Last updated: 16.1.2018
PRIVACY and COOKIES POLICY
“Personal Information” means information that we directly associate with a specific person or entity, which may include without limitations, name, address, telephone number, email address, payment information, IP address etc.
Please note that this Policy is governed by the Israeli laws.
- YOUR PRIVACY RIGHTS
- SCOPE AND CONSENT
You hereby authorize Company to collect, record, store, and use information in accordance with this Policy. Your information will include Personal Information about you and your transactions. If you give us Personal Information about yourself, you agree that we, including any company in our group of companies, can use it in the way set out in this Policy.
Please read the following carefully to understand our practices regarding your Personal Information and how we will treat it. You accept this Policy when you access, apply, sign up for, or use our products, services, including ATM services and any other face-to-face and over the counter services, content, features, technologies or functions offered on our Website and all related sites, applications, and services (collectively “Services”). This Policy governs the use of the Website and the Services by our users, including, without limitation:
- When you use the Website and Services, whether by using your computer, your mobile device or any other device, and whether accessing the Services from the Website or from other websites and/or applications or via a face-to-face service provided by the Company.
- Email, other electronic messages including SMS, telephone, web chat, website/portal and other communications between you and Company.
If you are not satisfied with any aspect of it please do not continue to use the Services.
Please note: you are not obligated by law to provide us with any Personal Information.However, without providing it you will not be able to receive the Services, which require registration and provision of details as stated. You hereby acknowledge and agree that you are providing us with Personal Information at your own free will, for the purposes described in this Policy, and that we may retain such Personal Information in accordance with this Policy and any applicable laws and regulations.Providing your details when signing up to the Services constitutes a declaration on your part regarding their correctness
- THE INFORMATION WE COLLECT
Company may collect, receive and store any information, including Personal Information, data and other details submitted, uploaded, posted, transmitted, communicated, shared or exchanged in connection with the Services which may include without limitation:
1. Information you provide us. When you register to our Website and Services you will be requested to provide Personal Information such as: your full name, e-mail address, phone number, address, gender, date of birth, contact details, location, and any other contact information you choose to provide on or via the Services or in any other communications with the Company.
- When you use the Services you will be requested to provide additional Personal Information and KYC information such as: your identification number, a copy of an identification card (e.g. ID card, driving license and/or passport), various business and financial information, including bank account details and any information of your transactions and financial activity with other payment processors, copies of utility bills, etc., and any proof of your identity as we may request, all as may be required by any applicable law and regulations at any given time. The legal regulation framework that applies on the Services may change from time to time, and accordingly we may require some additional information from you in order to align with such new regulation.
- Your Digital Coin wallets information, your digital coin information history and all of the information that may be shared with exchanges or retained on the Blockchain, if and as provided by you, all as may be necessary for the provision of the Services.
- Any other information you may provide regarding your personal situation. This information may include any Personal Information and/or identification information or other personally sensitive data.
- Information you may provide when you communicate with us by phone, e-mail, or otherwise,or once you enter information on our Website, submit survey responses. We may monitor and record phone calls, e-mails, live chats, or other communications between you and our Customer Service representatives or other Company's representatives.
Information we get from your use of our Website and Services:
- Information on your requested transactions provided through your use of the Services.
- Certain types of information which is automatically received, collected and recorded by Company via accessing the Services including certain "traffic data" on its server logs from your browser as specified under clause 2 below.
- Anonymized demographic information, which is not unique to you or identifying you, such as your ZIP code, age, gender, preferences, interests and favorites.
Information we collect from third parties
In order to fulfill our legal obligations to prevent fraud and money laundering, we will obtain information about you from our trusted service providers when you request to use our Services and at any time when we feel it is necessary to prevent fraud, to minimize financial risks or to prevent other risks, for instance - your financial history information.
- INFORMATION WE COLLECT AUTOMATICALLY
We automatically collect Personal Information associated with your use of the Website or Services in any one or more of the following ways:
- We may use third party services, such as Google Analytics, to collect and process such data in order to analyze the traffic to the Website.
- LEGAL BASIS FOR PROCESSING
We will only process your Personal Information where appropriate and necessary to perform our obligations towards you, or on the basis of your consent (including where consent is requested ‘as a condition of business’), or where it is necessary to comply with legal obligations which we are subject to (for example, money laundering or other anti-financial crime checks) or where we have a legitimate interest to process data, subject to such processing not overriding your own rights and freedoms in objecting to such processing.
- HOW WE USE THE INFORMATION
We may use information collected about you, including Personal Information, in any one or more of the following ways: (i) to provide you with the requested Services and transactions, (ii) for financial and identity checks, fraud prevention checks, anti-money laundering and credit checks, including examination of your request for Services according to legal regulatory requirements, risk management examination and fraud detection; (iii) to provide reports that include user's Personal Information to Anti Money Laundering Authorities, and to any other competent authority, with accordance to legal requirements; (iv) to improve the quality of the Services and customize your user experience; (v) for the Company purposes, including among others, service and surveys, statistical research and analysis, using external companies which gather and analyze statistical information about use of Website and Services and keeping track of your login name, passwords, and pages you have visited on the Services; (vi) for customer service, including answering questions and responding to feedback and complaints; (v) for sending communications, administrative e-mails, promotional e-mails messagesand/or reaching you via social media platforms, with respect to Services that may be of interest to you, including segmented advertising and advertisements on behalf of third parties, based on Information in our possession. You may tell us at any time if you do not wish to receive marketing messages from us by contacting us at firstname.lastname@example.org or by choosing to opt out of receiving additional promotional e-mails from Company by clicking on the 'unsubscribe' link in any such e-mail, or by following any instructions Company may include in the message sent to you (the “Opt-out request” or “Request”). Please note that, once we receive your request, it may take an additional period of time for the Opt-Out Request to become effective. Note that, if you opt-out of our promotional communications, Company may still e-mail or communicate with you from time-to-time, if Company needs to provide you with information or for other commercially, non-marketing reasons related to the Services.
- DISCLOSING OF INFORMATION TO THIRD PARTIES
We will not disclose to third parties the Personal Information gathered about you via the Website and Services, inasmuch as this Information identifies you personally, except in the cases set forth hereinafter: (a) To collect, hold and manage your Personal Information through Company's trusted vendors (including their sub-contractors) for example, cloud computing platform and hosting services provider, as reasonable for business purposes, which may be located in a country that does not have the same data protection laws as your jurisdiction; (b) To bill and collect money owed to us by our customers. This includes sending you emails, invoices, receipts, payment vendors, using CRM systems; (c) Risk management. We use trusted third parties to secure transaction processing and to conduct identity verification and prevention checks of fraud or any other illegal activities or otherwise address security or technical issues (for example, Simplex for credit card fraud detection) and of bank transfer transaction, and we send information to those third parties to process your orders and payments; (d) To communicate with our customers about their account and provide customer support, including by our third party trusted vendors; (e) To provide information to our authorized representatives and advisors, including attorneys and accountants, to help us comply with legal, accounting, security and other requirements; (f) To provide, support, and improve the Services we offer. This includes, for example, aggregating information of your use of the Services or Website and sharing this information with third parties to improve and support our Services and to make certain features of the Services available to you; (g) To promote use of our Services. Sharing your contact information with our trusted vendors that assist us in sending e-mails, marketing, advertisements and customer service, including via social media platforms. You can stop receiving our promotional messages by following the unsubscribe instructions included in every email or by contacting us at email@example.com. (h) To satisfy applicable laws and regulations, if and as applicable, including reports to Anti Money Laundering Authorities and to any other competent authority, with accordance to legal requirements, to financial institutions that take part in the processing of the services for compliance purposes, and to comply with a judicial proceeding, court order, or legal process; (i) To enforce the TOS, including investigation of potential violations thereof, and to protect against harm to the rights, property or safety of Company, its users or the public as required or permitted by law; (j) In the event Company goes through a business transition such as a merger, acquisition of all or a portion of Company's assets, your Personal Information may be among the assets transferred and it will be transferred only subject to restrictions similar to those contained herein or as otherwise be required by applicable laws and regulations.
Please note that these third parties may be in other countries where the laws on processing Personal Information may be less stringent than in your country.
Except where permitted as stated, Company does not sell, rent, share or otherwise disclose Personal Information about its users to third parties.
Company may transfer and disclose to third parties or otherwise use non-personal information at its own discretion. We may also disclose your Personal Information to any other third party with your prior explicit consent.
- STORING YOUR DATA
Where is it Stored?Any Personal Information which we may collect may be transferred to, processed and stored at destinations outside your territory and/or outside of the European Economic Area ("EEA"), where your personal information may not be protected by the same standards. By using the Website and Services you consent to such transfer and use of Personal Information outside your country of residence as stated above, for the reasons set out below.
- Where our hosting provider or cloud computing platform is outside your territory or outside the EEA.
- If necessary for providing you with the Services you request.
- Where our anti-fraud agencies, credit reference agencies and other service provider that are based outside your territory or outside the EEA, require access to your data to perform their obligations to us and provide the requested Services to you.
- Where Personal Information is processed by staff operating outside your territory or outside the EEA who work for us or one of our suppliers. Such staff may be engaged in, among other things, the fulfillment of orders, the processing of payment details and support services in provision of the Services. Where such staff is acting on behalf of Company, we will take all steps reasonably necessary to ensure that your Personal Information is treated securely and in accordance with applicable law and with this Policy.
- DATA RETENTION
Company may retain your Personal Information in conformance with applicable laws in order to: prevent fraud, resolve disputes, troubleshoot problems, assist with any investigations, enforce the TOS and take other actions otherwise permitted by law.
In addition, Company will retain your Personal Information after your registration to the Services is cancelled, or if your application is declined or abandoned, for as long as permitted under any applicable law, for legal, regulatory, fraud and other financial crime prevention.
Anonymized, Non-personally identifiable information may be retained and used by Company without limitation.
10. THIRD PARTY SOFTWARE/SERVICE
11. USE OF “COOKIES” AND SIMILAR MEANS
What is a cookie?
Cookies are alphanumeric identifiers that are transferred to and stored in your device through your web browser for record-keeping purposes. Some cookies allow making it easier for you to navigate a website, while others are used to enable a faster log-in process or to allow to track your activities on a website.
Third party cookies
We use third party services to review our Websites statistics, such as Google Analytics. To opt-out of Google Analytics, please go to: https://tools.google.com/dlpage/gaoptout/.
What if you don’t want cookies?
If you want to remove the existing cookies from your device, you can do this by using your browser settings. If you want to block future cookies being placed on your device, you can also change your browser settings to do this.
Unless you have adjusted your browser settingsto block cookies, your use of the Website and the Services constitutes consent on your part to the fact that the Company could perform computerized supervision of your use of the Services by placing “cookies” and web beacons in advertisements or similar means, for the purpose of the Website’s ongoing and proper operation, including for the purpose of gathering statistical data about use of the Website and verifying details, in order to adapt your use of the Website to your personal preferences as well as for information security.
12. THIRD PARTY SERVICES
Certain Services on the Website, such as services related to Facebook, are in fact managed by bodies other than the Company. In these cases, the Services are provided or operated not via the Company computers alone, but rather via the other bodies as stated.
Company is entitled to be assisted by third parties, including advertising companies, for the purpose of presenting advertisements on the Website or on other websites or providing other services. It is possible that these parties use information about your online activity (which does not include identifying personal information), among others in order to provide advertisements for products and services which may interest you.
13. THIRD PARTY LINKS
14. CHILDREN’S ONLINE PRIVACY PROTECTION
Protecting the privacy of children and/or minors is very important to us. If we obtain knowledge that a user is under the age of 18, we will take steps to cancel his/her registration.
15. SECURITY PRECAUTIONS TO PROTECT YOUR INFORMATION
We take a great care in implementing and maintainingreasonable and appropriate security procedures consistent with prevailing industry standards to protect the security of the Website, the Services, and our users’ Personal Information from accidental loss and from unauthorised access, use, alteration and disclosure.
Standard security safeguards are implemented, including strict access controls, to protect your Personal Information from loss, misuse, and unauthorized access, disclosure, alteration and destruction. While we take reasonable precautions against possible security breaches of the Services, no website or internet transmission is completely secure, and we cannot guarantee (i) that unauthorized access, hacking, data loss, or other breaches shall never occur; and (ii) the security of your data while it is being transmitted to and from the Services; any transmission is at your own risk. Company urges you to take steps to keep your Personal Information safe, including your Account password, and to log out of your Account after use.
You are responsible for keeping this password confidential and complying with our instructions. You must not share credentials with anyone else, and you authorise Company to act upon instructions and information from any person that enters your credentials. You also agree to promptly notify us of any information you have provided to us which has changed.
The transmission of information via the internet is not completely secure. Although we will do our best to protect your Personal Information, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
16. TERMS AND CONDITIONS
Please also review the Terms of Services section establishing the use, disclaimers, and limitations of liability governing the use of the Services, at: www.bitsofgold.co.il/terms_and_conditions.
17. RIGHT TO ACCESS
Where applicable, you may have certain rights under data protection legislation, including the right to object to direct marketing and the right to see the Personal Information held about you and you may ask us to make any necessary changes to ensure it is accurate and up to date. If, where applicable, you would like a copy of the Personal Information we hold about you, please submit a request to us by sending an email to firstname.lastname@example.org and we shall respond to your request as soon as we are able to. The right to access Personal Information may be limited in some circumstances by local law requirements. To exercise these rights, please contact us as set forth below.
19. CONTACT US
If you have any additional questions or concerns about this Policy, please feel free to contact us any time through the Services or by writing to us at email@example.com.