Silver Road Capital Ltd. (referenced below as “The Company”, “We”, “Us” or “Our”, as applicable), respects your privacy and is committed to protect the Personal Information that you share with Us. This policy describes the scope of Personal Information collection in respect of The Company’s website.
1. DATA AND PERSONAL INFORMATION WE COLLECT
may be used to identify an individual.
The Personal Information types are collected in accordance with your use of Our website and may
- Contact information – Your full name and/or nickname, a company or other entity to which
you are affiliated, e-mail address and phone number.
- Application/request information, questions, inquiries, comments, responses and/or derived
correspondences with the Company.
- Any information provided by you when you interact with Us.
Other Information – We may use Google Analytics to collect user interaction data of Our website users, in order to adjust your browsing and usage experience on our website and to derive statistical insights in those aspects. You can find further information on the Google website at https://www.google.com/intl/en/policies/technologies/ads/. We may also collect other analytics tools to collect information about the use of Our website and types of technical data in the context of the use of Our website, including information about your computer or mobile device or any other device and system, software, location data, time zone, Internet Protocol (IP) address, language preference etc.
In addition, you acknowledge that you are not required under applicable law to provide us with any of your Personal Information, and that if you provide such information, it’s at your own free will and consent
2. PURPOSE OF DATA COLLECTING AND PROCESSING
The purposes of Our collection and processing of information in the context of Our website are:
- To address users’ applications, inquiries, questions, requests, comments, responses etc.
- To study the users’ interaction with Our website and/or to study the behavior of users in the context of their use of Our website, for the purpose of assessing the website performance and/or effectiveness.
3. LEGAL BASIS FOR PROCESSING
In addition to your consent to the collection and processing of information as set forth herein, Our collection and processing of information, including Personal Information, is based on the following:
- To the extent that we use the information, including Personal Information, to provide customer service and/or customer support and/or to interact with Our website users, including addressing users’ applications, inquiries, questions, requests, comments and responses, the basis for Our collection of data is our legitimate interest to conduct an effective interaction with Our users which are customers and/or potential customers.
- To the extent that we use the information to analyse users’ interaction with Our website, the basis for Our collection of data is our legitimate interest to study the use of Our website and the behavior of users in the context of their use of Our website.
- To the extent that we use the Personal Information for advertising or promotional activities, we will request your specific, freely-given, unbundled, informed and separate consent to such uses.
4. INFORMATION SHARING AND DISCLOSURE
The Company is committed to protecting your privacy and will not share or disclose information about you, unless otherwise permitted under the following terms and/or circumstances:
- When we have your consent to share such information;
- When we need to share your information to provide the product and/or service you have requested as part of our contractual relationship;
- When we need to send the information to companies who work on Our behalf to provide a product and/or service you have requested as part of our contractual relationship (they are prohibited from using that information for any other purpose);
- For the purpose of analysis and statistics, provided that such disclosure is done anonymously and is non-personal identifiable;
- In the event of sale or transfer, in whole or in part, of the Company or any of its affiliate’s shares or assets, in cases of mergers or in case of negotiations with respect to the foregoing;
- If required to do so by applicable law, or in the good-faith belief, that (i) disclosing such information is necessary to comply with any applicable law or respond to any court order, search warrant or equivalent, or where in reasonable belief an action is needed in order to protect the personal safety of any individual; and (ii) such disclosure is appropriate or necessary in order to enforce the Terms and Conditions, take precautions against liabilities, investigate and defend against any third party claims or allegations, assist government enforcement agencies, protect the security or integrity of Our website and servers and protect Our rights and property.
All Personal Information as described above may be stored on servers and/or transferred (for the above purposes) to recipients which may be located outside of Israel, and in some cases may have a lower level of protection than that within the applicable law. You acknowledge and agree to such transfer of personal information, and the Company undertakes that it will take the necessary measures to ensure a sufficient level of protection.
Other than as described above, any other transfer of your Personal Information to third parties will be subject to your consent.
We may use industry-wide technologies such as cookies (a string of information that can be stored on your device, if your device is set to permit storage of cookies), or other similar tracking technologies, which store certain local information on your device to help us learn more about how you use Our website and enhance your experience. You may adjust your device or operating system settings to limit this tracking or to decline cookies, but by doing so, you may not be able to use certain features on Our website. It is possible to prohibit and/or delete the cookies, inter alia, via settings option of your device.
6. DATA RETENTION & SECURITY
- The Company stores Personal Information if it is necessary to fulfil the purpose for which the information has been collected. This means that The Company deletes your Personal Information when such information is no longer necessary. Statistics and analysis which have been anonymised may be saved thereafter.
- We will take commercially reasonable measures in providing secure transmission of your information across the internet to our servers, and in securing the data which relates your information while at rest.
- We may use Cloud Service Providers for our servers and\or storage. In such cases, we rely on the security measures taken by the Cloud Service Provider for the physical security, the integrity, redundancy and the data protection of the data which relates your information.
- However, you should be aware that there is always some risk involved in transmitting information over the internet and that there is also some risk that others could find a way to thwart our and/or the Cloud Service Provider security systems. As a result, while we strive to protect your information, we cannot ensure or warrant the security and privacy of your Personal Information or other content you may have provided while using Our website, and you do so at your own risk. We encourage you to exercise discretion regarding the Personal Information you choose to disclose.
7. DATA SUBJECT RIGHTS
- You may at any time request a review and rectification of your Personal Information. Please note however that deletion could mean that The Company will not be able to process your applications/inquiries and to provide you any requested answers and/or services. If you wish to do so, you can send us an e-mail with your request to: firstname.lastname@example.org, and we will make reasonable efforts to respond within a reasonable period of time, and pursuant to any applicable privacy laws.
- Note that unless you instruct us otherwise, we may retain and use your Personal Information for as long as reasonably required for the purposes of which such Personal Information was collected, including without limitation, for future analytics and analysis, comply with our legal or business requirements or obligations, to resolve disputes, to enforce our Terms and Conditions, all as permitted under any applicable privacy laws.
- Aggregate and/or anonymous information derived from your use of Our website, may remain on our servers indefinitely.