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IsraTransfer Ltd. (“IsraTransfer,” “us,” “we,” or “our”) recognizes and respects the importance of maintaining the privacy of our customers and, as a result, we have established this Privacy Policy. This Privacy Policy describes the types of information we collect from you when you visit and/or use our Site and/or utilize our Services. This Privacy Policy also explains how we may use, transfer, store, and disclose the collected information, as well as your ability to control certain uses of the collected information. If not otherwise defined herein, capitalized terms have the meaning given to them in the Terms of Service, available at https://isratransfer.com/terms-conditions/ (the “Terms”).

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The Information We Collect

We collect information from users when visiting or using our Site and/or Services, as applicable. In order to utilize our Services, you will be required to register an account and provide us with certain Personal Information (as defined below). We may also collect Personal Information when you request information from us, sign up for newsletters or our email lists, complete online forms, use our chat or contact us for any other reason.

“Personal Information” means information that can be directly associated with a specific person such as a name, telephone number, e-mail address, or information about activities directly linked to a person, such as a person’s location. Examples of the Personal Information that we collect from you may include your name, address, identification number, phone number, e-mail address, IP address, bank related information you provide us with for provision of the Services and historical trades and any other information included in your dashboard included in the Services, chat conversations and other communication with IsraTransfer. It is your voluntary decision whether to provide us with any such Personal Information, but if you refuse to provide such information we may not be able to register you to the Site and/or provide you with the Services.

When you use the Site or Services, certain information may be automatically gathered about your computer, operating system, browsing history and any data you upload to the Site in order to use the Services. 

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How We Use Your Information

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Services

We use your information (including, but not limited to, Personal Information) to provide you with Services.

Solving Problems and Personalizing the Services
We may use Personal Information internally – for example, to help diagnose problems with our servers, to make the Site and/or Services more useful, to customize the Site and/or Services and personalize its content for you, and to provide you with the Services.

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Statistical Information

In addition, by analyzing all information we receive, including all information concerning users, we may compile statistical information across a variety of such information and users (“Statistical Information”). Statistical Information helps us understand trends and customer needs so that new products and services can be considered and so existing products and services can be tailored to customer desires. Statistical Information is anonymous and aggregated. We may share such Statistical Information with our partners, without restriction, on commercial terms that we can determine in our sole discretion.

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Analytics

We use various tool to collect information about the use of the Site and/or Services (“Tools”). The Tools collect information such as how often users visit this Site, what pages they visit when they do so, and what other Site(s) they used prior to coming to ours. The tools collect only the IP address assigned to you on the date you visit this Site, rather than your name or other identifying information. We do not combine the information collected through the use of the Tools with Personal Information. We use the information we get from the Tools only to improve our Site and Services.

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Regulatory Obligations

We may use your Personal Information in manners necessary to comply with applicable law, including but not limited to financial regulations, during the processing of currency exchanges and transfer of funds, including sharing certain Personal Information with banks and governmental agencies, as required by applicable law.

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We will keep Personal Information as long as it remains necessary to provide our clients with access to and use of the Site and Services, comply with our legal obligations, resolve disputes, and enforce our agreements.

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Who We Share Information With

Except as expressly set forth herein, we will not share your Personal Information with third parties without your explicit permission, in response to subpoenas, court orders, or other legal process or in response to a law enforcement agency’s request; to establish or exercise our legal rights; to defend against legal claims; or as we reasonably believe appropriate to comply with applicable laws, regulations, orders, legal processes or government or regulatory requests, including tax authorities in Israel, the United States and elsewhere, as well as in order to comply with anti-money laundering laws and regulations. In such cases we reserve the exclusive right to raise or waive any legal objection or right available to us.

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We may share your information, including Personal Information, as follows:

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Service Providers and Subcontractors

We may disclose information, including Personal Information we collect from and/or about you, to our trusted service providers and subcontractors, who may use such information to: (1) help us provide you with Services; and (2) aid in their understanding of how users are using our Site and Services.

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Service providers and subcontractors may be located in countries other than your own. All our subcontractors will be subject to non-disclosure and non-use obligations. Nevertheless, some countries may have levels of protection of personal and other information which are not as high as in your country of residence or business. We will obtain your consent, however, before using your personal information for any purposes other than performing the Services for which you provided the personal information.

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Business Transfer

We may transfer our databases containing your Personal Information if we sell our business or part of it.

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When we believe it is appropriate to investigate, prevent, or take action regarding illegal or suspected illegal activities; to protect and defend the rights, property, or safety of our company or this Site, our clients, or others; and in connection with our Terms and other agreements, including where we believe you may have breached the Terms or other agreements with IsraTransfer or its affiliates, to detect, prevent or otherwise address fraud or illegal behavior, security or technical issues, or protect against imminent harm to the rights, property or safety of IsraTransfer, its affiliates or users or the public as required or permitted by law.

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We review our retention periods for personal information regularly. We are legally required to hold some types of information to fulfil our statutory and regulatory obligations. We will hold your personal information on our systems for as long as is necessary to fulfil the purposes outlined in this Privacy Policy, or as long as is set out in any relevant contract you hold with us, unless a longer retention period is required or permitted by law.

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For EU users only – Transferring your information outside the European Economic Area

As part of the services offered to you, the information which you provide to us may be transferred to countries outside the European Economic Area (“EEA”). By way of example, this may happen if any of our servers are from time to time located in a country outside of the EEA. These countries may not have similar data protection laws to the EEA.

In such circumstances, we will enter into model contractual clauses as adopted by the European Commission, or rely on alternative legal bases such as the Privacy Shield, where applicable, or binding corporate rules where our affiliates, consultants or service providers have adopted such internal policies approved by European data protection authorities.
If you use our services while you are outside the EEA, your information may be transferred outside the EEA in order to provide you with those services.

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Legal Basis For The Processing of Personal Information from EEA Residents

If you reside within the European Economic Area (EEA), our processing of your personal information will be legitimized as follows: Whenever we require your consent for the processing of your personal information such processing will be justified pursuant to Article 6(1) lit. (a) of the General Data Protection Regulation (EU) 2016/679 (“GDPR”). If the processing of your personal information is necessary for the performance of a contract between you and us or for taking any pre-contractual steps upon your request, such processing will be based on GDPR Article 6(1) lit. (b). Where the processing is necessary for us to comply with a legal obligation, we will process your information on basis of GDPR Article 6(1) lit. (c), and where the processing is necessary for the purposes of our legitimate interests, such processing will be made in accordance with GDPR Article 6(1) lit. (f).

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How We Protect Information

We make efforts to follow generally-accepted industry standards to protect the Personal Information submitted to and collected by us, both during transmission and once we receive it. However, no method of transmission over the Internet, or method of electronic storage is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security. IsraTransfer’s employees are kept up-to-date on security and privacy practices.

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Cookies

A cookie is a small piece of text that is sent to a visitor’s browser. The browser provides this piece of text to the device of the originating visitor when this visitor returns. IsraTransfer uses cookies to help personalize your IsraTransfer experience. A “persistent” cookie may be used to help save your settings and customizations across visits. Also, if you log into the Site, such a cookie will be used to recognize you as a valid user so you will not need to log in each time you use the Site. Most Web browsers are initially configured to accept cookies, but you can change this setting so your browser either refuses all cookies or informs you when a cookie is being sent. Also, you are free to delete any existing cookies at any time. Please note that some features of the Site may function improperly when cookies are disabled or removed.

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Communications

We may send you emails or other messages and/or a newsletter about us or our services. By accepting the terms of this Privacy Policy or using the Site and/or Services, you affirmatively consent to receive such commercial messages. As a registered member, you can remove your Personal Information from our mailing list and stop receiving future communications from us by following the UNSUBSCRIBE link located at the bottom of each communication or by emailing us at info@isratransfer.com. You will also be given the opportunity to unsubscribe from commercial messages in any such e-mail or message we send. Please note that we reserve the right to send you service-related communications, including service announcements and administrative messages, relating either to your account or to your transactions on the Site, without offering you the opportunity to opt out of receiving them. Should you not wish to receive such communications you may cancel your account.

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Children

You must be 18 years or older to register as a customer of IsraTransfer and to utilize our Services. We do not knowingly collect personally identifiable information from or market our Site to children under the age of 18. In the event that you become aware that an individual under the age of 18 has enrolled without parental permission, please advise us immediately.

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Changes and Deletion of Information

By using our Site, you automatically accept the terms of this Privacy Policy. If you do not agree with the terms hereof, please do not use this Site or the Services. We may update this Privacy Policy from time to time – we encourage you to review it periodically. By continuing to access or use the Site after those changes become effective, you agree to be bound by the revised privacy policy.

We will delete information provided to us by a user within a reasonable time from the receipt of a written request, which may be sent to info@isratransfer.com by such user to delete its account provided, however, that we may retain a copy of certain information for audit and record-keeping purposes. We cannot restore information once it has been deleted.

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Comments and Questions

If you have any comments or questions about our privacy policy, please contact us at info@isratransfer.com, alternatively, you can call +972-074-701-8887

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Last updated: May 2018