Privacy Policy

About This Policy

This Privacy Policy (Privacy Policy) describes the privacy practices of Tombolo Ltd, a private company incorporated under the Israeli law(hereinafter, “Tombolo” or the “Company“) (collectively, “Tombolo ”, “we,” “our,” or “us”) with respect to how we collect, use, store, disclose and transfer the information you provide when you interact with us through our websites and when you communicate with us through other means such as email or by telephone.

This Privacy Policy governs websites owned or operated by Tombolo that provide a link to this Privacy Policy on the homepage of the site (“Tombolo Sites”).

All your personal Information shall be held and used in accordance with Data Protection Laws, being: (i) the Data Protection Act 1998, until the effective date of its repeal (ii) the General Data Protection Regulation ((EU) 2016/679(GDPR) and any national implementing laws, regulations and secondary legislation, for so long as the GDPR is effective in the UK, and (iii) any successor legislation to the Data Protection Act 1998 and the GDPR, in particular the Data Protection Bill 2017-2019, once it becomes law and any other legislation relating to the protection of Personal Data.

Data Controller

Tombolo is the Data Controller and responsible for your personally identifiable information (Personal Data) as listed in clause 3 below.

Types of Information We Collect About You

Information you or your organization may provide

Depending upon the Tombolo Site you are accessing or other method of contact, we may collect receive from you, use, store and transfer different kinds of personal data about you such as:

Information collected automatically

As you navigate the Tombolo Site, Tombolo may also automatically collect information about you or your computer that does not directly identify you. This information may include IP address and device identifiers, information about your Internet connection and information about the equipment or software you use to access the Tombolo Website. Such information is only collected to the extent that it is necessary for us to provide services that you use, to optimize your user experience, and/or to make improvements to the Tombolo Website and service offerings. Tombolo does not serve third party advertising.

You have the ability to choose to opt out of inclusion of your personal information at the point of disclosure.  You may choose whether your personal information is (i) to be disclosed to a third party or (ii) to be used for a purpose that is materially different from the purpose(s) for which it was originally collected or subsequently authorized by you. You may also opt out of use of your personal information as outlined below under Access, Correction, and Erasure.

We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your Personal Data but is not considered Personal Data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this privacy notice.

We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

How We Collect Information About You?

We collect information about you in three main ways: 

The legal basis for processing your Personal Data

Tombolo will only process Personal Data where there is a lawful basis as per Data Protection Laws. This lawful basis shall be one or more of the following: (a) Express consent from you; (b) In order to perform and/or complete a contract with a third party; (c) To comply with a legal obligation; (d) To protect your vital interest; (e) It is in the public int

Legitimate interests are a flexible basis upon which the law permits the processing of an individual’s Personal Data. To determine whether we have a legitimate interest in processing your data, we balance the needs and benefits to us against the risks and benefits for you of us processing your data. This balancing is performed as objectively as possible by our Data Protection Lead. You are able to object to our processing and we shall consider the extent to which this affects whether we have a legitimate interest. If you would like to find out more about our legitimate interests, please contact us via the email address set out above.

How we share your information

In certain circumstances we will share your Information with other parties. Details of those parties are set out below along with the reasons for sharing it.

Data Retention and Deletion

Tombolo may retain your information for a period of time consistent with the original purpose of collection, and for a reasonable time thereafter in accordance with applicable law. We also may retain your information during the period of time needed for Tombolo to conduct audits, comply with our legal obligations, resolve disputes and enforce our agreements.

If you request to delete your personal information, we will endeavor to fulfill your request but some personal information may persist in backup copies for a certain period of time and may be retained as necessary for legitimate business purposes or to comply with our legal obligations.

Your rights and Choices

Communication Preferences and Opt-outs

When reading this notice, it might be helpful to understand that your rights arising under Data Protection Laws include:


Tombolo uses cookies to manage and improve the functionality of our websites and to enable us to better understand how you use our services. A cookie is a tiny text document, which usually includes anonymous information about the user. You can set your browser to not accept Tombolo’ cookies, but you might not be able to access all aspects of the Tombolo Site you are visiting.

Data Security

Tombolo takes commercially reasonable security measures to protect against unauthorized access to, or unauthorized alteration, disclosure or destruction of, data that you share and that we collect and store. These security measures may include practices such as keeping your data on a secured server behind a firewall, internal reviews of our data collection practices and platforms, industry-standard encryption technologies, and physical security measures to guard against unauthorized access to systems where we store your information.

If you have reason to believe that a third-party has gained unauthorized access to your information, please contact us immediately at If Tombolo becomes aware of any data breach, we will notify affected individuals or, with respect to Tombolo Services, affected organizations as soon as reasonably possible.

Does your Personal Data leave the EU?

Your Personal Data may be transferred to our affiliated companies 

We may transfer your Personal Data to third parties which are outside the EU, this will be carried out in accordance with Data Protection Laws and for the purposes of carrying out any services we provide for you.

Tombolo may from time to time use overseas web and IT providers. We can disclose such details of what data is sent where, and the safeguards in place, following your written request.

Changes to our Privacy Policy

From time to time, we may revise this Privacy Policy. If we make material revisions to the way we collect or use your information, we will provide you with notice of those changes by either: (1) notifying you directly, (2) announcing the change on the Tombolo Website, and/or (3) posting the revised version of this Privacy Policy online.

You can determine when this Privacy Policy was last revised by referring to the “Last Updated” legend at the bottom of this page. By continuing to use Tombolo Website after such updates, you affirm your agreement with the terms of the Privacy Policy. If we have made changes you don’t agree with, you are free to request that we delete your information as set out in the Your Rights and Choices section above.


For any questions on this Privacy Policy or our data practices, you can contact us at 

Despite the measures outlined in this Privacy Policy, Tombolo cannot guarantee the security of any information that is disclosed online. To the extent permissible under law, Tombolo shall not be liable for any direct, indirect, special, incidental, consequential or punitive damages relating to this Privacy Policy.