Last Updated: 2024-01-01

SUMMARY Thank you for using 99 Digital! We respect your concerns about privacy and appreciate your trust and confidence in us. Here is a summary of the information contained in this privacy policy (“Privacy Policy“). This summary is to help you navigate the Privacy Policy and it is not a substitute for reading everything! You can use the hyperlinks below to jump directly to particular sections in the Privacy Policy.

WHAT INFORMATION DO YOU NEED TO PROVIDE 99 Digital?
When you register for a 99 Digital account, we will need your mobile number. You can further refine and populate your profile with additional information. If you use certain functions available within 99 Digital (such as posting photos), we will process your information to provide these functions.

HOW DO WE USE YOUR INFORMATION?
We use your information to provide 99 Digital to you, allow you to communicate with other users, allow you to use the features available on 99 Digital, and to improve and support your 99 Digital experience.

WHO DO WE SHARE YOUR DATA WITH?
We do not share your information with third parties, except where we need to in order to provide the service (e.g., SMS service providers) or if we are instructed to by a court, authority or compelled by law. We use these third party services solely to process or store your information for the purposes described in this Privacy Policy . Any third party with whom we share user data is required to provide the same or equal protection of user data as stated in this Privacy Policy.

WHERE DO WE PROCESS YOUR DATA?
Our servers are located in Israel. Rigorous internal control measures are in place to strictly limit access to your data by designated personnel.

HOW LONG DO WE KEEP HOLD OF YOUR DATA?
How long we retain information for depends on the type of information – for example, log-in data is retained for up to 365 days from the date the data is collected. We do not retain your information for longer than the time period prescribed by law.

HOW CAN YOU EXERCISE YOUR RIGHTS OVER YOUR DATA?
Depending on where you live, you may have special rights over your data and how we can use it. These include how you can access the data, erase the data, restrict how your data can be used, object to our use, and get a copy of your information.

HOW WILL WE NOTIFY YOU OF CHANGES?
If there are any significant changes to this Privacy Policy, we will update it here and notify you before the change becomes effective.

DATA CONTROLLER

• 99 Digital INC of Israel

CONTACT US
If you have any questions or complaints regarding this Privacy Policy or the use of your Personal Information, please contact our Data Protection Officer via email at service@99digital.com If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.

INTEROPERABILITY WITH WhatsApp
99 Digital is interoperable with WhatsApp, such that you are able to communicate with WhatsApp users and view one another’s messages and files posts. You may also be able to use certain features operated by Meta, in accordance with the applicable terms. When you interact with a WhatsApp user (or vice versa), or use or receive notifications or invitations from any feature operated by Meta, (together “Interoperable Interaction”), we will share your information with WhatsApp to the extent necessary to facilitate the Interoperable Interaction.

1. INTRODUCTION

Welcome to 99 Digital! When you use the 99 Digital mobile app, desktop app, or the websites www.99digital.co.il or help.99digital.co.il (together, “99 Digital”), certain of your Personal Information (defined below) will be collected and processed by us. This Privacy Policy explains the when, how and why when it comes to processing of your Personal Information in connection with 99 Digital, and sets out your choices and rights in relation to that Personal Information.
Please note that this Privacy Policy only applies to 99 Digital. If you use any other products or services please refer to the privacy policy for that particular product or service. If you do not agree to the processing of your personal information in the way this Privacy Policy describes, please do not provide your information when requested and stop using 99 Digital. By using 99 Digital you are acknowledging how we process your personal information as described in this Privacy Policy. In this Privacy Policy, “we”, “our” or “us” refers to:

• 99 Digital INC of Israel

Each of the above entities is also the data controller for users located in the abovementioned jurisdictions. Any capitalised terms used in this Privacy Policy have the same meaning as the equivalent defined terms in the 99 Digital Terms of Service, unless they are defined otherwise in this Privacy Policy.

CONTACT
If you have any questions or complaints regarding this Privacy Policy or the use of your Personal Information, please contact our Data Protection Officer via email at service@99digital.com If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.

2. SCOPE AND APPLICATION

This Privacy Policy only applies to you if you are a 99 Digital user.
If you are a WhatsApp user, you are subject to the WhatsApp Agreement on Software License and Service of Meta INC and not this Privacy Policy.
This Privacy Policy does not apply to Personal Information collected by third party services that you may access through the 99 Digital platform (e.g., features operated by WhatsApp such as Advanced Search, Channels, Top Stories; WhatsApp Open Platform services including Official Accounts, Mini Programs, and WhatsApp Login; Meta Pay or 99 Digital Pay; or a third-party web site viewed via the internal browser), and Personal Information that you choose to share with a WhatsApp user. Please refer to the privacy policy of the relevant third party service.
If you are using 99 Digital on behalf of a company, partnership, association, government or other organisation (your “Organisation“), you agree to notify such persons in your Organisation whose Personal Information (defined below) we collect or you provide to us (“Connected Persons“), and you agree to obtain such Connected Persons’ consent to the processing of their Personal Information in accordance with this Privacy Policy as required by applicable laws and regulations. When this Privacy Policy refers to “you”or “your”, this includes you and any Connected Persons. If you or any Connected Persons would like to request for your Personal Information to be removed from our database, please contact us at service@99digital.com.

3. DEFINITIONS

“Location Data” is information that is derived from your GPS (GPS coordinates), WiFi (approximate city location), IP address (country location), or public posts that contain location information (the location you geo-tag). Location Data will be disclosed (either to us, to other users, or both):

• when you use location-based features and when you share your location with other 99 Digital and/or WhatsApp users; and
• when you access 99 Digital, we automatically derive Location Data from your IP address, device, or internet service for security purposes including to prevent fraudulent log-ins and connections to your account.

You may disable the collection and use of your location data through device-level settings. “Log Data” is information that is automatically collected when you use 99 Digital, including:

• device attributes, such as your mobile carrier and network-related information, your device version and resettable identifiers, configuration information made available by your 99 Digital mobile app or desktop or web browser, and your IP address;
• information about your viewing history on 99 Digital, such as social media profiles visited and details of other content accessed or requested by you;
• general information about your communications on 99 Digital, such as the user that you have communicated with, the time, date and duration of your communications (but not the content of such communications), statistics about your use of 99 Digital, and traffic data; and
• metadata, which means information related to items you have made available through 99 Digital, such as the date, time or location that a shared photograph or video was taken or posted.

“Personal Information” is any information, or combination of information, that relates to you, that can be used (directly or indirectly) to identify you, which we process in connection with your use of 99 Digital. Please see the section entitled “How do we use your information?” below for examples.
“Shared Information” is information that you include in your publicly-visible 99 Digital profile, information you make available to other users via 99 Digital (e.g., via your Moments and Status posts), information about you that is made available by another user via their use of 99 Digital or WhatsApp, and Location Data.

4. HOW DO WE USE YOUR INFORMATION?

This section provides more detail on the types of Personal Information we collect from you, purpose of processing, and retention periods for each type of Personal Information.
For users resident in a Relevant Jurisdiction, it also identifies the legal basis under which we process your data. For the purposes of this Privacy Policy, a “Relevant Jurisdiction” includes the EEA, UK, Switzerland, Brazil, Indonesia, Thailand, and Türkiye.
We do not retain Personal Information for longer than is necessary unless we are required or permitted to do so under applicable laws. If we are required to retain your Personal Information beyond the retention periods set out below, for example to comply with applicable laws, we will store it separately from other types of Personal Information. Aggregated registration data (which does not contain Personal Information) is retained for spam prevention and system security purposes. For further details on how long we keep your data, please refer to the retention periods set out below.

Information	Purpose of Processing	Retention Period
Registration data and log in data. Your name, alias, Apple ID, Facebook ID, IP address, account identifier, mobile number, region, location as determined by your currently registered mobile number, Facebook account, email address used to register a 99 Digital account and date of registration. Legal Basis (Relevant Jurisdictions only): Necessary to perform our contract with you to create your 99 Digital profile and provide 99 Digital services.	– To set up your 99 Digital account and facilitate your log in; – to facilitate communication between users of 99 Digital and WhatsApp; – to facilitate your use of WhatsApp features; – to enforce our terms, conditions, and policies; – to place VoIP calls using 99 Digital; – to communicate with you to notify you about changes to 99 Digital; – to provide you with personalised user support; – to develop new and improve existing services as well as the tools we use to detect account violations and enhance the safety and quality of accounts; – to provide language and location customisation; – to protect any rights, property or safety of ours, our affiliate companies, or other users of 99 Digital; and – to administer 99 Digital and for troubleshooting, data analysis, testing, research, security, fraud-detection, account management, and survey purposes.	Registration data is retained until your account is deleted, or until you unlink your 99 Digital account from your Apple or Facebook account, whichever is earlier. Log in data is retained for a period of 3 months from the date of such log in.
Shared Information – profile data. Any information that you include in your publicly-visible 99 Digital profile, which includes your 99 Digital ID, name, gender, region, and photo. Legal Basis (Relevant Jurisdictions only): Necessary to perform our contract with you to provide your 99 Digital profile and provide 99 Digital services.	– To allow your profile data to be shared with other 99 Digital and WhatsApp users; – to allow you to use your 99 Digital ID to log in to or otherwise connect with third party services; – to facilitate your use of WhatsApp features; – to provide you with personalised user support; – to provide language and location customisation; – to develop new and improve existing services and app experience; – to maintain and administer the 99 Digital platform; and – for troubleshooting, data analysis, testing, research, security, fraud-detection and account management.	Until you request removal of the Shared Information or your account is deleted, whichever is earlier (however, the data may be cached on third party services and retained in accordance with their own privacy policies).
Shared Information – profile media. This comprises all of the information you make available to other users or information about you that is made available by other 99 Digital and WhatsApp users, including Moments and Status posts. Legal Basis (Relevant Jurisdictions only): Necessary to perform our contract with you to provide your 99 Digital profile and provide 99 Digital services.	– To allow your profile media to be shared with other 99 Digital and WhatsApp users; – to provide location customisation; – to develop new and improve existing services and app experience; – to maintain and administer the 99 Digital platform; – for troubleshooting, data analysis, testing, research, security, fraud-detection and account management; and – to develop and improve tools we use to detect account violations and enhance the safety and quality of 99 Digital accounts.	Until you request removal of the Shared Information or your account is deleted, whichever is earlier (however, the data may be cached on third party services and retained in accordance with their own privacy policies).
Information for additional account security (if you choose to secure your account). Password, Emergency Contacts, Managed Devices, email address, and QQ ID. Legal Basis (Relevant Jurisdictions only): Necessary to perform our contract with you to provide and secure your 99 Digital account.	To provide additional security for your account.	Until you request removal of the information or your account is deleted, whichever is earlier.
Personal settings. These include personal account settings viewable to you but not shared with other users such as settings to customize your 99 Digital experience, personal annotations and details that you add to your own account and to your contacts. Legal Basis (Relevant Jurisdictions only): Necessary to provide you with services customized to your preferences.	To provide you services customized to your preferences.	Until you request removal of the information or your account is deleted, whichever is earlier.
Chat data. Content of communications between you and another user or group of users. We do not permanently retain chat data on our servers and it only passes through our servers so that it can be distributed to your intended recipients. Chat data is only stored on your device and the devices of the users that you have sent communications to, unless your recipient adds any of your communications to their Favorites or it is a message that the owner or administrator of your group chat added as a Group Notice. Legal Basis (Relevant Jurisdictions only): Necessary to perform our contract with you to provide the chat services of 99 Digital.	To provide our communication service.	Chat messages are automatically and permanently deleted from our servers within 3 hours of delivery to the recipient’s device, and in any event, permanently deleted after 72 hours of you sending them. Chat media such as images, audio, videos, and files are automatically and permanently deleted from our servers after 120 hours of you sending them.
Contacts and friends list. Your on-device contact list and your 99 Digital list of group chats and friends list. Legal Basis (Relevant Jurisdictions only): Necessary to perform our contract with you to provide 99 Digital and connect you with your friends.	– To connect you with other 99 Digital and WhatsApp users; – (in relation to your list of group chats and friends list) to develop and improve tools we use to detect account violations and enhance the safety and quality of 99 Digital accounts; and – to facilitate your use of 99 Digital Out.	Until you request removal or amendment of the Personal Information or your account is deleted, whichever is earlier.
Log Data. See definition above. Legal Basis (Relevant Jurisdictions only): It is in our legitimate interest to ensure the security of our services, manage registrations and improve our services.	– For troubleshooting, data analysis, testing, research, security, fraud detection, and account management.	Permanently deleted 3 months from the date of collection.
Location Data. See definition above. Legal Basis (Relevant Jurisdictions only): Necessary to perform our contract with you to provide 99 Digital location-based services. Please note that your use of location-based services is subject to the terms of use and privacy policies of third party service providers that power the location-based services of such services.	– To facilitate your use of location-based services such as: • sharing your real time location via chat, which relies on your GPS; • manually geo-tagging a location in a Moments or Status post; • People Nearby and Shake, which rely on your GPS; – for security, fraud detection and account management; and – to provide language and location customisation.	Location data used for location-based services: – Location data shared via chat is permanently deleted after 72 hours from the time of your sharing. – Moments and Status when you manually choose to geo-tag a location in your post: retained until you delete such post or your account is deleted, whichever is earlier. – People Nearby and Shake: permanently deleted after 1 hour from the time of you leaving the function. Location data used for all other purposes is retained for a period of 3 months from the date of collection.
Payment card information – parental/guardian consent. In order to comply with laws protecting children, payment card information of a parent/guardian is collected to verify parental/guardian consent where a Child attempts to create a 99 Digital account, and the payment card information is verified via a third party payment processing service. After a verification request has been performed by the third party payment processing service, 99 Digital only retains the date of verification and hashed payment card number. Legal Basis (Relevant Jurisdictions only): We process this data in accordance with our obligations under applicable laws.	To verify parental/guardian consent where a Child attempts to create a 99 Digital account.	Until the parent/guardian or user requests removal of the payment card information and only if the user has reached the age of majority under relevant local laws.
Text for which you request a translation. Legal Basis (Relevant Jurisdictions only): Necessary to perform our contract with you.	To provide you with translation of the text as requested by you.	Text to be translated and translated text is hashed and cached for 24 hours from the time you request for translation.
Customer Support Information Communications with and any information that you or other users provide to our customer support team. Legal Basis (Relevant Jurisdictions only): Necessary to perform our contract with you to provide and support 99 Digital.	– To investigate the issue and provide customised customer support; – to develop new and improve existing services and app experience; – for security, fraud detection, and account management; and – for moderation of content or behaviour that is prohibited by applicable laws and regulations, or which otherwise violate 99 Digital’s terms of service or other rules applicable to 99 Digital users.	Until your account is deleted, unless otherwise required by law.
Access tokens. Access tokens that facilitate the linkage of your 99 Digital account with your third party social media accounts. Legal Basis (Relevant Jurisdictions only): Necessary to perform our contract with you to provide 99 Digital services.	If you connect third party social media accounts to your 99 Digital account, we process access tokens to facilitate your log ins and your sharing of content between these accounts.	Until you unlink your 99 Digital account from these third party social media accounts.
Surveys. If you participate in a survey, we may request certain Personal Information from you. The purpose of the survey and the identity of the service provider providing the survey (if we engaged a service provider), will be notified to you prior to you completing the survey. Legal Basis (Relevant Jurisdictions only): We collect this information with your consent.	– To better understand how you access and use 99 Digital; – to develop new and improve existing services and app experience; – to improve 99 Digital and respond to customer requests and preferences; and – and for any purposes enumerated in the survey itself.	Until your account is deleted or as otherwise stated in the survey itself, whichever is earlier.

We may also pseudonymise or aggregate Personal Information for analytical purposes. This helps us develop new and improve existing services, conduct fraud detection and account safety analysis, analyse usage trends, and provide third party service providers with basic statistics about how their service is being used by 99 Digital users.

SENSITIVE PERSONAL INFORMATION
In some jurisdictions, certain types of Personal Information, such as information about your race, religious, political or philosophical views, sexual orientation, and health, are characterised as sensitive and are subject to stricter regulation than other types of Personal Information.
99 Digital does not require you to provide sensitive Personal Information to use the service. By posting or communicating any sensitive Personal Information within 99 Digital, you consent to such information being available within the privacy controls you have selected.

SHARED INFORMATION
You can control which Shared Information is made public to other users of 99 Digital and WhatsApp via the privacy settings in 99 Digital. After you delete Shared Information, it may still be separately cached, copied, or stored by, or remain public through, other users or third parties who are not affiliated with and not controlled by us. Please consider carefully what you post and communicate through 99 Digital.

PERSONAL INFORMATION WITHIN YOUR CONTENT
If any of your Personal Information comprises Your Content (as defined in the 99 Digital Terms of Service), we and our affiliate companies may (subject to this Privacy Policy) use such Personal Information in accordance with the “Your Content” section of the 99 Digital Terms of Service. Your Content will be processed to ensure compliance with the 99 Digital Terms of Service and acceptable Use Policy.

5. WHO DO WE SHARE YOUR DATA WITH?

We will not transfer your Personal Information to third parties except as specified below, or where you consent to such transfer. Only where necessary will we share your information with selected recipients, including:

• service providers. We engage service providers to supply services to support or improve 99 Digital. These include SMS, Message, files processing and verification, translation, location and mapping, customer service, account data labelling and safety assurance (where applicable) and content delivery service providers. These service providers are required to provide the same or equal protection of user data as stated in this Privacy Policy and are prohibited from retaining, using, or disclosing your information except as necessary to provide services to us;
• third party services. When you:
  • log in to 99 Digital using third party authentication services;
  • share content from 99 Digital to third party services;
  • share content on 99 Digital from third party services;
  • access content of non-WhatsApp third party services from 99 Digital; or
  • link your 99 Digital contact list with your list on third party services, we may receive information about you from such third party services and/or share your information with such third party services. Third party services may collect information (including personal information and log data), and set cookies on your device. This Privacy Policy only applies to information collected by us, and does not apply to information collected by third parties.

Interoperability with WhatsApp
99 Digital is interoperable with WhatsApp, such that you are able to communicate with WhatsApp users and view one another’s messages and files posts, in accordance with the applicable terms. You may also be able to use certain features operated by WhatsApp.When you interact with a WhatsApp user (or vice versa), or use or receive notifications or invitations from any feature operated by WhatsApp, (together “Interoperable Interaction”), we will share your information with WhatsApp to the extent necessary to facilitate the Interoperable Interaction. Official Accounts and Mini Programs accessible via 99 Digital are developed, operated, and owned by third parties unrelated to 99 Digital (unless otherwise stated in the relevant Official Account or Mini Program). When you interact with such Official Accounts and Mini Programs, your information will be collected, retained, shared and/or stored by the relevant Official Account or Mini Program in accordance with their own privacy policies and not this Privacy Policy.
If available in your jurisdiction, you may be able to access WhatsApp Pay and 99 Digital Pay via the 99 Digital platform. Due to regulatory requirements, WhatsApp Pay and 99 Digital Pay are operated by different licensed entities in different jurisdictions. When you use any of the WhatsApp Pay or 99 Digital Pay payment services, your information will be collected, retained, shared and/or stored by the relevant WhatsApp Pay or 99 Digital Pay entity and/or their affiliates in accordance with their respective privacy policies and not this Privacy Policy. We will also share your information with these entities to the extent necessary to facilitate your use of these services.

You can control which third parties have access to your information and you can withdraw your agreement to the sharing of your information by following the instructions set out in the privacy policy. Please note however that if you ask us not to share your information with certain third parties, you may no longer be able to use those third party services;

• third parties or related group companies in the event of a merger, acquisition, restructuring, or sale of assets, or by operation of law or otherwise, we will transfer your information to such entity accordingly so that your service can continue. Under these circumstances, we will always require the third parties or related group companies to comply with this Privacy Policy;
• government, public, regulatory, judicial and law enforcement bodies or authorities. There are circumstances in which we are legally required to disclose your information, including (i) to comply with a legal obligation or request, such as a court order, subpoena or other legal process, (ii) to enforce our terms, (iii) to address issues relating to security or fraud, or (iv) where there is an imminent emergency involving risk of death, serious physical injury to a person or any risk of harm to a child, and in both cases, provided that the requesting entity has valid jurisdiction to obtain your Personal Information. Our Law Enforcement Data Request Guidelines are available here; and
• third parties pursuant to your request, for example, pursuant to your data portability request.

6. WHERE DO WE PROCESS YOUR DATA?

99 Digital is a global platform. Our engineering, technical, and other support teams are based in our offices around the world (including Israel), and may have incidental access to certain of your information, for example, in order to fix technical issues that you report. The Personal Information that we collect from you will be transferred to, stored at, or processed in Israel.

7. SECURITY OF YOUR PERSONAL INFORMATION

We are committed to maintaining the privacy and integrity of your Personal Information no matter where it is stored or accessed. We protect your Personal Information through the use of information security and access policies that limit unauthorised access to our systems, and technological protection measures such as encryption that ensure confidentiality of your Personal Information during transmission and in storage.
We do not permanently retain chat data between you and other users on our servers. Chat data only passes through our servers so that it can be securely distributed to your intended recipients. Chat data is only stored on your device and the devices of the users that you have sent communications to, unless any of you or your recipient adds any of your communications, shares the relevant chat externally such as by saving it to Favorites or including the chat history when reporting a chat for abuse, or when the administrator of your group chat has added a Group Notice, in which case the Group Notice will be retained so it can be accessed by group members in the future.
Although we will implement and maintain reasonable measures to protect your Personal Information, please note that as any transmission of information via the internet is never completely secure.

8. ADVERTISING

99 Digital does not display personalised advertising.

9. COMMUNICATIONS FROM US

We may send you service-related announcements via 99 Digital, email, or SMS when necessary, such as when we temporarily suspend 99 Digital for maintenance, or security, or privacy reasons. You may not opt-out from these service-related announcements which are not promotional in nature.

10. AGE RESTRICTIONS AND PARENTAL/GUARDIAN CONTROLS

Children under the age of 16 (or such applicable age of majority under relevant local laws of the user) (“Child“) must not use 99 Digital for any purpose without first obtaining parental/guardian consent to and acknowledgment of this Privacy Policy (both for themselves and on their Child’s behalf). In certain jurisdictions, you may be required to provide your date of birth; we will however only process the year and month of your birth. We do not knowingly collect Personal Information from any Child without such consent and acknowledgment. Please contact our Data Protection Officer if you believe we have any Personal Information from any Child without such parental/guardian consent and acknowledgment so that we can promptly investigate and remove such Personal Information.

11. YOUR RIGHTS

You may have certain rights in relation to the personal information we hold about you. Some of these only apply in certain circumstances (as set out in more detail below). Please note that in order to protect your information, we will need to verify your identity before responding to any request to exercise your rights (“DSR Request“). To exercise any of your rights, please complete the request form our support email.
Access & Correction
This section also applies to users resident in Israel.
You have the right to request access to your Personal Information we hold about you, how we use it, and who we share it with. We may not be able to provide you with certain Personal Information if providing it to you would interfere with another person’s rights (e.g. where providing the Personal Information we hold about you would reveal information about another person).
You also have the right to correct that information if it is inaccurate or incomplete.
You can access and correct your Personal Information by logging into your 99 Digital account at any time. For example, you can delete certain Location Data via your device settings or the “Clear Location” option within 99 Digital.
If you want us to correct your Personal Information that you are unable to correct using your account, please complete the request form here.
Where we agree to correct your Personal Information, we will use reasonable steps to inform any third party to whom we have disclosed the relevant Personal Information so that they can rectify the Personal Information too.
Erasure
This section also applies to users resident in Israel.
You can delete your account, or remove certain Personal Information, by sending us request via our email service. Subsequent to account deletion, aggregated registration data is retained for spam prevention and systems security purposes.
Note that we will not be able to delete your account if you have a positive balance in your WhatsApp or 99 Digital invoice account or are the administrator of an Official Account or Mini Program.
If there is any other Personal Information you believe we process that you would like us to erase, please send us an email.
You may request that we erase the Personal Information we hold about you where:

• you believe that it is no longer necessary for us to hold your Personal Information;
• we obtained your consent to process the Personal Information and you withdraw that consent (and we have no other valid legal grounds for processing the Personal Information);
• you believe we are unlawfully processing your Personal Information; or
• you are or were under the age of 16 (or such applicable age of majority under relevant local laws) when we collected the Personal Information and we can verify this.

You may exercise your right to restrict our processing your Personal Information (as described below) whilst we consider a request to erase your data.
We may retain the Personal Information if there are valid legal grounds for us to do so (e.g., for the defence of legal claims, freedom of expression or some other legal obligation) but we will let you know if that is the case.
Where you have requested that we erase your Personal Information that we have made public and there are valid legal grounds for erasure, we will use reasonable steps to inform any third party to whom we have disclosed the relevant Personal Information so that they can erase it too.
Restriction of Processing to Storage Only
This section also applies to users resident in Israel.
You have a right to require us to stop processing your Personal Information other than for storage purposes in certain circumstances. However, we may process it if there are other valid legal grounds for us to do so (e.g., for the defence of legal claims or for another’s protection).
Where we agree to stop processing the Personal Information, we will use reasonable steps to inform any third party to whom we have disclosed the relevant Personal Information so that they can stop processing it too.
You may request we stop processing and just store the Personal Information we hold about you where:

• you believe the Personal Information is not accurate (for the period it takes for us to verify whether it is accurate);
• we wish to erase the Personal Information as the processing is now unlawful (but you want us to retain the Personal Information and just store it instead); or
• we wish to erase the Personal Information as it is no longer necessary for our purposes (but you require it to be stored for the establishment, exercise or defence of legal claims).

Portability
You have the right to receive a copy of certain of your Personal Information in a structured, commonly used and machine-readable format. This comprises any Personal Information we process on the basis of your consent (e.g., Shared Information and content saved to Favorites) or pursuant to our contract with you (e.g., profile data), as described in the section “How do we use your information?. You can exercise your right to export your data by following the instructions.
You also have the right to request that we transfer that Personal Information to another party. If you wish for us to transfer the Personal Information to a third party, please ensure you provide details of such party. Note that we can only make such transfers where it is technically feasible. We are not responsible for the security of the Personal Information or its processing once received by the third party.
Objection
This section also applies to users resident in Israel.
You may object to our use of your Personal Information that we use on the basis of our legitimate interests (e.g., when we use your Personal Information to ensure account security). If you object to such processing, please complete th request email. To the extent provided by applicable laws and regulations, you may withdraw any consent you previously provided to us by following the instructions set out in our documentations.

12. CHANGES TO THIS PRIVACY POLICY

We may from time to time revise this Privacy Policy. We will update the revised version here along with the “last updated” date, and notify you via 99 Digital or other means, as appropriate, before the change becomes effective.

13. LANGUAGE

We have provided translations of this Privacy Policy, but in the event of any conflict between the local language version and the English version, unless otherwise prescribed by applicable laws, the English version shall prevail.