Privacy policy

‍Last Updated: September 24, 2020

In order to ensure transparency and give you more control over your personal data, this privacy policy (“Privacy Policy”) governs how we, Tolstoy (together, “we”, “our” or “us”) use, collect and store personal data we collect or receive from or about you (“you”) such as in the following use cases:

  1. When you browse or visit our website, available at: https://www.gotolstoy.com/  ("Website") or Platform (defined below);
  2. When you are our Customer and you have signed up to and are using our platform ("Platform");
  3. When you are a user and you are viewing, accessing, interacting or otherwise using the content created via our Platform;
  4. When you contact us (e.g. customer support, need help, submit a request);
  5. When you attend a marketing event, provide us with your business cards and/or provide us with your personal data for marketing purposes;
  6. When we use the personal data of our service providers (e.g. contact details); and 
  7. When you interact with us on our social media profiles (e.g., Facebook, Instagram, Twitter, LinkedIn). 

We greatly respect your privacy, which is why we make every effort to provide a platform that would live up to the highest of user privacy standards. Please read this Privacy Policy carefully, so you can fully understand our practices in relation to personal data. "Personal Data" or "Personal Information" means any information that can be used, alone or together with other data, to uniquely identify any living human being.

Important note: Nothing in this Privacy Policy is intended to limit in any way your statutory right, including your rights to a remedy or means of enforcement. 

Table of contents: 

‎1.  What Information We Collect, Why We Collect It, And How It Is Used

‎2.  How We Protect And Retain Your Information

‎3.  How We Share Your Personal Data

‎4. Storage Of Personal Data

‎5.  Your Privacy Rights.

‎6.  Use By Children 

‎7.  Interaction With Third Party Products

8.  Log Files

‎9.  Analytic Tools

10.  Your Choices

‎11.  How to contact us

This Privacy Policy can be updated from time to time and, therefore, we ask you to check back periodically for the latest version of this Privacy Policy.  If we implement significant changes to the use of your Personal Data in a manner different from that stated at the time of collection, we will notify you by posting a notice on our Website and/or Platform or by other means.

  1. WHAT INFORMATION WE COLLECT, WHY WE COLLECT IT, AND HOW IT IS USED


When you browse, or visit, our Website or Platform, we collect data about you through Cookies, analytic tools and log files.


When you are our Customer and you have signed up to and are using our Platform, you will provide us with your sign up information which may include email addresses, names, phone numbers, payment information and/or IP addresses. While using our Platform you may provide us with other information such as videos, pictures and/or any other content that you choose to upload to our Platform. We collect this information in order to allow you to use and access our Platform, create content using our Platform and to otherwise use the services provided by the Platform. We may store some of this information on third party servers such as Amazon Web Services and may share this information with third parties such as Google Analytics, Mixpanel and/or Segment.

When you are a user and you are viewing, accessing, interacting or otherwise using the content created via our Platform, we may collect  information from you which may include email addresses, names, phone numbers, comments, IP addresses, the time you spent interacting with the content created by our Platform and/or any other information you choose to share with us. We collect this information in order to allow you to interact, view, access and/or otherwise use the content created by our Platform. We may store some of this information on third party servers such as Amazon Web Services and may share this information with third parties such as Google Analytics, Mixpanel, Segment and/or with our customers who may engage with you using the content created on our Platform.

When you contact us (e.g. customer support, need help, submit a request), you will provide us with the following information: name, email address, country, and any messages or other information you wish to share with us. We use this information to answer your questions and to provide support (e.g. to solve problems, bugs or issues). We may also use your name and email details that you provide us with in order to send you marketing communications. We may store some of this information on third party servers such as Amazon Web Services and may share this information with third parties such as Google Analytics, Mixpanel and/or Segment.

When you attend a marketing event, provide us with your business cards and/or provide us with your personal data for marketing purposes, we collect personal data that you provide us with, such data contains the following types of Personal Data: name, email address, phone number, company name, job title, country, and any other information you may wish to share with us. We use this information to establish a business connection and to send you marketing communications. We may store some of this information on third party servers such as Amazon Web Services and may share this information with third parties such as Google Analytics, Mixpanel and/or Segment.

When we use the Personal Data of our service providers, we collect the following Personal Data from our service providers: name, email address, phone number, company name, job title, country, and any other data our service providers may choose to share with us. We collect this information in order to communicate with and perform the applicable agreement with our service providers. We may store some of this information on third party servers such as Amazon Web Services and may share this information with third parties such as Google Analytics, Mixpanel and/or Segment.

When you interact with us on our social media profiles (e.g., Facebook, Instagram, Twitter, LinkedIn), we collect the following Personal Data: name, email address, phone number, company name, job title, country, and any other data you may choose to share with us. We collect this information in order to communicate with you, respond to your questions and/or requests and/or to otherwise engage with you. We may store some of this information on third party servers such as Amazon Web Services and may share this information with third parties such as Google Analytics, Mixpanel and/or Segment.

Finally, please note that some of the abovementioned Personal Data will be used for detecting, taking steps to prevent, and prosecution of fraud or other illegal activity, to identify and repair errors, to conduct audits, and for security purposes. Personal Data may also be used to comply with applicable laws, with investigations performed by the relevant authorities, law enforcement purposes, and/or to exercise or defend legal claims. In certain cases, we may or will anonymize or de-identify your Personal Data. "Anonymous Information" means information which does not enable identification of an individual user, such as aggregated information about the use of our services. We may use Anonymous Information and/or disclose it to third parties without restrictions (for example, in order to improve our services and enhance your experience with them). 

  1. HOW WE PROTECT AND RETAIN YOUR INFORMATION 
  1. Security. We have implemented appropriate technical, organizational and security measures designed to protect your Personal Data. However, please note that we cannot guarantee that the information will not be compromised as a result of unauthorized penetration to our servers. As the security of information depends in part on the security of the computer, device or network you use to communicate with us and the security you use to protect your user IDs and passwords, please make sure to take appropriate measures to protect this information.
  2. Retention of your Personal Data. In addition to the retention periods mentioned above, in some circumstances we may store your Personal Data for longer periods of time, for example (i) where we are required to do so in accordance with legal, regulatory, tax or accounting requirements, or (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, or (iii) if we reasonably believe there is a prospect of litigation relating to your Personal Data or dealings. 


  1.  HOW WE SHARE YOUR PERSONAL DATA 

We share your Personal Data as follows:

  1. With our hosting providers. 
  2. With our customers, service providers and business partners. 
  3. With our staff and other entities within our group. 

We may also share your Personal Data as follows:

  1. With our customers or business partners in order offer products or services. We may also share Personal Data with our affiliated companies. 
  2. To the extent necessary, with regulators, courts or competent authorities, to comply with applicable laws, regulations and rules (including, without limitation, federal, state or local laws), and requests of law enforcement, regulatory and other governmental agencies or if required to do so by court order;
  3. If, in the future, we sell or transfer, or we consider selling or transferring, some or all of our business, shares or assets to a third party, we will disclose your Personal Data to such third party (whether actual or potential) in connection with the foregoing events;
  4. In the event that we are acquired by, or merged with, a third party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer, disclose or assign your Personal Data in connection with the foregoing events; and/or 
  5. Where you have provided your consent to us sharing or transferring your Personal Data (e.g., where you provide us with marketing consents or opt-in to optional additional services or functionality).


  1. STORAGE OF PERSONAL DATA 
  1. Storage and access: We may store your information on AWS servers in the US and may have access to your information from our offices in Israel.

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  1. YOUR PRIVACY RIGHTS. 

Rights:  You may have certain rights under applicable privacy laws, such as accessing, correcting and deleting Personal Data, objecting to processing of Personal Data, withdrawing of consent to processing Personal Data. To the extent such privacy laws apply to you, we will respect your rights and comply with such laws. 

You can exercise your rights by contacting us at privacy@gotolstoy.com. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly in accordance with applicable law or inform you if we require further information in order to fulfil your request. When processing your request, we may ask you for additional information to confirm or verify your identity and for security purposes, before processing and/or honoring your request. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive. In the event that your request would adversely affect the rights and freedoms of others (for example, would impact the duty of confidentiality we owe to others) or if we are legally entitled to deal with your request in a different way than initial requested, we will address your request to the maximum extent possible, all in accordance with applicable law. 

  1. USE BY CHILDREN 

We do not offer our products or services for use by children and, therefore, we do not knowingly collect Personal Data from, and/or about children under the age of eighteen (18). If you are under the age of eighteen, do not provide any Personal Data to us without involvement of a parent or a guardian. In the event that we become aware that you provide Personal Data in violation of applicable privacy laws, we reserve the right to delete it. If you believe that we might have any such information, please contact us at: privacy@gotolstoy.com.

  1. INTERACTION WITH THIRD PARTY PRODUCTS 

We enable you to interact with third party websites, mobile software applications and products or services that are not owned or controlled by us (each a "Third Party Service"). We are not responsible for the privacy practices or the content of such Third Party Services. Please be aware that Third Party Services can collect Personal Data from you. Accordingly, we encourage you to read the terms and conditions and privacy policies of each Third Party Service.

  1. LOG FILES 

We use log files. The information inside the log files includes internet protocol (IP) addresses, type of browser, Internet Service Provider (ISP), date/time stamp, referring/exit pages, clicked pages and any other information your browser may send to us. We use such information to analyze trends, administer the Website and/or Platform, track users’ movement around the Website and/or Platform, and gather demographic information.

  1. TOOLS 
  1. Google Analytics. The Website and/or Platform uses a tool called "Google Analytics" to collect information about use of the Website and/or Platform. Google Analytics collects information such as how often users visit this Website and/or Platform, what pages they visit when they do so, and what other websites they used prior to coming to this Website and/or Platform. We use the information we get from Google Analytics to maintain and improve the Website, Platform and our products. We do not combine the information collected through the use of Google Analytics with Personal Data we collect. Google’s ability to use and share information collected by Google Analytics about your visits to the Website and/or Platform is restricted by the Google Analytics Terms of Service, available at https://marketingplatform.google.com/about/analytics/terms/us/, and the Google Privacy Policy, available at http://www.google.com/policies/privacy/. You may learn more about how Google collects and processes data specifically in connection with Google Analytics at http://www.google.com/policies/privacy/partners/. You may prevent your data from being used by Google Analytics by downloading and installing the Google Analytics Opt-out Browser Add-on, available at https://tools.google.com/dlpage/gaoptout/. 
  2. Mixpanel. We collect Personal Information such as your email address and your user activity through the use of Mixpanel. Mixpanel’s ability to use and share information is governed by the Mixpanel Terms of Use, available at https://mixpanel.com/terms/, and the Mixpanel Privacy Policy, available at https://mixpanel.com/privacy/. You can opt-out of Mixpanel’s services by clicking on the following link: https://mixpanel.com/optout/.
  3. Segment. Some of the Personal Information collected by us may be shared with Segment. Segment's access to such Personal Information is governed by its terms of service available at https://segment.com/legal/terms/

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We reserve the right to remove or add new analytic tools.

  1. Your Choices

You have certain choices about your Personal Data. Where you have consented to the processing of your Personal Data, you may withdraw that consent at any time and prevent further processing by contacting us as described in this Privacy Policy. Even if you opt out, we may still collect and use non-Personal Data regarding your activities on our services and for other legal purposes as described above. While we cannot guarantee privacy perfection, we will address any issue to the best of our ability as soon as possible. We will process such requests in accordance with applicable laws.  To protect your privacy, we will take steps to verify your identity before fulfilling your request. 


  1. How to contact us

If you have any questions, concerns or complaints regarding our compliance with this notice and the data protection laws, or if you wish to exercise your rights, we encourage you to first contact us at privacy@gotolstoy.com.