This ImmiNet (also referred to as “we” or “us”) privacy policy (“Privacy Policy”) describes how we collect and use information pertaining to each of our unregistered visitors and registered users (each, a “Visitor” or “User” (respectively), or “you”), in connection with their access to and use of ImmiNet’s website (the “Site”) (“Services”).

The purpose of this Privacy Policy is to provide you with a clear explanation of when, why and how we collect and use your personal information, as well as an explanation of your statutory rights. This Privacy Policy is not intended to override any rights you might have under applicable data privacy laws.

Read this Privacy Policy and make sure you fully understand our practices in relation to your personal information, before you access or use any of our Services. If you read and fully understand this Privacy Policy, and remain opposed to our practices, you must immediately leave this website, application or service, and avoid or discontinue all use of any of our Services. If you have any questions or concerns regarding this policy, please contact us at [email protected]

This privacy policy is divided into the following sections:

Section 1          information we collect

Section 2          How do we collect such information?

Section 3          How and Why We Use such Information?

Section 4          Sharing Personal Information

Section 5          How Long We Keep Information?

Section 6          Security

Section 7          Public forums and user content

Section 8          Your rights

Section 9          Use of cookies and other tracking technologies

Section 10        Our Policy Towards Children

Section 11        Privacy Policy Changes

Section 12        Indemnification

Section 13        Contacting us

1. Information We Collect

We collect two types of information regarding our Visitors and Users:

• Un-identified and non-identifiable information of a Visitor or un-identified User, which may be made available to us, or collected automatically via his/her use of the Services (“Non-personal Information”). Such Non-personal Information does not enable us to identify the Visitor or User from whom it was collected. The Non-personal Information collected by us mainly consists of demographic information, age, zip code, gender, etc., and technical and aggregated usage information, such as Visitors’ and Users’ browsing activity on the Site, your device, operating system, internet browser, screen resolution, language and keyboard settings, internet service provider, referring/exit pages, date/time stamps, etc.
• Individually identifiable information, namely information that identifies an individual or may with reasonable efforts cause the identification of an individual, or may be of private or sensitive nature (“Personal Information”). The Personal Information collected by us mainly consists of personal details (e.g., name, I.D. number, e-mail address or phone number), billing details (name, physical billing address, payment method, credit card number and transaction details), details regarding a browsing or usage session (IP address, Geo-location and/or device unique identifier), details regarding connected third party accounts (such as the e-mail or username for a connected PayPal, Google or Facebook account), and any other Personal Information provided to us by Visitors and/or Users through their access to and/or use of the Services. For the avoidance of doubt, any Non-personal Information that is connected or linked to Personal Information is deemed and treated by us as Personal Information, as long as such connection or linkage exists.

2. How do we collect such information?

There are two main methods we use:

• We collect your information through your use of the Services. When you visit or use our Services, including when you browse the Site, register a User account, edit your User account and upload information and content, we are aware of it and will usually gather, collect and record such uses, sessions and related information, either independently or with the help of third-party services as detailed in Section 4 below, including through the use of “cookies” and other tracking technologies, as further detailed in Section ‎9 below.
• We collect information which you provide us voluntarily. For example, we collect the Personal Information you provide us when you register to our Services; when you submit or upload such Personal Information as you use any of our Services and/or when you contact us directly by any communication channel.

3. How and Why We Use such Information?
   • Legal Bases for Collecting and Using Information

A note here for those in the European Union about our legal grounds for processing your Personal Information under EU data protection laws, which is that our use of your Personal Information is based on the grounds that:

• The use is necessary in order to fulfill our commitments to you under our Terms of Use or other agreements with you or is necessary to administer your account; or
• The use is necessary for compliance with a legal obligation; or
• The use is necessary in order to protect your vital interests or those of another person; or
• We have a legitimate interest in using your Personal Information, for example, to provide and update our Services, to improve our Services so that we can offer you an even better user experience, to safeguard our Services, to communicate with you, to measure, gauge, and improve the effectiveness of our advertising, and better understand user retention and attrition, to monitor and prevent any problems with our Services and to personalize your experience; or
• You have given us your consent.
  • Purposes for Using Information

We use information about you as mentioned above and for the purposes listed below:

• To provide you the Services;
• To further develop and improve our Services;
• To manage our Users accounts and provide our Users and Visitors with customer support;
• To monitor and analyze trends and better understand how users interact with our Services, which helps us improve our Services and make them easier to use;
• To communicate with you, for example through an email, about offers and promotions;
• To personalize your experience using our Services and provide content recommendations;
• To administrate and maintenance the Site;
• To process e-commerce transactions, contest entries and other matters you initiate;
• To identify preferences in content and advertising;
• To describe our Services to potential advertisers, other third parties, our affiliate companies, and for any other lawful purposes;
• To enhance our data security and fraud prevention capabilities; and
• To comply with any applicable laws and regulations.
  • Where do we store your information?

Visitors’ and Users’ Personal Information may be maintained, processed and stored by us and our authorized affiliates and service providers in Israel, Europe, and in other jurisdictions as necessary for the proper delivery of our Services and/or as may be required by law.

ImmiNet affiliates and service providers that store or process your Personal Information on ImmiNet’s behalf are each contractually committed to keep it protected and secured, in accordance with industry standards and regardless of any lesser legal requirements which may apply in their jurisdiction.

4. Sharing Personal Information
   • How We Share Personal Information

We do not sell our users’ private Personal Information.

We share Personal Information about you in the limited circumstances spelled out below and with appropriate safeguards on your privacy:

• Employees and Independent Contractors. We may disclose your Personal Information to our employees and individuals who are our independent contractors that need to know the Personal Information in order to help us provide our Services or to process the Personal Information on our behalf. We require our employees and independent contractors to follow this Privacy Policy for the Personal Information that we share with them.
• Services. Our disclose of your Personal Information is required for the purposes of providing you with the Services. We may need to disclose Clients Personal Information to Providers, for the purpose of providing Clients with relevant Providers offers, and vice versa. We require all of our Clients and Providers to follow this Privacy Policy for the Personal Information that we share with them.
• Third Party Service Providers.We engage certain trusted third parties to perform functions and provide services to us, including, without limitation, hosting and maintenance, customer relationship, database storage and management, etc. We will share your Personal Information with these third parties, but only to the extent necessary to perform these functions and provide such services, and only pursuant to binding contractual obligations requiring such third parties to maintain the privacy and security of your Personal Information.
• Law Enforcement, Legal Requests and Duties. Where permitted by local data protection laws, we may disclose or otherwise allow others access to your Personal Information pursuant to a legal request, such as a subpoena, legal proceedings, search warrant or court order, or in compliance with applicable laws, if we have good faith belief that the law requires us to do so, with or without notice to you.
• To Protect Rights, Property, and Others.We may disclose your Personal Information when we believe in good faith that disclosure is reasonably necessary to protect the property or rights of ImmiNet, third parties, or the public at large.
• Business Transfers:In connection with any merger, sale of company assets, or acquisition of all or a portion of our business by another company, or in the unlikely event that ImmiNet goes out of business or enters bankruptcy, User information would likely be one of the assets that is transferred or acquired by a third party. If any of these events were to happen, this Privacy Policy would continue to apply to your information and the party receiving your information may continue to use your information, but only consistent with this Privacy Policy.

To clarify, ImmiNet may share your Personal Information in manners other than as described above, pursuant to your explicit approval, or if we are legally obligated to do so. Moreover, ImmiNet may transfer, share, disclose or otherwise use Non-personal Information in its sole discretion and without the need for further approval.

• Transferring Information

Because ImmiNet’s Services are offered worldwide, the information about you that we process when you use the Services in the EU may be used, stored, and/or accessed by individuals operating outside the European Economic Area (“EEA”) who work for us or third party data processors. This is required for the purposes listed in the ‘How and Why We Use Information’ section above. When providing information about you to entities outside the EEA, we will take appropriate measures to ensure that the recipient protects your personal information adequately in accordance with this Privacy Policy as required by applicable law. These measures include:

• In the case of US based entities, entering into European Commission approved standard contractual arrangements with them, or ensuring they have signed up to the EU-US Privacy Shield; or
• In the case of entities based in other countries outside the EEA, entering into European Commission approved standard contractual arrangements with them.

5. How Long We Keep Information

We generally discard such Personal Information about you when we no longer need the information for the purposes for which we collect and use it and we are not legally required to continue to keep it.

We may continue to retain such Personal Information even after you deactivate your User account and/or cease to use any particular Services, as reasonably necessary to comply with our legal obligations, to resolve disputes regarding our Users, prevent fraud and abuse, enforce our agreements and/or protect our legitimate interests.

6. Security

While no online service is 100% secure, we work very hard to protect your Personal Information against unauthorized access, use, alteration, or destruction, and take reasonable measures to do so, such as monitoring our Services for potential vulnerabilities and attacks.

We therefore encourage you to set strong passwords for your User account, and avoid providing us or anyone with any sensitive information of which you believe its disclosure could cause you substantial or irreparable harm.

If you have any questions regarding the security of our Services, you are welcome to contact us at [email protected]

7. Public forums and user content

Our Services offer publicly accessible blogs, communities and support forums. Please be aware that any information you provide in any such areas may be read, collected, and used by others who access them. To request removal of your Personal Information from our blogs, communities or forums, feel free to contact us at [email protected]

In any event, we advise against posting any information (or use any posting means to post information) you don’t wish to publicize on these platforms.

If you upload any content to your User account and provide it in any other way as part of the use of any Service, you do so at your own risk.

8. Your Rights

If you are located in certain countries, including those that fall under the scope of the European General Data Protection Regulation (AKA the “GDPR”), data protection laws give you rights with respect to your Personal Information, subject to any exemptions provided by the law, including the rights to:

• Request access to your Personal Information;
• Request correction or deletion of your Personal Information;
• Object to our use and processing of your Personal Information;
• Request that we limit our use and processing of your Personal Information; and
• Request portability of your Personal Information.

You can usually access, correct, or delete your Personal Information using your account’s settings and tools that we offer, but if you aren’t able to do that, or you would like to contact us about one of the other rights, please contact us at [email protected]

EU individuals also have the right to make a complaint to a government supervisory authority.

9. Use of cookies and other tracking technologies

ImmiNet, together with its partners, uses certain monitoring and tracking technologies (such as cookies, beacons, pixels, tags and scripts). These technologies are used in order to maintain, provide and improve our Services on an ongoing basis, and in order to provide our Visitors and our Users with a better experience. For example, thanks to these technologies, we are able to maintain and keep track of our Visitor’s and Users’ preferences and authenticated sessions, to better secure our Services, to identify technical issues, user trends and to monitor and improve the overall performance of our Services.

Please note that third party services placing cookies or utilizing other tracking technologies through our Services may have their own policies regarding how they collect and store information. Such practices are not covered by our Privacy Policy and we do not have any control over them.

Cookies: In order for some of these technologies to work properly, a small data file (“cookie”) must be downloaded and stored on your device. By default, we use several persistent cookies for purposes of session and user authentication, security, keeping the User’s preferences (e.g., regarding default language and settings), connection stability (e.g., for uploading media, using e-commerce features, etc.), monitoring performance of our services and generally providing and improving our Services.

If you want to delete or block any cookies, please refer to the help and support area on your internet browser for instructions on how to locate the file or directory that stores cookies. Please note that deleting our cookies or disabling future cookies or tracking technologies may prevent you from accessing certain areas or features of our Services, or may otherwise adversely affect your user experience.

10. Our Policy Towards Children

The Site is not directed to persons under 18. If a parent or guardian becomes aware that his or her child has provided us with Personal Information without their consent, he or she should contact us at [email protected]. We do not knowingly collect Personal Information from children under 13. If we become aware that a child under 13 has provided us with Personal Information, we will delete such information from our files.

11. Privacy Policy Changes

We may update this Privacy Policy as required by applicable law, and to reflect changes to our information collection, usage and storage practices. If we make any changes that we deem as “material” (in our sole good faith discretion), we will notify you (as set forth in our Terms of Use) prior to the change becoming effective. We encourage you to periodically check this page for the latest information on our privacy practices.

You are responsible for reviewing the Privacy Policy so you are aware of any changes or updates. Any new features that augment or enhance the current Services, including the release of new tools, services and resources, are subject to the Privacy Policy. Continued use of the Services after any such changes shall constitute your consent to such changes.

Any heading, caption or section title contained herein, is provided only for convenience, and in no way defines or explains any section or provision hereof, or legally binds any of us in any way.

12. Indemnification

You agree to defend, indemnify and hold ImmiNet, its third parties, successors, officers, directors, employees, agents, licensors, suppliers and service providers (and their successors, officers, directors, and employees) harmless from and against any and all claims, actions or demands, costs, liabilities, judgment, losses, expenses and damages (including attorneys’ fees), resulting from, or alleged to result from, your violation of the Privacy Policy.

13. Contacting us

If you have any questions about this Privacy Policy or wish to exercise any of your rights as described in Section 8, please contact us at [email protected]