>Privacy Policy
Privacy Policy Hagshama 2017-03-10T16:15:26+00:00

Hagshama Privacy Policy

Introduction

We at Keren Hagshama Ltd. (“we”, “us“) respect your privacy and are committed to protect the privacy of our users (“user” or “you”).

This Privacy Policy outlines our practices with respect to collecting, using and disclosing your information through the use of our website and the Hagshama application controlled by us (collectively: “the Services”).

The Privacy Policy is a part of our End User License Agreement and is incorporated therein by references.

We encourage you to read the Privacy Policy carefully and use it to make informed decisions. By using our Services, you agree to the terms of this Privacy Policy and your continued use of the Services constitutes your ongoing agreement to this Privacy Policy.

In this Privacy Policy you will read about:

  • What type of information we collect
  • How we collect your information
  • How we use the information we collect
  • With whom we share the information, and for what purpose
  • For how long we retain the information we collect
  • How do we safeguard your information
  • How we use the information we collect for marketing purposes
  • How to contact us
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What type of information we collect

We collect two types of data and information from our users.

The first type of information is un-identified and non-identifiable information pertaining to a user(s), which may be made available or gathered via the User’s use of the Services (“Non-personal Information”). We are not aware of the identity of the User from which the Non-personal Information was collected. Non-personal Information which is being collected may include your aggregated usage information and technical information transmitted by your device, including certain software and hardware information (e.g. the type of browser and operating system your device uses, language preference, access time and the domain name of the website from which you linked to the Services; etc.), in order to enhance the functionality of our Services.

The second type of information is individually identifiable information, namely information that identifies an individual or may with reasonable effort identify an individual (“Personal Information”). The Personal information we collect through our Services includes information which is submitted directly by the user, such as: phone number; full name; e-mail address; home address; identification number; signature; social security number; passport number; copy of the user’s identity card and passport; bank account number; payment means; and other financial information that we may need in order to provide our Services (e.g. details regarding your annual income, experience in investments, etc.).

We may also collect Personal Information from your device (e.g. geolocation data, IP address) and information on your activity on the Services (e.g. pages viewed, online browsing, clicks, actions, etc.).

If we combine Personal Information with Non-personal Information, the combined information will be treated as Personal Information for as long as it remains combined.

How we collect information

There are two main methods we may use to collect information:

  1. We collect information through your use of the Services. In other words, when you are using our Services, we are aware of it and may gather the information relating to such usage, either independently or through the help of third-party services as detailed below.
  2. We collect information which you provide us voluntarily. For example, we collect Personal Information which you provide when you register and use the Services. In addition, you may also share with us email addresses of your friends or acquaintances in order to notify them about an investment that may interest them.

How we use the information we collect

We use and share Personal Information in the manners described in this Privacy Policy. The Personal Information will be disclosed to a third party only to the extent required for the specific purpose, as stipulated in this Privacy Policy, and in such case we require the relevant third party to agree to process such information in compliance with our Privacy Policy.

In addition to the purposes listed above, the Personal Information we collect is used for the following purposes:

  • To set up your account and to provide our Services;
  • To identify and authenticate your access to certain features of the Services;
  • To communicate with you in order to keep you informed of our latest updates and to provide you information with regard to investments that may interest you.
  • To perform a research or to conduct anonymous analytics in order to improve and customize our Services to your needs and interests;
  • To support and troubleshoot our Services, to respond to your queries and communicate with you;
  • To investigate violations and enforce our policies, and as required by law, regulation or other governmental authority, or to comply with a subpoena or similar legal process or respond to a government request.

With whom we share the information we collect

We do not rent, sell, or share your Personal Information with third parties except as described in this Privacy Policy.

We may transfer or disclose Personal Information to our subsidiaries, affiliated companies, subcontractors or such other trusted third party service providers or partners, who are located in different jurisdictions across the world, for the purpose of: (a) storing or processing such information on our behalf (e.g. on cloud computing services) or to assist us with our business operations, to authenticate your access and to provide and improve our Services; (b) performing research, technical diagnostics, analytics or statistical purposes; (c) e-mail marketing, in accordance with our marketing policy (see below under ”Marketing”).

We may also disclose to our registered users Personal Information relating to other users, who joined the Services following their recommendations (i.e. through the “sharing with a friend” feature). The Personal Information which is being disclosed in such event may include the user’s full name, past and current investments, email address, etc.

We may also disclose Personal Information, or any information you submitted via the Services if we have a good faith belief that disclosure of such information is helpful or reasonably necessary to: (i) comply with any applicable law, regulation, legal process or governmental request; (ii) enforce our policies (including our Agreement), including investigations of potential violations thereof; (iii) investigate, detect, prevent, or take action regarding illegal activities or other wrongdoing, suspected fraud or security issues; (iv) to establish or exercise our rights to defend against legal claims; (v) prevent harm to the rights, property or safety of us, our users, yourself or any third party; or (vi) for the purpose of collaborating with law enforcement agencies and/or in case we find it necessary in order to enforce intellectual property or other legal rights.

Third party collection of information

Our policy only addresses the use and disclosure of information we collect from you. To the extent that you disclose your information to other parties via our Services (e.g. by clicking on a link to any other website or location) or via other sites throughout the internet, different rules may apply to their use or disclosure of the information you disclose to them.

It is important to note that such third party services may have their own privacy policies and we advise you to read them carefully. Inclusion of a link to third party website or service is not a recommendation of such a website or service. Third party sites may contain information or service that is illegal, unreasonable or that some people may find inappropriate or offensive. Before using third party sites and services or before making a purchase, we recommend you to read and understand those sites’, service’ or product’s terms and conditions, warranty, and privacy policies and to ensure you agree to their terms. You acknowledge that we are not responsible for the products, services, or descriptions of those products or services that you receive from third party sites or to the content or privacy practices of those sites, and that this Privacy Policy does not apply to any such third party products and services. You are knowingly and voluntarily assuming all risks of using third party sites to purchase products and services. You agree that we shall have no liability whatsoever with respect to such third party sites and your usage of them.

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For how long we retain the information we collect?

We value your privacy and control over your Personal Information, and therefore you may, at any time, change, update or request to remove (subject to any other legal obligation that may require us to keep the information) your Personal Information by contacting us at info@kerenhagshama.co.il.

Please note that unless you instruct us otherwise we retain the information we collect for as long as needed to provide the Services and to comply with our legal obligations, resolve disputes and enforce our agreements.

We may rectify, replenish or remove incomplete or inaccurate information, at any time and at our own discretion.

How do we safeguard and transfer your information?

We take great care in implementing and maintaining the security of the Services and your information. We employ industry standard procedures and policies to ensure the safety of our users’ information, and prevent unauthorized use of any such information. Although we take reasonable steps to safeguard information, we cannot be responsible for the acts of those who gain unauthorized access or abuse our Services, and we make no warranty, express, implied or otherwise, that we will prevent such access.

We will store your Personal Information on our trusted cloud service providers which may be located in countries outside the European Union. The data protection and other laws of these countries may not be as comprehensive as those in the European Union − in these instances we will take steps to ensure that a similar level of protection is given to your Personal Information. You hereby consent to transfer of your Personal Information to countries outside the European Union.

If you feel that your privacy was treated not in accordance with our policy, or if any person attempted to abuse our Services or acted in an inappropriate manner, please contact us directly at info@kerenhagshama.co.il.

Affiliates and corporate transaction

We may share your information, including your Personal Information, with any subsidiaries, joint ventures, or other companies under a common control (collectively “affiliated companies“). We may share Information, including Personal Information, in the event of a corporate transaction (e.g. sale of a substantial part of our business, merger, consolidation or asset sale). In the event of the above, our affiliated companies or acquiring company will assume the rights and obligations as described in this Privacy Policy.

Minors

The Services are not designated to users under the age of 18. We do not knowingly collect Personal Information from children. If you are under 18, you should not download or use the Services nor provide any Personal Information to us.

In the event that we become aware that a user under the age of 18 has shared any information, we will discard such information. If you have any reason to believe that a child under the age of 18 has shared any information with us, please contact us at info@kerenhagshama.co.il.

Marketing

We may use your Personal Information, such as your email address ourselves or by using our third party subcontractors for the purpose of providing you with promotional material, which we believe may interest you.

Out of respect to your right to privacy, at any time, you may request to unsubscribe and discontinue receiving marketing offers by contacting us at info@kerenhagshama.co.il.

If you unsubscribe we will remove your email address from our marketing distribution list. Please note that even if you unsubscribe from our marketing mailing list, we may continue to send you service-related updates and notifications.

Updates or amendments to the Privacy Policy

We may revise this Privacy Policy from time to time, in our sole discretion, and the most current version will always be posted on our website (as reflected in the “Last Revised” heading). We encourage you to review this Privacy Policy regularly for any changes. In case of material changes we will notify you through our Services or by email. Your continued use of the Services, following the notification of such amendments on our website, constitutes your acknowledgement and consent of such amendments to the Privacy Policy and your agreement to be bound by the terms of such amendments.

How to contact us

If you have any general questions about the Services or the information that we collect about you and how we use it, please contact us at info@kerenhagshama.co.il.

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