PRIVACY POLICY

Effective as of 04.12.2017

This Privacy Policy applies to your use of the website www.bitsofgold.co.il (the "Website"), and the Services (as defined in the Terms of Service published in the Website ("TOS")) provided thereunder. All terms not otherwise defined herein, shall have the meaning ascribed to them in the TOS. The Services are developed, owned and operated by BITS OF GOLD LTD. and its subsidiaries (“Company”, "we""). This Privacy Policy specifies what information Company collects and how it collects the information, how Company uses the collected information, and how Company shares the information and protects it. Please note that this Privacy Policy is governed by the Israeli laws. You hereby authorize Company to collect, record, store, and use information in accordance with this Privacy Policy. Using the Services implies acceptance of this Privacy Policy. If you are not satisfied with any aspect of it please do not continue to use the Services. Company reserves the right at its sole discretion, to replace, change, alter, update, modify or revise the Privacy Policy, at any time without prior notice, and if Company does so, you agree to be bound by any such changes, alterations, revisions, updates or modifications to the Privacy Policy for as long as you use the Services. Therefore, you should periodically check this website to review the most current terms and conditions of the Privacy Policy.

Please note: you are not obligated by law to provide us with any Information. However without providing it you will not be able to receive the Services, which require registration and provision of details as stated. You hereby acknowledge and agree that you are providing us with personal information at your own free will, for the purposes described below, and that we may retain such information in accordance with this Privacy Policy and any applicable laws and regulations. Providing your details when signing up to the Services constitutes a declaration on your part regarding their correctness.

In this Policy, “Personal Information” means information that we directly associate with a specific person or entity, which may include without limitations, name, address, telephone number, email address, payment information, IP address etc.

  1. THE INFORMATION  WE COLLECT

Company may collect, receive and store any information, including Personal Information, data and other details submitted, uploaded, posted, transmitted, communicated, shared or exchanged in connection with the Services which may include without limitation:

1. Information you provide us. When you register to our Website and Services you will be requested to provide Personal Information such as: your full name, e-mail address, phone number, address, gender, date of birth, contact details, location, and any other contact information you choose to provide on or via the Services or in any other communications with the Company.

  • When you use the Services you will be requested to provide additional Personal Information and KYC information such as: your identification number, a copy of an identification card (e.g. ID card, driving license and/or passport), various business and financial information, copies of utility bills, etc., and any proof of your identity as we may request, all as may be required by any applicable law and regulations at any given time. The legal regulation framework that applies on the Services may change from time to time, and accordingly we may require some additional information from you in order to align with such new regulation.
  • Your Virtual Coin wallets information, and your bank account details, if and as provided by youand any information shared with payment processors, all as may be necessary for the provision of the Services.
  • Any other information you may provide regarding your personal and/or health situations. This information may include any Personal Information and/or identification information or other personally sensitive data.
  • Information you may provide when you communicate with us by phone, e-mail, or otherwise,or once you enter information on our Website, submit survey responses. We may monitor and record phone calls, e-mails, live chats, or other communications between you and our Customer Service representatives or other Company's representatives.

Information we get from your use of our Website and Services:

  •  Information on your requested transactions provided through your use of the Services.
  • Certain types of information which is automatically received, collected and recorded by Company via accessing the Services including certain "traffic data" on its server logs from your browser as specified under clause 2 below.
  • Anonymized demographic information, which is not unique to you or identifying you, such as your ZIP code, age, gender, preferences, interests and favorites.

Information we collect from third parties

In order to fulfill our legal obligations to prevent fraud and money laundering, we will obtain information about you from our trusted service providers when you request to use our Services and at any time when we feel it is necessary to prevent fraud, to minimize financial risks or to prevent other risks, for instance - your financial history information.  

  1. INFORMATION WE COLLECT AUTOMATICALLY

We automatically collect Personal Information associated with your use of the Website or Services in any one or more of the following ways:

  • When you access and use the Services, we may collect information about your visit to our Website, your usage of the Services, and your web browsing. That information may include your IP address, your operating system, your browser ID, location data, browser type, domain names, language settings and other information about how you interacted with our Website or other websites. We may collect this information as a part of log files as well as through the use of cookies, log files and other tracking technologies on the Services, to collect, store and analyze certain information.
  • We may use third party services, such as Google Analytics, to collect and process such data in order to analyze the traffic to the Website (for more information - www.google.com/policies/privacy/partners/, or any other URL Google may provide from time to time).
  1. HOW  WE USE THE INFORMATION

We may use information collected about you, including Personal Information, in any one or more of the following ways: (i) to provide you with the requested Services and transactions, (ii) for financial and identity checks, fraud prevention checks, anti-money laundering and credit checks, including examination of your request for Services according to legal regulatory requirements, risk management examination and fraud detection; (iii) to provide reports that include user's Personal Information to the Israeli Anti Money Laundering Authority, and to any other competent authority, with accordance to legal requirements; (iv) to improve the quality of the Services and customize your user experience; (v) for the Company purposes, including among others, service and surveys, statistical research and analysis, using external companies which gather and analyze statistical information about use of Website and Services and keeping track of your login name, passwords, and pages you have visited on the Services; (vi) for customer service, including answering questions and responding to feedback and complaints; (v) for sending communications, administrative e-mails, promotional e-mails messagesand/or reaching you via social media platforms, with respect to Services that may be of interest to you, including segmented advertising and advertisements on behalf of third parties, based on Information in our possession. You may tell us at any time if you do not wish to receive marketing messages from us by contacting us at info@bitsofgold.co.il or by choosing to opt out of receiving additional promotional e-mails from Company by clicking on the 'unsubscribe' link in any such e-mail, or by following any instructions Company may include in the message sent to you (the “Opt-out request” or “Request”). Please note that, once we receive your request, it may take an additional period of time for the Opt-Out Request to become effective. Note that, if you opt-out of our promotional communications, Company may still e-mail or communicate with you from time-to-time, if Company needs to provide you with information or for other commercially, non-marketing reasons related to the Services.

  1. DISCLOSING OF INFORMATION TO THIRD PARTIES

We will not transfer to third parties the Personal Information gathered about you via the Website and Services, inasmuch as this Information identifies you personally, except in the cases set forth hereinafter: (a) To collect, hold and manage your Personal Information through Company's trusted vendors (including their sub-contractors) for example, cloud computing platform and hosting services provider, as reasonable for business purposes, which may be located in a country that does not have the same data protection laws as your jurisdiction; (b) To bill and collect money owed to us by our customers. This includes sending you emails, invoices, receipts, payment vendors, using CRM systems; (c) Risk management. We use trusted third parties to secure transaction processing and to conduct identity verification and fraud prevention checks or otherwise address security or technical issues (for example, Simplex for credit card fraud detection) and of bank transfer transaction, and we send information to those third parties to process your orders and payments; (d) To communicate with our customers about their account and provide customer support, including by our third party trusted vendors; (e) To provide information to our authorized representatives and advisors, including attorneys and accountants, to help us comply with legal, accounting, security and other requirements; (f) To provide, support, and improve the Services we offer. This includes, for example, aggregating information of your use of the Services or Website and sharing this information with third parties to improve and support our Services and to make certain features of the Services available to you; (g) To promote use of our Services. Sharing your contact information with our trusted vendors that assist us in sending e-mails, marketing, advertisements and customer service, including via social media platforms. You can stop receiving our promotional messages by following the unsubscribe instructions included in every email or by contacting us at info@bitsofgold.co.il. (h) To satisfy applicable laws and regulations, if and as applicable, and to comply with a judicial proceeding, court order, or legal process; (i) To enforce the TOS, including investigation of potential violations thereof, and to protect against harm to the rights, property or safety of Company, its users or the public as required or permitted by law; (j) In the event Company goes through a business transition such as a merger, acquisition of all or a portion of Company's assets, your Personal Information may be among the assets transferred and it will be transferred only subject to restrictions similar to those contained herein or as otherwise be required by applicable laws and regulations.  

Company may transfer and disclose to third parties or otherwise use non-personal information at its own discretion. We may also disclose your Personal Information to any other third party with your prior explicit consent.

  1. STORING YOUR DATA

Where is it Stored?Any Personal Information which we may collect may be transferred to, processed and stored at destinations outside your territory and outside of the European Economic Area ("EEA"). By using the Website and Services you consent to the transfer of Personal Information outside your country of residence as stated above, for the reasons set out below.  

  • Where our hosting provider or cloud computing platform is outside your territory or outside the EEA.
  • If necessary for providing you with the Services you request.
  • Where our anti-fraud agencies, credit reference agencies and other service provider that are based outside your territory or outside the EEA, require access to your data to perform their obligations to us and provide the requested Services to you.
  1. DATA RETENTION

Company may retain your Personal Information in conformance with applicable laws in order to: prevent fraud, resolve disputes, troubleshoot problems, assist with any investigations, enforce the TOS and take other actions otherwise permitted by law.There may be residual personal information remains within our databases, access logs, and other records.

In addition, Company will retain your Personal Information after your registration to the Services is cancelled, or if your application is declined or abandoned, for as long as permitted under any applicable law, for legal, regulatory, fraud and other financial crime prevention.

Anonymized, Non-personally identifiable information may be retained and used by Company without limitation.

  1. THIRD PARTY SOFTWARE/SERVICE

While using the Website or Service we may be using third party software and service, in order to collect or process the information. Such software may include, without limitation, Google Analytics, which privacy policy is available at http://www.google.com/intl/en/analytics/privacyoverview.html.

  1. USE OF “COOKIES” AND SIMILAR MEANS

Use of the Website and the Services constitutes consent on your part to the fact that the Company could perform computerized supervision of your use of the Services by placing “cookies” and web beacons in advertisements or similar means, for the purpose of the Website’s ongoing and proper operation, including for the purpose of gathering statistical data about use of the Website and verifying details, in order to adapt your use of the Website to your personal preferences as well as for information security.

You have the option to avoid creating “cookies” by changing the definitions on your browser. For this purpose, please consult the browser’s help file. However, remember that disabling cookies might result in your inability to use some of the Services and applications on the Website or on other websites.

  1. THIRD PARTY SERVICES

Certain Services on the Website, such as services related to Facebook, are in fact managed by bodies other than the Company. In these cases, the Services are provided or operated not via the Company computers alone, but rather via the other bodies as stated.

Company is entitled to be assisted by third parties, including advertising companies, for the purpose of presenting advertisements on the Website or on other websites or providing other services. It is possible that these parties use information about your online activity (which does not include identifying personal information), among others in order to provide advertisements for products and services which may interest you.

Without derogation to the foregoing, you confirm that you are aware that your activity on the Website may enable third parties, such as online search engine, to rely on the nature of your activity as stated, in order to present to you adapted advertisements in the framework of online activity, even outside of the Website, as an inseparable part of their ongoing activity and in the absence of any affinity to the Company’s activity. The activity of third parties as stated is subject to the privacy policy used by them alone, and is done in their full and exclusive responsibility, without the Company having any responsibility whatsoever for it.

  1. THIRD PARTY LINKS

The Services contain links to third party websites and services, which are outside the Company's control and are not covered by this Privacy Policy.  Company does not assume responsibility for the privacy practices of such other websites to which it may link or web-sites that link to the Services, and encourages you to review those privacy policies yourself.

  1. CHILDREN’S ONLINE PRIVACY PROTECTION

Protecting the privacy of children and/or minors is very important to us. If we obtain knowledge that a user is under the age of 18, we will take steps to remove that user's Personal Information from our databases.

  1. SECURITY PRECAUTIONS TO PROTECT YOUR INFORMATION

We take a great care in implementing and maintainingreasonable and appropriate security procedures consistent with prevailing industry standards to protect the security of the Website, the Services, and our users’ Personal Information.   

Standard security safeguards are implemented, including strict access controls, to protect your Personal Information from loss, misuse, and unauthorized access, disclosure, alteration and destruction. While we take reasonable precautions against possible security breaches of the Services, no website or internet transmission is completely secure, and we cannot guarantee (i) that unauthorized access, hacking, data loss, or other breaches shall never occur; and (ii) the security of your data while it is being transmitted to and from the Services; any transmission is at your own risk. Company urges you to take steps to keep your Personal Information safe, including your Account password, and to log out of your Account after use.

  1. TERMS AND CONDITIONS

Please also review the Terms of Services section establishing the use, disclaimers, and limitations of liability governing the use of the Services, at: www.bitsofgold.co.il/terms_and_conditions.

  1. RIGHT TO ACCESS

To obtain a copy of your Personal Information the Company keeps, please write with full details to us per the contact details as set forth above. You have a right to review, request edits, and ask to delete you Personal Information (subject to applicable law).

Please submit with respect to your Personal Information in writing to info@bitsofgold.co.il.

  1. CONTACT US

If you have any additional questions or concerns about this Privacy Policy, please feel free to contact us any time through the Services or by writing to us at info@bitsofgold.co.il.