PRIVACY POLICY

General

We, at Mobile Research Labs Ltd. ("MRL"), are committed to respect our Customers, their users and our Users' right for privacy with regards to the use of their Personal Data. We have adopted this privacy policy (as may be amended from time to time) (the "Privacy Policy") to ensure you are fully informed and aware as to the scope and nature of the Data MRL collects, generate and/or otherwise received from or about you while you are using the App, and how is it being Processed and/or otherwise used by MRL.

Definitions

For the purpose of this Privacy Policy, the following terms shall have the respective meanings set forth besides them:

"Anonymized Data" shall mean any information, data or content which is collected, processed and/or otherwise generated by MRL about or from your Use of the App which is anonymous and/or does not personally identify you and/or reveal your specific identity as an individual, and/or cannot be attributed to you, or as otherwise defined under Data Protection Laws, such as device data (such as, network status, battery level, screen/device on/off, usage data (including used application, headphone usage).

“App” shall mean MRL’s mobile application called Asound, which can be downloaded from the applicable virtual stores (“Google play” and/or “Apple” App Store).

"Data" shall mean Personal Data and Anonymized Data, together.

"Data Protection Laws" shall mean the General Data Protection Regulation (EU) 2016/679 (as may be amended, replaced or superseded from time to time) ("GDPR"), the laws in the EEA implementing or supplementing the GDPR in the relevant countries, and any other data protection laws applicable to MRL with respect to processing Personal Data, according to the terms of the Privacy Policy.

“EULA” shall mean the App’s end user license agreement, which is incorporated in the App and governs the terms and conditions for the use of the App by Users.

"Personal Data" shall mean any information, data or content, which can personally identify you as an individual and/or otherwise can be attributed to you as an individual, or as otherwise defined in Data Protection Laws, such as your age, gender, advertising ID., IMEI, Android ID, GPS location including background location, IP address, WiFi.

"Process" shall have the meaning ascribed to it under Data Protection Laws.

“Purposes” shall mean the Research Company Purposes and/or the MRL Purposes, together.

"Research Company" shall mean a business entity which entered into a commercial agreement with us, for the execution of the Research Company Purposes.

“Research Company Data” shall mean any Personal Data that the Research Company chooses to provide us about users who participate in its market-research program in designated field (the “Research Program”), in the course of using our services. Research Company Data excludes User Data.

“Sensitive Personal Data” shall have the meaning ascribed to it under applicable Data Protection Laws.

"Use" shall mean any download, access, view, visit and/or browsing the App for any purpose.

"User" or "you" or "your" (including any alterations thereof) shall mean any individual who Uses the App for the Purpose(s), by using a mobile device, including cellular device and/or by any other means of communications.

"User Data" shall mean any Personal Data the User uploads and/or we collect when he/she Uses the App for the MRL Purposes. User Data excludes Research Company Data.

Collection of Data – General Provisions

We collect and Process two types of data: Personal Data and Anonymized Data. As for Personal Data, the collection is further divided to two parts: User Data and Research Company Data.

The collection and Process of Research Company Data commences when the Research Company provides us Personal Data about you. Any other information you independently upload to the App and/or that we otherwise collect by technological tools is automatically transformed to a numeric vector, and thus cannot be referred to you and/or otherwise attributed to you as an individual in any way, nor can it be re-transformed to its original format, including by reserve engineering process.

The collection and Process of User Data commences on your first download of the App.

We do no collect and/or need and/or use any Sensitive Personal Data for the Purposes, and hereby ask you not to share with us Sensitive Personal Data when you Use the App for any Purpose.

Collection of Personal Data

Personal Data you Provide:

The types of User Data you provide may include (by way of a non-exhaustive list) your age, phone number, email address.

You do not provide us any Personal Data in the course of using the App for the Research Company Purposes, and any such Personal Data, to the extent provided, is provided to us by the Research Company.

Personal Data we receive from Third Parties:

We may obtain certain Research Company Data from the Research Company, which includes Age, Gender, Country, Region, phone number, email address.

We do not receive User Data from any third party.

Personal Data we Collect or Generate:

When you Use the App, we may collect some Personal Data about you, which may vary, dependent on the Purpose you use the App: We may collect your advertising ID, by using certain technological tools as detailed below. An advertising ID is a unique, user-resettable ID, assigned by the mobile device, and enables Users to reset their identifier or opt out of personalized ads within the App (to the extent downloaded from “Google Play”)

How we use your Personal Data:

Personal Data that you provide and/or that we Process shall be used by us for the following main purposes (as may be amended from time to time):

User Data will be used for the MRL purposes, as further detailed below:

We may use your age (a) in order to measure your exposure to noises, and/or (b) for research purposes, including the assessment of the implication of noises on individuals in the same age range.

If we collect your Advertising ID, we may use it in order to track your usage of the App and if applied personalize your advertising preferences.

We may use your Personal Data for sending marketing materials. In order to do so, in some jurisdictions we will obtain your prior consent and/or otherwise act as required by applicable law, using push notifications.

In addition, where applicable, we may use your User Data in order to improve our services, to enforce this Privacy Policy, resolve disputes, comply with any applicable law, regulations or other requests from authorized authority(ies), and/or as otherwise authorized by you.

We may use your location and background location in order to show you your daily sound exposure on a map. We may also use your location when measuring your exposure to media when you decide to take part in an opt-in panel.

Research Company Data will be used for the Research Company Purposes, as further detailed below:

We may use Research Company Data in order to provide the services to the Research Company which are associated with the Research Program, in accordance with the applicable agreement we have with the Research Company, and to carry our obligations arising from our agreement(s) with the Research Company.

Comply with our legal obligations and in order to be able to protect our rights and legitimate interests, including in order to improve the Services.

Lawful basis for Processing General. We only process Personal Data where we have a lawful basis to do so. The lawful basis will depend on the reason(s) we collected and need to use your Personal Data and may differ according to Data Protection Laws.

The lawful basis for Processing User Data will be: (a) when you gave us your consent for processing your User Data for specific purpose. For example, if you sent us your age in order for us to evaluate your exposure to noises and assess the impact of it on individuals in your age-range; or (b) where there is a legitimate interest to process the User Data (for example, to identify and prevent abuse of the App, to improve the performance of the App); or (c) To comply with a legal obligation that apply to us (for example, to disclose information to authorities)

As for Research Company Data: The Research Company Data that we collect and Process is owned and controlled by the Research Company, who is the Controller of such information, and we only act as a Processor on behalf of the Research Company. We will Process the Research Company Data in accordance with the provisions of the data processing addendum we have with the Research Company. The Research Company initiates the collection of Research Company Data, determines from whom to collect such data, defines what data to collect and how to use it. As such, the lawful basis for processing of Research Company Data has been determined exclusively by the Research Company. For further queries with respect to the Research Company Data and the lawful basis of its processing, please review the Research Company 's privacy policies and/or contact the Research Company.

Your Rights regarding your Personal Data.

Your rights with respect to Research Company Data: As stated above, we have no control over what types of Research Company Data that the Research Company chooses to provide us, nor do we collect Personal Data from Research Company’s users. Therefore, we are not able to communicate with any user and/or grant him/her any rights. As a result, the Research Company is solely responsible for satisfying all legal obligations owed directly to its users under applicable Data Protection Laws. We are not responsible for Research Company’s privacy policies or practices or for the Research Company’s compliance with such policies or practices. If you wish to execute your rights regarding Research Company Data, please contact the Research Company.

As for User Data: In this section, we hereby inform you what rights you may have with respect to the Processing of your User Data. Please note that your rights may differ, dependent on your jurisdiction and the Data Protection Laws:

You may have the right to request a review of your User Data we Process.

You have the right to have your User Data rectified to the extent it is incorrect, incomplete, or not processed in compliance with Data Protection Laws.

You may be entitled to require that we erase certain part of your User Data if its processing is not justified.

You may have the right to ask the transfer of your User Data to other controllers.

In some circumstances, you have the right to withdraw consent (where the lawful basis for Processing is consent).

Under certain circumstances, you may have the right to object to the Processing of your User Data due to your particular situation.

Where applicable, you have the right to lodge a complaint before the applicable Supervisory Authority of your jurisdiction.

If you wish to exercise any of your rights regarding your User Data, please contact us at: support@mobilerl.com. We will act in accordance with the Data Protection Laws, in order to comply with your request. We have appointed a Data Protection Officer, who can be contacted by email: dpo@mobilerl.com.com

Collection of Anonymized Data

In addition to the categories of Personal Data described above, we may also collect and Process Anonymized Data from you when you Use our App.

Anonymized Data we Collect. Anonymized Data we collect may include:
(1) Specific features from the audio you are exposed to via the Media – to the extent you participate in the Research Program;
(2) technical information about your mobile device, such as the type of device, its battery status, internet connection status, whether it is switched on, off or in "Airplane" mode, Wi-Fi MAC Address and/or SSID of networks you connect to, your general time zone, panel person/household IDs (but excluding specific home address), foreground application changes, number of answered incoming calls (but excluding the specific phone-numbers), number of outgoing text messages (but excluding the content of such messages and their destination), accelerometer events, screen unlock events, charging events, max accelerometer reading, application version installed and audio signatures and similar type of information;
(3) any audio/sound/voice you transmit or pronounce while the App is activated, or other commends and/or actions and/or functions executed by you in your mobile device, which you provided your consent for their disclosure to Us (such as GPS readings). Anonymized Data may be stored in different forms, either aggregated and/or combined with other information or as a raw data form.

How we Use Anonymized Data. We may use Anonymized Data for the following purposes:

We have been asked by the Research Company to collect Anonymized Data from participant in the Research Program for the following purposes (as may be updated from time to time, based on the Research Company's discretion): (a) conducting a market research for the monitoring and/or measurement of exposure to television programs, radio stations, and other applicable media (the "Media"), which you may be watching, listening to and/or otherwise using, and also for profiling and advertising purposes. The foregoing will be executed by analyzing and/or otherwise performing a match (either manually or automatically) with reference databases of broadcast TV and Radio programs, provided Us by the Research Company, in order to determine which Media, you have been exposed to (above and hereinafter: the "Research Company Purposes").

Except for Anonymized Data which is collected for the Research Company Purposes, we may use Anonymized Data for the same purposes as the use of Personal Data (where applicable) and for the following additional purposes: (a) commercial research purposes; and/or (b) improving the App by creating system analytics and statistical data; and/or (c) for technical administration and troubleshooting of the App; and/or (d) protect the Platform(s) (as defined in the EULA); (e) for any other legitimate purpose (above and hereinafter: “MRL Purposes”).

Sharing Data with Others

We respect your privacy and will not disclose, share, rent, or sell your Personal Data to any third party, other than as permitted under this Privacy Policy. We may share Data with third parties, as set forth below:

Research Company. In some cases, the Research Company will be legally responsible for safeguarding Anonymized Data derived and/or otherwise extracted from the Research Company Data (either instead of or together with MRL). Therefore, the Research Company will often receive a copy of Anonymized Data for the Research Company's needs

Service Providers. We may share Data with our contracted service providers, such as cloud vendors, IT service providers, advertisers, companies that provide analysis and processing activities, messaging services etc., so that these service providers can provide services on our behalf.

Business Transfers: If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, the Data may be transferred to a successor or affiliate as part of that transaction along with other assets.

Official Authorities: We may need to disclose Data in response to resolve any disputes with you, lawful requests by public authorities or law enforcement officials, including meeting national security or law enforcement requirements. We cooperate with government and law enforcement officials to enforce and comply with the law.

International transfer of Information collected

We may store, process, or maintain Data in various sites worldwide, including through cloud-based service providers worldwide.

Where the GDPR applies and we transfer Personal Data to another country outside the EEA, we will ensure that it is protected and transferred in a manner consistent with legal requirements. In relation to data being transferred outside of the EEA, for example, this may be done in one of the following ways:

the country that we send the data to might be approved by the European Commission as offering an adequate level of protection for Personal Data.

the recipient might have signed up to a contract based on “model contractual clauses” approved by the European Commission, obliging them to protect your Personal Data.

where the recipient is located in the US, it might be a certified member of the EU-US Privacy Shield scheme; or in other circumstances the law may permit us to otherwise transfer your Personal Data outside the EEA.

Retention

We retain different types of Data for different periods, depending on the purposes for processing the Data, our legitimate business purposes as well as pursuant to legal requirements under the applicable law. We will retain Research Company Data as long as required in order to provide the Research Company the services associated to the Research Program; We will retain User Data for as long as required and needed to comply with our legal obligations or to pursue our legitimate business purposes (such as defend ourselves. Unless otherwise restricted under applicable law, Anonymized Data will be retained indefinitely.

Security

We are committed to protecting the security of Personal Data. We use a variety of administrative, technical, and physical security technologies and procedures to help protect your Personal Data from unauthorized access, use, or disclosure. While we strive to protect your Personal Data, we cannot ensure or warrant that the Personal Data or private communications you transmit to us will always remain private and will not be illegally accessed, and accordingly you assume all risk associated therewith and agree that we will not under any circumstances be liable to you in respect thereof.

Our Policy Regarding Children's Privacy

The App is intended for use by adults. However, we may be required to collect Personal Data from minors (under the age of 16) for the Purposes (whether in whole or in part). We have no control over the age of Users who download the App from the virtual stores. Therefore, if you are under the age of 16, please do not submit any Personal Data through the App unless your parent or legal guardian has approved.

Privacy Policy Changes

We reserve the right to change this Privacy Policy at our sole discretion and/or subject to specific request of the Research Company and/or the Platform(s)' requests. We will inform you of any such change by posting a new privacy policy and a prior notice prior to such change; the effective date of any change of privacy policy will be clearly marked at the end of each new privacy policy posted.

Contact Us

We value your opinions and feedback. If you have comments or questions about our Privacy Policy, please email: info@mobilerl.com. When the GDPR applies, if you are not satisfied with the response you receive from us or you think that your rights have been infringed by us, you may escalate your concerns to the applicable privacy regulator in your jurisdiction. Upon request, we will provide you with the contact information for that regulator. However, we recommend you contact us first – and we will do our best to solve any complaint.

Additional information for Israeli Users:

No Legal Requirement We hereby inform you, and you hereby acknowledge that you have no legal obligation to provide us with any Personal Data (or any other data) when you use the App, and the provision of it is solely based on your free will. However, you are aware that without the provision Personal Data, we will not be able to provide you with your personalized sound map.

Your Consent by Using the App for any of the Purposes, you hereby represent, acknowledge, and provide your informed consent that your Personal Data will be stored in our database(s), and will be Processed by MRL (including, by third parties acting on our behalf) for the purposes and the terms as specified in this Privacy Policy.

International transfer. Data may be stored, processed, maintained, and transferred to various countries outside of Israel, where the privacy laws may not be as protective as those in Israel. By using the App for any of the Purposes, you hereby provide us your informed consent to the use and/or process and/or storage and/or transfer of the Data to countries

outside of Israel. We undertake to comply with the applicable provision set forth in the Data Protection Laws that relate to the transfer of Personal Data abroad.