(Last revised – April 30, 2017)

Simbla Ltd., (hereinafter: “Simbla”, “we”, or “the Company”) respects the privacy of users on the Website that is available at the following address: /http://www.simbla.co.il and/or of the Services that it provides (hereinafter: “users” or “you”) and is committed to protect the personal information that users share with the Company. We believe that our users will have the full right to acquaint themselves with our policy and procedures in relation to the gathering and use of the information that is received by us when you make use of the Website and/or the Services.

Terms appearing in the Terms of Use (and which are available at https:www.simbla.com/Terms_Of_Use (hereinafter: “Terms of Use”) bear the same meanings when used in this Privacy Policy (hereinafter: “the Privacy Policy”), unless otherwise expressly stated herein.

1. Agreement

 Please read carefully: by accessing and connecting to the Website and and/or by using the Website or the Services or opening an account (as that term is defined in the Terms of Use, you are granting your consent to the terms appearing in this Privacy Policy, including your agreement to gather and process your Personal Information (as hereinafter defined). If you do not agree to any of the conditions set out below, you must immediately refrain from entering or connecting or accessing the Website, and you may not make any use whatsoever of the Website and/or the Services.

2. What information may be gathered by us about our users

 The Company gathers two types of information:

• The first type of information that the Company gathers is anonymous and non-identifying (hereinafter: “Non-personal Information”): the Company is not aware of the user’s identity from whom it has gathered Non-personal Information. Non-personal Information is any information that is disclosed and available to the Company when users use the Website and/or the Services, and does not enable the user to be identified.

  Non-personal Information that is gathered by the Company includes anonymous, technical information and information concerning user behavior, and may, inter alia, include identifying the operating system and the user’s browser, the flash version which it uses, user history of the Website and the duration of his visit to the Website, the order of the Website pages visited by the user and the time he used them, the click-stream, screen resolution, keyboard language and other connectivity data.

 

  This information is processed by the Company anonymously and on an aggregatively basis.

• The second type of information that the Company gathers concerning the users is identifying personal information (hereinafter: “Personal Information”): the Personal Information enables the Company to personally identify the user or is of a private or sensitive nature.

• Users of the Website automatically supply their IP address, according to the network that they use. This information is gathered in order to improve the user experience and for security purposes.

• In the process of opening the account (at the following link: https://siteadmin.simbla.com/account/login the user is asked to supply the following particulars to the Company: full name, telephone number, e-mail address, country, residential address, business sector that the user operates or seeks to operate.

• In addition, we will gather Personal Information that is provided by you knowingly and willingly, during the course of using the Website and/or the Services, for example, Personal Information that is supplied by you and which is included in the User Content, according to the Conditions.

• To the extent the user is required to pay for the Services or any of them by means of Clearing House Suppliers (as defined below) then the user will be required to provide to the Clearing House Supplier, certain Personal Information (such as a credit 

 For the avoidance of any doubt, all Non-personal Information that is related or linked to Personal Information will be deemed to be Personal, as long as such link is maintained.

 

3. How do we gather information about our users

• When you visit or use the Website and/or the Services, we are aware of the actual use and may gather and document information relating to that use, either independently or by means of receiving services from third parties that are authorized service suppliers, as detailed below.

• In the account opening process, the user is required to supply various particulars of information that may include: Non-personal Information.

• We gather Personal Information that you have voluntarily shared with the Company, as described below.

• In the account opening process, a user is required to supply various particulars of information that may include Personal Information, as detailed below.

  A user’s Personal Information that is supplied to us knowingly and willingly is retained by us for the purposes set forth below. We may gather and store this Personal Information either independently or by means of approved third parties, as described below.

4. Purposes of gathering and using information

• What use is made of “Non-personal Information”: the Company may use Non-personal Information in order to: (1) for statistical, analytical and research purposes, and in order to adapt, develop and enhance the Services of the Company and the Website; (2) supply the Services to users and enable the development of incidental services in the future; (3) develop and improve the Company’s Services by means of upgrading the user experience; (4) gather aggregative business information for various trading purposes; and (5) gather statistical information for advertising purposes, and also to supply advertising content that may be of interest.

• What use is made of “Personal Information”: the Company may use Personal Information in order to: (1) supply the Services to the user, adapt them to the specific user’s needs and enable the development of incidental services in the future; (2) reply to the user’s questions concerning the use of the Website and/or the Services and provide technical support services; (3) for purposes of adapting, developing and improving the Company’s Services including the Website and the Services; (4) for the purpose of making various payments for the Services by means of Clearing House Suppliers (as described below); and (5) verify the user’s identity at the time of connecting to the Services, and also identify the user in cases of inappropriate or unlawful conduct that has been reported in the framework of the Services.

5. Sharing Personal Information with third parties

 The Company may only disclose Personal Information in the following cases: (a) in order to fulfil and comply with the requirements of any law, for purposes of any legal proceeding, orders, including disclosure orders or requests of any governmental authority; (b) in order to enforce this Privacy Policy or the Company’s Terms of Use, including in the framework of an investigation of possible infringements of the Privacy Policy or the Terms of Use; (c) in order to disclose, prevent or otherwise deal with fraud, deception or security and safety issues as well as technical problems; (d) in order to respond to users’ requests for support; (e) in order to respond to any action, claim or demand that the content appearing on the Website and/or the Services and the use thereof has been made without authorization and/or in breach of third party rights; (f) in order to reply to claims, demands or allegations that information for creating any contact (e.g. name, address, e-mail address and the like) of any third party has been published or transmitted without his consent or in a manner that could amount to harassment; (g) in order to protect the rights, property or personal safety of the Company, of its users or of the general public; (h) in the event of any change in the control of the Company, including by way of merger, acquisition or purchase of all or most of its assets; (i) in order to gather, maintain or administer the Personal Information of users by means of third parties that provide services to the Company (including, their related parties as are required in order to supply the Services), as dictated by the Company’s corporate and operational needs, some of whom third parties may be located in a country in which the privacy and information protection laws may be at variance with those that apply in your territory; (j) co-operation with third parties for the purpose of enhancing user experience; (k) in order to enable the making of payments by way of Clearing House Suppliers (as described below); (l) by the express approval of the user, before disclosure; (m) disclose to an affiliate of Simbla the e-mail of users who were referred to Simbla's website by such affiliate.

 For the avoidance of any doubt, the Company may disclose and transmit Non-personal Information to any third parties at its sole discretion.

6. Change or deletion of Personal Information

 If, for any reason, you wish to change, revise or delete the Personal Information that you have sent to the Company, please do so in the framework of the definitions of your account. you may, in addition send an e-mail message to the following address:support@simbla.com, and we will use reasonable efforts in order to change, revise or delete such Personal Information, in accordance with the applicable privacy laws.

 We maintain and use Personal Information for a reasonable period after receiving your instruction to delete the same, in order to meet our statutory obligations and corporate commitments (including those that are required by applicable law), to resolve disputes, enforce the Terms of Use, for the purpose of giving the user the opportunity of resuming receipt of the Service, as well as for research and security purposes.

 The Company will retain the Personal Information that has been gathered from the users for a reasonable period in accordance with the applicable privacy laws.

7. Competitions

 The Company may hold competitions on its facebook page (once only or from time to time). If you wish to participate in such competitions, you may be required to provide Personal Information about yourself (such as connection details, including full name, e-mail address, residential address or address for the dispatch of prizes, etc.,). Participation in the competitions does not obligate you as user and is elective only. Therefore, if you have chosen not to participate in a competition, you are under no obligation to provide us with any information that we require of participants in the competition. We use the above information in order to notify winners of their win and give them prizes, transfer messages and notices to competition participants, display winners’ names and/or the participants on the Website or on the Company’s facebook page or other marketing information of the Company, and also in order to secure the proper management of the competition. In order to hold the competition, we may seek help of third parties who are service suppliers, (e.g. facebook). Additional details regarding competitions may be found on the Terms of Use at the link: https:www.simbla.com/Terms_Of_Use.

8. Third party social network features

 The Website and/or the Services may contain features of social networks of third parties (such as “Like” and “Share” of facebook. Accessing these features may cause the gathering of information about you (such as – IP address), as well as Non-personal Information. Use may also be made of cookies for the purpose of applying these features. Your use of these features is subject to the privacy policy of the third party who has supplied the features.

9. Cookies and local storage

 When using the Website, the Company or third parties may use a technology that is accepted in the industry and known as “cookies” and “flash” (or similar technologies), that stores certain information on the user’s device enabling the Company to invoke certain features automatically, and improve the user’s experience of using the Company’s services. The cookies will aid the Company to enable an automatic connection process to the Website to be applied.

 The Company or third parties may use temporary cookies (which expire when disconnecting from the Website and permanent cookies (that continue to attach to the user’s device until he chooses to delete them).

 Cookies may be blocked or deleted, inter alia, by means of the device settings. Most Internet browsers enable the users to delete cookies from the user’s device, block the receiving of cookies or the receipt of warnings before the cookies are stored. Nonetheless, one must be alert to the fact that if the user deletes the cookies or does not enable them to be stored, or if he changes the features of Flash, the user’s on-line experience via the Website, will be limited. Please study the terms that are contained in your browser or on the “Help” screen in order to learn more about these functions. In order to do anything relating to cookies of third parties, you will generally be able to find appropriate instructions in their privacy policy or terms of use.

10. Means of payment

 The use of some of the Services involves payment in such manner and such amounts and dates as appear on the Website. The Company reserves the right to vary the payment terms at any time (“the Payments”). The payment policy to designers, to the extent it is relevant, is similarly detailed on the Website.

 The Payments may be made by means of Internet Clearing Services, such as Paypal (Clearing House Provider), that allow different users to send or receive payments in a secure manner by means of using credit card or bank account details. For further information concerning these Services, please read the terms of use and privacy policy of the relevant Clearing House Provider.

 It is hereby stated that the Company does not belong to nor does it have only connection to the Clearing House Providers, who are independent contractors, and that employees or agents of the Company or of the providers are not responsible for either of the other’s acts or omissions. Use of the Clearing Services is at the user’s risk only. The user is bound to comply with the terms of the relevant Clearing House Providers’ terms of use and privacy policy, including the user’s age restrictions.

11. Security

 The Company employs reasonable efforts in applying and maintaining security of the Website, the Services and the users’ Personal Information (either independently or by receiving services from third parties who are authorized service suppliers). The Company applies industry-standard information security procedures and policy in order to secure the information security of its users and in order to prevent any unauthorized use of that information.

 The Company employs amongst others, measures and stores the Personal Information on a commercial data bank system with built-in access and information security and applies industry standard information security procedures and policy. Access to a user’s Personal Information is limited to the user himself and/or such person who the user has expressly agreed should have access to that information. Notwithstanding this, the Company cannot make any commitment and guarantee that unauthorized access to that information will never occur.

12. Services of third parties

 When using the Services, including for purposes of providing the storage services of Dedicated Websites, the Company may use the services of a third party or software of third parties for different purposes, inter alia, in order to gather, maintain or process information described above (hereinafter: “Third Party Services”). Third Party Services include, amongst others, “Cloud services” of the Amazon company, whose privacy policy appears at: http://aws.amazon.com/privacy/ and “Cloud services” of the Firehost company, whose privacy policy appears at http://www.firehost.com

13. Links to websites of third parties

 Certain links that are included in the Website enable users to leave them and enter websites or services that are not connected to the Company. The links to these are offered for your convenience only, these websites and services are not in the control of the Company, the Company is not responsible for their availability, does not endorse them nor is it responsible for any content (including advertisements, products and other information) that appears thereon or is available through them (including the links that are included therein) and is not responsible for the privacy policy or other practices that appear thereon or the conduct of these third parties. Your entry, use of and reliance on these websites, services or content and any interaction between you and these third parties is at your responsibility and you bear exclusive responsibility for the expenses related thereto. The Company reserves the right to cancel or delete any link, at any time. You agree and acknowledge that the Company will not be directly or indirectly responsible for any damage or loss that has been caused (or is alleged to have been caused)) in connection with or as a result of the use of any service, content, products or other information that is available through these websites or services. Most of these contain legal documents, including a privacy policy and terms of use, that regulate the use thereof. We recommend that you carefully read such documents before using these websites or services (amongst other things, in order to know what sort of information is being gathered about you).

14. Advertising information

 You hereby confirm the use of the contact details that you have sent us in order to transfer advertising information that may interest you, as well as in order to advise you of material developments or changes in the Services. Such content will be sent to the e-mail address that you sent us when registering. You may withdraw your consent by sending an e-mail message to the Company at the following address: support@simbla.com, or alternatively follow the removal instructions from the distribution list that are available in the notice that we have sent you.

15. Changes in the Privacy Protection Policy

 The provisions of this Privacy Policy are an integral part of the Website and the information that is gathered thereon, and they form a fundamental and integral part of the Terms of Use. The Company reserves the right to vary this Privacy Policy at any time, and asks all the users to return and visit this page as regularly as possible. We will advise the user of any material modification in the conditions of this Privacy Policy, by replacing the link to the “Privacy Policy” on the Website homepage in the link called “Revised Terms of Use as of  https://www.simbla.com/Terms_Of_Use” and/or by sending an e-mail to the address that the user has indicated in the framework of using the Website. Non-material changes will enter into effect within 7 (seven) days of the date of such notice. All remaining modifications in the Privacy Policy will enter into effect immediately and your continued use of the Website after the last update will constitute your consent to the fact that the modifications will be binding upon you.

16. Questions

 If you have any questions or other remarks pertaining to this Privacy Policy, please do not hesitate to send us a notice to the following address: support@simbla.com. We will use our best efforts to revert to you within a reasonable time.