Privacy Policy

Privacy Policy - Summary

We, at Natural Intelligence, are committed to protecting the privacy rights of our users. Therefore, we designed and maintain on an ongoing basis, a privacy compliance framework under which our users will be able to get information and exercise their rights with respect to their information and privacy. 

Our privacy policy is designed to inform you about the information we collect, how we use it, and your options about certain uses of information. Key elements of our full privacy policy are summarized below for your convenience. If you are a California resident, please see our California privacy notice as well. 

Our privacy policy applies to website visitors. This summary is designed to provide you with the highlights in an easy to understand language. However, the full version of our privacy policy is the legally binding one.

Read more.

Information We Collect and How We Use It: When you visit our websites, we collect certain information about your visit, interaction with content, the site from which you arrived and to which you are heading, and some additional technical information about the device and system from which you are consuming the services. upon your choice to use a “click to call” service we may offer, the phone number from which you made the call may be collected for a limited time of up to 3 months.

The information is used to operate our websites, provide you with the services, improve them over time, monitor analytics and statistics and enable us to sync and resolve payment issued with our business partners (including clients, vendors and affiliates).

We will not share your information unless we are required to by law, or as required to provide you with our websites and services.

We truly encourage you to read, understand and revisit our full privacy policy from time to time.

Privacy Policy

Last Updated: February 25, 2020

This privacy policy ("Privacy Policy") is designed to describe Natural Intelligence’s ("NI”, "we", "our" or "us") data collection practices in connection with this site (together with its subdomains, features, and services available thereon, the "Site"), and in connection with your use or engagement with any feature, content, offer, element or service we make available to you via the Site (the “Services”). The section and sub-section headings used below are for convenience of reading only (and are not to be used for interpretive purposes), and we hope they ease navigating this Privacy Policy. 

We reserve the right, in our sole and absolute discretion, to change this Privacy Policy at any time. In which case, we will post the modified Privacy Policy on the Site, and the “Last Updated” statement at the bottom shall reflect the effective date of the modified version. Any access or use you make of the Site following such date constitutes your consent and acceptance of the modified Privacy Policy. If we make significant changes, we will make sure to provide more prominent notice to you, such as posting a notification on the Site, seven (7) days before the changes become effective. In which case, the changes will be effective seven (7) days after such notification was published.

This Privacy Policy includes:

1.    Terms of Use

2.    Our Legal Bases of Processing

3.    Information We Process

4.    Consent, Choice, and Modifications

5.    Purposes for the collection of information

6.    Sharing Your Information with Third Parties

7.    Links to and Interaction with Third Party Properties

8.    Choices and Opt-Out

9.    Your Rights

10.    Information Security

11.    Children’s Privacy

12.    Non-US Users

13.    Commitment

14.    Contact Us

1.    Terms of Use. This Privacy Policy forms an integral part of the Site's Terms of Use (the "Terms"). Any capitalized term in this Privacy Policy that we don't define, will have the meaning given to it in the Terms.

2.    Our Legal Bases of Processing. We process and use Personal Information in accordance with data protection laws. Our legal ground for processing your Personal Information will typically be one or more of the following: 

2.1.    Performance of a Contract. By accessing or using the Site, you ask us to provide the Services to you in accordance with our Terms of Use. In order to do that, we need to process some of your Personal Information (such as your IP address).

2.2.    Legitimate Interests. We may use some of your Personal Information where we have legitimate business grounds to do so. We use this Personal Information to operate, improve and promote the Services (for example, when we customize your experience of the Services or for analytics purposes) and to protect our business (for example, to prevent fraud or ensuring the Site security).

2.3.    Legal Obligations. In some cases, our use of your personal information will be necessary to comply with regulatory obligations or legal requirements (for example, addressing complaints from users or authorities);

2.4.    Consent. In certain cases. We will ask for your consent to process and use your Personal Information in order to provide additional services (for example, when you subscribe to our newsletters, create your user profile, provide us Personal Information to get tailored offers or add a review on a service or product). When we rely on consent as our legal basis of processing You may ask to withdraw your consent by sending us a request to privacy@top10.com. Once we have verified your request, we will contact you.

3.    Information We Process. When you visit the Site or use the Services we may collect certain information about your visit and usage of the Site and the Services, in one or more of the following ways:

3.1.    Information You Provide to Us. Some of the Services will require you to provide or submit certain Personal Information in order to be able to use them. Some of the features and/or services that require you to provide Personal Information are subject to your specific and active consent (e.g. creating user profile, adding your review to one of the services or products that appear our Sites, newsletters which may become available in certain Sites from time to time, promotional material and forms) and choice, and some will be collected upon your consent to this Privacy Policy, as described below.

For the purposes of this Privacy Policy, "Personal Information" means information that may be used, either alone or in combination with other information, to personally identify an individual, such as a first and last name, an email address, phone number, a home or other physical address, and other contact information. In some jurisdictions and given the specific use we make with the information, IP address that your Internet service provider allocates for your device may also be considered as Personal Information. In which case, we will be treating the information as personal in all handling and safeguarding aspects, however, we do not make any use of such information for user identification purposes.

3.1.1.    Third-Party Forms and Services: The Site lists, rates and compares various 3rd party businesses, brands and commercial entities (collectively, "Partners") and their respective products and/or services (collectively, "Products"). We may, from time to time, provide you with offers, services and Products of Partners via an online form to be filled by you, upon your intent choice and consent, and such information will be used to facilitate your connection and/or engagement with the relevant Partner (“Lead”). Additionally, if you want to receive more information about a Partner or a Product, or if you otherwise want to pursue a transaction with a Partner, and you click the relevant Partner icon or tab, you may be directed to a landing page or an online form that is owned and operated by the Partner (the "Landing Page"); similarly, you may also be directed to the Landing Page through other websites and online searches. In either case, however, you may be prompted to submit certain information on the Landing Page, including Personal Information such as your name, email address, and phone number (such information collectively, "Landing Page Info"). The Landing Page Info that you submit is collected directly by the Partner who provided it and will include its own privacy policy and data collection practices information. We advise you to refer to such privacy policy to better understand the purpose of the collection and use of the Personal Information you submit. 

3.1.2.    Contact Us. If you send us a ‘Contact Us’ (or similar) request, whether by submitting an online form that we make available, by sending an email to an email address that we display, by using a feedback or reporting feature that is available on the Site, or by other means, you may be required to provide us with certain Personal Information, such as your name and email address. Such information, including the content of your approach, will be used for the purposes of processing and addressing your request and for our legitimate business purposes, as further described in sections 4 and 5 of this Privacy Policy.

3.1.3.    Blogs, Newsletters, Surveys and Promotions. The Site may contain a blog forum, reviews, and articles displaying information about our services, Partners, Products, and the relevant market vertical. The Site may also offer you the opportunity to subscribe to newsletters and participate in surveys and other promotional activities (some of which may be administered by us, and some of which may be administered by third party services with which we engage). In each of the foregoing cases, your interaction (such as responding on the blog forum, subscribing to a newsletter, or participating in a survey) may require you to provide certain Personal Information such as your name and email address. In which case, your submission of information will also be provided directly to such third party and will be used according to this privacy policy as well as such third party’s own privacy policy, and for the purpose for which you provided the information. 

3.1.4.    User Profile and User Reviews. We may offer you to give a review to our Partners or to create a user profile in some of our Sites and provide us with additional information about you that will assist us in providing a customized experience for you.  

3.2.    Information We Collect from You. We collect information about your use of the Services and your interaction with the Site or the Services, as follows, and in the following ways:

3.2.1.    Device Information: For delivering and compatibility purposes, so as for language, geographic location and time zone, we collect device information such as: device type and version, operating system type, language and version, and information that can be extracted out of a user agent, such as browser type and version, screen resolution. 

3.2.2.    Interactions and Usage: In order to provide the Services, operate the Site, and keep improving it, so as to be able to sync with our Partners and affiliates, we collect information about your interaction and use of the Services, such as: URLs from which you were directed to the Site and to which you are referred from the Site, internal URL’s of the Site in which you visited and your actions with respect to the Services (such as view or click), date/time stamp of Site use, timing for clicks and page-views.

3.2.3.    Log Files: We collect information through server log files, but also by deploying tracking technologies within the Site, such as pixel tags. We do this to analyze trends, track user’s engagement and interaction with the Site and respective Services. The type of information collected may include internet protocol (IP) addresses that your Internet Service Provider allocated to your device. We collect IP for a limited time and for specific purposes. One, is to better understand your geographic location (country, region and language) and therefore be able to provide the Services in your own language and relevant to your place of origin. Second, we use automated tools to analyze IP addresses and flag those that are fraudulent. 

3.2.4.    Cookies and Similar Technologies. The Site may use "cookies" and other anonymous web tracking technologies (such as "web beacons" and "pixel tags") implemented by us or by third-party service providers. A cookie is a small file containing a string of characters that is sent to your computer when you visit a website. When you visit the website again, the cookie allows that website to recognize your browser. Cookies may store your online preferences and other information about the interaction you make in the Site. You can reset your browser to refuse all cookies or to indicate when a cookie is being sent to your browser. However, some features or services, included in the Site, may not function properly without cookies, and some features may become unavailable for you in such a case. A pixel tag is a type of technology placed on a website for the purpose of tracking activity on websites, or when emails are opened or accessed (if applicable), and is often used in combination with cookies. 

Please refer to our Cookie Policy for more information about the type of cookies used and the manner in which we use cookies/tracking technologies on our Site. 

3.3.    Information we receive from Third Parties. Like many Internet-based services, the Site and the Services are operated and provided in collaboration, sync, and interaction with third parties, including Partners, affiliates and other third parties. In order to enable and facilitate such sync, we may receive information from third parties, such as: an internal user identifier that our system generates to each user (not a unique identifier), and the summary of action taken by you (click, purchase, view, form submission or a phone call). In some Sites, you will be able – upon your choice – to consume the Service on a click-by-call basis. In which case, a third-party vendor/s facilitate the call transmission, tracking, and feedback for success. In such cases, the phone number from which you called may be provided to us (with no other information about you attached), for a limited time and for purposes of resolving referrals and successful calls with our Partners. Except for this purpose, we do not make any other use of such information, unless you will give us your explicit consent.

4.    Consent, Choice, and Modifications. You are not legally obligated to provide us with Personal Information (and you acknowledge that providing us with Personal Information is done freely). Nor are you required to use the Site in the first place. By using the Site and engage or interact with the Services, you consent to this Privacy Policy and to our information practices described herein. If you do not agree to this Privacy Policy, please do not access or otherwise use the Site or the Services. 

Some of the Services will require you to submit specific Personal Information. In such a case you can choose whether you want to use such Services or not. Be aware that even if you provided us with your Personal Information, you have the full right to withdraw such consent at any time (please refer to section ‎8 below to get further details about opting out and withdrawing consent). 

5.    The Way We Use Personal Information. In addition to the uses of information we collect (including Personal Information, jointly “your Information”) described elsewhere in this Privacy Policy, we also use Personal Information in the following ways:

To generally provide you with the Site, Services and constantly improve them. We will use your Information to: (a) administer and make available the Site and Services to you; (b) further develop and generally improve the Site and the Services; (c) counting and tracking purposes of referrals and ads (; (d) validation of users as human and anti-fraud monitoring (e) respond to your inquiries and other communications with you; (f) identify or authenticate your access and use of the Site.

6.    Sharing Your Information with Third Parties. 

We do not share Personal Information about you with third parties, except for the following circumstances:

6.1.    Data Storage and Security Platforms (“Data Platforms); We use third party cloud and storage services to store and retain your Information. It means that we send or otherwise share your Information to/with third party entities that are located anywhere in the world, including in the U.S, for the purpose of storing such information on our behalf, or for other processing needs. Such entities include Amazon Web Services (which privacy policy available at: https://aws.amazon.com/privacy/), and Xplenty (which privacy policy available at: https://www.xplenty.com/privacy/), both are Privacy Shield certified (which details can be further found here). These Data Platforms may be located anywhere in the world. We use Data Platforms that maintain strict privacy protection and data security policies, and strict compliance with applicable data protection laws. However, their practices and activities are fully governed by their own privacy policies. 

6.2.    Social Media Platforms. We may share not identified information with social media platforms (such as Facebook, LinkedIn etc.) for marketing and operation purposes. Such social media platforms may collect your Personal Information independently and may combine the not identified information provided by us, with your Personal Information which they collect to which you gave your separate and independent consent. Any such action and any personal Information that may derive from it is subject to the social media's own privacy policy and is not, governed, controlled or known by us. 

6.3.    Other Third Parties. We may send or otherwise share your Information to/with various third parties that help us with our business operations (for example, customer service operators and email or phone administration providers), that help us understand how our users use the Site and Services, operate them and to improve them. These third parties may have their own privacy policies that they adhere to, and we require them to make it available whenever their services are provided. We recommend you revisit such privacy policies when those third parties render their services directly to you. Also, these third parties may be based (and their servers may be located) anywhere in the world. 

6.4.    Enforcement. We may share your Personal Information with any third party if we believe that disclosure of such information is helpful or reasonably necessary to: (a) comply with any applicable law, regulation, legal process, or governmental request; (b) enforce our Terms of Use, including investigations of potential violations thereof; (c) detect, prevent, or otherwise address fraud or security issues; and/or (d) protect against harm to the rights, property or safety of NI, our affiliated entities, our users, yourself, and/or the public.

6.5.    Partners and Products. The Services may include submission of online forms, in case you will choose and be interested to receive additional information about one service or another (“Online Form”). In which case, we may send your Online Form information or otherwise share it to/with the Partner about whom (or about whose Product) you wanted to receive more information or with which you have expressed interest in pursuing a transaction (the "Corresponding Partner" and "Corresponding Product", respectively), for such Corresponding Partner to contact you back with the information you have requested. In either case, you acknowledge that: (a) the Partners may contact you using the Online Form information which you submitted; (b) we do not control the way in which Partner may contact you, or the subject matter of such contact; and (c) each Partner is required to provide its own privacy policy, and so it would not necessarily adhere to this Privacy Policy; and (d) Partners may be based (and their servers may be located) anywhere in the world. 

6.6.    Merger, Sale or Bankruptcy. In the event that NI or one of our affiliated entities is acquired by or merged with, a third party entity, or otherwise sells all or part of our/its assets, we may (and hereby reserve the right to) transfer or assign the Personal Information and other information we have collected or received. In such a case, we will require the acquiring entity to post its data practices and provide you with any of your rights as per the jurisdiction of your residency.

We may also share some non-Personal Information with the following type of third parties and under the following circumstances:

6.7.    Third parties we engage or host or provide us with services and features we can offer to you collect data from the Site and visitors’ engagement with the content and features on our behalf, or for the provisioning of their services. This happens in cases where we use or deploy third party technology, service or feature, or where we otherwise give these third parties access to our Site or technology for specific purposes, as described in the Privacy Policy or in the Site. We may use analytics tools, including Google Analytics and Tableau. These tools help us understand users’ behavior on our Site and Services, including by tracking page content, and click/touch, movements, scrolls, and keystroke activities. The privacy practices of these tools are subject to their own policies and they may use their own cookies to provide their services. For further information about cookies, please see our Cookie Policy. Click here for further information about Google cookies. Click here to opt-out of Google Analytics.

7.    Links to and Interaction with Third-Party Properties. The Site may link to third party websites (such as those of Partners), content, and other online properties (collectively, "Third Party Properties"). Data associated with your clicking through to such Third Party Properties, as well as any Personal Information you provide on such Third-Party Properties, is provided to the third party (although NI and its affiliated entities may have arrangements with such third parties pursuant to which such data and Personal Information is sent or shared back to/with us). We are not responsible for the privacy practices of such third parties, or for such Third-Party Properties, Products, and respective data collection practices. We encourage you to read the terms and conditions and privacy policy of each Third-Party Property that you choose to use or interact with

8.    Choices and Opt-Out. It is your choice to provide us with your information for the uses described in this Privacy Policy. You can decide at any time to exercise your rights with respect to your Personal Information and the jurisdiction of your residency. For example (where applicable and relevant):

8.1.    Cookies and Tracking Technologies. you may set your browser to refuse and/or block any cookies from the Site or third party services (for more details please refer to Section ‎2.1.1 hereof). 

8.2.    When applicable, review and update or request to remove your Personal Information from our servers (for more details please refer to Section ‎2).

9.    Your Rights

9.1.    EU Data Subject Rights. Any Personal Information we collect according to this Privacy Policy is handled and treated in compliance with the GDPR. 

As an EU based user, you may:

•    Access the Personal Information that we keep about you. We will 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 Personal Information is not accurate, complete or updated, then please provide us the necessary information to correct it.

•    Contact us if you want to withdraw your consent to the processing of your Personal Information. Exercising this right will not affect the lawfulness of processing based on consent before its withdrawal.

•    Request to delete or restrict access to your Personal Information. 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 Information, in accordance with this Privacy Policy, will act accordingly.

•    Object to the processing of your Personal Information for direct marketing purposes, in case your Personal Information used for such purpose.

•    Have a right to lodge a complaint with a data protection supervisory authority.

9.2.    Canada. If you are a residence of Canada, you are permitted to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes, where applicable. To make such a request, please send an email to privacy@top10.com. 

9.3.    California. If you are a California resident, this section applies to you and supplements the main privacy policy. The California Consumer Privacy Act (CCPA) provides specific rights to California residents in relation to their personal information. As a California resident you may:

•    Request to Know/Access. You have the right to know what information we have collected, used, disclosed, or in the preceding twelve (12) months. Please read Section 3.1 (Information you provide to us), Section 3.2 (Information we collect) and Section 3.3 (Information we receive from third parties) to exercise this right. We will also disclose to you the specific pieces of personal information that we collected about you if we receive your request for such information and verify your identity. 

•    Request to Deletion. You have the right to request that we delete from our databases any of your personal information that we collect and retain, subject to certain exceptions (such as detecting security incidents, debugging, comply with legal obligations, etc.). We will delete your personal information from our records, once we verify your identity and unless an exception applies.

•    Request to Opt-Out from Sale of Personal Information. We do not currently sell personal information. If we will engage in sales of personal information in the future your right to opt-out would apply subject to your request and once we verify your identity.

•    No Discrimination. We will not discriminate against you for exercising your above rights, by: (A) denying you goods or services; (B) charging you different rates for goods or services; (C) providing you with a different level or quality of goods or services; or (D) suggesting that you will receive a different price, rate, level, or quality of goods or services. We may have a different rate or provide a different level or quality of service if the difference is reasonably related to the value provided to you by your personal information we collect.

•    Handling Privacy Requests. We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If the exercise of your right requires more time (up to 45 additional days), we will inform you of the reason and extension period in writing. We may deny your request if we couldn’t verify your request or if we must retain your personal information for certain activities (such as detecting security incidents, debugging, comply with legal obligations, etc.).  

•    Our California Do Not Track Notice. Some web browsers offer a “Do Not Track” (“DNT”) signal. A DNT signal is an HTTP header field indicating your preference for tracking your activities on the Service or through cross-site user tracking. We do not currently respond to DNT signals. We may allow third parties, such as companies that provide us with analytics tools, to collect Personal Information about an individual consumer’s online activities over time and across different web sites and services when a user uses the Site. 

10.    Information Security. We and respective third-party services/affiliate entities implement data security systems and procedures to secure the information transmitted, processed and stored on the Site, our computer servers, and systems. For example, the Site is encrypted by using SSL and so as any other information at transport, we periodically review our information and data collection practices to ensure constant monitoring, we use third-party processing and serving services that implement various information security standards and certifications (at rest and transmission), and we monitor and filter access to data when it comes to personnel in our organization. Such systems and procedures reduce the risk of security breaches, but they do not provide absolute security, as there is no such thing when it comes to the world-wide network. Therefore, we cannot guarantee that the Site and our servers are immune to unauthorized access to the information stored therein and to other information security risks. 

11.    Children’s Privacy. The Site or the Services are not designed to attract children under the age of 16. Accordingly, we do not intend to collect Personal Information from anyone we know to be under 16. If we learn that we have collected Personal Information from a child under 16, we will use commercially reasonable efforts to delete that information as quickly as possible. If you believe that we might have any such information, please contact us at: privacy@top10.com.

12.    Non-US Users. We may transfer your Information (including Personal Information) outside the country in which it is collected or in which you reside (e.g., to the United States), including to a country that may not offer the same level of protection for Personal Information as the country in which you reside. However, in which case we make sure to place all contractual safeguards (such as verification of Privacy Shield Certification) to ensure your Information is processed in a way that offers an adequate level of protection when it is shared between or among our third-party vendors. 

By providing Personal Information and using the Services, you expressly consent to the use of such information in accordance with this Privacy Policy and to the transfer of your Information to another country (including e.g., the United States).

 

13.    Commitment. Protecting your privacy online is an evolving practice, and we use our best efforts to evolve our Site in a manner that meets these requirements and best practices as per all jurisdictions in which the Site is available. 

14.    Contact Us. 

14.1.    General Data Protection Regulation (GDPR) - European Representative. Pursuant to Article 27 of the General Data Protection Regulation (GDPR), Natural Intelligence Ltd. has appointed European Data Protection Office (EDPO) as its GDPR representative in the EU. You can contact EDPO regarding matters pertaining to the GDPR by:

•    Sending an email to privacy@edpo.brussels

•    Using EDPO’s online request form at https://www.edpo.brussels/contact

•    Writing to EDPO at Avenue Huart Hamoir 71, 1030 Brussels, Belgium

14.2.    We try to make this Privacy Policy simple and easy to understand. However, if you have any question you may contact us at: Natural Intelligence Ltd., ToHa Building, 6 Totseret HaArets st., Tel Aviv 6744129. Our privacy email box privacy@top10.com is for data protection inquiries in accordance with your legal rights listed above. Any other inquiries sent to this email box will be ignored