True Equity Israel Ltd. ("TruEquity," or "us," "our," "we") respects your right to privacy. Your ability to make informed choices about the uses of your information is important to us. This Privacy Policy explains how TruEquity may use, transfer, store, and disclose any information collected, as well as your ability to control certain uses of the collected information. If not otherwise defined herein, capitalized terms have the meaning given to them in the TruEquity Terms of Service, available at https://www.truequity.com/terms-conditions.php (the “Terms”).

Information We Collect

We collect information from you when you choose to use our Site and/or Services. In order to access and use our Site and/or Services, you will be required to register an account and provide us with certain Personal Information (as defined below). We may also collect Personal Information when you make use of the Site, request information from us, sign up for newsletters or our email lists, complete online forms, or contact us for any other reason.

Personal Information” means information that can be directly associated with a specific person such as a name, telephone number, e-mail address, or information about activities directly linked to a person. Examples of the Personal Information that we collect from you may include your name, phone number, email address and your browsing history on the Site. In addition, when you use the Site, certain information may be automatically gathered about your computer, mobile device, operating system, IP address, and your (geo) location. We may collect such Personal Information through the Site and/or the Services.

It is your voluntary decision whether to provide us with any such Personal Information, but if you refuse to provide such information, we may not be able to register you to the Site and/or provide you with Services.

Any information you upload to the Services, included but not limited to Customer Information is encrypted and TruEquity cannot independently view such information.

How We Use Information

General

TruEquity and any of our trusted third-party subcontractors and service providers may use the information we collect from and/or about you and the information you upload to the Site and/or Services, including but not limited to Customer Information for any of the following purposes: (1) to respond to your inquiries, e-mails, or requests, and to contact and communicate with you; (2) to provide you with the Services; (3) to contact you with informational newsletters and promotional materials relating to our Site and Services, as well as to tell you about future services we believe might be of interest to you; (4) to help us improve the content and functionality of the Site and the Services; (5) review the usage and operations of our Site and Services; (6) to use your data in an aggregated, non-specific format for analytical purposes (as detailed below); and (7) to prevent fraud, protect the security of our Site and Services, and address any problems with the Site and/or Services.

Statistical Information

By analyzing all information we receive, including information concerning users, we may compile statistical information across a variety of platforms and users (“Statistical Information”). Statistical Information helps understand trends and customer-needs so that new products and services may be considered and so existing products and services may be tailored to customer desires. Statistical Information is anonymous and aggregated and we will not link Statistical Information to any Personal Information. We may share such Statistical Information with our partners, without restriction, on commercial terms that we shall determine in our sole discretion. We may provide non-Personal Information that we receive in order to receive an analysis of the use of our Site and Services. In an ongoing effort to better understand and serve the users of the Services, TruEquity often conducts research on its customer demographics, interests and behavior based on the Personal Information and other information provided to us. This research may be compiled and analyzed on an aggregate basis. TruEquity may share this non-identifiable and aggregate data with its affiliates, agents and business partners, but this type of non-identifiable and aggregate information does not identify you or any of the Customers personally. TruEquity may also disclose aggregated user statistics in order to describe our Services to current and prospective business partners as well as to other third parties for other lawful purposes.

Analytics

When you interact with TruEquity through the Site and/or the Services, we receive and store certain non-personally identifiable information. Such information, which is collected passively using various technologies, cannot presently be used to specifically identify you. TruEquity may store such information itself or such information may be included in databases owned and maintained by TruEquity affiliates, agents or service providers. We may use certain analytics tools (“Tools”) to collect information about the use of the Site and/or Services. Such Tools collect information such as how often users visit the Site, what pages they visit when they do so, and what other sites they used prior to coming to this Site. The Tools collect only the IP address assigned to you on the date you visit this Site, rather than your name or other identifying information. We do not combine Personal Information with the information collected through the use of such Tools. We use the information we receive from such Tools only to improve our Site and Services.

Disclosure of Information

TruEquity is not in the business of selling your information. We consider this information to be a vital part of our relationship with you. Except as expressly set forth herein, we will not share your or your Customers and their respective employee's Personal Information with third parties without your explicit permission, except when required by law, regulation, subpoena, court order or other law enforcement related issues, as specified below.

We may share your information, including Personal Information, as follows:

Business Partners, Service Providers, Affiliates, and Subcontractors

We may disclose information, including Personal Information we collect and/or receive from and/or about you and/or your Customers and/or their respective employees, as applicable, to our trusted service providers, business partners, affiliates, and subcontractors, who may use such information to: (1) help us provide you with Services and (2) aid in their understanding of how users are using our Site and Services.

We may use subcontractors and service providers who are located in countries other than your own, and send them information we receive (including Personal Information). All our subcontractors will be subject to non-disclosure and non-use obligations. Nevertheless, some countries may have levels of protection of Personal Information and other information which are not as high as in your country of residence or business.

Business Transfers

We may transfer our databases containing your Personal Information if we sell our business or part of it.

Law enforcement related disclosure

We will fully cooperate with any law enforcement authorities or court order requesting or directing us to disclose the identity, behavior or digital content of any user suspected to have engaged in illegal or infringing behavior. We may also share your Personal Information with third parties if we believe in good faith that disclosure is appropriate to protect our rights, property or safety (including the enforcement of the privacy policy), or to protect the rights, property or safety of third parties.

You can request such Personal Information as specified herein by emailing us at [email protected]

We keep the collected information as long as it remains necessary to provide our clients with access to and use of the Site and Services, comply with our legal obligations, resolve disputes, and enforce our agreements.

How we Protect Information

We make efforts to follow generally accepted industry standards to protect the Personal Information submitted to and collected by us, both during transmission and once we receive it. However, no method of transmission over the Internet, or method of electronic storage is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security. In the event that a data breach occurs, we shall report such breach to the appropriate supervisory authorities and individuals affected by a breach within seventy-two (72) hours of when the breach was detected.

Cookies

A cookie is a small piece of text that is sent to a visitor's browser. The browser provides this piece of text to the device of the originating visitor when this visitor returns. We use cookies to help personalize your Site experience. A “persistent” cookie may be used to help save your settings and customizations across visits. Also, if you log into the Site and/or Services, such a cookie will be used to recognize you as a valid user so you will not need to log in each time you use the Site. Most Web browsers are initially configured to accept cookies, but you can change this setting so your browser either refuses all cookies or informs you when a cookie is being sent. Also, you are free to delete any existing cookies at any time. Please note that some features of the Site may not function properly when cookies are disabled or removed.

Third Party Applications and Services

This privacy policy applies only to the Site and the Services. Portions of the Site may involve linking to or using web applications or services belonging to third parties. We have no control over third-party applications or services, and all use of third-party applications or services is at your own risk. Additionally, we cannot accept responsibility for any payments processed or submitted through such third party applications and/or services, or for the privacy policies of any such applications and/or services. We are not responsible for content or available by means of such applications and/or services. We do not endorse any products or offered by third parties and we urge our users to exercise caution in using third-party applications and/or services.

Communications

We may send you e-mail, texts or other messages and/or a newsletter about us or our events and Services. By using the Site and/or Services, you affirmatively consent to receive such commercial messages. You may remove your Personal Information from our mailing list and stop receiving future communication from us by following the UNSUBSCRIBE link located at the bottom of each communication or by emailing us at [email protected]  You will also be given the opportunity to unsubscribe from commercial messages in any such e-mail or message we send. Please note that we reserve the right to send you service related communications, including service announcements and administrative messages, relating either to your account or to your transactions on the Site, without offering you the opportunity to opt out of receiving them. Should you not wish to receive such communications you may cancel your account.

How to Access and Limit Our Use of Certain Information

Users of our Site and/or Services are given the opportunity to “opt out” of having their Personal Information used for purposes not directly related to the provision of the Services. You may “opt out” at any time, even if you have previously elected to receive direct marketing communications from us. If you prefer to do so and do not want us to use your information except in relation to offering the Services, you may notify us by emailing us at [email protected] (and include your email address).

You have a right to know what information we hold about you and, in some cases and subject to certain conditions, to have such information communicated to you, amended and/or entirely deleted. If you wish to exercise this right, please contact us and let us know that you wish to exercise your right of access and specify which information you would like to receive, amend and/or delete. We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any information, and may charge a fee for exercising this right of access in accordance with applicable law. Where we are not able to provide you with information that you have asked for, we will endeavor to explain the reasoning for this. If you notify us of an amendment or update to your Personal Information, we will take reasonable steps to update or correct Personal Information in our possession that you have previously submitted via this Site or the Services.

We will delete information provided to us by a user within a reasonable time from the receipt of a written (including via e-mail) request by such user to delete such collected information, provided however, that we may retain a copy of certain information for audit and record-keeping purposes.

We cannot restore information once it has been deleted. You acknowledge that due to the nature of the Services and TruEquity's limited ability to access any of your information, you are in the best position to amend and/or delete any information you include and/or upload to the Services You further acknowledge that TruEquity cannot delete only partial information; therefore, once a deletion request has been submitted, we shall delete all information relating to such account.

Children

TruEquity does not knowingly collect personally identifiable information from children under the age of thirteen (13). In the event you become aware that an individual under the age of thirteen (13) has enrolled in the Services without parental permission, please advise us immediately.

Changes

The Site, the Services, and our business may change from time to time. As a result, at times it may be necessary for TruEquity to update this privacy policy. TruEquity reserves the right to update or modify this privacy policy at any time and from time to time without prior notice. Please review this policy periodically, and especially before you provide any Personal Information. This privacy policy was last updated on the date indicated below. Your continued use of the Site and the Services after any changes or revisions to this privacy policy shall indicate your agreement with the terms of such revised privacy policy.

Comments and Questions

If you have any comments or questions about our privacy policy, please contact us at [email protected]

 

Last updated: September 2017

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