Updated: January 2020

In Summary

Kenshoo is a global software company that engineers cloud-based digital marketing solutions and predictive media optimization technology.

As such, we collect, process and analyze data from various sources, produce statistical information and identify trends to enable our customers to manage, optimize and analyze their digital marketing activities across multiple advertising channels and devices.

This Privacy Policy discloses the privacy principles and practices applied by Kenshoo in the course of providing services to its customers and from individuals visiting our website.

Privacy Shield

We are self-certified with the US Department of Commerce – EU-US Privacy Shield Framework, in connection with the collection, use, and retention of personal information from EU member states. We are committed to adhere to the Privacy Shield principles, including notice, choice, accountability for onward transfer, security, data integrity, purpose limitation, access, recourse, enforcement and liability.

For further information about the Privacy Shield program and to view our certification page, please visit: https://www.privacyshield.gov/list. If there is any conflict between the terms in this Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. The Federal Trade Commission (FTC) has jurisdiction over our compliance with the Privacy Shield.

We are further committed to refer unresolved Privacy Shield complaints to TrustArc, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please visit https://www.trustarc.com/ for more information or to file a complaint. The services of TrustArc are provided at no cost to you.

Kenshoo commits to cooperate with UK’s independent data protection authority (ICO) and comply with the advice given by the ICO about human resources data transferred from the EU of a human resources nature.

      • Customer”:
        An entity that has entered into an agreement with Kenshoo and is receiving the Kenshoo Services.
      • Customer Website”:
        A website or other application, operated by a Customer.
      • Engagement”:
        Any interaction of a User (including viewing and/or clicking) with Customer’s advertisement or website.
      • Kenshoo” (or “us”, “we” or “our”):
        Kenshoo Ltd. 6 Ha’barzel St., Tel-Aviv, Israel 6971010 or any of its subsidiaries.
      • Kenshoo Services” (or “Services”):
        Services provided by Kenshoo.
      • Kenshoo Site” (or “Site”):
        www.kenshoo.com or any of its pages.
      • Privacy Policy” or “Policy”:
        Kenshoo’s privacy policy as described herein.
      • User”:
        An individual who visits or otherwise engages a Customer Website.

 

Overview of our Services

Kenshoo Services allow Customers to manage, optimize and analyze their digital marketing activities across multiple advertising channels and devices. As such, Kenshoo does not have a direct relationship with Users who visit or otherwise engage Customer Websites or are exposed to Customer’s advertisements that are managed using our Services.

We collect and use information related to Users as part of the provision of the Kenshoo Services to our Customers as will be detailed below.

As a rule of thumb, the information collected by the Kenshoo Services is typically used to identify trends and optimize overall advertising activities of our Customers. Kenshoo does not know and does not attempt to know the identity of the Users, does not match such information with any identifiable information, and does permit others to use such information to identify Users.

Kenshoo requires its Customers to acknowledge this Privacy Policy to promote transparency of our privacy practices to Users.

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The types of data we collect and how we collect it through our Services

We collect information in a number of ways as described below, to provide our services and for other purposes that we describe in this Privacy Policy. Note, that you are not required by law to provide us with any information about you.

  1. Data obtained from engaging Customer’s ads and/or Websites

    As part of our Services we offer our Customers anonymous tracking of Users who engage Customer ads and/or Customer Website. Consequently, we collect the following information:

    • The time and date of the Engagement;
    • Details about the device, operation system and browser used by the User;
    • The IP address associated with the  User’s specific device;
    • The URL of the landing page of the Customer Website;
    • The URL of the referring website;
    • Targeting data disclosed by publishers (e.g. keywords).

    In order to obtain this information, we use Tracking Pixels and Cookies (as such terms are defined below).

    A Tracking Pixel is a piece of code embedded on a web page of Customer’s Website that collects information about Users’ engagement on that web page. The tracking pixel can be provided either by the advertising channels, affiliate networks or by Kenshoo. The Tracking Pixel may include a command to create Cookies.

    A Cookie is a small text file that can be stored on a User’s browser (on any type of device). Our Cookie contains a random unique identifier that enables anonymous tracking activity from a browser that is associated with products and services of a Customer.

  2. Data obtained from Customers or from third parties

    Subject to Customer’s approval, we will collect information of Customers or of third-party partners, and may combine it with our own data. Such information is un-identifiable, and we do not know, nor will we attempt to know the identity of Users.

    For example:

      Customers may generate and send us anonymous Users’ IDs in order to associate cross device activity of same User.
  3. Data which we DO NOT collect

    Kenshoo does not collect any information for the purpose of unveiling the anonymity of a User. In particular, we don’t collect sensitive personal data such as financial data, medical data or any data that may be associated with race, religion, sexual orientation or political opinions of a specific identifiable individual. If any such data would inadvertently be received by us, we will make no use of it.

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How we use the data we collect through our Services

We use the data we collect for all the following purposes: provide our Services; study and analyze the functionality of the Services and Users’ activities; provide support; measure Services’ activity; conduct surveys and send questionnaires; provide various reports and enhance our Services to our Customers; maintain the Services; make them better and continue developing the Services.

For example:

  • Aggregate performance data of keywords used in search engines for the purpose of generating a report that includes, for each keyword, the number of clicks, the click-through rate or other performance data;
  • Create an average attribution scheme for one or more conversions, based on an analysis of numerous Engagements of Users across time;
  • Detect a trend in a certain market or industry and publish our findings.

Additionally, we facilitate advertisements based on past interactions of Users with Customer advertisements and Customer Websites (“Retargeting Services”). We utilize Cookies to enable this service.

We use automated processes, including automated decision making to provide our services to our customers and enhance their online marketing capabilities and campaigns.

We obey the law and expect you to do the same. If necessary, we will comply with court orders and warrants, and assist law enforcement agencies to prevent fraud, misappropriation, infringements, identity thefts and any other misuse of the Services, and to take any action in any legal dispute and proceeding.

We commit to process personal information solely for the purposes described in this Privacy Policy. To the extent relevant and possible, we will make efforts to maintain the information accurate, complete and up-to-date.

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Data we collect and use via our Site

We collect personal information from Users who may be prospective customers and engage our Site. The information collected is typically voluntarily supplied by you through the “Contact Us” form. This information will only be used for the purpose of evaluating, contacting and serving the prospective customers and/or candidates applying for a position. If you are a candidate applying for a position through our Site, please see our Recruitment Privacy Policy.

Additionally, we use third-party suppliers to better understand the usage of our Site, to qualify leads obtained following registration to our Site or to further advertise our Services. In such scenarios, our Site utilizes a Cookies on your device.

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Sharing data with third parties

In certain instances Kenshoo will share Users’ data with third parties, including:

  • Service We engage trusted third-party companies and individuals to facilitate or provide services on our behalf or to perform Site-related services and analysis for the purpose of providing and operating our Services. Such engagement will be only to the extent necessary and we require that such third parties comply with privacy and data protection principles.
  • We use the standard analytics tools of Google Analytics and we may use additional or other analytics tools, from time to time. The privacy practices of these tools are subject to their own privacy policies. See Google Analytics Privacy Policy at: http://www.google.com/analytics/learn/privacy.html. We may disclose personal data with or without notice (a) if required by a subpoena or other judicial or administrative order; (b) where required by law; or (c) at our sole discretion, where we deem it necessary to protect the safety of any individual, the general public, or to prevent violations of the rights of Kenshoo or any third party. Legal We may disclose Users’ or Site visitors’ data if we are required to do so by any applicable law or an order issued by a governmental authority, or to comply with industry privacy standards.
  • We may also disclose or use Users’ or Site visitors’ data to defend or enforce our legal rights and in accordance with any applicable
  • Corporate We may disclose, share or transfer Users’ data in connection with a merger, acquisition, reorganization or sale of our assets or in the event of bankruptcy.
  • We may be liable for onward transfers to third parties in violation of the Privacy Shield For further information, please see below the EU-US Privacy Shield chapter of this Privacy Policy.
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Aggregated and Analytical Information

We may use anonymous, statistical and aggregated data that we derive from your personal data, to drive insights, statistics, trends and predictions for our internal use and may share it with our customers, affiliates and business partners for their lawful business purposes.

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Data Transfer

We use the services of cloud-based service providers which store and process information in the US region.

We may store and process information in various sites throughout the globe, including on sites operated and maintained by cloud-based service providers. If you are a resident in a jurisdiction where the transfer of your personal information to another jurisdiction requires your consent, then by agreeing to comply with this Privacy Policy, you provide us your express and unambiguous consent to such transfer.

If you are interested in obtaining more information about the safeguards of our data transfer, you may contact our Data Protection Officer at: Privacy@Kenshoo.com.

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Opting out from our Services

At any time, you can unsubscribe from our mailing lists by sending an opt-out request to privacy@kenshoo.com.

At any time, you can stop using the Site or terminate your use of our Services. Termination of your use of our Services is subject to the Kenshoo Services Agreement.

At any time, you can exercise the following opt-out options:

  • object to the transfer of your personal data to a third party, other than to third parties who help us perform tasks as explained above under “Sharing Data with Third Parties“, or
  • object to the use of your personal data for a purpose that is materially different from the purposes for which we originally collected such information, under this Privacy Policy, or from the purposes that authorized at a later stage.

Please note that we will be able to exercise your opt-out rights, if we are able to identify specific data on our databases that are related specifically to you.

At any time following your opt-out request, we can remove or de-identify your personal data altogether and request that you stop using the Website.

Following the termination or expiration of your use of our Site or Services, we will stop collecting any personal data from or about you. However, we will store and continue using or making available your personal data according to our data retention section in this Privacy Policy.

Web browsers offer a “Do Not Track” (“DNT”) signal. A DNT signal is a HTTP header field indicating your preference for tracking your activities on a service or through cross-site user tracking.

Our Site does not respond to Do Not Track (DNT) signals.

You can exercise your choice by contacting us at: privacy@kenshoo.com.

We will need to ask you to provide us necessary details to authenticate your identity and to identify data related to you on our systems.

Cookie opt-out – You may elect to opt-out of enabling Cookies in the browser’s settings tools, usually by choosing between several options offered by the browser. For further information about Cookies please see our Cookies and Tracking Technologies Policy.

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Data Retention and Security

Kenshoo retains personal data for as long as necessary to fulfill the purposes of using such data under this Privacy Policy and as permitted by law.

We will keep aggregated non-identifiable data without limitation, and to the extent reasonable We will delete or de-identify potentially identifiable data, when we no longer need to process the data in an identifiable form.

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Your Rights as an EU Data Subject

Under EU data protection laws, Kenshoo, will be considered a data processer as such term is defined therein, with respect to its Services. However, with respect to the Site, Kenshoo is a data controller, as such term is defined in the EU data protection, and the following will apply only in such case.

We base our processing of Personal Information as a data controller on the following lawful grounds: 

  • All processing of personal data related to you which are not based on the lawful grounds indicated below, are based on your consent.
  • We process your personal data to perform the contract with you or as a preliminary necessary step prior to entering a contract with you.
  • We will process personal data related to you to comply with a legal obligation and to protect your and others’ vital interests.
  • We will rely on our legitimate interests, which we believe are not overridden by your fundamental rights and freedoms, for the following purposes:
  • Communications with you, including direct marketing where you are our client or a user of our client, or where you make contact with us through our website and other digital assets;
  • Cyber security;
  • Support, customer relations, service operations;
  • Enhancements and improvements to yours and other users’ experience with our services;
  • Fraud detection and misuse of our Site.

At any time, you may contact our Data Protection Officer at: privacy@kenshoo.com  and request to exercise your rights in accordance with the provisions provided by law:

  • You may access the data that we keep about We may need to ask you to provide us certain credentials to make sure that you are who you claim you are. If you find that the data is not accurate, complete or updated, then please provide us the necessary information to correct it.
  • You may contact us if you want to withdraw your consent to the processing of your Exercising this right will not affect the lawfulness of processing based on consent before its withdrawal.
  • You may request to delete or restrict access to your personal

If you exercise one (or more) of the above-mentioned rights, in accordance with the provisions under the law, you may request to be informed that third parties that hold your personal data, in accordance with this Privacy Policy, will act accordingly.

  • You may ask to transfer your personal data in accordance with your right to data
  • You may object to the processing of your personal data for direct marketing
  • You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affecting
  • You have a right to lodge a complaint with a data protection supervisory

We do periodical assessments of our data processing and privacy practices, to make sure that we comply with this Privacy Policy, to update the Privacy Policy when needed, and to verify that the Privacy Policy is displayed properly and accessible.

If you have any concerns about the way we process your personal information, you are welcome to contact our privacy team at: privacy@kenshoo.com, or write to us to: Kenshoo Ltd., 30 Ha’barzel St., Tel-Aviv, Israel 6971010

We will look into your query and make good-faith efforts to resolve any existing or potential dispute with you.

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request

You may also invoke binding arbitration in certain cases, as further described in Annex I of the EU-U.S. Privacy Shield Agreement. For further information, please visit the Privacy Shield web site at: www.privacyshield.gov.

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Your California Privacy Rights

This section applies solely to Site visitors and Users who reside in the State of California.

Personal Information that We Collect

We have collected the following categories of personal information from consumers within the last twelve (12) months:

  • Identifiers and Personal Information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). These include names, telephone numbers, business postal addresses, Internet Protocol address and business email address.
  • Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an Internet Website, application, or advertisement.
  • Inferences drawn from any of the information identified to create a profile about a consumer reflecting the consumer’s preferences and characteristics.

Our Categories of Sources for Personal Information

We obtain the categories of personal information listed above from the following categories of sources:

  1. Directly and indirectly from Users and from visitors to the Site.
  2. Customers and third parties as further detailed above.

Our Use and Disclosure Practices

We use the personal information we collect for the business purposes detailed under the sections titled “How We Use the Data We Collect Through Our Services” and “Data We Collect and Use Via Our Site” of this Privacy Policy.

We disclose personal information to third parties for business purposes as described above under the section titled “Sharing Data with Third Parties” in this Privacy Policy.

In the preceding twelve (12) months, We have disclosed the following categories of personal information for business purposes:

  • Identifiers;
  • Contact details;
  • Internet or other similar network activity;
  • Inferences;

In the preceding twelve (12) months, We have not sold personal information.

Your Rights as a California Resident

You are entitled to the following specific rights under the California Consumer Privacy Act (‘CCPA’) in relation to your Personal Information:

  1. Access to Specific Information and Data Portability Rights

You have the right to request that we will disclose certain information to you about our collection and use of your personal information over the past 12 months. After verifying your request, We will disclose to you:

  • The categories of personal information we collected about you;
  • The categories of sources for the personal information we collected about you;
  • Our business or commercial purpose for collecting that personal information;
  • The categories of third parties with whom we share that personal information;
  • The specific pieces of personal information we collected about you;
  • If we disclosed your personal information for a business purpose, we will provide you with a list which will identify the personal information categories that each category of recipient obtained.
  1. Deletion Rights

You have the right to request that we delete any of your personal information. Upon confirmation of your request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your request if maintaining your personal information is necessary for us or for our service providers for the reasons specified under the CCPA or if we are unable to identify any personal information on our systems, that is related specifically to you.

Exercising Your Rights

To exercise the access, data portability, and deletion rights described above, please submit your request to us by sending an email to: privacy@kenshoo.com

Only you or a person authorized to act on your behalf, may make a request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

We cannot respond to your request or provide you with the requested personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.  We will only use the personal information provided in your request to verify your identity or authority to make the request.

We will do our best to respond to your request within 45 days of its receipt.  If we require more time (up to additional 45 days), we will inform you of the reason and extension period in writing.   If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding receipt of your request.

The response We provide will also explain the reasons for Our inability to comply with your request, if applicable.

We do not charge a fee to process or respond to your request unless it is excessive, repetitive, or manifestly unfounded.  If we determine that the request warrants a fee, we will inform you of the reasons for such decision and provide you with a cost estimate before completing your request.

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Changes to this Privacy Policy

Kenshoo reserves the right to change, modify, add or remove portions of this Privacy Policy at any time and without prior notice. If we materially change our Privacy Policy, we will post the revised Privacy Policy via our Site and/or Services. You are advised to consult this Privacy Policy regularly for any changes.

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If You Have Questions About This Privacy Policy:
To address any questions, comments, or concerns related to this Privacy Policy, please send a detailed message to: privacy@kenshoo.com.

© 2012-2019 Kenshoo, Ltd. All rights reserved.