Viralemon Privacy Policy

Last updated – May 25, 2018


This Privacy Policy is designed to help You decide whether to use Viralemon’s services and in what manner. This Privacy Policy explains how we make use of data and information received from our users that use our services (“Users”).  This Policy is incorporated into, subject to and a part of the Terms of Service of, its app or Facebook app/pages (the “Website”).

When this policy mentions “Viralemon,” “We,” “Us,” or “Our,” it refers to Growlead Marketing Ltd. that is responsible for your information under this Privacy Policy (the “Data Controller”).

Scope of This Privacy Policy

Please note that this Policy governs your use of the services offered at the Website (the “Services”) alone and does not apply to third party services or sites that You or any User access during the use of the Services. We do not assume any responsibility for third parties' privacy practices, actions or omissions and once You link or click on an advertisement or third party site or service, You should review the applicable privacy policy of the third party service or site.

IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, YOU MAY NOT AND SHOULD NOT USE the Website. The definitions in the Terms of Service apply to this Policy unless stated otherwise.

The Information We Collect

We receive information about You from two sources: (i) information that you give us or allow us to access such as from your Facebook account; and (ii) information we automatically collect from Your use of the Services.

Information You Allow Us to Access or Give Us

None of the personal information and other information that You give us or allow Us access to is mandatory. You are free to refuse to give Us or allow Us access to any kind of personal information and other information, which we offer You to provide Us. This information is necessary for the adequate performance of the Services. Without it, we may not be able to provide you with some of the requested Services.

If You use Our Services on and chose to log-in for such purpose, You will be required to provide us access to your public information that You chose to share on your Facebook account, such as your age, sex, location, friend list, email address, timeline posts and public photos. Such information can be used to personally identify You. Such information is necessary to access certain features of the Services, like inviting your Facebook friends to use the Services and also to provide you with a better user experience of Our Services.

In order to access some of our Services, Users will be required to provide Us with their photo that can be used to personally identify them (together with the pervious paragraph the "Personal Information"). If You do not use such Services, You are not requested or need to give Us your photo. It is not mandatory but rather your voluntary decision whether to provide us with such Personal Information, but if You refuse to provide such information You may not be able to use some of our Services.

The use of the Services involving your personal photo is only permitted for users who have reached the minimum age required for consent. The minimum age is generally 16 years but may be lower or higher in accordance with the regulations of individual countries. In order to determine how high the legally permissible minimum age in the country from which the User uses our Services, We can use the IP of the Users to determine their location.

Information We Automatically Collect from Your Use of the Services

Collection of Analytics End Users Information

During the use of the Services, or when You view or click on content or ads, share or Services or their results, we automatically collect non-identifiable information from Users’ computer, tablet or mobile phone regarding the Services You use and how You use them. We do not intentionally collect any information that may personally identify any User, which You don’t clearly agree to provide us. We obtain this information as a result of data being sent to our servers. The data collected by us includes: IP address, mobile device’s GPS, your precise or approximate location, your mobile carrier if You use your mobile phone, your use of the Services, User agent, platform, SDK version, anonymous User ID, log data and device information (such as access dates and times, hardware and software information, device information, device event information, unique identifiers, crash data, cookie data, and the pages You have viewed or engaged with before or after using the Services), time tamp Developer Key, application version, device identifiers such as: unique device identifier “UDID” (iOS device) (UDID not collected by default. opt-in is needed in order to collect UDID), Media Access Control (“MAC”) Address, ODIN, Android ID (Android device), device model, manufacture, OS version, in-app events, locale, time zone, and network status (WiFi/3G).

Most mobile devices allow You to control or disable the use of location services for applications in the device’s settings menu. We may also collect this information even when You are not using the Services if this connection is enabled through your settings or device permissions.


We may use browser cookies, web and DOM storage data, Adobe Flash cookies, pixels, beacons, mobile identifiers and other tracking and data collection technologies, which may include an anonymous unique identifier. These technologies may be used to collect and store information about Your use of the Services, including without limitation, web pages, features and content You have accessed, referral URL information and links you have clicked on. This data is used for business purposes such as providing more relevant ads and content, and market research.

We may also allow our business partners to use these tracking technologies on the Website, or engage others to track your behavior on our behalf.


How we use your personal data will depend on which Services you use, how you use those Services and the choices you make in your settings. We use the data that we have about you to provide and personalize, including with the help of automated systems and inferences we make, our Services (including ads) so that they can be more relevant and useful to you and others. We use, store, and process through others as provided in this Privacy Policy information, including personal information, about you to provide, understand, improve, and develop the Services.

Provide, Improve, and Develop the Services

  • Enable you to access and use the Services, such as processing your personal photo into amusing results.

  • Operate, protect, improve, and optimize the Services and your user experience, such as by performing analytics and conducting research.

  • We use data to conduct research and development for the further development of our Services in order to provide You and others with a better, more intuitive and personalized experience, drive Users growth and engagement on our Services.

  • Provide customer service.

If you provide us your personal photo as required in order to use some of the Services which deliver You with an amusing edited version of the original photo that You will upload to the Service, we will keep on our servers or cloud servers both original and edited photo for 30 days to provide you access to the original and edited photos. Following such 30-day period we will delete from our servers or could servers both original and edited photos. The Processor of your photo will analyze the photo and edits it according to the functions selected by You (e. g. prediction of how You will look in old age).


We target (and measure the performance of) ads to Users both on and off our Services directly or through our partners include ad networks, exchanges and others, using the following data, whether separately or combined:

  • Data from advertising technologies on and off our Services, like web beacons, pixels, ad tags, cookies, and device identifiers.

  • User ember-provided information (e.g., information shares from Facebook account as provided above).

  • Data from your use of our Services (e.g., content you read, page visits, videos you watch, clicking on an ad, etc.), including as described above.

  • Information from advertising partners and publishers.

We will send you promotional messages, marketing, advertising, and other information that may be of interest to you based on your preferences and social media advertising through social media platforms such as Facebook or Google.

We do not share your personal data with any third-party advertisers or ad networks for their advertising except for with your separate permission. However, if you view or click on an ad on or off our site or apps, the ad provider will get a signal that someone visited the page that displayed the ad, and they may through the use of mechanisms such as cookies determine it is you.


We use data and content about Users for invitations and communications promoting Our growth, engagement and our Services.

Aggregated Information

We use your data to produce and share aggregated insights that do not identify you. For example, we may use your data including inferences drawn from data about you such as your age or gender to generate statistics about our Users, their interests, to calculate ad impressions served or clicked on, or to publish visitor demographics for a Service.

This information, which will only be collected and maintained in aggregate, anonymous form, will be used, among other things, to: provide a better understanding of how Users use the Services and the various features thereof, help to create and provide new services and offerings to Users, provide and improve the functionalities of the Services, offer You an improved user experience and conduct aggregate, anonymous, market research results.

We may use the aforesaid information on Users you provide to us, and information we collect about Your use of the Services through tracking and other technologies, to assist us in delivering You and the Users relevant ads and content when You or they use the Services. We may work with third party advertising networks and advertisers who help deliver these ads to You or Users. These third party advertising networks and advertisers may also use cookies and other technologies to collect and track non-personally identifiable information such as demographic information, aggregated information, and Internet activity to assist them in delivering advertising that is more relevant to Your or the Users interests. They may also utilize supplemental data from other sources and analytics methods to help deliver more relevant ads.

Sharing Information with Third Parties

Our Services

Some of our Services allows You to upload your personal photo and receive an amusing edited version of your photo (for example, for a male – how would I look as a woman). We will ask your consent to provide us with your photo, and your permission to transfer it to third party processor as provided in this section, in order to use such Services. We do not process your photo but use the services of image processing providers (“Processors”) and transfer your photo to them, in their location outside the EU, currently in Russia. Our current Processors are (i) FaceApp (wireless lab OOO 16 Avtovskaya 401 Saint-Petersburg, 198096, Russia); and (ii) VicMan LLC. Their website and privacy policy can be accessed by clicking the following links;;; Uploading your photo is not mandatory, and it is absolutly voluntary. However, if You chose not to upload your photo, You will not be able to use such Services. If You chose to use such Services and upload your photo, your photo will be sent to processors outside the EU for editing, so You will be able to get the amusing edited photo You desire by using the aforesaid Services.

The processing of your personal data resulting from the photo is carried out by the Processor for the sole purpose of the selected function. The photo is only temporarily stored by the Processor for this purpose and is then deleted within five days. Data other than the photo will not be transmitted to the Processor. The photo is transmitted via an interface to the Processor, so that the Processor itself cannot collect any further user data (e. g. no IP address, cookies, etc.). 

Social Media Platforms

Where permissible according to applicable law we may use certain limited personal information about you, such as your email address, to hash it and to share it with social media platforms, such as Facebook or Google, to generate leads, drive traffic to our websites or otherwise promote our products and Services. These processing activities are based on our legitimate interest in undertaking marketing activities to offer you products or services that may be if your interest.

We do not control or supervise the social media platforms with which we may share your personal data. Therefore, any questions regarding how your social media platform service provider processes your personal data should be directed to such provider.

Please note that you may, at any time ask Us to cease processing your data for these direct marketing purposes by sending an e-mail to [email protected].

Aggregated Data

We may also share aggregated information (information about our users that we combine together so that it no longer identifies or references an individual user) and other non-identifiable information for regulatory compliance, industry and market analysis, demographic profiling, marketing and advertising, and other business purposes.

Our Corporate Affiliates

We may share your Personal Information with our parent or subsidiaries without restriction.

Linking Third Party Accounts

You may log-in to the Services with your account at a third party social networking service, where you maintain a friend list. When you log-in this way:

  • We will have access to the public information on your social network account such as age, sex, location, friend list, email address, timeline posts and public photos.

  • your use of the Services may be displayed to your friend list on the social network site.

  • the publication and display of information that you provide to Us through this linkage is subject to your settings and authorizations on the social network site.

Legal Disclosure

It is possible that we will need to disclose information about you when required by law, subpoena, or other legal process or if we have a good faith belief that disclosure is reasonably necessary to (1) comply with law, regulation, subpoena or court order; (2) detect, prevent or otherwise address fraud, security, violation of our policies or technical issues; (3) enforce the provisions of this Privacy Policy and/or any other agreements between You and Us, including investigation of potential violations thereof; or (4) protect against harm to the Our rights, property or safety, partners, affiliates, Users and/or the public. We attempt to notify Users about legal demands for their personal data when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority, but we do not undertake to challenge every demand.

Change in Control or Sale

We can also share your personal data as part of a sale, merger or change in control, or in preparation for any of these events. Any other entity which buys us or part of our business will have the right to continue to use your data, but only in the manner set out in this Privacy Policy unless you agree otherwise.


Data Access and Portability

You can request from us to receive copies of your personal information held by us at the time of your request. You may also be entitled to request copies of personal information that you have provided to us in a structured, commonly used, and machine-readable format and/or request us to transmit this information to another service provider (where technically feasible).

Data Retention and Erasure

We generally retain your personal information for as long as is necessary for the providing the Services to you. If you no longer want us to use your information to provide the Services to you, you can request that we erase your personal information.

Withdrawing Consent and Restriction of Processing

Where you have provided your consent to the processing of your personal information by a Processor you may withdraw your consent at any time by sending Us a communication to specifying which consent you are withdrawing. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal.


Data Security

We place great emphasis on the security and integrity of your information and the data stored in our systems.

Our Services are provided under the best commercially reasonable data security practices, in order to prevent unauthorized access, disclosure, alteration or deletion of any and all information stored in Our systems.

You acknowledge, however, that no such effort can completely guarantee the security of the stored data, that breaches of security are still a possibility both regarding Our systems and that a data security breach resulting in unauthorized access to Your information can occur in third party system (for example, ISP's and hosting services providers).

As a result, We do NOT warrant or ensure the integrity and security of the data stored in Our systems, including without limitation your information.

We shall notify any user whose information is suspected of being accessed, disclosed, altered or deleted by an unauthorized person, so that he can take appropriate measure to minimize the adverse effect of such a data security breach (the “Breach Notification”). Such Breach Notification will be given in a reasonable time after We learn of said breach, unless We deem, at our sole discretion, that such Breach Notification might hinder and prevent ongoing efforts to detect the source of the breach.

For the avoidance of doubt, a Breach Notification does NOT constitute an admission by Us that the breach occurred as a result of malpractice, failure, bad faith or negligence on Our behalf or that the breach even occurred in our systems.

Changes to this Privacy Policy

This Policy may be modified from time to time at Our sole discretion and each such modification will be effective upon notice to You, including posting on our web site. Upon such modification we will update the “Last Updated” date at the top of this Privacy Policy. Your continued use of the Services following any such modification constitutes your acceptance of the Privacy Policy as so modified. It is therefore important that you review this Privacy Policy regularly.

Enforcement, Choice of Law, Choice of Forum

Every provision of this Private Policy will be construed, to the extent possible, so as to be valid and enforceable. If any provision of this Private Policy so construed is held invalid, illegal or otherwise unenforceable, such provision will be deemed severed from this Private Policy, and all other provisions will remain in full force and effect. This Private Policy will in all respects be governed by and interpreted, construed and enforced in accordance with the laws of Israel without respect to its choice of law provisions. Any action between the parties will be conducted exclusively in competent courts of Tel Aviv, Israel. You irrevocably and exclusively submit to the Tel Aviv, Israeli court any dispute related to this Private Policy or the Services.

You hereby waive the right to bring any claim covered by this dispute resolution provision as a class, consolidated, representative, collective, or private attorney general action, or to participate in a class, consolidated, representative, collective, or private attorney general action regarding any claim covered by this dispute resolution provision brought by anyone else.

Contact Us

If you have any questions or complaints about this Privacy Policy, you may us to [email protected] or contact us at: 20B Galgalei Haplada St., Herzliya, Israel.