StepDepending on the type of Map that the administrator decides to create, cannot share the Map with the users of the App and allow them to create contentCannot understand user preferences and cannot improve the servicesCannot help you and other users to find points of interestCannot view and/or interact with your and other users contentWhen you create content and post it in, or otherwise interact with (including by liking, posting, rating, or adding tags), a specific Map in our App AtlyUser namePhoto / PicturesCamera detailsIP AddressLocation of a point of publishing the contentInformation in or about the content you provide (like metadata)Value, subject, description, comments, messagesFlairsFeedback and rating (such as, like)Any other data you decide to provide/supplyTo enable you to create content in a MapTo perform the serviceTo publish your content in a MapTo help you and other users to find points of interest in specific MapsTo view and/or interact with your and other users content in the MapsTo enable you to find specific MapsTo enable you to find points of interestTo give you accurate search resultsTo personalize and improve our servicesProcessing is necessary for the performance of a contract to which the data subject is party or in order to take Atly at the request of the data subject prior to entering into a contractLegitimate interest (e.g. to enable you to create content in a Map)3rd party platforms such as for the following purposes:Amazon (Cloud)Mixpanel (Analyze user usage)Appsflyer (Online campaign tool)Firebase (Push notifications)Fabric (beta testing and bugs analysis)Cognito (Authentication tool)Google Analytics (Analyze user usage)Cannot enable you to create content in a MapCannot perform the serviceCannot publish your content in a MapCannot help you and other users to find points of interest in specific MapsCannot enable you to find specific MapsCannot enable you to find points of interestCannot give you accurate search resultsCannot personalize and improve the servicesGeolocationTo enable you to find points of interestTo post your StepImportant note: To create a Step you need to be in the place at the moment of creationConsentCannot enable you to find points of interestCannot post your StepWhen you make use of, or interact with our WebsiteWhen you browse or visit our websiteCookies, Log files and Analytic toolsFor user preferences and to improve the servicesConsentLegitimate interest (e.g. essential cookies)3rd party platforms such as for the following purposes:Mixpanel (Analyze user usage)Appsflyer (Online campaign tool)Firebase (Push notifications)Fabric (beta testing and bugs analysis)Cognito (Authentication tool)Google Analytics (Analyze user usage)Cannot collect and store the informationCannot use or access some parts of the websiteWhen you subscribe to the email list / newsletters / blogFull nameEmail addressAny other data you decide to provide/supplyTo add you to our mailing listTo send marketing communicationsConsentLegitimate interest (e.g. send you more information about Atly)3rd party platforms such as for the following purposes:Mixpanel (Analyze user usage)Appsflyer (Online campaign tool)Firebase (Push notifications)Fabric (beta testing and bugs analysis)Cognito (Authentication tool)Google Analytics (Analyze user usage)Cannot add you to our mailing listCannot send you marketing communicationsWhen you contact us (e.g. customer support)Full nameEmail addressCommentAny other data you decide to provide/supplyTo answer questionsTo provide you supportProcessing is necessary for the performance of a contract to which the data subject is party or in order to take Atly at the request of the data subject prior to entering into a contractLegitimate interest (e.g. respond to a query sent by you)3rd party platforms such as for the following purposes:Mixpanel (Analyze user usage)Appsflyer (Online campaign tool)Firebase (Push notifications)Fabric (beta testing and bugs analysis)Cognito (Authentication tool)Google Analytics (Analyze user usage)Cannot assist you and respond your queryCannot provide supportWhen you attend a marketing event and/or we exchange business cards and you provide us with your Personal DataFull nameEmail addressCompany nameAny other data you decide to provide/supplyTo establish a business connectionTo send marketing communicationsProcessing is necessary for the performance of a contract to which the data subject is party or in order to take Atly at the request of the data subject prior to entering into a contract (e.g. showing you certain products and features that you have shown an interest in).Legitimate interest (certain B2B marketing communications)SalesForce (CRM)Cannot establish a business connectionCannot send marketing communicationsWhen you request a demo or a free trialFull nameEmail addressCompany name and numberPhone numberAny other data you decide to provide/supplyTo provide a demo or a free trialTo send marketing communicationsLegitimate interest (e.g. perform the contract, send contract-related communications)3rd party platforms such as for the following purposes:SalesForce (CRM)Cannot provide a demo or a free trialWhen we use the Personal Data of our service providers and suppliersFull nameEmail addressCompany name and numberPhone numberAny other data you decide to provide/supplyTo contact our service providersTo perform the applicable agreementeProcessing is necessary for the performance of a contract to which the data subject is party or in order to take Atly at the request of the data subject prior to entering into a contractLegitimate interest (e.g. perform the contract, send contract-related communications)3rd party platforms such as for the following purposes:Mixpanel (Analyze user usage)Appsflyer (Online campaign tool)Firebase (Push notifications)Fabric (beta testing and bugs analysis)Cognito (Authentication tool)Google Analytics (Analyze user usage)Cannot communicate with youCannot perform the applicable agreementWhen we use the Personal Data of our customerFull nameEmail addressCompany namePhone numberAny other data you decide to provide/supplyProviding our servicesPerforming the agreementProcessing is necessary for the performance of a contract to which our customer is a party.Compliance with a legal obligation (e.g. tax laws, bookkeeping laws, etc.).Legitimate interest (e.g. send you contract-related communications)3rd party platforms such as for the following purposes:Mixpanel (Analyze user usage)Appsflyer (Online campaign tool)Firebase (Push notifications)Fabric (beta testing and bugs analysis)Cognito (Authentication tool)Google Analytics (Analyze user usage)Cannot provide the servicesCannot communicate with youCannot perform the agreementWhen you interact with us on our social media profiles (e.g., Facebook, Instagram, Twitter, LinkedIn)When you import content from your social media platforms to Step, and when you export Atly content to your social media platformsFull nameEmail addressCompany nameAny other data you decide to provide/supplyEstablishing a business connectionConsentLegitimate interest (e.g. send you more information about Atly)3rd party platforms such as for the following purposes:Mixpanel (Analyze user usage)Appsflyer (Online campaign tool)Firebase (Push notifications)Fabric (beta testing and bugs analysis)Cognito (Authentication tool)Google Analytics (Analyze user usage)Cannot establish a business connectionFinally, please note that some of the abovementioned Personal Data will be used for detecting, taking Atly to prevent, and prosecution of fraud or other illegal activity, to identify and repair errors, to conduct audits, and for security purposes. Personal Data may also be used to comply with applicable laws, with investigations performed by the relevant authorities, law enforcement purposes, and/or to exercise or defend legal claims. In certain cases, we may or will anonymize or de-identify your personal data and further use it for internal and external purposes, including, without limitation, to improve the services and for research purposes. “Anonymous Information” means information which does not enable identification of an individual user, such as aggregated information about the use of our services. We may use Anonymous Information and/or disclose it to third parties without restrictions (for example, in order to improve our services and enhance your experience with them)..PERIOD OF STORAGE OF COLLECTED INFORMATIONThe information we collect will be stored until we no longer need the information and proactively delete it or you send a valid deletion request. Please note that we may retain it for a longer or shorter period in accordance with data retention laws.This depends on the cookie in question. Some cookies (e.g. essential cookies) cannot be disabled. You may also control and delete these cookies through your browser settings.HOW WE PROTECT, STORE AND RETAIN YOUR INFORMATIONSecurity. We have implemented appropriate technical, organizational and security measures designed to protect your Personal Data. However, please note that we cannot guarantee that the information will not be compromisedas a result of unauthorized penetration to our servers. As the security of information depends in part on the security of the computer, device or network you use to communicate with us and the security you use to protect your user IDs and passwords, please make sure to take appropriate measures to protect this information.Retention of your Personal Data. In addition to the retention periods mentioned above, in some circumstances we may store your Personal Data for longer periods of time, for example (i) where we are required to do so in accordance with legal, regulatory, tax or accounting requirements, or (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 or dealings. We have an internal data retention policy to ensure that we do not retain your personal data perpetually.HOW YOUR PERSONAL INFORMATION IS SHARED4.1 We share your information as follows:In addition to the recipients described in Section 1, we may share your information as follows:With our business partners with whom we jointly offer products or services. We may also share Personal Data with our affiliated companies.To the extent necessary, with regulators, courts or competent authorities, to comply with applicable laws, regulations and rules (including, without limitation, federal, state or local laws), and requests of law enforcement, regulatory and other governmental agencies or if required to do so by court order;If, in the future, we sell or transfer some or all of our business or assets to a third party, we will (to the minimum extent required) disclose information to a potential or actual third party purchaser of our business or assets. In the event that we are acquired by or merged with a third party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer or assign Personal Data in connection with the foregoing events, including, in connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or to another company.Where you have provided your consent to us sharing or transferring your Personal Data (e.g., where you provide us with marketing consents or opt-in to optional additional services or functionality); and/orWhere we receive requests for information from law enforcement or regulators, we carefully validate these requests before any Personal Data is disclosed.We share the following information with other users and the general public of Atly: The content that you post or submit it is set to be viewable by the users and general public of our App and geolocation. This content may be viewed and shared by the public.If you want to receive the list of the current recipients of your personal data, please make your request by contacting us to info@atly.com4.2 You may share your information as follows:You may share a Step:With your family and friends using Third Party Services, and/orWith users and the general public of Atly App.ADDITIONAL INFORMATION REGARDING TRANSFERS OF PERSONAL INFORMATIONStorage: Amazon (AWS) Ireland.Access from Israel: It is covered by Israel’s Adequacy Decision and involves no data transfer issue. You can read more about this here: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en/External transfers: Where we transfer your Personal Data outside of EU/EEA, for example to third parties who help provide our products and services, we will obtain contractual commitments from them to protect your Personal Data.Where we receive requests for information from law enforcement or regulators, we carefully validate these requests before any Personal Data is disclosed.YOUR PRIVACY RIGHTSThe following rights (which may be subject to certain exemptions or derogations), shall apply to certain individuals (some of which only apply to individuals protected by the GDPR):You have a right to access Personal Information held about you. Your right of access may normally be exercised free of charge, however we reserve the right to charge an appropriate administrative fee where permitted by applicable law;You have the right to request that we rectify any Personal Data we hold that is inaccurate or misleading.You have the right to request the erasure/deletion of your Personal Data (e.g. from our records). Please note that there may be circumstances in which we are required to retain your Personal Data, for example for the establishment, exercise or defense of legal claims;You have the right to object to or to request restriction of the processing. However, there may be circumstances in which we are legally entitled to refuse your request;You have the right to data portability. This means that you may have the right to receive your Personal Data in a structured, commonly used and machine-readable format, and that you have the right to transmit that data to another controller;You have the right to object to profiling;You have the right to withdraw your consent at any time. Please note that there may be circumstances in which we are entitled to continue processing your data, in particular if the processing is required to meet our legal and regulatory obligations. Also, please note that the withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal;You also have a right to request certain details of the basis on which your personal data is transferred outside the European Economic Area, but data transfer agreements and/or other details may need to be partially redacted for reasons of commercial confidentiality;You have a right to lodge a complaint with your local data protection supervisory authority (i.e., your place of habitual residence, place or work or place of alleged infringement) at any time or before the relevant institutions in your place of residence. We ask that you please attempt to resolve any issues with us before you contact your local supervisory authority and/or relevant institution.The right to withdraw your consent. Please note that t there may be circumstances in which we are entitled to continue processing your data, in particular if the processing is required to meet our legal and regulatory obligations.You also have a right to request details of the basis on which your Personal Data is transferred outside the European Economic Area, but you acknowledge that data transfer agreements may need to be partially redacted for reasons of commercial confidentiality.You can exercise your rights by contacting us at info@atly.com. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly or inform you if we require further information in order to fulfil your request. When processing your request, we may ask you for additional information to confirm your identity and for security purposes, before disclosing the Personal Data requested to you. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive. In the event that your request would adversely affect the rights and freedoms of others (for example, would impact the duty of confidentiality we owe to others) or if we are legally entitled to deal with your request in a different way than initial requested, we will address your request to the maximum extent possible, all in accordance with applicable law.USE BY CHILDRENWe do not offer our products or services for use by children under the age of thirteen (13) years. We do not intend to collect Personal Data from anyone we know to be under thirteen (13) years. If you believe that we might have any such information, please contact us at info@atly.com. If you are under thirteen (13), you may not use the App, or provide any information to the Website and/or App without involvement of a parent or a guardian. If a parent or guardian becomes aware that his or her child has provided us with personally identifiable information without his/her consent, then he or she should contact us as described below. If we become aware that a child under the age of 16 has provided us with personally identifiable information, we will delete such information from our files. Further, the Children’s Online Privacy Protection Act (“COPPA”) requires parental consent for collection of data from children younger than the age of 13 years old. For tips on protecting children’s privacy online, generally, please view the U.S. Federal Trade Commission (“FTC”) website at https://www.ftc.gov/privacy/privacyinitiatives/childrens.html. For the purposes of the GDPR, we do not intend to offer information society services directly to children. Regardless, in the event that we become aware that you provide Personal Data in violation of applicable privacy laws, we reserve the right to delete it.PUBLIC INFORMATION ABOUT YOUR ACTIVITY ON THE SERVICESSome of your activity on and through the Services is public by default. This may include, but is not limited to, content you have posted publicly, and other interaction you have with public content (such as liking, saving, rating, tagging) on the Site or otherwise through the Services.Registered users may have some of this information associated with their Accounts. Unregistered users will not have this association, but information concerning their use of the Services (such as what pages they have visited) may be tracked anonymously through the use of cookies and stored by us.Please also remember that if you choose to provide Personal Information using certain public features of the Services, then that information is governed by the privacy settings of those particular features and may be publicly available. Individuals reading such information may use or disclose it to other individuals or entities without our control and without your knowledge, and search engines may index that information. We therefore urge you to think carefully about including any specific information you may deem private in content that you create or information that you submit through the Services.HOW CAN I DELETE MY ACCOUNT?Should you ever decide to delete your Account, you may do so by emailing info@atly.com. If you terminate your Account, any association between your Account and information we store will no longer be accessible through your Account. However, given the nature of sharing on the Services, any public activity on your Account prior to deletion will remain stored on our servers and will remain accessible to the public.INTERACTION WITH THIRD PARTY PRODUCTSWe enable you to interact with third party websites, mobile software applications and products or services that are not owned or controlled by us (each a “Third Party Service”). We are not responsible for the privacy practices or the content of such Third Party Services. Please be aware that Third Party Services can collect Personal Data from you. Accordingly, we encourage you to read the terms and conditions and privacy policies of each Third Party Service.LOG FILESWe may use log files. We use such information to analyze trends, administer the Site, to find bugs and enhance our product, track users’ movement around the Site, and gather demographic information.ANALYTIC TOOLSGoogle Analytics. The Website uses a tool called “Google Analytics” to collect information about use of the Website. Google Analytics collects information such as how often users visit this Website, what pages they visit when they do so, and what other websites they used prior to coming to this Website. We use the information we get from Google Analytics to maintain and improve the Website and our products. We do not combine the information collected through the use of Google Analytics with Personal Information we collect. Google’s ability to use and share information collected by Google Analytics about your visits to this Website is restricted by the Google Analytics Terms of Service, available at https://marketingplatform.google.com/about/analytics/terms/us/, and the Google Privacy Policy, available at http://www.google.com/policies/privacy/. You may learn more about how Google collects and processes data specifically in connection with Google Analytics at http://www.google.com/policies/privacy/partners/. You may prevent your data from being used by Google Analytics by downloading and installing the Google Analytics Opt-out Browser Add-on, available at https://tools.google.com/dlpage/gaoptout/.Firebase Analytics. We also use “Google Analytics for Firebase”. By enabling this tool, we enable the collection of data about App Users, including via identifiers for mobile devices (including Android Advertising ID and Advertising Identifier for iOS), cookies and similar technologies. We use the information we get from Google Analytics for Firebase to maintain and improve our App(s). We do not facilitate the merging of personally-identifiable information with non-personally identifiable information unless we have robust notice of, and your prior affirmative (i.e., opt-in) consent to, that merger. Finally, please note that Google Analytics for Firebase’s terms (available at https://firebase.google.com/terms/) shall also apply.Mixpanel. We collect Personal Information such as your email address and your user activity through the use of Mixpanel. Mixpanel’s ability to use and share information is governed by the Mixpanel Terms of Use, available at https://mixpanel.com/terms/, and the Mixpanel Privacy Policy, available at https://mixpanel.com/privacy/. You can opt-out of Mixpanel’s services by clicking on the following link: https://mixpanel.com/optout/.AppsFlyer. We use a tool called “AppsFlyer”, a mobile attribution and marketing analytics platform, to understand the use of our Service. AppsFlyer is exposed to the following data: (i) unique identifiers and technical data, such as IP address, User agent, IDFA (Identifier For Advertisers) or Android ID (in Android devices); (ii) technical data regarding your operating system, device attributes and settings, applications, advertising opt-out signals, Google Advertiser ID, in-app events, device motion parameters and carrier. The use of this data allows us to analyze our campaigns and performance, as well as your habits and characteristics. For example, the data AppsFlyer receives includes downloads, impressions, clicks and installations of their mobile applications, mobile device use and data regarding in-app events. AppsFlyer’s terms of use (available at https://www.appsflyer.com/terms-of-use/) and privacy policy (available at https://www.appsflyer.com/privacy-policy/) also apply to the use of AppsFlyer.AppSee and other third party technologies. We use Appsee https://www.appsee.com/legal/terms and other third parties to collect and analyze data from our Services.Hotjar. The Website uses Hotjar in order to better understand our users’ needs and to optimize this service and experience. Hotjar is a technology service that helps us better understand our users experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables us to build and maintain our service with user feedback. Hotjar uses cookies and other technologies to collect data on our users’ behavior and their devices (in particular device's IP address (captured and stored only in anonymized form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), preferred language used to display our Website). Hotjar stores this information in a pseudonymized user profile. Neither Hotjar nor we will ever use this information to identify individual users or to match it with further data on an individual user. For further details, please see Hotjar’s privacy policy at https://www.hotjar.com/legal/policies/privacy. You can opt-out to the creation of a user profile, Hotjar’s storing of data about your usage of our Website and Hotjar’s use of tracking cookies on other websites on this link https://www.hotjar.com/legal/compliance/opt-out.Facebook Pixels and SDKs. We use Facebook pixels or SDKs, which are tools that provide help to website owners and publishers, developers, advertisers, business partners (and their customers) and others integrate, use and exchange information with Facebook, as such the collection and use of information for ad targeting. Please note that third parties, including Facebook, use cookies, web beacons, and other storage technologies to collect or receive information from your websites and elsewhere on the internet and use that information to provide measurement services and target ads. Facebook’s ability to use and share information is governed by the Facebook Tools Terms, available at: https://www.facebook.com/legal/technology_terms/. You can prevent your data from being used by Facebook Pixels and SDKs by exercising your choice through these mechanisms: http://www.aboutads.info/ choices or http://www.youronlinechoices.eu/.Google Signals. The Website uses a tool called “Google Signals” to collect information about use of the Website. When we activate Google Signals, some existing Google Analytics features are updated to also include aggregated data from Google users who have turned on “Ads Personalization” (Ads Personalization available at https://support.google.com/ads/answer/2662856/). Audiences that we create in Google Analytics and publish to Google Ads and other Google Marketing Platform advertising products can serve ads in cross device-eligible remarketing campaigns to Google users who have turned on Ads Personalization. Google Analytics collects additional information about users who have turned on Ads Personalization, base across device types and on aggregated data from users who have turned on Ads Personalization. The data is user based rather than session based. The Cross Device reports include only aggregated data. No data for individual users is ever exposed. You can modify your interests, choose whether your Personal Data is used to make ads more relevant to you, and turn on or off certain advertising services in the Ads Personalization link above.We reserve the right to remove or add new analytic tools.SPECIFIC PROVISIONS APPLICABLE UNDER CALIFORNIA PRIVACY LAWCalifornia Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our subscribers who are California residents to request and obtain from us once a year, free of charge, information about the personal information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of personal information that was shared and the names and addresses of all third parties with which we shared information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to our privacy officer as listed below.We do not track consumers over time and across third party websites and therefore do not respond to Do Not Track signals. We do not allow third parties to collect personally identifiable information about an individual consumer’s online activities over time and across different web sites when a consumer uses the Services.If you are a California resident under the age of 18 and a registered user, California Business and Professions Code Section 22581 permits you to remove content or Personal Information you have publicly posted. If you wish to remove such content or personal information and you specify which content or personal information you wish to be removed, we will do so in accordance with applicable law. Please be aware that after removal you may not be able to restore removed content. In addition, such removal does not ensure complete or comprehensive removal of the content or Personal Information you have posted and that there may be circumstances in which the law does not require us to enable removal of content.CONTACT USIf you have any questions, concerns or complaints regarding our compliance with this notice and the data protection laws, or if you wish to exercise your rights, we encourage you to first contact us at info@atly.com.
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