Privacy Policy

1. Scope and platforms covered

This Privacy Policy applies to all services operated by MiddleBlock Ltd, including but not limited to:

• The marketing website at https://www.middleblock.com — public-facing information, contact forms, newsletter signup
• The Reporting Dashboard at https://reporting.middleblock.com — analytics platform for content providers
• The Video Management System (VMS) at https://cp.fos.middleblock.com — content upload, metadata management, and distribution platform
• The Marketplace (planned) — on-demand video clip sourcing for publishers
• Any other subdomains, applications, or services operated under the middleblock.com domain or by MiddleBlock Ltd

Throughout this Policy, "Services" refers to all of these platforms collectively.

Different platforms collect different categories of information depending on their function. We describe these specifically in Section 2.

2. Information we collect

2.1 Information you provide directly

We collect personal information you voluntarily provide when interacting with our Services:

On the marketing website (middleblock.com):

• Name and email address (contact form, newsletter signup, partnership inquiries)
• Company name and role (optional, contact form)
• Message content you submit through forms
• Calendar booking details (when scheduling calls via Calendly)

When creating an account on Reporting Dashboard, VMS, or other product platforms:

• Email address and password (used to log into your account)
• Username (chosen by you or assigned)
• Company name and contact information
• Job title or role within your organization
• Phone number (if voluntarily provided)
• Mailing address (when needed for business operations)

For content providers using the VMS:

• Video files you upload (and any personal data contained within them — including metadata, descriptions, captions, and the visual/audio content itself)
• Video metadata (titles, descriptions, tags, categories, SEO information)
• RSS feed URLs and source material
• Channel and brand information

For payment-related interactions (creator payouts):

• Bank account details (for wire transfers)
• PayPal account information
• Tax identification information (where required by law)
• Billing addresses

For customer support and business operations:

• Email correspondence with our team
• Records of communications and inquiries
• Information shared during support sessions or onboarding calls

2.2 Information collected automatically

When you access our Services, we automatically collect:

• IP address and approximate geographic location (city/country)
• Browser type, version, and language
• Device information (operating system, screen resolution, device identifiers)
• Usage data (pages visited, features used, time spent, click patterns)
• Performance data (page load times, errors, crash reports)
• Login/access logs (when you sign in to product platforms — timestamps, source IP)
• Activity logs within product platforms (uploads, downloads, configuration changes, exports)

2.3 Information generated through your use of Services

For users of our product platforms (Reporting Dashboard, VMS), we generate and store:

• Performance metrics — view counts, impressions, revenue, CPM data tied to your account
• Distribution records — which videos went to which publishers, when, with what metadata
• API usage logs — when accessing our APIs programmatically
• Settings and preferences you configure

2.4 Information we do NOT collect

We do NOT collect:

• Sensitive personal information (race, religion, sexual orientation, health data, biometric data)
• Government-issued ID numbers (passport, social security)
• Information from minors (see Section 10)
• Information from third-party data brokers

We do NOT purchase or acquire personal information from third-party data sources.

3. How we process your information

We process your personal information for the following purposes:

Across all platforms:

• Communication: Responding to inquiries, providing support, sending requested information
• Service operation: Operating, maintaining, and improving our Services
• Security: Detecting and preventing fraud, abuse, unauthorized access, and security threats
• Analytics: Understanding how our Services are used to improve user experience
• Legal compliance: Meeting legal obligations, regulatory requirements, and lawful requests

For product platforms (Reporting Dashboard, VMS):

• Account management: Creating, authenticating, and managing user accounts
• Service delivery: Providing the specific features of each platform (analytics, video management, distribution)
• Performance tracking: Calculating metrics, generating reports, tracking distribution
• Data export: Providing reports and data exports as requested

For business operations:

• Payment processing: Calculating and processing creator payouts (quarterly)
• Partnership management: Managing relationships with content providers and publishers
• Contractual obligations: Fulfilling our agreements with partners
• Internal records: Maintaining business and financial records as required by Israeli law

For marketing communications (only if you've subscribed):

• Newsletter delivery: Sending the Middle Block Journal
• Product updates: Notifying subscribers of new features or significant changes

4. Legal bases for processing

For users in the EU/EEA/UK (under GDPR)

We rely on the following legal bases:

• Consent — When you explicitly agree to specific processing (e.g., newsletter signup, optional cookies)
• Contractual necessity — When processing is needed to fulfill our agreement with you (account management, service delivery, payment processing)
• Legitimate interests — When processing supports our legitimate business needs (security, fraud prevention, service improvement) and doesn't override your fundamental rights
• Legal obligation — When processing is required by law (tax records, legal compliance)
• Vital interests — In rare cases, when processing is necessary to protect someone's life or safety

For users in Canada (under PIPEDA)

We process information based on your consent (express or implied), or where permitted by law.

For users elsewhere

We process information consistent with applicable local privacy laws and our legitimate business needs.

5. Sharing your information

We share information only with trusted service providers who help us operate our Services. We do NOT sell, rent, or share your personal information for third-party marketing purposes.

Service providers we share data with:

Other sharing situations:

• Banking/payment partners: When processing creator payouts, we share necessary information with banks (for wire transfers) or PayPal (for PayPal payments). This information is shared solely for executing the payment.
• Publishers and OVPs: When videos flow through our syndication network, video metadata (titles, descriptions, content) is shared with publisher partners. Personal information about content providers is generally NOT shared with publishers, except as required for the partnership (e.g., attribution where applicable).
• Legal disclosures: We may disclose information when required by law (court orders, regulatory requests) or to protect our rights, safety, or property.
• Business transfers: In the event of a merger, acquisition, or sale of business assets, your information may be transferred as part of the transaction.

We require all service providers to handle data securely and only for the specified purposes. All providers are contractually bound by data processing agreements where applicable.

6. Payments and financial data

This section explains how we handle payment-related information for creator payouts.

What we collect for payouts

When you become a content provider and earn revenue through Middle Block, we collect:

• Bank account details (account number, routing/IBAN, account holder name)
• OR PayPal email address
• Tax identification information (where legally required)
• Billing/business address

How we process payment information

• No third-party payment processors are used for outbound payouts. Payments are processed directly by MiddleBlock Ltd through our banking partners or PayPal.
• Payments are made quarterly based on accumulated earnings tracked in your Reporting Dashboard.
• Bank/PayPal information is stored securely in our internal systems with restricted access (only authorized finance personnel).
• No payment information is shared with publishers, OVPs, or other content providers.

Payment information is NOT collected on the marketing site

The middleblock.com marketing website does not collect any payment information. Payment details are only provided after you've established a partnership with Middle Block and are exclusively used for your payouts.

Your rights regarding payment data

You can:

• Request a copy of the payment information we have on file
• Update your payment details (bank account, PayPal, etc.)
• Request deletion (subject to retention requirements for tax/legal records — typically 7 years under Israeli law)

7. Cookies and tracking technologies

On the marketing website

We use:

• Essential cookies — Required for site functionality (session management, security)
• Analytics cookies — Google Analytics 4 to understand site usage (anonymized)
• Functional cookies — Remembering preferences

Visitors in jurisdictions that require opt-in consent see a cookie banner before optional analytics or similar non-essential tracking runs on this marketing site. Use the Cookie preferences control in the site footer (under Legal) to update your choices at any time.

On product platforms (Reporting Dashboard, VMS)

We use:

• Authentication cookies — Required for secure login sessions
• Functional cookies — Storing user preferences, dashboard configurations, recently viewed items
• Security cookies — Preventing unauthorized access, detecting anomalies

These are essential for platform operation and cannot be disabled while using the platforms.

What we do NOT use

• We do NOT use third-party advertising cookies
• We do NOT use targeted advertising trackers
• We do NOT sell or share data with advertising networks

For more on Google Analytics, see https://policies.google.com/privacy. To opt out of Google Analytics across all sites, visit https://tools.google.com/dlpage/gaoptout.

8. Data retention

We retain your information only as long as necessary for the purposes outlined in this Policy, unless required by law to keep it longer:

• Marketing site form submissions: Until you request deletion
• Newsletter subscriptions: Until you unsubscribe
• Product platform accounts: For the duration of your active account, plus 90 days after account closure
• Account activity logs: Up to 24 months
• Performance/analytics data: Up to 24 months in identifiable form, then anonymized
• Payment records: Retained for 7 years to comply with Israeli tax and corporate law
• Communication records: Retained as long as needed for the relationship, plus 2 years
• Video content (VMS): Retained while your account is active. After account termination, content may be retained for up to 90 days for backup purposes, then deleted.

When we no longer need your information, we will delete or anonymize it. If immediate deletion isn't possible (e.g., backup archives), we securely store and isolate it from further processing until deletion is possible.

You can request earlier deletion at any time by emailing business@middleblock.com (subject to legal retention requirements).

9. Information security

We implement appropriate technical and organizational security measures, including:

• TLS/SSL encryption for all data in transit
• Encrypted storage for sensitive data (passwords, payment details)
• Hashed passwords — we never store passwords in plain text
• Access controls — only authorized personnel can access user data
• Regular security reviews and software updates
• Multi-factor authentication available for product platform accounts (recommended)
• Activity logging for security audit purposes
• Backup procedures with appropriate access restrictions

However, no system is 100% secure. While we use industry-standard measures, we cannot guarantee absolute security. You access our Services at your own risk.

If we discover a security incident affecting your information, we will notify you and applicable authorities as required by law.

Your role in security

You are responsible for:

• Keeping your account credentials confidential
• Using strong, unique passwords
• Notifying us immediately of any unauthorized access
• Not sharing your account access with others

10. Children's privacy

Our Services are intended for business users 18 years of age or older. We do NOT knowingly collect, solicit, or market to children under 18.

By using our Services, you represent that you are at least 18 years old, or that you are a parent/guardian of a minor and consent to their use.

If we learn that we've collected information from anyone under 18, we will delete it promptly. If you believe we may have collected such information, contact us immediately at business@middleblock.com.

11. International data transfers

MiddleBlock Ltd is based in Israel. Some of our service providers operate in the United States, European Union, or other jurisdictions.

For users in the EU/EEA/UK, your information may be transferred to and processed in countries outside your home jurisdiction. We rely on:

• Standard Contractual Clauses (SCCs) with our service providers for transfers to the US
• Adequacy decisions by the European Commission where applicable
• Israeli adequacy status — Israel is recognized by the EU as providing adequate data protection

You have the right to request information about the safeguards we use for international transfers.

12. Your privacy rights

Universal rights (all users)

• Right to access — Request a copy of the information we hold about you
• Right to correction — Ask us to correct inaccurate information
• Right to deletion — Request deletion (subject to legal retention requirements)
• Right to unsubscribe — Stop receiving marketing communications
• Right to update — Modify your account information at any time

EU/EEA/UK users (under GDPR)

• Right to data portability — Receive your data in a portable format
• Right to restriction — Limit how we process your data
• Right to object — Object to processing based on legitimate interests
• Right not to be subject to automated decision-making
• Right to withdraw consent — Withdraw consent at any time
• Right to lodge a complaint — File a complaint with your local data protection authority

If located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

Canadian users (under PIPEDA)

Rights including access, correction, and withdrawal of consent.

How to exercise your rights

Email business@middleblock.com or contact us through https://www.middleblock.com/contact. We respond within 30 days (or as required by applicable law).

We may verify your identity before processing requests. For sensitive requests (deletion, data export), we may require additional verification.

13. US state privacy rights

If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia, you have specific privacy rights.

Categories of personal information we collect

Your US state privacy rights

You have the right to:

• Know whether we process your personal data
• Access your personal data
• Correct inaccuracies
• Delete your personal data
• Obtain a copy of your data
• Opt out of the sale or sharing of personal data
• Non-discrimination for exercising your rights
• Limit use of sensitive personal information (where applicable)

Sale and sharing

We have NOT sold or shared personal information to third parties for monetary or valuable consideration in the preceding 12 months. We will NOT sell or share personal information in the future. To the extent any tracking technology might be considered "sharing" under California law, you can opt out via the cookie consent banner or browser settings.

How to exercise your rights

Email business@middleblock.com or visit https://www.middleblock.com/contact. We may verify your identity before processing your request.

California "Shine the Light" law

We do not share personal information with third parties for their direct marketing purposes, so this law does not affect our practices.

14. Do-Not-Track signals

Most browsers offer a Do-Not-Track ("DNT") feature. As no uniform standard has been finalized, we do not currently respond to DNT signals. If a standard is adopted, we will update this Policy.

15. Updates to this policy

We may update this Privacy Policy from time to time. The updated version will show a new "Last updated" date at the top.

For material changes, we may notify you by:

• Posting a prominent notice on our websites
• Sending direct notifications (if you've subscribed to updates or are an account holder)
• Displaying notices within product platforms

We encourage you to review this Policy periodically.

16. Contact us

For privacy questions, requests, or concerns:

MiddleBlock Ltd
Shtulim 59
Tel Aviv, Israel 6762559

Email: business@middleblock.com
Website: https://www.middleblock.com
Contact form: https://www.middleblock.com/contact

For EU/EEA users: You have the right to contact your local data protection authority. The European Data Protection Board provides a list at https://edpb.europa.eu.

For Swiss users: Federal Data Protection and Information Commissioner (FDPIC) — https://www.edoeb.admin.ch

17. Reviewing, updating, or deleting your data

You may request to review, update, or delete the personal information we hold about you by:

1. Emailing business@middleblock.com
2. Contact form at https://www.middleblock.com/contact
3. Updating directly in your account settings (for product platform users)

We respond within 30 days (or as required by applicable law). Some rights may be limited by legal retention requirements (e.g., tax records). We'll explain any limitations in our response.