This Privacy Policy (hereinafter, "Policy") applies to Haim Tov Ltd., company no. 514728310 (herein: "the Company," "we" or "us"), which established and developed a second hand market platform for second hand items (herein: "the Items"), available to users through an application named Shareitt (herein: "the App") which allows its users to offer, exchange and receive second hand items and to provide accompanying services as described in detail herein (herein: "the Services").

Terms in this Policy which have not been explicitly defined will be construed in accordance with the definitions provided by the Terms of Service, available on https://www.shareitt.com/termsandconditions (herein: "Terms of Service" or "Terms"). In order to use the App, you are required to approve the Terms of Service and Privacy Policy. If you do not agree to do so, you may not use the App or Services for any purpose. 

This Privacy Policy applies to:

 

This Policy describes the types of personal data we collect on our users, how we collect it, use it, share it with third parties, protect it, process it, etc.

When we refer to "personal data" in this Policy, the intent is to any information relating to a person's private affairs and/or data about an identified or identifiable person (namely, not a corporation or a group of people); an identifiable person is a person who may be identified whether directly or whether in conjunction with additional data available to us or to which we have access.

Moreover, when we refer to the "processing" of personal data in this Policy, the intent is to any action relating to personal data, including, inter alia, collecting, protecting, organizing, forming, storing, adapting, modifying, retrieving, consulting, using, disclosing, broadcasting, distributing, gaining access, integrating, compiling, merging, arranging, limiting, deleting and/or destroying.  

In any reference within this Privacy Policy to "data subject", "you" or "your", the intention is to any user making use of the App or Services, and to whom the personal data refers.

The Policy is worded in the masculine for convenience purposes only and applies to all users, regardless of gender. 

By choosing to provide personal data to the Company through the App and/or Services via any means mentioned in this Policy, you hereby declare and undertake as follows:

Personal data provided by you is true, complete, exact, and belongs to you.

Personal data will be stored in the Company's database/s by Law and the Company may use and transfer it to third parties working on its behalf or in collaboration with it, in accordance with the terms of this Policy.

You are under no legal obligation to provide personal data; provision of personal data is done with your consent only. If you do not consent to provide personal data, in its entirety or any part thereof, it is possible that some of the Services may not be available to you.

When do we collect your personal data?

Personal data collected or received from you as follows: we collect personal data any time you use the App and/or Services in any manner. In some cases, you actively provide this data. In others, we gather information by observing your usage of the App.

Non-provision of personal data

You are not required to provide any personal data; provision of personal data is done with your consent only. Nevertheless, in certain instances, non-provision of personal data may lead to our inability to provide the Services, partially or in their entirety. 

The types of personal data we collect

The personal data we collect is limited to the data necessary for your usage of the Services, therefore collection of personal data is dependent on the types of Services you use, as described below:

Data on those registered on the App: in order to gain access to the Services, you are required to register on the App. At the time of registration, you will be required to provide personal information such as: name and phone number, and additional information you chose to provide.

Data collected automatically as you use the App and/or Services: this data includes, inter alia, your IP address or other device identifiers through which you access the App, browser type, device and system software through which you access the App, how you use the App, dates and times you access the App, Items you are interested in.  Notwithstanding, it is hereby stated that for some users, data mentioned in this section, in full or in part, does not constitute "personal data". In accordance, rights granted to the data subject in regard to personal data will not apply to the types of data described in this section, respectively.

Data provided in the framework of communication with you: in the event that you contact the Company and/or any one on its behalf with a request and/or question, we may record our communication with you and thus any information you provide, such as your name, contact information, including phone number and email address, and the content of the request or question. In the event that the subject of the said communication is connected with another user, it may contain information on the other user, such as in the case of a complaint regarding conduct that is contrary to the Terms of Service.

Location data for your device: Within the framework of your usage of the App, subject to your consent, we will collect data regarding the location of your device. Furthermore, the IP address allows the Company to extrapolate general data regarding your device location (country and city).

Purposes of data processing 

 

The Company processes or makes use of personal information for one or more of the purposes described in this section hereafter. The Company will not make any use of personal data unless there is a legal basis for the said use. 

The following are the legal foundations for the Company to process your data:

Your consent that the Company may process data about you for a specific purpose. For example, in order to respond to an active request from you. 

Processing the information necessary to uphold an agreement to which you are a party or in order to take measures at your request prior to entering into an agreement. For example, processing data necessary to provide the Services, including offering and/or receiving items.

Processing the information necessary to fulfill a legal obligation applying to the Company. For example, for the purposes of meeting a binding directive from a law enforcement body.  

Processing the information necessary to fulfill the legitimate interests of the Company or a third party. For example, the Company collects data on the usage of the App and/or Services in order to identify and prevent their misuse and to protect third parties.

In any case in which your personal data is processed in accordance with this legal basis, you are welcome to contact us at any time in order to receive information on the assessment we carried out to determine that a certain processing action may be implemented according to  this legal basis.  

Without derogating from the abovementioned, you hereby agree and confirm that the Company will be authorized to retain in its files the details provided by you and personal data that has been accumulated about you, and may treat the files in accordance with the instructions of the Law and make use of the files in the manners described in this Policy, including for the following purposes:

Services and Modifications. We and/or our service providers shall use your personal data for the following purposes: (1) providing access to the App and/or Services; (2) providing support and assistance to solve problems that you or other users may encounter; (3) contacting you if necessary; (4) examining questions that arise, including via the App and providing appropriate responses; and (5) preventing attempted fraud, safeguarding the App and Services and responding to any problem in relation to the App and/or Services.

Internal purposes. We may use your personal data for internal purposes, including to assist in identifying operational issues and in implementing reviews and assessments for the purpose of developing new services and/or content, in order to improve the App and/or Services and adjust them to our specific needs and/or those of the users, develop new products or services, analyze activity scope, evaluate the usage potential of users, use some of the data for research, development and testing purposes, and adjust the servers' capacity to meet the projected scope of work.

Statistical data and analytical tools. We and/or our suppliers use statistical tools, including, inter alia, Google Analytics, in order to collect and analyze information about use of the App and/or Services, such as App visit frequency by users, what pages they frequent, and what other websites and Apps they visited before visiting the App. By analyzing the data we collect, we may compile statistical information spanning various platforms and users, which assists us in improving the App and our Services, in understanding the trends and needs of the user, in considering new products and services, and in adjusting existing services to clients' wishes. We may share information with our partners, without limitation, under commercial conditions which we will determine by our sole discretion. Additional information on the manner in which Google collects data and how its usage may be controlled may be found in the following policy: 

https://policies.google.com/technologies/partner-sites

Transferring information to third parties 

 

As mentioned above, the Company shares personal data with third parties.

In addition, we may transfer your personal data to the following third parties, for the purposes described below:

1. Service providers and suppliers which provide services that assist us in assessing App and/or Service usage. For example, server and IT services providers.

2. Service providers and suppliers in cases of disputes, claims, lawsuits, demands or legal proceedings to which the Company is a party or in any other instance in which sharing information is necessary in order to safeguard property and/or Company rights or those of any third party.

3. Public authorities in various countries in order to uphold legal obligations which apply to us.

4. Public authorities in various countries in order to uphold judicial decrees.

5. In addition, we shall transfer your information to relevant third parties in cases in which the Company discovers that any of your activities on the App and/or Services violate the Terms of Service or took place with fraudulent intent of any kind.  

The transfer of your personal data as described above will be carried out at the earliest instance necessary or at the earliest instance the Company is required to transfer the said personal data. Please note that third parties to whom your said personal data shall be transferred are (all or in part) located outside the country.

In addition, in the case that any third party offers to purchase the Company or another company that belongs to the Company or the assets of either (in their entirety or in part), your personal data may be exposed to them.

You have the right to the following privileges in relation to your personal data:

The right to access – To the extent that you request such, you have the right to receive authorization as to whether the Company holds your personal data, and if it does – to receive a copy of said data, in addition to information on (1) the processing purposes of your personal data, (2) the different types of your personal data, (3) present or future recipients (or types of the recipients) of your personal data, and specifically said present or future recipients in countries outside the European Union or which are international corporations, (4)  to the extent possible, the length of time your personal data shall be retained, or, if not possible, the criteria for determining said time, (5) your vested interests in regard to your personal data and its processing by the Company, (6) your right to submit a complaint to the competent authorities, (7) insofar as your personal data held by the Company did not originate with you – information regarding the source. 

The Company may request ID or additional information in regard to your request, inter alia, in order to ensure that it is not providing your personal information to third parties.

Any additional request for information, beyond the initial request, may entail a fee for the costs involved in responding to such a request. It is hereby stated that your right to receive a copy of your personal data is subject to the rights of others. As such, to the extent that the provision of a copy of your personal data may infringe on the rights of others as aforementioned, the Company may not fulfill your request to receive your personal data (in full or in part) or may fulfill it in a limited manner.

The right to data correction - If your personal data processed by the Company is not accurate, you may request the correction of said personal data. Furthermore, if your personal data is not complete, you may request that the Company make addendums to said personal data and, in accordance with the data processing purposes, the Company will fulfill your request.

The right to deletion  – You may request the deletion of your personal data held by the Company if (1) there is no need for your personal data for the purposes for which it was collected and/or is being processed, (2) where data processing is carried out subject to your consent, you withdraw your consent to its processing, unless there is a legal or other basis that justify the continuation of the data processing, (3) you object to the data processing, for your own reasons, provided that the legal basis of its processing is to carry out a task or tasks for public benefit, to fulfill an officially sanctioned right that was granted to the Company or the legitimate interests of the Company and/or a third party, including creating a profile for you by virtue of the any of the abovementioned legal bases, unless there is a legal or other basis that justify the continuation of the data processing that overrides your interests, rights and liberties, (4) you object to the data processing for direct marketing purposes, (5) your personal data was attained or is being processed in an illegal manner, (6) your personal data must be erased in accordance with legal obligations imposed upon the Company, or (7) the personal data was collected relating to services offered to a minor.

These rights may not be applicable if the Company is obliged to process your personal data by virtue of relevant laws, for the purposes of implementing an obligation deriving from a public interest or an official capacity of the Company, for a public health interest, or for requirements relating to defense against legal claims.

The right to limit the usage of personal data – You may request to limit the usage of your personal data by the Company (1) to the extent that you believe that your personal data held by the Company is not accurate – for a satisfactory period of time that will allow the Company to  verify its accuracy, (2) if data processing of your personal data is illegal and you request to limit its use rather than to delete it, (3) if the Company no longer has use for your personal data but you require it in order to initiate legal proceedings, oversee or defend yourself against them, or (4) if you object to the data processing, for your own reasons, provided that the legal basis of its processing is to carry out a task or tasks for public benefit, to fulfill an officially sanctioned right that was granted to the Company or the legitimate interests of the Company and/or a third party, including creating a profile for you by virtue of the any of the abovementioned legal bases, unless there is a legal or other basis that justify the continuation of the data processing that overrides your interests, rights and liberties, or for the purpose of establishing grounds for, implementing or defending against legal action. 

The right to object to use of your personal data against you – You may, at any time and for your own reasons, object to the processing of your personal data, unless the Company establishes legitimate and decisive reasons that justify the continuation of the data processing that overrides your interests, rights and liberties, or for the purpose of establishing grounds for, implementing or defending against legal action. Moreover, you may object at any time to the processing of your personal data for purposes of direct marketing, including creating a profile on you for this purpose, and in said case, the Company will cease processing your personal data for purposes of direct marketing.

The right to portability of personal data – You may request to receive the personal data you provided to the Company in an accepted, structured and machine-readable manner and to transfer the said information to another data controller. Inasmuch as it is technically feasible, you may request that your personal data be transferred directly by the Company to the other data controller. It is hereby underscored that your right to receive or transfer your personal data to another data controller applies solely to personal data on you that is being processed based on your consent or based on the need to uphold an agreement to which you are a party or to take action at your request, prior to entering an agreement. It is further underscored that this in no way derogates from the Company's right to store a copy of your personal data as determined by the privacy protection regulations under European Union Law.

The right to withdraw consent – You may you may withdraw your consent to the Company's use of your personal data being made based on your consent, from this time forward, and without derogating from the legality of the use of your personal data that was carried out prior to the withdrawal of said consent.

The right to file a complaint – To the extent that you have a complaint relating to the use of your personal data and/or to this Policy, you may contact the Company via the following email address: privacy@shareitt.com.  

Minors

To the extent that your personal data was collected based on your consent, you must be over the age of 16 (or over the age of 13, if so determined by the Law of your country). If you do not meet these age requirements, you must have the written consent of your parent or guardian to process data in accordance with this Policy; without said consent, the Company will not provide the Services. The Company may request information and proof in regard to your age, at its discretion.

Cookies

A cookie is a small file stored by the Company's server on the user's hard drive through the web browser. We use cookies to tailor the user experience for personal use. We may use a "permanent" cookie to save your preferences and modifications. For example, when you visit the App, a cookie will identify you as the current user, so that you don't have to reenter your details each time you visit. You may change your device settings to block certain cookies or to notify you each time a cookie is used. Furthermore, you may erase cookies at any time. It is possible that your ability to use some of the features of the Services and/or App may be limited or unavailable if you block or erase a cookie.

How long is your information retained?

The Company will retain personal data for as long as the purpose declared in this Privacy Policy applies or for a longer period of time as required by Law. For the most part, provided that you are no longer using the App and/or Services, we will retain your personal data in accordance with the statute of limitations in the applicable local Law or in accordance with the regulations applicable to the Company, in the case that these require data retention for a longer period of time. 

The Company performs periodic assessments in order to ascertain that personal data is not being retained beyond the required time period.

Transferring data outside the country

Your personal data may be transferred outside the boundaries of your state, including to countries whose data protection laws provide a lower level of privacy protection than Israeli Law. In such cases, the Company will take steps to ensure an adequate degree of protection for your personal data as described in this Policy and as required by the applicable Law.

How we protect your personal data

We take all technical and organizational measures necessary to protect a high level of protection of your personal data. Moreover, wherever we transfer or share personal data with third parties, we require them to take the same technical and organizational measures necessary to ensure that the level of protection of your personal data is not diminished. Nevertheless, it is hereby stated that we have limited control over the level of information security implemented by said parties.

Our App containing sensitive personal data is protected according to the standard protocol Secure Sockets Layer SSL 256, a protocol for establishing authenticated and encrypted internet connections between networked computers. 

Notwithstanding the aforementioned, the transfer of information on the internet is not completely safe. Accordingly, the Company cannot guarantee the security of data transferred to websites or our Apps, including the security of your personal data provided to the Company. 

Changes to the Privacy Policy

The Company may revise this Policy from time to time. The Company will inform you of any revisions by posting the update on the App. Moreover, in the case of fundamental changes to the Privacy Policy, we will make every effort to notify you of such through the standard channels of communication and by posting a visible notification on the matter on the App, and will obtain your consent to said fundamental changes to the use of your personal data by the Company in accordance with the Law. Unless stated otherwise, any change will be valid beginning on the date it was posted on the App.

Communication with us

In any question or issue regarding this Privacy Policy, please contact the Company via the following email address: privacy@shareitt.com.  

 Last Update: March 2021