ISRAEL SECONDAY FUND PRIVACY POLICY
Last Updated: October 01, 2020
In order to ensure transparency and give you more control over your personal information, this privacy policy (“Privacy Policy”) governs how we, ISFM Ltd. (together, “Israel Secondary Fund” “we”, “our” or “us”) use, collect and store personal data we collect or receive from or about you (“you”) such as in the following use cases:
- When you browse or visit our website, https://www.israelsecondary.com/ (“Website”)
- When you make use of, or interact with, our Website
- When you contact us
We greatly respect your privacy, which is why we make every effort to provide a platform that would live up to the highest of user privacy standards. Please read this Privacy Policy carefully, so you can fully understand our practices in relation to personal data. “Personal Data” or “Personal Information” means any information that can be used, alone or together with other data, to uniquely identify any living human being.
Important note: Nothing in this Privacy Policy is intended to limit in any way your statutory right, including your rights to a remedy or means of enforcement.
Table of contents:
- What information we collect, why we collect it, and how it is used
- Period of storage of collected Personal Data
- How we protect and retain your Personal Data
- How we share your Personal Data
- Your privacy rights
- Use by children
- Interaction with third party products
- Log files
- Analytic tools
- Contact us
This Privacy Policy can be updated from time to time and, therefore, we ask you to check back periodically for the latest version of this Privacy Policy. If we implement significant changes to the use of your personal data in a manner different from that stated at the time of collection, we will notify you by posting a notice on our Website or by other means.
- WHAT INFORMATION WE COLLECT, WHY WE COLLECT IT, AND HOW IT IS USED
Specific Personal Data we collect |
Why is the Personal Data collected and for what purposes? |
Third parties with whom we share your Personal Data |
Consequences of not providing the Personal Data |
When you browse or visit our Website |
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Cookies, analytic tools and log files For more information, please read our cookies policy [link] |
Analytics, analysis, market research, to improve our Website |
3rd parties with whom we share your Personal Data such as:
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Certain Website features may not be available Read more about the purposes of each cookie here [add link to cookies policy] |
When you make use of, or interact with, our Website |
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When you contact us |
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3rd parties with whom we share your Personal Data such as:
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Cannot respond your request Cannot customize your experience Cannot send you marketing communications |
Finally, please note that some of the abovementioned personal data will be used for detecting, taking steps to prevent, and prosecution of fraud or other illegal activity, to identify and repair errors, to conduct audits, and for security purposes. Personal Data may also be used to comply with applicable laws, with investigations performed by the relevant authorities, law enforcement purposes, and/or to exercise or defend legal claims. In certain cases, we may or will anonymize or de-identify your Personal Data and further use it. “Anonymous Information” means information which does not enable identification of an individual user, such as aggregated information about the use of our services. We may use Anonymous Information and/or disclose it to third parties without restrictions (for example, in order to improve our services and enhance your experience with them).
- PERIOD OF STORAGE OF COLLECTED PERSONAL DATA
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- Personal Data. Your Personal Data (as described above) will be stored until we no longer need the information and proactively delete it or you send a valid deletion request. Please note that we will retain it for a longer or shorter period in accordance with data retention laws.
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- Cookies. This depends on the cookie in question. Some cookies (e.g. essential cookies) cannot be disabled. You may also control and delete these cookies through your browser settings. Read more in our cookie policy [*].
- HOW WE PROTECT AND RETAIN YOUR PERSONAL DATA
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- Security. We have implemented appropriate technical, organizational and security measures designed to protect your personal data. However, please note that we cannot guarantee that the information will not be compromised as a result of unauthorized penetration to our servers. As the security of information depends in part on the security of the computer, device or network you use to communicate with us and the security you use to protect your user IDs and passwords, please make sure to take appropriate measures to protect this information.
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- Retention of your Personal Data. In addition to the retention periods mentioned above, in some circumstances we may store your Personal Data for longer periods of time, for example (i) where we are required to do so in accordance with legal, regulatory, tax or accounting requirements, or (ii) to consider potential business opportunities and for archival and record-keeping purposes and other internal compliance and policies, or (iii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, or (iv) if we reasonably believe there is a prospect of litigation relating to your Personal Data or dealings.
- HOW WE SHARE YOUR PERSONAL DATA
In addition to the recipients described above, we may share your personal data as follows:
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- With our business partners with whom we jointly offer products or services. We may also share Personal Data with our affiliated companies.
- To the extent necessary, with regulators, courts or competent authorities, to comply with applicable laws, regulations and rules (including, without limitation, federal, state or local laws), and requests of law enforcement, regulatory and other governmental agencies or if required to do so by court order;
- If, in the future, we sell or transfer, or we consider selling or transferring, some or all of our business, shares or assets to a third party, we will disclose your personal data to such third party (whether actual or potential) in connection with the foregoing events;
- In the event that we are acquired by, or merged with, a third party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer, disclose or assign your personal data in connection with the foregoing events; and/or
- Where you have provided your consent to us sharing or transferring your personal data (e.g., where you provide us with marketing consents or opt-in to optional additional services or functionality).
- YOUR PRIVACY RIGHTS
Rights: The following rights (which may be subject to certain exemptions or derogations) shall apply to certain individuals:
- You have the right to be informed and access personal data held about you;
- You have the right to request that we rectify any personal data we hold that is inaccurate or misleading;
- You have the right to require that we stop, or not begin, or cease the processing for a specified purpose or in a specified way;
- You have the right to stop direct marketing and automated decision making;
- You have the right to request the erasure/deletion of your personal data;
- You have a right to lodge a complaint with the Ombudsman. We ask that you please attempt to resolve any issues with us before you contact your local supervisory authority and/or relevant institution.
You can exercise your rights by contacting us at info@israelsecondary.com. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly in accordance with applicable law or inform you if we require further information in order to fulfil your request. When processing your request, we may ask you for additional information to confirm or verify your identity and for security purposes, before processing and/or honoring your request. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive. In the event that your request would adversely affect the rights and freedoms of others (for example, would impact the duty of confidentiality we owe to others) or if we are legally entitled to deal with your request in a different way than initial requested, we will address your request to the maximum extent possible, all in accordance with applicable law.
- USE BY CHILDREN
We do not offer our products or services for use by children and, therefore, we do not knowingly collect personal data from, and/or about children under the age of eighteen (18). If you are under the age of eighteen (18), do not provide any personal data to us without involvement of a parent or a guardian. We do not intend to offer services directly to children. In the event that we become aware that you provide personal data in violation of applicable privacy laws, we reserve the right to delete it. If you believe that we might have any such information, please contact us at info@israelsecondary.com.
- INTERACTION WITH THIRD PARTY PRODUCTS
We enable you to interact with third party websites, mobile software applications and products or services that are not owned or controlled by us (each a “Third Party Service”). We are not responsible for the privacy practices or the content of such Third Party Services. Please be aware that Third Party Services can collect Personal Data from you. Accordingly, we encourage you to read the terms and conditions and privacy policies of each Third Party Service.
- LOG FILES
We use log files. The information inside the log files includes internet protocol (IP) addresses, type of browser, Internet Service Provider (ISP), date/time stamp, referring/exit pages, clicked pages and any other information your browser may send to us. We use such information to analyze trends, administer the Website, track users’ movement around the Website, and gather demographic information.
- ANALYTIC TOOLS
- Google Analytics. The Website uses a tool called “Google Analytics” to collect information about use of the Website. Google Analytics collects information such as how often users visit this Website, what pages they visit when they do so, and what other websites they used prior to coming to this Website. We use the information we get from Google Analytics to maintain and improve the Website and our products. We do not combine the information collected through the use of Google Analytics with personal information we collect. Google’s ability to use and share information collected by Google Analytics about your visits to this Website is restricted by the Google Analytics Terms of Service, available at https://marketingplatform.google.com/about/analytics/terms/us/, and the Google Privacy Policy, available at http://www.google.com/policies/privacy/. You may learn more about how Google collects and processes data specifically in connection with Google Analytics at http://www.google.com/policies/privacy/partners/. You may prevent your data from being used by Google Analytics by downloading and installing the Google Analytics Opt-out Browser Add-on, available at https://tools.google.com/dlpage/gaoptout/.
We reserve the right to remove or add new analytic tools.
- CONTACT US
If you have any questions, concerns or complaints regarding our compliance with this notice and the data protection laws, or if you wish to exercise your rights, we encourage you to first contact us at info@israelsecondary.com.