Privacy Policy
Last update: 6/07/2020 Version: 2.0
This privacy policy governs the processing of personal data collected through the website
https://paletton.com, the related mobile applications and services (collectively, “Website”).
Please read this document carefully to make sure that you understand how we handle
your personal data. If you have any further questions regarding our data protection
practices, please feel free to contact us.
Our privacy policy explains in detail:• What personal data (“PD”) and non-personal data (“NPD”) we collect from you, for what
purposes we use it, how we protect it, and how we share it with third parties;• How you can access and change your PD and how you can limit our sharing of it; and• Your legal rights that you have with respect to your PD.
The topics covered in this privacy policy include:

1. General Information and Definitions

1

2. Types and Purposes of PD and NPD that We Process2

3. Sharing Your PD and NPD with Third Parties

4

4. Transfer of PD Outside Your Country

5

5. Retaining and Destroying Your PD and NPD

6

6. Your Rights Regarding Your PD

6

7. Protecting the Privacy Rights of Third Parties

8

8. Do Not Track Settings

8

9. Links to Third-Party Websites

8

10. Protecting Children’s Privacy

8

11. Our Email Policy

9

12. Our Security Policy

9

13. Term and Changes to Our Privacy Policy

9

14. Contact Us

10

1. General Information and Definitions
1.1 About the Website. The Website is a designer tool for creating colour combinations.
1.2 Our role as a data controller. The entity that is responsible for the processing of yourPD though the Website is Landocs Ventures LTD & Crispox LTD having an address at
Hasaham 30, Petah tiqwa, 49517 Israel (“we”, “us”, and “our”). We act as a data controller
with regard to your PD collected through the Website (e.g., when you register your user
account, browse the Website, or communicate with us). In such instances, we are a data
Page 1 of 10

controller because we make decisions about the types of PD that should be collected fromyou and the purposes for which such PD should be used.
1.3 Applicable laws. We process PD in accordance with applicable data protection laws,
including, but not limited to, the Israeli Protection of Privacy Law, the EU General Data
Protection Regulation (“GDPR”), and the California Consumer Privacy Act (“CCPA”).
1.4 Definitions. In this privacy policy, you will encounter recurrent terms. For yourconvenience, we would like to explain what they mean:• “NPD” means non-personal data that does not allow us to identify you in any manner;• (“PD”) means personal data, i.e., any information relating to an identified or identifiable
natural person; an identifiable natural person is one who can be identified, directly or
indirectly, by reference to an identifier such as a name, an identification number, location
data, an online identifier or to one or more factors specific to the physical, physiological,
genetic, mental, economic, cultural or social identity of that natural person. PD is in many
ways the same as Personally Identifiable Information (PII). However, PD is broader inscope and covers more data.
• “Visitor” is someone who merely browses our Website. A “member” is someone who
has registered with us to use our services. The terms“ user”, “you”, and “your” arecollective identifiers that refer to either a visitor or a member.
• “Consent” means a freely given, specific, informed and unambiguous agreement to theprocessing of PD.
• “Data controller” means the entity that determines the purposes and means of theprocessing of PD.
• “Data processor” means a natural or legal person, public authority, agency or otherbody which processes personal data on behalf of the data controller.
• “Processing” means the use of PD in any manner, including, but not limited to,collection, storage, erasure, transfer, and disclosure of personal data.
1.5 Cookies. We use cookies on the Website. For more information on the types andpurposes of our cookies, please refer to our cookie policy available at
http://paletton.com/cookie-policy.html .

2. Types and Purposes of PD and NPD that We Process
2.1 PD that we collect. We comply with data minimisation principles and collect only aminimal amount of PD that is necessary to ensure your proper use of the Website. The typesof PD that we collect and process are listed below. We process your PD only for specified
and legitimate purposes explicitly mentioned in this privacy policy. In short, we will use yourPD only for the purposes of enabling you to use the full functionality of the Website, providing
you with the requested services, maintaining and improving the Website, conducting
research about our business activities, administrative purposes, and replying to yourenquiries. The detailed description of the purposes and legal basis for processing of yourPD is provided below.
Situation/PD

PurposePage 2 of 10

Legal basis

When you contact us by email, we ▪
collect your:▪
• Name• Email address• Information you provide inyour message

To respond to your enquiries
To provide you with the requested
information

When you use the Website:•• IP address• Cookie-related data•
(please refer to our cookie
policy for more•
information)

To analyse, improve, and evaluate •our business activities
To personalise the Website for yourlocation
To ensure security of the Website•

Pursuing our legitimate
business interests (i.e.,
to analyse and improve
our business activities
and ensure security)
Your consent (for certain
cookie-related data)•

Performing a contract
with you
Pursuing our legitimate
business interests (i.e.,administer our business)

When you donate through theWebsite, we collect your:• PayPal details

•
•

•

•

To process your donation
To maintain our accountancy
records•

Pursuing our legitimate
business interests (i.e.,
to grow and promote ourbusiness)
Your consent (foroptional personal data)

2.2 NPD that we collect. When you use the Website, we automatically receive informationfrom your web browser or mobile device. This information includes the name of the website
from which you entered our Website, if any, as well as the name of the website you’ll visit
when you leave our Website. This information also includes your Internet service provider’sname, your web browser type, the type of mobile device, your computer operating system,and data about your browsing activity when using our Website. We use all this NPD to (i)analyse trends among our users to help improve our Website, (ii) identify and fix errors, and(iii) develop additional features and services.
2.3 PD obtained from third parties. When using the Website, you can choose to permit or
restrict services, functionalities, and integrations provided by third parties, including, but notlimited to, payment gateways and social media service providers (“Third-Party Services”).
Once enabled, the providers of the Third-Party Services may share certain information andPD with us, subject to the privacy policy of the Third-Party Services. We will use such PD
only for the purposes for which it was provided. You are strongly encouraged to checkcarefully the privacy settings and notices of the Third-Party Services to understand what
information may be disclosed to us.
2.4 What Happens If You Don’t Give Us Your PD? If you do not provide us with the PD
when requested, we may not be able to provide you with all our products and services.
However, you can access and use some parts of our Website without giving us your PD.
2.5 Sensitive data. We do not intentionally collect special categories of personal data(‘sensitive data’), such as opinions about your religious and political beliefs, racial origins,
membership of a professional or trade association, or information about sexual orientation.

Page 3 of 10

2.6 Your feedback. If you contact us, we may keep records of any questions, complaints orcompliments made by you and the response, if any. Where possible, we will de-identify yourPD. Please note that de-identified PD is also considered to be NPD.
2.7 Aggregated data. In case your NPD is combined with certain elements of your PD in a
way that allows us to identify you, we will handle such aggregated data as PD. If your PD is
de-identified in a way that it can no longer be associated with an identified or identifiable
natural person, it will not be considered PD and we may use it for any legitimate businesspurpose.

3. Sharing Your PD and NPD with Third Parties
3.1 Selling your PD and NPD. WE DO NOT SELL YOUR PD TO THIRD PARTIES FOR
MARKETING OR OTHER PURPOSES. The term “sell” refers to selling, renting, releasing,disclosing, disseminating, making available, transferring, or otherwise communicating orally,in writing, or by electronic or other means, your PD by us to another business or a third party
for monetary or other valuable consideration. For data aggregation purposes, we may use
your NPD, which might be sold to other parties at our discretion. Any such data aggregation
would not contain any of your PD.
3.2 Sharing PD with our data processors. If necessary for the purposes listed below, we
will share your PD specified in section 2.1 with our third-party service providers we hire toprovide services to us (“Our Processors”). Our Processors include, but are not limited to,
payment processors, web analytics companies, advertising networks, help desk providers,accountants, law firms, auditors, and email service providers. The disclosure of your PD to
Our Processors is limited to the situations when such data is required for the following
purposes:
 Ensuring the proper operation of our Website;Ensuring the delivery of the services requested by you;

Providing you with the requested information;Pursuing our legitimate business interests;

Enforcing our rights, preventing fraud, and security purposes;

Carrying out our contractual obligations;

Law enforcement purposes; or

If you provide your prior consent to such a disclosure.

3.3 List of Our Processors. We will share your personal data only with Our Processorsthat agree to ensure an adequate level of protection of personal data that is consistent withthis privacy policy and the applicable data protection laws. Our Processors that may haveaccess to your PD are listed below.
Service
Hosting service
providerName

Hostmonster,
google fire baseLocation

United states

Page 4 of 10

More information

https://www.hostmonster.com/
https://firebase.google.com/

Business analytics
service provider

Google Analytics

United States

Header bidding
partner

AdapexUnited States

Email service
providerSendgrid

United States

https://sendgrid.com

Donation (payment
processing) service
providerPayPalUnited States

https://www.paypal.com

IT Syndicate

IT Syndicate

HongKong

Freshdesk

United States

https://freshdesk.com

Technical support
service providers
Our group ofcompanies
Software developing
partners andbusiness
advisors

https://analytics.google.com

https://adapex.io/

Landocs Holdings Ltd, Ran Ventures Ltd, Komantra Holdings Ltd, Keeper Holdings Ltd

Independent contractors

3.4 Legally required releases of PD. We may be legally required to disclose your PD if
such disclosure is: (i) required by subpoena, law, or other legal process; (ii) necessary toassist law enforcement officials or government enforcement agencies; (iii) necessary toinvestigate violations of or otherwise enforce our legal terms; (iv) necessary to protect us
from legal action or claims from third parties, including you and/or other users or members;or (v) necessary to protect the legal rights, personal/real property, or personal safety of ourcompany, users, employees, and affiliates.
3.5 Disclosures to successors. If our business is sold or merges in whole or in part withanother business that would become responsible for providing the Website to you, we retain
the right to transfer your PD to the new business. The new business would retain the rightto use your PD according to the terms of this privacy policy as well as to any changes to thisprivacy policy as instituted by the new business. We also retain the right to transfer your PD
if our company files for bankruptcy and some or all of our assets are sold to anotherindividual or business.
3.6 Disclosure of NPD. We may disclose your NPD and de-identified PD for any purpose.
For example, we may share it with prospects or partners for business or research purposes,
for improving the Website, responding to lawful requests from public authorities, ordeveloping new products and services.

4. Transfer of PD Outside Your Country
4.1 The PD that we collect from you may be stored, processed, and transferred between
any of the countries in which we or Our Processors operate. For example, if you reside in
the European Economic Area (EEA), we may need to transfer your personal data tojurisdictions outside the EEA.
Page 5 of 10

4.2 Wherever we transfer, process or store your PD, we will take reasonable steps to protect
it. For example, we will make sure that the jurisdiction in which the recipient third party is
located guarantees an adequate level of protection for your PD (e.g., the country in which
the recipient is located is white-listed by the European Commission or the recipient is a
Privacy-Shield certified entity) or we conclude an agreement with the respective third party
that ensures such protection (e.g., a data processing agreement based on the Standard
Contractual Clauses provided by the European Commission).
4.3 The European Commission has not found the United States and some other countries
where we and our Processors are located to have an adequate level of protection of PD
under Article 45 of the GDPR. We rely on derogations for specific situations as defined in
Article 49 of the GDPR. We will use your PD to provide the goods, services, and/or
information you request from us to perform a contract with you or to satisfy a legitimate
interest of our company in a manner that does not outweigh your freedoms and rights.

5. Retaining and Destroying Your PD and NPD
5.1 Retention of PD. We retain information that we collect from you (including your PD)
only for as long as we need it for legal, business, or tax purposes. We always make surethat we have a lawful basis for storing your PD. Your information may be retained inelectronic form, paper form, or a combination of both. When your PD is no longer needed
and there is no lawful basis for storing it, we will securely destroy, delete, or erase it.
5.2 Retention of NPD. We may retain your NPD for as long as necessary for the purposes
described in this privacy policy. This may include keeping NPA for the period that isnecessary to pursue our legitimate business interests, conduct audits, comply with (anddemonstrate compliance with) legal obligations, resolve disputes and enforce ouragreements.
5.3 Retention as required by law. Please note that, in some cases, we may be obliged bylaw to store PD for a certain period of time (e.g., we have to keep our accountancy records
for the time period prescribed by law). In such cases, we will store PD for the time period
stipulated by the applicable law and delete it as soon as the required retention period
expires.

6. Your Rights Regarding Your PD
6.1 Updating Your PD. You can update your PD using services found on our Website. If nosuch services exist, you can contact us using the contact information found at the bottom of
this privacy policy and we will help you.
6.2 Revoking Your Consent for Using Your PD. You have the right to revoke your consent
for us to use your PD at any time, if you have provided such a consent. Your opt-out will notaffect disclosures otherwise permitted by law including but not limited to: (i) disclosures toaffiliates and business partners; (ii) disclosures to third-party service providers that provide
certain services for our business, such as credit card processing, computer system services
and data management services; (iii) disclosures to third parties as necessary to fulfil yourrequests; (iv) disclosures to governmental agencies or law enforcement departments, or asotherwise required to be made under applicable law; (v) previously completed disclosures
Page 6 of 10

to third parties; or (vi) disclosures to third parties in connection with subsequent contests or
promotions you may choose to enter, or third-party offers you may choose to accept. If you
want to revoke your consent for us to use your PD, please contact us using the contact
information found at the bottom of this privacy policy and we will help you. You can easily
opt-out from our marketing communication by clicking on the “unsubscribe” link included inevery marketing email sent by us.
6.3 You rights. When using our Website and submitting PD to us, you may have certain
rights under the GDPR, the CCPA, and other applicable laws. Depending on the legal basis
for processing your PD, you may have some or all of the following rights:• The right to be informed. You have the right to be informed about the PD we collect fromyou, and how we process it.
• The right of access. You have the right to get confirmation that your PD is being
processed and have the ability to access your PD.
• The right to rectification. You have the right to have your PD corrected if it is inaccurate
or incomplete.
• The right to erasure (right to be forgotten). You have the right to request the removal ordeletion of your PD if there is no compelling reason for us to continue processing it.
• The right to data portability. You have the right to request and get your PD that you
provided to us and use it for your own purposes. We will provide your PD to you in amachine-readable format (e.g., a .pdf file) within 30 days of your request.
• The right to restrict processing. You have a right to ‘block ’or restrict the processing ofyour PD. When your PD is restricted, we are permitted to store your PD, but not to process
it further.
• The right to object. You have the right to object to us processing your PD for the following
reasons:(i) If the processing was based on legitimate interests or the performance of a task inthe public interest/exercise of official authority (including profiling);(ii) Direct marketing (including profiling); and(iii) Processing for purposes of scientific/historical research and statistics.
• Automated individual decision-making and profiling. You have the right not to be
subject to a decision based solely on automated processing, including profiling, which
produces legal effects concerning you or similarly significantly affects you.
• Filing a complaint with authorities. You have the right to file a complaint with supervisory
authorities if your information has not been processed in compliance with the applicablelaws. If the supervisory authorities fail to address your complaint properly, you may havethe right to a judicial remedy.
6.4 How to exercise your rights? If you would like to exercise your rights, please contact
us by using the contact details at the end of this privacy policy and explain in detail yourrequest. You can contact us electronically (by email) or by post, whichever method you
prefer. In order verify the legitimacy of your request, we may ask you to provide us with an
identifying piece of information, so that we would be able to locate you in our system (wewill use such information for verification purposes only). We will answer your request withina reasonable timeframe but no later than 30 days. We will provide your PD in a portable andreadily useable format. You can exercise your rights free of charge up to 2 times per year.
Page 7 of 10

We will direct all our services providers, including Our Processors, to act according to yourrequest. Please note that, in certain cases (e.g., if we need your PD for completing atransaction, carry out our contractual obligations, comply with the applicable laws, or carryout our legitimate business interests), we may not be able to delete your PD from oursystems.
6.5 How to launch a complaint? If you would like to launch a complaint about the way inwhich we handle your personal data, we kindly ask you to contact us first and express yourconcerns. After you contact us, we will investigate your complaint and provide you with our
response as soon as possible (no later than 30 days). If you are not satisfied with theoutcome of your complaint, you have the right to lodge a complaint with your local dataprotection authority.

7. Protecting the Privacy Rights of Third Parties
If any postings you make on our Website contain information, including PD, about third
parties, you must make sure you have the permission to include that information in yourposting. While we are not legally liable for the actions of our users, we reserve the right toremove any postings about which we are notified, if such postings violate the privacy rights
of others.

8. Do Not Track Settings
Some web browsers have settings that enable you to request that our Website not track
your movement within our Website. Our Website does not obey such settings whentransmitted to and detected by our Website. You can turn off tracking features and othersecurity settings in your browser by referring to your browser’s user manual.

9. Links to Third-Party Websites
Our Website may contain links to other websites. These third-party websites are not under
our control and are not subject to our privacy policy. Third-party websites will likely havetheir own privacy notices. We have no responsibility for these third-party websites and we
provide links to these websites solely for your convenience. You acknowledge that your useof and access to these websites are solely at your risk. It is your responsibility to check theprivacy notices of any third-party websites to see how they treat your PD.

10. Protecting Children’s Privacy
Our Website is not designed for use by anyone under the age of 18. Thus, we do notknowingly collect PD from children under the age of 18. If you are a parent or guardian andbelieve that your child under the age of 18 is using our Website or submit any PD throughit, please contact us. Before we remove any PD from our systems, we may ask for proof ofidentification to prevent malicious removal of account information. If we discover that a childunder the age of 18 is accessing our Website, we will delete his/her PD within a reasonable
period of time.

Page 8 of 10

11. Our Email Policy
Normally, we do not send marketing messages or informational notices to you. However, if
we decide to do so and you sign up to receive our newsletter or provide your consent, wewill, from time to time, send you marketing messages, such as newsletters, brochures,promotions and advertisements, informing you about our new services or new features ofthe Website. You will be able to easily opt-out from receiving marketing messages by clicking
on the “unsubscribe” link included in every email. We will not sell, rent, or trade your email
address to any unaffiliated third party without your permission.

12. Our Security Policy
12.1 We have built our Website using industry-standard security measures andauthentication tools to protect the security of your PD. We and Our Processors also maintaintechnical and physical safeguards to protect your PD.
12.2 We implement organisational and technical information security measures to protect
your PD from loss, misuse, unauthorised access, and disclosure. The security measurestaken by us include secured networks (we use SSL encryption), strong passwords, DDOS
mitigation, limited access to your PD by our staff, and anonymisation of PD (when possible).
12.3 When we collect your credit card information through our Website, we will encrypt it
before it travels over the Internet using industry-standard technology for conducting secure
online transactions. Unfortunately, we cannot guarantee against the loss or misuse of yourPD or secure data transmission over the Internet because of its nature. We use third-party
billing services and have no control over these services. We use our commerciallyreasonable efforts to make sure your credit card number is kept strictly confidential by using
only third-party billing services that use industry-standard encryption technology to protect
your credit card number from unauthorised use.
12.4 We strongly urge you to protect any password you may have for our Website and tonot share it with anyone. You should always log out of our Website when you finish using it,
especially if you are sharing or using a computer in a public place.
12.5 Security breaches. Although we put our best efforts to protect your PD, given thenature of communications and information processing technology and the Internet, wecannot be liable for any unlawful destruction, loss, use, copying, modification, leakage, andfalsification of your PD caused by circumstances that are beyond our reasonable control. In
case a PD breach occurs, we will immediately take reasonable measures to mitigate thebreach, as required by the applicable law. Our liability for any security breach will be limited
to the highest extent permitted by the applicable law.

13. Term and Changes to Our Privacy Policy
13.1 Term. This privacy policy enters into force on the effective date indicated at the top of
the privacy policy and remains valid until terminated or updated by us.
13.2 Changes. We reserve the right to change this privacy policy at any time. If we decide
to do so, we will post those changes on our Website so that our users and customers arealways aware of our data protection practices. For significant material changes or, where

Page 9 of 10

required by the applicable law, we may seek your consent. If you disagree with the changes
to the privacy policy, you should cease using the Website.
13.3 Repurposing of PD. If at any time we decide to disclose or use your PD in a method
different from that specified at the time it was collected, we will provide advance notice byemail (if we have it) and, if necessary seek your consent.

14. Contact Us
If you have any questions about our privacy policy or would like to exercise your rights,
please contact us using the following contact details:
Company: Landocs Ventures LTD & Crispox LTD
Address: Hasaham 30, Petah tiqwa, 49517 Israel
Email address: info@paletton.com© Copyright notice - This document is protected under the Israeli and foreign copyrights.
The copying, redistribution, use or publication by you without our consent is strictly
prohibited.

Page 10 of 10