Privacy Policy

Citizen Café Ltd. – Privacy policy

Last modified: September 12, 2022

• Introduction

  Citizen Café Ltd. (“Citizen”, “we”, “our” or “us”) is providing language learning, with different method that teaches you to speak Hebrew with more ease and confidence, https://www.citizencafetlv.com/ , its subdomains and its related features (“Website“, collectively “Services”).

  Citizen is dedicated to protecting your privacy rights and making our practices regarding your personal data more transparent and fair. This Privacy Policy (“Policy”) was designed to help you understand the information we collect, store, use and share, and it applies whenever you visit our Website or otherwise access or use any of our Services. Citizen Café Ltd. a company registered in Israel, is the data controller for the purposes of the General Data Protection Regulation (“GDPR”) and any relevant local legislation (“Data Protection Laws”).

  We strongly encourage you to read and understand this Policy. In the event that you do not agree to our Policy, please do not use our Services.
  Providing us with Personal Data is not legally required, but without it we will be unable to provide you with the full range or the best experience of our Services.
  This Privacy Policy is integrated into and forms part of the Citizen Terms of Use, and is incorporated therewith by reference.
  By using the Services, including our Apps and Website, you signify your acceptance of this Privacy Policy. If you do not agree to the terms of this Privacy Policy, please do not use our Services. Your continued use of the Services following the posting of changes to this Privacy Policy will mean that you accept those changes.

1. What types of data we collect?

1.1 Information You Provide. When you register your account, we require you to provide us with your email address, your name, and your password. In addition, when you subscribe to our Services or place an order with us, we collect payment details and record your agreement to our Terms and Conditions. If you choose to log in, access or otherwise connect to the Services through a social networking service or a single sign on service (such as Facebook, Twitter, Instagram, Google, Apple etc.), we may collect your user ID and/or username associated with that social networking service, as well as any information you make public using that social networking service or that the social networking service allows us to access.

1.2 Automatically Technical Information. When you use our Services, we collect technical information about your device. Such information may include pages and files accessed, time of access; amount of data transferred; browser version; operating system; language settings; device ID; previously visited pages (if you access our website via a link); IP address; session ID.
1.3 Communication Information. When you send us an email or contact us via the support in our Services, we collect the Personal Data you provide us. This may include your name, email address and any other information you choose to provide.

2. Tracking Technologies

When you visit or access our Services, we use cookies, pixels, beacons, local storage and similar technologies (“Tracking Technologies“). These allow us to automatically collect information about you, your device, and your online behavior, in order to enhance your navigation in our Services, improve our Services’ performance, perform analytics, customize your experience and offer you, for example, tailored content and advertisements that better correspond with your interests.

Citizen may use non-Personal Data for commercial, marketing, and/or business purposes, such as reporting and conducting research and development in order to enhance our existing Services and/or develop new products and services. We may share this information internally and/or with third parties for our or their purposes in an anonymous or aggregated form that is designed to prevent anyone from identifying you.

2.1 How do we collect information?
When you enter the Website, we collect your browser type and your IP address (a unique address that identifies your computer on the Internet). When you use our mobile Application, we collect your device type, your device ID, and your IP address.

In addition, we store certain information from your browser using “cookies.”
A “cookie” is a small text file that a website can send to your computer’s browser. It’s like an internet user’s identification card, which tells a website when a user is re-visiting the site. Their ability is limited to containing and transferring to the website as much information as the users have disclosed to that site. Cookies can’t read or interfere with other information saved on your hard drive.

We use cookies on certain of our pages to help analyze our web page flow, customize our services and content. We use cookies to help identify you and maintain your signed-in status. Most cookies are “session cookies” which exist only during one session and they disappear from your computer when you close your browser software or turn off your computer. Persistent cookies remain on your computer after you close your browser or turn off your computer.

If you have chosen to identify yourself in this website, we will use session cookies containing encrypted information to uniquely identify you. Each time you log into the Service, a session cookie containing an encrypted, unique identifier that is tied to your account is placed in your browser. Session cookies are required to use the Service.

We use persistent cookies that only we can read and use to identify browsers that have previously visited this website. When you use the Service or provide us with personal information, a unique identifier is assigned to you. This unique identifier is associated with a persistent cookie that we place on your Web browser. We are especially careful about the security and confidentiality of the information stored in persistent cookies (e.g. we do not store account numbers or passwords in persistent cookies). If you disable your Web browser’s ability to accept cookies, you will be able to navigate in this websites, but you will not be able to use the Service.

Most computers are set up to automatically accept cookies. However, you can reset your browser settings to refuse cookies, or alert you when a cookie is being sent so you can choose whether or not to accept it.

To learn more about how can manage your cookies, below is a list of useful links that can provide you with more information on how to manage your cookies:

• Google Chrome
• Internet Explorer
• Mozilla Firefox
• Safari (Desktop)
• Safari (Mobile)
• Android Browser

You can learn more and turn off certain third party targeting and advertising cookies by visiting the following third party webpages:

• The Interactive Advertising Bureau (US)
• The Interactive Advertising Bureau (EU)
• European Interactive Digital Advertising Alliance (EU)

We use cookies:

• for login authentication and login status;
• for load distribution and corresponding optimization of our Services;
• to save your language settings;
• to provide and improve our Services;
• to analyze user behavior on different devices
• for analytics and advertising.

3. Why we process your Personal Data?

3.1 Provision of our Services; support. We use your Personal Data, such as your name and email address, for consumer services purposes. This includes, for example, responding to your inquiries. Our interests in this case are enforcing our policies, protection against fraud and misuse of our Services.

3.2 Improve our Services. We collect and analyse information about you and your usage of our Services to improve the usability and effectiveness of our Services.

3.3 Marketing and Advertising. When you visit our Services, we may use Tracking Technologies (which may collect Personal Data). Your consent (where required) and our legitimate interests are the legal bases for processing this data. In this case, our legitimate interests are to provide you with tailored services, content and advertisements that are more relevant to you.

3.4 Compliance with applicable laws. We may be required to collect, retain, or share your Personal Data, under applicable laws.

4. How we use your information?

• To provide and improve our Services;
• To monitor interactions with our marketing emails;
• For machine learning, artificial intelligence, or natural language processing research, pseudonymized, anonymized, or aggregated;
• To conduct surveys under pseudonyms or anonymities;
• For the purpose of processing subscriptions to our services;
• In order to protect our interests or those of third parties;
• For the purpose of maintaining and enhancing the security of our services;
• For the purpose of preventing abuse of our services;
• For the purpose of complying with our legal obligations;
• to communicate with you;
• for analytics and advertising, including personalized ads;
• In order to perform or enforce our obligations;
• for any other purpose with your consent.

5. With whom we share your data?

We may share your Personal Data as described below:

a) Affiliated companies: we may share Personal Data internally within our affiliated companies, for the purposes described in this Policy.

b) Service providers: we work with service providers that work on our behalf that may need access to certain personal data in order to provide their services to us. These companies may include, but are not limited to, cloud storage providers, analytics services, fraud prevention, identity verification provider, etc.

c) Mergers and acquisitions: we may transfer, sell or otherwise share your data if we enter into a business transaction such as a merger, acquisition, reorganization, bankruptcy, or sale of some or all of our assets. Any party that acquires our assets as part of such a transaction may continue to use your data in accordance with the terms of this Policy. If we believe that such change in control might materially affect your Personal Data then stored with us, we will notify you of this event and the choices you may have via e-mail and/or prominent notice on our Services.

d) Any Purpose we might share your information to fulfill any purpose for which you provide it; for any other purpose disclosed to you when you provide the information; or with your consent.

e) Our rights we might share your information if we believe disclosure is necessary or appropriate to protect our rights, property, or interests, our investors, or others.

6. Your rights

This section addresses the specific rights you may have concerning your Personal Data.

You may request to:

1. Receive confirmation as to whether or not Personal Data concerning you is being processed, and access your stored Personal Data, together with supplementary information.
2. Receive a copy of Personal Data you directly volunteer to us in a structured, commonly used and machine-readable format.
3. Request rectification of your Personal Data that is in our control.
4. Request erasure of your Personal Data.
5. Object to the processing of Personal Data by us.
6. Request to restrict processing of your Personal Data by us.

Please note that these rights are not absolute, and may be subject to our own legitimate interests and regulatory requirements. You are welcome to contact us for any questions, requests or complaints through our contact details below.

We will make an effort to reply within a reasonable timeframe. Please feel free to reach out to us at any time. If you are unsatisfied with our response, you can lodge a complaint with the competent supervisory authority.

6.1 Residents of California: This Privacy Policy discloses the categories of personal information we have collected about California residents over the past twelve months, the sources of collection, how we use that information, and the categories of third parties with whom we share that information for a business or commercial purpose. California residents have the right to request that we disclose information about the personal information we collected, used, disclosed, and sold about them during the past twelve months and the right to request specific pieces of their personal information. California residents also have the right to request deletion of the personal information we have collected about them. California residents or their authorized agent can submit a request by calling Toll-Free (only calls): +1 888-808-0334 or by emailing office@citizenCafeTLV.com. 

Requestors will need to provide us with certain personal information for us to match with our records in order to verify their identity and residency. The personal information that we use to verify a requestor’s identity and residency will not be used for any other purpose. California residents have the right not to be discriminated against for exercising their CCPA privacy rights and we do not discriminate against California residents who exercise their CCPA privacy rights.

6.2 California and Nevada Residents: We may share your personal information in ways that could be considered a “sale” of personal information under certain state laws. Residents of California and Nevada have the right to opt out of the sale of their personal information. To do so please emailing us at office@citizenCafeTLV.com.

6.3 Individuals in the EEA: In addition to the foregoing rights, you have the right to lodge a complaint with a supervisory authority if you believe we have processed your information in a manner inconsistent with your privacy rights. We kindly request that you contact us first so that we may address your concern by emailing us at office@citizenCafeTLV.com.

You may also have the right to make a GDPR complaint to the relevant Supervisory Authority. A list of EEA Supervisory Authorities is available here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm and the UK here: https://ico.org.uk/global/contact-us/. If you need further assistance regarding your rights, please contact us using the contact information provided below and we will consider your request in accordance with applicable law. In some cases our ability to uphold these rights for you may depend upon our obligations to process personal information for security, safety, fraud prevention reasons, compliance with regulatory or legal requirements, or because processing is necessary to deliver the services you have requested. Where this is the case, we will inform you of specific details in response to your request.

7. Transfer of data

We may transfer your Personal Data to third parties, as set out in this Policy. Such third parties may reside in various jurisdictions around the world. In such circumstances and where required by law, we have put in place contractual measures to ensure that the recipients of your Personal Data provide appropriate safeguards for your data (for example, by training its staff and implementing effective technological and organizational security measures) and are only using it for the purposes of performing their services, or otherwise for those purposes for which we have disclosed your information to them.

8. How we protect your data?

In order to protect your personal data, Testing ID, User Photo, access credentials, and Citizen Hebrew Tests results etc., Citizen has implemented, technical, and physical safeguards to help prevent unauthorized access, use, or disclosure of your Personal Data. While we seek to protect your information to ensure that it is kept confidential, we cannot guarantee the security of any information. You should be aware that there is always some risk involved in transmitting information over the internet and that there is also some risk that others could find a way to thwart our security systems. Such breaches can lead to things such as reputational harm, fraud or identity theft. Therefore, we encourage you to exercise discretion regarding the Personal Data you choose to disclose. If you feel that your privacy was treated not in accordance with our Policy, or if any person attempted to abuse the Services or acted in an inappropriate manner, please contact us directly via our contact details available below.

9. Retention

We will retain your Personal Data for as long as necessary to provide our Services, and as necessary to comply with our legal obligations, resolve disputes, and enforce our policies. Retention periods will be determined to take into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time.

10. Updates to this Policy

We reserve the right to change this Policy at any time. The most current version will always be posted on our Services (as reflected in the “Last Updated” heading). You are advised to check for updates regularly. By continuing to access or use our Services after any revisions become effective, you agree to be bound by the updated Policy.

11. Children under age of digital consent

Children deserve extra privacy protection. Due to this, we treat child users differently to ensure their parents remain in control, and we only collect the bare minimum information to make Citizen work.
Upon creating a Ciitizen account, we collect a user’s age and compare it with the local standard for child online consent in their country. The term “child user” refers to users under this age. User accounts can be created by children, but they must use their parent’s email address rather than their own. As well, we do not require child users to provide their own names.
Our email will inform parents about Citizen’s privacy practices regarding child users, including what personal data we collect, how we use, share, and protect that information. The email also explains how parents can request that Citizen access, change or delete the personal data about their child.

Child users receive the following special treatment:

• We remove mature words like “beer” and “wine” from lessons to make them age-appropriate.
• Advertisements are set to family-friendly content.
• In the Profile page, the child cannot state their name, location, or bio.
• Avatar photos cannot be uploaded.
• Email promotions are disabled.
• Forums for discussion are disabled.
• A child’s profile is made private and hidden from other users.
• It is not possible for other users to follow the child.
• Users cannot follow or search for other users.
• Email invitations cannot be sent.
• The ability to find friends on Facebook is disabled.
• It is not possible to log in with Facebook, Google, or Apple.
• Twitter, Facebook, and Instagram follow buttons are disabled.

Furthermore, all users under the age of 16 receive the following special treatment:

• Non-personalized advertisements are displayed.
• We disable third-party behavioural tracking.
• Analytics from third parties are disabled.

In order to prevent restricted users from amending these features, these settings will be hidden or grayed out. As soon as the user is old enough, we’ll automatically remove the restrictions, reset settings to defaults, and let them configure the settings themselves.
With regards to the Children’s Online Privacy Protection Rule (“COPPA“), Citizen only collects personal information from children under the age of 13 for the sole purpose of performing internal operations of the Service. If we discover that we have unknowingly collected additional personal information from these children we will delete it. If you believe this to be the case, please contact us at hello@citizenCafeTLV.com.

12. Third party websites and links

Please note that you may have cookies placed on your computer by third party websites that refer you to our Service. Although we do not share your personal data with these third party websites unless it is reasonably necessary to offer the Service, they may be able to link certain non-personally identifiable information we transfer to them with personal data they previously collected from you. Please review the privacy policies of each website you visit to better understand their privacy practices. In addition, Citizen would like to inform you that anytime you click on links (including advertising banners), which take you to third party websites, you will be subject to the third parties’ privacy policies.

Our Services contain links to other sites operated by third parties. Citizen does not control such other sites and is not responsible for their content, their privacy policies, or their use of personal data, including any personal or financial information collected by our third party payment processor to process payments for in-app purchases. Citizen inclusion of such links does not imply any endorsement of the content on such sites or of their owners or operators except as disclosed on the Services. Any information submitted by you directly to these third parties is subject to that third party’s privacy policy.

13. Contact Us