Privacy Policy

Privacy Policy for Tourbo Ensemble

Last updated: October 4, 2023

This Privacy Policy describes Our policies and procedures on the collection, use and dis
closure of Your information when You use the Service and tells You about Your privacy
rights and how the law protects You.
We use Your Personal data to provide and improve the Service. By using the Service,
You agree to the collection and use of information in accordance with this Privacy Policy.
Interpretation and Definitions

Interpretation
The words of which the initial letter is capitalized have meanings defined under the
following conditions. The following definitions shall have the same meaning regardless of
whether they appear in singular or in plural.

Definitions
For the purposes of this Privacy Policy:

Account means a unique account created for You to access our Service or parts
of our Service.

Affiliate means an entity that controls, is controlled by or is under common
control with a party, where “control” means ownership of 50% or more of the
shares, equity interest or other securities entitled to vote for election of directors
or other managing authority.

Application refers to Tourbo Ensemble, the software program provided by the
Company.

Company (referred to as either “the Company”, “We”, “Us” or “Our” in this
Agreement) refers to TourboApp LTD, Ahad Ha’Am, Tel Aviv 6525101.
For the purpose of the GDPR, the Company is the Data Controller.

Country refers to: Israel

Data Controller, for the purposes of the GDPR (General Data Protection
Regulation), refers to the Company as the legal person which alone or jointly with
others determines the purposes and means of the processing of Personal Data.

Device means any device that can access the Service such as a computer, a cell
phone or a digital tablet.

Facebook Fan Page is a public profile named Tourbo specifically created by the
Company on the Facebook social network, accessible from https://www.facebook
.com/Tourboapp/

GDPR refers to EU General Data Protection Regulation.

Personal Data is any information that relates to an identified or identifiable
individual.
For the purposes of GDPR, Personal Data means any information relating to You
such as a name, an identification number, location data, online identifier or to one
or more factors specific to the physical, physiological, genetic, mental, economic,
cultural or social identity.

Service refers to the Application.

Service Provider means any natural or legal person who processes the data on
behalf of the Company. It refers to third-party companies or individuals employed
by the Company to facilitate the Service, to provide the Service on behalf of the
Company, to perform services related to the Service or to assist the Company in
analysing how the Service is used. For the purpose of the GDPR, Service
Providers are considered Data Processors.

Usage Data refers to data collected automatically, either generated by the use of
the Service or from the Service infrastructure itself (for example, the duration of a
page visit).

You means the individual accessing or using the Service, or the company, or
other legal entity on behalf of which such individual is accessing or using the
Service
, as applicable.
Under GDPR, You can be referred to as the Data Subject or as the User as you
are the individual using the Service.
Collecting and Using Your
Personal Data
Types of Data Collected
Personal Data
While using Our Service, We may ask You to provide Us with certain personally
identifiable information that can be used to contact or identify You. Personally
identifiable information may include, but is not limited to:

Email address

First name and last name

Phone number

Address, State, Province, ZIP/Postal code, City

Usage Data
Privacy Policy – Device ID Collection
Tourboapp LTD is committed to protecting the privacy and security of our users. This
privacy policy explains how we collect, use, and safeguard the device ID information
obtained through our Android application.
Collection of Device ID Information
We may collect and store the unique identifier associated with your device, commonly
known as the Device ID. This identifier helps us recognize your device and provide you
with a personalized experience within our app. We may collect the Device ID information
automatically or with your explicit consent, depending on the features and functionalities
of the app.
Purpose of Device ID Collection
The Device ID information is collected for the following purposes:

To facilitate the proper functioning of our app, including personalized features and
services.

To enhance your user experience and provide relevant content and
recommendations.

To improve our app’s performance, troubleshoot technical issues, and conduct
analytical research to optimize our services.
Storage and Security
We take appropriate measures to ensure the security and confidentiality of the collected
Device ID information. This includes using industry-standard security protocols and
encryption techniques to prevent unauthorized access, disclosure, alteration, or
destruction of the data.

Third-Party Services and Disclosure
We may share the collected Device ID information with trusted third-party service
providers to assist us in delivering our app’s features and functionalities. However, we do
not sell, rent, or lease this information to any third parties for their marketing purposes.

User Consent and Control
By using our Android app, you acknowledge and consent to the collection and use of your
Device ID information as outlined in this privacy policy. You have the right to control your
data and can request the deletion or modification of your Device ID information by
contacting us through the provided channels.

Children’s Privacy
Our app does not knowingly collect any personally identifiable information from children
under the age of 13. If you believe that we may have inadvertently collected any such
information, please contact us immediately, and we will take appropriate steps to remove
it.

Changes to this Privacy Policy
We reserve the right to modify or update this privacy policy at any time. Any changes will
be effective immediately upon posting the revised policy in our app. We encourage you to
review this policy periodically to stay informed about how we collect, use, and protect your
information.

Usage Data
Usage Data is collected automatically when using the Service.
Usage Data may include information such as Your Device’s Internet Protocol address (e
.g. IP address), browser type, browser version, the pages of our Service that You visit, t
he time and date of Your visit, the time spent on those pages, unique device identifiers
and other diagnostic data.
When You access the Service by or through a mobile device, We may collect certain
information automatically, including, but not limited to, the type of mobile device You use,
Your mobile device unique ID, the IP address of Your mobile device, Your mobile operat
ing system, the type of mobile Internet browser You use, unique device identifiers and
other diagnostic data.
We may also collect information that Your browser sends whenever You visit our
Service or when You access the Service by or through a mobile device.
Information Collected while Using the Application
While using Our Application, in order to provide features of Our Application, We may
collect, with Your prior permission:

Information regarding your location
We use this information to provide features of Our Service, to improve and customize
Our Service. The information may be uploaded to the Company’s servers and/or a
Service Provider’s server or it may be simply stored on Your device.
You can enable or disable access to this information at any time, through Your Device
settings.

Use of Your Personal Data
The Company may use Personal Data for the following purposes:

To provide and maintain our Service, including to monitor the usage of our Ser
vice.

To manage Your Account: to manage Your registration as a user of the Service
. The Personal Data You provide can give You access to different functionalities
of the Service that are available to You as a registered user.

For the performance of a contract: the development, compliance and
undertaking of the purchase contract for the products, items or services You
have purchased or of any other contract with Us through the Service.

To contact You: To contact You by email, telephone calls, SMS, or other
equivalent forms of electronic communication, such as a mobile application’s
push notifications regarding updates or informative communications related to the
functionalities, products or contracted services, including the security updates,
when necessary or reasonable for their implementation.

To provide You with news, special offers and general information about other
goods, services and events which we offer that are similar to those that you have
al ready purchased or enquired about unless You have opted not to receive such
in formation.

To manage Your requests: To attend and manage Your requests to Us.

For business transfers: We may use Your information to evaluate or conduct a
merger, divestiture, restructuring, reorganization, dissolution, or other sale or
transfer of some or all of Our assets, whether as a going concern or as part of
bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us
about our Service users is among the assets transferred.

For other purposes: We may use Your information for other purposes, such as
data analysis, identifying usage trends, determining the effectiveness of our
promotional campaigns and to evaluate and improve our Service, products,
services, marketing and your experience.
We may share Your personal information in the following situations:

With Service Providers: We may share Your personal information with Service
Providers to monitor and analyze the use of our Service, to contact You.

For business transfers: We may share or transfer Your personal information in
connection with, or during negotiations of, any merger, sale of Company assets,
financing, or acquisition of all or a portion of Our business to another company.

With Affiliates: We may share Your information with Our affiliates, in which case
we will require those affiliates to honor this Privacy Policy. Affiliates include Our
parent company and any other subsidiaries, joint venture partners or other
companies that We control or that are under common control with Us.

With business partners: We may share Your information with Our business
partners to offer You certain products, services or promotions.

With other users: when You share personal information or otherwise interact in
the public areas with other users, such information may be viewed by all users an
d may be publicly distributed outside.

With Your consent: We may disclose Your personal information for any other
purpose with Your consent.

Retention of Your Personal Data
The Company will retain Your Personal Data only for as long as is necessary for the
purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the
extent necessary to comply with our legal obligations (for example, if we are required to
retain your data to comply with applicable laws), resolve disputes, and enforce our legal
agreements and policies.
The Company will also retain Usage Data for internal analysis purposes. Usage Data is
generally retained for a shorter period of time, except when this data is used to strength
en the security or to improve the functionality of Our Service, or We are legally obligated
to retain this data for longer time periods.
Transfer of Your Personal Data
Your information, including Personal Data, is processed at the Company’s operating
offices and in any other places where the parties involved in the processing are located.
It means that this information may be transferred to — and maintained on — computers
located outside of Your state, province, country or other governmental jurisdiction where
t he data protection laws may differ than those from Your jurisdiction.
Your consent to this Privacy Policy followed by Your submission of such information rep
resents Your agreement to that transfer.
The Company will take all steps reasonably necessary to ensure that Your data is
treated securely and in accordance with this Privacy Policy and no transfer of Your
Personal Data will take place to an organization or a country unless there are adequate
controls i n place including the security of Your data and other personal information.
Delete Your Personal Data
You have the right to delete or request that We assist in deleting the Personal Data that
We have collected about You.
Our Service may give You the ability to delete certain information about You from within
the Service.
You may update, amend, or delete Your information at any time by signing in to Your Ac
count, if you have one, and visiting the account settings section that allows you to
manage Your personal information. You may also contact Us to request access to,
correct, or delete any personal information that You have provided to Us.
Please note, however, that We may need to retain certain information when we have a l
egal obligation or lawful basis to do so.
Disclosure of Your Personal Data
Business Transactions
If the Company is involved in a merger, acquisition or asset sale, Your Personal Data m
ay be transferred. We will provide notice before Your Personal Data is transferred and
becomes subject to a different Privacy Policy.
Law enforcement
Under certain circumstances, the Company may be required to disclose Your Personal
Data if required to do so by law or in response to valid requests by public authorities (e.
g. a court or a government agency).
Other legal requirements
The Company may disclose Your Personal Data in the good faith belief that such action
is necessary to:

Comply with a legal obligation

Protect and defend the rights or property of the Company

Prevent or investigate possible wrongdoing in connection with the Service

Protect the personal safety of Users of the Service or the public

Protect against legal liability
Security of Your Personal Data
The security of Your Personal Data is important to Us, but remember that no method of
transmission over the Internet, or method of electronic storage is 100% secure. While W
e strive to use commercially acceptable means to protect Your Personal Data, We cann
ot guarantee its absolute security.
GDPR Privacy
Legal Basis for Processing Personal Dat
a under GDPR
We may process Personal Data under the following conditions:

Consent: You have given Your consent for processing Personal Data for one or
more specific purposes.

Performance of a contract: Provision of Personal Data is necessary for the
performance of an agreement with You and/or for any pre-contractual obligations
thereof.

Legal obligations: Processing Personal Data is necessary for compliance with a
legal obligation to which the Company is subject.

Vital interests: Processing Personal Data is necessary in order to protect Your
vital interests or of another natural person.

Public interests: Processing Personal Data is related to a task that is carried out
in the public interest or in the exercise of official authority vested in the Company.

Legitimate interests: Processing Personal Data is necessary for the purposes o
f the legitimate interests pursued by the Company.
In any case, the Company will gladly help to clarify the specific legal basis that applies t
o the processing, and in particular whether the provision of Personal Data is a statutory
or contractual requirement, or a requirement necessary to enter into a contract.
Your Rights under the GDPR
The Company undertakes to respect the confidentiality of Your Personal Data and to
guarantee You can exercise Your rights.
You have the right under this Privacy Policy, and by law if You are within the EU, to:

Request access to Your Personal Data. The right to access, update or
deletem the information We have on You. Whenever made possible, you can
access, update or request deletion of Your Personal Data directly within Your
account setting s section. If you are unable to perform these actions yourself,
please contact Us t o assist You. This also enables You to receive a copy of the
Personal Data We h old about You.

Request correction of the Personal Data that We hold about You. You have
the right to have any incomplete or inaccurate information We hold about You
corrected.

Object to processing of Your Personal Data. This right exists where We are re
lying on a legitimate interest as the legal basis for Our processing and there is
something about Your particular situation, which makes You want to object to our
processing of Your Personal Data on this ground. You also have the right to
object where We are processing Your Personal Data for direct marketing
purposes.

Request erasure of Your Personal Data. You have the right to ask Us to delete
or remove Personal Data when there is no good reason for Us to continue
processing it.

Request the transfer of Your Personal Data. We will provide to You, or to a
third-party You have chosen, Your Personal Data in a structured, commonly
used, machine-readable format. Please note that this right only applies to
automated information which You initially provided consent for Us to use or
where We used the information to perform a contract with You.

Withdraw Your consent. You have the right to withdraw Your consent on using
your Personal Data. If You withdraw Your consent, We may not be able to
provide You with access to certain specific functionalities of the Service.
Exercising of Your GDPR Data
Protection Rights
You may exercise Your rights of access, rectification, cancellation and opposition by
contacting Us. Please note that we may ask You to verify Your identity before
responding to such requests. If You make a request, We will try our best to respond to
You as soon as possible.
You have the right to complain to a Data Protection Authority about Our collection and u
se of Your Personal Data. For more information, if You are in the European Economic A
rea (EEA), please contact Your local data protection authority in the EEA.
Facebook Fan Page
Data Controller for the Facebook Fan
Page
The Company is the Data Controller of Your Personal Data collected while using the
Service. As operator of the Facebook Fan Page https://www.facebook.com/Tourboapp/,
the Company and the operator of the social network Facebook are Joint Controllers.
The Company has entered into agreements with Facebook that define the terms for use
of the Facebook Fan Page, among other things. These terms are mostly based on the
Facebook Terms of Service: https://www.facebook.com/terms.php
Visit the Facebook Privacy Policy https://www.facebook.com/policy.php for more inform
ation about how Facebook manages Personal data or contact Facebook online, or by m
ail: Facebook, Inc. ATTN, Privacy Operations, 1601 Willow Road, Menlo Park, CA 9402
5, United States.
Facebook Insights
We use the Facebook Insights function in connection with the operation of the
Facebook Fan Page and on the basis of the GDPR, in order to obtain anonymized
statistical data about Our users.
For this purpose, Facebook places a Cookie on the device of the user visiting Our Face
book Fan Page. Each Cookie contains a unique identifier code and remains active for a
period of two years, except when it is deleted before the end of this period.
Facebook receives, records and processes the information stored in the Cookie,
especially when the user visits the Facebook services, services that are provided by
other members of the Facebook Fan Page and services by other companies that use
Facebook services.
For more information on the privacy practices of Facebook, please visit Facebook Priva
cy Policy here: https://www.facebook.com/privacy/explanation
Children’s Privacy
Our Service does not address anyone under the age of 13. We do not knowingly collect
personally identifiable information from anyone under the age of 13. If You are a parent
or guardian and You are aware that Your child has provided Us with Personal Data,
please contact Us. If We become aware that We have collected Personal Data from
anyone under the age of 13 without verification of parental consent, We take steps to
remove t hat information from Our servers.
If We need to rely on consent as a legal basis for processing Your information and Your
country requires consent from a parent, We may require Your parent’s consent before
We collect and use that information.
Links to Other Websites
Our Service may contain links to other websites that are not operated by Us. If You click
on a third party link, You will be directed to that third party’s site. We strongly advise
You to review the Privacy Policy of every site You visit.
We have no control over and assume no responsibility for the content, privacy policies o
r practices of any third party sites or services.
Changes to this Privacy Policy
We may update Our Privacy Policy from time to time. We will notify You of any changes
by posting the new Privacy Policy on this page.
We will let You know via email and/or a prominent notice on Our Service, prior to the
change becoming effective and update the “Last updated” date at the top of this Privacy
Policy.
You are advised to review this Privacy Policy periodically for any changes. Changes to
this Privacy Policy are effective when they are posted on this page.

Contact Us
If you have any questions about this Privacy Policy, you can contact us by email: office@tourbo.io