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The following policy and cookie policy ("Privacy Policy") governs how Retailors Ltd. (“Company”, “we” or “us“) handle information collected from users of this website and from any other websites, mobile applications, digital services or online platforms operated by Retailors (collectively, the “Site”), and from any individual using them (“User(s)” or “you”). The EU representative of Retailors Ltd. for data protection purposes is Retailors Netherlands B.V. This Privacy Policy also explains how User data is used, shared and protected, what choices you have relating to your data, and how you can contact us.[SR1] 

Please note that this Privacy Policy covers our privacy practice only with respect to the Site.

 I. General

By accessing the Site and/or using the Site, you agree to the terms and conditions set forth in this Privacy Policy, including to the collection and processing of your information. If you disagree to any term provided herein, you may not use the Site.

How do we collect information?

• Information you voluntarily provide us- when choosing to communicate with us via an online form on the Site or email, you may provide us with information such as your name, and your email address, and any other information you choose to share with us.

• Information collected automatically from Users who are visiting the Site- When you visit the Site, it may store or retrieve information on your browser, in the form of cookies ("Site Information"). This Site Information might be about you or your device and is mostly used to make the Site work as you expect it to. The Site Information does not usually directly identify you, but it can give you a better web experience.

 

For what purposes do we use the information?

• In order to contact you and reply to your queries or complaint.

• In order to improve our website and services provided therein.

• For the purpose of proper operation of the website, which includes gathering of statistics regarding the use of the website, in order to adapt the website to your personal preferences and for the purpose of data security.

 

What Site Information do we collect?

• Technical Information – technical information about your browser and device is automatically collected when you visit the Site. Such information consists of the device’s IP address, device ID, the type and version of browser used to access the Site, operating system, the language of the browser and operating system, and type of device.

• Interaction Information – Information about your interactions with the Site or (e.g. whether you clicked on a specific link, where you clicked, time on site, etc.).

 

Which cookies do we use to collect Site Information?

• Essential cookies- in order to collect the Technical Information. These cookies are required for basic site functionality and are therefore always enabled. You can set your browser to block these cookies, but some parts of the Site may not then work. These cookies do not store any personally identifiable information.

• Performance Cookies- in order to collect the Interaction Information. We use Wix Analytics to gather statistics on how our Site is being used, so that we may improve it. Wix Analytics uses cookies that help us to know which pages are the most and least popular and see how visitors move around the site. We have switched on the function «anonymizeIP» so that your IP address is not stored with Google.

 

If you are not interested in getting cookies, you may do so by changing your browser's settings. For this purpose, please use the assistance file in your browser.

 

When we share the information?

As long as we hold personal information about you, we may share such information with our subsidiaries and affiliated companies, and with vendors and service providers for the purposes set forth in this Privacy Policy. We may also disclose your information if we have a good faith belief that disclosure of such information is reasonably necessary to: (i) comply with any applicable law, regulation, legal process or governmental request; (ii) investigate, detect, prevent, or take action regarding illegal activities or other suspected fraud or security issues; (iii) prevent harm to the rights, property or safety of us, our users, yourself or any third party (iv) to establish or exercise our rights to defend against legal claims; (v) where you have provided your consent; or (vi) when we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, spin-off, dissolution or liquidation).

Data security

We ensure that our systems and Site are managed at a proper level of information security. We use a variety of technical and organizational security measures, including encryption and authentication tools, to maintain the safety of your information.

Retention of your Personal Data

We store information for as long as is reasonably necessary for the purposes for which it was collected, as explained in this Privacy Policy. In some circumstances we may store information for longer periods of time, for instance where we are required to do so by law.

Rights relating to the information collected

As long as we store personal information about the you, you have the right to request: (i) access to your personal information.; (ii) an electronic copy of the personal information (portability); (iii) correction of the personal information if it is incomplete or inaccurate; or (iv) deletion or restriction of the personal information in certain circumstances provided by applicable law. These rights are not absolute.

Where we have obtained your consent for the processing your personal information (e.g. when you communicate with us via an online form on the Site or email), you have the right to withdraw your consent at any time.

If you like would to request a copy of your personal data or exercise any of your other rights, please contact us by registered mail or email specified at the end of this Privacy Policy.

Changes to Our Privacy Policy

We reserve the right, at our discretion, to change this Privacy Policy at any time. Such change will be effective upon posting of the revised Privacy Policy on the Site, and the User continued use of the Site thereafter means that he accept those changes.

Get in Touch

If you have any questions or concerns about our Privacy Policy and privacy practices, you are welcome to contact us at: Hermon St., Airport City, P.O.B. 76, 701990, Israel, or at info@retailors.com.  You may also contact our EU representative, Retailors Netherlands B.V., at: Kalverstraat 11, 1012 NX Amsterdam, The Netherlands, or at infoeurope@retailors.com.

 

II. Additional [SR2] Disclosures (GDPR)

This section supplements the general Privacy Policy (as outlined above) and sets additional necessary information about the processing of personal data as required by European data protection law. If there is any inconsistency between this section and the general Privacy Policy, this section prevails for Users located in Europe.

1. Data Controller - Europe

For Users located in Europe, the data controller for processing of personal data including in connection with the Retailors Loyalty Program is Retailors Netherlands B.V.

2. Legal Bases for Processing

For Users located in Europe, we process personal data on one of the following legal bases:

• Performance of a contract with you: including managing Loyalty Program membership, where applicable.

• Based on your consent: when we send marketing communications or in case of some personalization features.

• To pursue our legitimate business and other interests (or those of third parties): this includes managing our internal customer database, carrying out other related business activities such as responding to queries or complaints, improving our services and understanding how we can better serve our customers, generating statistics and analytics about our business, for security purposes including for fraud prevention and to maintain the integrity of our systems, and for enabling us to carry out business transactions such as mergers, sales, reorganisations, transfers of our assets or acquisitions.

• Compliance with statutory obligations: including keeping accurate business records, complying with binding requests from government agencies, regulatory bodies or authorities and complying with other applicable legislation.

3. Your GDPR Rights

Users located in Europe may exercise the following rights (subject to limitations):

• Request access to their personal data or for information about how it is processed

• Request correction or completion of personal data

• Request deletion of personal data

• Request restriction of processing

• Object to the processing of your personal data (including where we rely on our legitimate interests to process your personal data)

• Request the transfer of your personal data to a third party (where that data was processed on the basis of your consent or to perform a contract with you and the processing is carried out using automated means)

If you have provided your consent you can withdraw this consent at any time. Please note that withdrawing consent does not affect the legitimacy of any processing that took place before the consent was withdrawn.

Requests to exercise any of the above rights may be submitted through the contact information for Europe provided in the general Privacy Policy.

If you are not satisfied with the way that we process your personal data or you believe that your data protection rights have been violated, you have the right to lodge a complaint with the supervisory authority in the member state of the European Union that you live or work or where you believe your rights were violated.

4. Data Retention

Personal data is retained only for the period necessary to fulfill the purposes for which it was collected (including providing you with the Loyalty Program, responding to your communications or queries, delivering services you request, or sending you marketing communications where permitted). Marketing-related data is generally retained until you opt out of receiving such communications or until it is no longer necessary for our legitimate business purposes. We may also retain personal data for the period required to comply with applicable legal obligations or for the duration in which retention is advisable under applicable statutes of limitation. After these periods expire, the data will be securely deleted or irreversibly anonymized.

5. Recipients of Personal Data

From time to time, we need to share your personal data with other companies to help us provide our services. These parties will only have access to your personal data if it is strictly necessary for the performance of their tasks and services. In each case that we share personal data, we enter into a contractual agreement to ensure the continued integrity and protection of your personal data.

Recipients of your personal data include:

• Other entities in the Retailors corporate group where necessary for internal administrative purposes, management purposes or other business-related purposes as described in this Privacy Policy.

• External service providers which provide us with services that also require access to personal data such as IT service providers, accountants and professional advisors.

• Third parties to comply with legal requirements such as tax authorities, insurance institutions or law enforcement agencies.

• Third parties in the event of a business transaction such as companies involved in mergers, sales or reorganisations or companies that we acquire.

6. International Transfers

Due to the nature of our business and activities, the personal data that we process may be transferred or otherwise accessible to other entities within the Retailors corporate group. In particular, some processing activities may be performed from Israel. Israel currently benefits from an EU adequacy decision, which permits data transfers without additional safeguards under the GDPR. If the adequacy decision is modified or withdrawn, we will implement appropriate alternative safeguards and notify Users, where required.

It is possible that we may use external service providers located outside the European Economic Area (EEA) in the future. If this is the case, we will implement appropriate safeguards (and apply additional measures where necessary) to ensure that your personal data is protected at an equivalent level to that guaranteed in the EEA. This could include entering into model contractual clauses approved by the European Commission with the recipients of the personal data. In such case, you can request a copy of documentation demonstrating that adequate security measures have been taken.

 

III. Additional Disclosures for Members of Retailors Loyalty Program (Europe)

This section applies in addition to the Privacy Policy and the Additional Disclosures (GDPR) for individuals joining the Retailors Loyalty Program in Europe. If there is any inconsistency with the general Privacy Policy, this section applies for Loyalty Program processing activities.

1. Personal Data Processed for the Loyalty Program

In addition to the information already described in the Privacy Policy, we may process the following data when a User joins the Loyalty Program:

• Registration details (name, email address, country, language, age confirmation, birth date and phone number).

• Purchase history.

• Communication preferences and interactions with loyalty communications (such as opens or clicks).

If the Program introduces new features requiring new categories of data or new processing purposes, we will update this supplement to Privacy Policy and notify Users in advance, seeking consent where required.

2. Purposes of Loyalty Program Processing

Your data may be used to:

• Create and manage your Loyalty Program membership.

• Send program updates, operational notices, and - where consent is provided - marketing communications (incl. personalised benefits).

• Understand engagement with the Program and improve customer experience including understanding how best to design future phases and benefits of the program.

• Respond to any communications or queries submitted by you in relation to the Loyalty Program.

3. Data Storage & Recipients

Personal data collected processed for the Loyalty Program is stored securely in a European data center however it may be processed by other members of the Retailors group of companies or other recipients as set out in the Additional Disclosures (GDPR). Specifically for purposes connected to the Loyalty Program, Retailors works with a third-party marketing platform for managing registration, storing data, executing marketing activities and conducting analytics and performance tracking. This service provider is subject to the same controls and measures as described in the Additional Disclosures (GDPR).

 

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