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PRIVACY POLICY

Effective as from March 21st, 2021

The website www.memoriz.plus (hereinafter the “Website”) is operated by Memoriz Plus Ltd, an Israeli company registered under the number 516206612 (hereinafter the “Company”, “We” or “Us”).

1. GENERAL
   1. This privacy policy (the " Privacy Policy " or " Policy ") sets out the method pursuant to which We collect, store, use, protect, disclose or otherwise handle information that our Users (as defined below) have provided or shared with Us and your rights, in this respect. This Policy does not apply to practices of entities that are not owned, operated or controlled by Us, or of people who are not employed by Us.
   2. This Policy applies to any registered user or unregistered visitor that uses the Website (hereinafter the “ User ” or " You ").
   3. All terms in capital letters that are not defined in this Policy shall have the meaning assigned to them in the Terms and Conditions by which You are also bound.
   4. By using the Website, You hereby authorize Us to collect, store, record, and use information in accordance with this Policy, whether by Us or by any company included in our group of companies, and to transfer it to third party, as the case may be, all as detailed below.



2. WHAT INFORMATION WE COLLECT
   1. “ Personal Information ” is defined as any information that we may collect from You and that You share with Us in respect of yourself and/or others , that identifies or can be used to identify, contact, or locate the person to whom such information pertains, for example, names, genders, date of birth and of death, contact details (such as emails address, postal address, phone numbers), , photos, videos, and other sensitive information You share with Us (such as the medical condition), that is not otherwise publicly available.
   2. As protecting the Personal Information of our Users is fundamental to Us, We are committed to protecting the Personal Information that You share with us upon using our Website.
   3. We collect, store, use, protect, disclose or otherwise process Personal Information by lawful means, in a reasonable manner, and in accordance with this Policy. Any Personal Information, whether of You or of any third party, provided by You constitutes (i) your consent to our use, disclosure and processing of the Personal Information in accordance with this Policy, and (ii) a representation on your side of its accuracy and truthfulness and a warranty that You have all necessary rights to share this Personal Information and We are entitled to rely on such representation.
   4. We are not responsible for any Personal Information that is shared by You. By sharing Personal Information on the Website, You understand and confirm that You do so at your own risk and You release the Company from any liability in this regard.



3. HOW DO WE COLLECT INFORMATION
   1. When You visit the Website as an unregistered visitor, which will allow You to only search and view public Sites, We may collect Non-Personal Information about You in furtherance of such connection and Website visit.
   2. In addition, the Company may collect your Personal Information when You interact with Us in the following occurrences:
      1. When You register to the Website, as the creator or the contributor of a Site, or when you start the process to do so;
      2. When You contact or are contacted by Us or our service providers by email, phone, electronic messages, through our Website, or any type of interaction with our social media services or our support services or when you register to our mailing list;
      3. When You invite or are being invited to a Site by the Site owner which will provide your email address in order to transfer the invitation;
      4. When You pay or make an order or any other transaction through our Website using a credit card or any other payment method. Note however that We neither collect nor store your credit card details to process your payment. Your credit card details are collected and processed directly by our third-party payment processors pursuant to their terms of use and privacy policies.
   3. Please note that You are not obliged by law to provide Us with any Personal Information and that should You disagree with the collection and processing of your Personal Information, You may simply refuse our services.
   4. We may also collect Personal Information about You from third parties, such as other Users or independent sources. This may occur, for example, when other Users upload Content that includes Personal Information about You, when You are being invited to the Website or a Site by other Users, or when You permit Us to access your Personal Information via other sources such as Facebook or Google. Personal Information that has been collected by Us from a third party will be held in accordance with this Policy.
   5. If You are under the age of 13, You are not allowed to create a Site by your own and your parent(s) or guardian are responsible for your creation of a Site. Should You use or visit the Website without your parents' consent or knowledge, the Company rejects any claim of liability as it never knowingly intended or attempted to solicit or receive information from children.



4. COOKIES
   1. We may also collect Personal and Non-Personal Information through automatic means, for instance by using cookies, and regarding your use of our Website. That may include the date, time, or duration of your visit and the Sites You accessed on our Website, as well as your IP address, your browser ID, and your location data, and all other type of data recorded through cookies (altogether “ Cookies Information ”). We may use third-party service providers in order to process the Cookies Information, notably to assess the existing traffic on our website.
   2. Cookies are alphanumeric identifiers that are transferred to and stored in your electronic device through your web browser for record-keeping purposes. Some cookies allow making it easier for You to navigate, while others are used to enable a faster log-in process or to allow Us to track your activities.
   3. We use cookies to ensure You get the best experience on our Website. You can choose to enable or disable Cookies in your internet browser or delete them. If You choose to enable or delete them, it may have an impact on your User experience on our Website.
   4. When You access the Website, You will be presented with a message bar requesting your consent to set those cookies, or to define the parameters for the cookies. You are responsible for your decision in respect of allowing and/or configuring the cookies. By continuing to browse the Website You enable Us to place cookies on your device and/or our partners, to provide a better experience and service to You.
   5. We do not use Cookies with the objective to identify You personally. However, if the Cookies Information is linked to Personal Information, this information will be considered as Personal Information and will be treated accordingly.
   6. You can choose to enable or disable Cookies in your internet browser at any time. By default, most internet browsers accept cookies.



5. HOW WE USE YOUR INFORMATION
   1. We may use, disclose, or hold the information collected, including your Personal Information, for several purposes and in any of the following ways:
   1. To provide You with our services, by displaying it on the Website, and to fulfill our obligations towards You, including by sharing with our partners and any third parties necessary for the performance of our services;
   2. To perform authorized financial transactions with You;
   3. To communicate with You concerning your account, transactions, security, privacy, and any other administrative issues relating to the use of our services, including any modification in our services offering;
   4. To transfer information to others in the event of your passing, in accordance with your preferences;
   5. To improve the quality of our services and our customer service, including answering questions and responding to feedback;
   6. To enforce the rights and obligations under our Terms and Conditions;
   7. For our purposes based on the use of aggregated transactional information and anonymized information, including commercial purposes, surveys, statistical data research and analysis, and using external companies which gather and analyze statistical information; this use of aggregated and anonymized information would not allow a User identification by third parties;
   8. To draw patterns of use of the Website and to use such data in order to improve our services, their operation, and contents;
   9. To deliver marketing and/or other notices and updates and to improve the customization of the Website;
   10. To send communications, administrative or promotional e-mails or SMS and/or reaching You via social media platforms, with respect to services that may be of your interest based on information in our possession. Should You refuse to receive marketing messages from Us, You can inform Us at any time by contacting Us at [email protected] or by choosing to opt-out of receiving additional promotional e-mails from Us by clicking on the 'unsubscribe' link in any such e-mail, or by following any instructions the Company may include in the message sent to You (hereinafter the “ Opt-out Request ”). Please note that, once We receive such an Opt-out Request, it may take an additional period of time for it to become effective. Note that, if You opt-out of our promotional communications, the Company may still communicate with You from time-to-time, if the Company needs to provide You with information or for other non-marketing reasons related to our Website and services;
   11. To protect our legal interests and to provide information to any competent authority of any relevant jurisdiction, in accordance with legal requirements, without any claim from You against the Company in this respect;
   12. In any other circumstances, with your prior consent.



6. HOW WE DISCLOSE INFORMATION TO THIRD PARTIES
   1. Unless otherwise provided in this Policy, We will not disclose your Personal Information to third parties.
   2. We may share your Personal Information with third parties based on your consent, or legal requirement or authorization.
   3. Even though We attempt to minimize the amount of Personal Information We disclose to what is directly relevant and necessary to accomplish the specified purposes, We may disclose to third parties the Personal Information collected from You via the Website and other services, notably in the following cases:
   1. To collect, hold, and manage your Personal Information through the Company's trusted service providers (and their sub-contractors) operating under suitable safeguards to protect the privacy and security of your Personal Information, for example, cloud computing platform and hosting services provider, as reasonable for business purposes, including when located in a country that does not have the same data protection laws as in your jurisdiction;
   2. To partners and financial institutions in regards to services We provide, including Credit Card service providers, credit institutions, and any other financial institution where You have an account, in order to process transactions;
   3. To communicate with You and provide You our customer support;
   4. To provide information to our authorized representatives and advisors, including attorneys and accountants, to help Us comply with legal, accounting, security, and other requirements;
   5. to comply with our legal obligations, to respond to legal process, or to protect the rights or property of the Company, of our customers, or of others;
   6. To improve our services, notably by using aggregated information of your use of the Website and sharing this information with third parties to improve and support our services, and to make certain features of the Website available to You;
   7. To promote the use of our Website. Sharing your contact information with our trusted service providers that assist Us in sending notifications, marketing, advertisements, and customer service, including via social media platforms. You can stop receiving our promotional messages by choosing the Opt-out Request and unsubscribe or by contacting us at [email protected] .
   8. To enforce the Terms and Conditions, including investigation of potential violations thereof, and to protect against harm to the rights, property, or safety of the Company, its Users, or the public as required or permitted by law;
   9. Should the Company go through a business transition such as a merger, acquisition of all or a portion of the 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;
   10. In any other circumstances, with your prior consent.
   4. Please note that the third parties involved in the transfer of Personal Information for the purposes detailed above may be located in other countries.
   5. Unless it is permitted as stated, the Company does not sell, rent, share, or otherwise disclose Personal Information to third parties. Nevertheless, the Company may disclose or otherwise use information that qualifies as Non-Personal Information at its discretion.
   6. Our Website may contain links to third parties’ websites and services, which are outside the Company's control and are not covered by this Policy. The Company does not assume responsibility for the privacy practices of such other applications or websites to which it may link, and encourages you to review those privacy policies yourself.



7. HOW WE STORE AND PROTECT YOUR PERSONAL INFORMATION
   1. We care about security procedures consistent with prevailing industry standards to protect the security of the Website and of our Users’ Personal Information from accidental loss and unauthorized access, use, alteration, and disclosure.
   2. We have set up internal procedures designed to try to prevent potential unauthorized access and misuse of the information that We process and store, including training of our employees and our contractors regarding confidentiality and privacy of customer information, but we cannot guarantee the absolute security of your Personal Information.
   3. 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, including Personal Information, while it is being transmitted to and from our Website. Any internet transmission is at your own risk. The Company urges You to take steps to keep your Personal Information safe while logging on our Website and using our services.
   4. You are responsible for keeping and maintaining the security of your password and any other account information.
   5. You agree to promptly notify Us of any reason to suspect that your Personal Information has been compromised.



8. DATA RETENTION
   1. We may retain your Personal Information in conformity with applicable laws in order to comply with our legal requirements, resolve disputes, troubleshoot problems, assist with any investigations, enforce the Terms and Conditions and take other actions otherwise permitted by law.
   2. When such retention period has elapsed, your Personal Information will be deleted in accordance with our procedures.



9. YOUR PRIVACY RIGHTS
   1. You have certain rights under the relevant data protection legislation including the right to see the Personal Information held about You, and You are entitled to ask Us to make necessary changes to ensure that it is accurate and up to date. Where applicable, data protection legislation may also provide You with the following rights in relation to Personal Information:
   1. request Us to give You access to it;
   2. request Us to rectify inaccurate or incomplete information, or erase it, where applicable;
   3. request Us to restrict or to stop our using it, in certain circumstances;
   4. withdraw your consent to our using it;
   5. data portability, in certain circumstances;
   6. opt-out from our direct marketing, if applicable; and
   7. lodge a complaint with the relevant Data Protection Authority.
   2. Dealing with the requests You may have in respect of your rights shall be in principle free of charge, however, We reserve the right to charge a reasonable fee notably where the request appears to be manifestly unfounded or excessive, or burdensome, in particular, because of its repetitive character, in which cases We may also choose to refuse to act.
   3. The Company is entitled to verify, according to its procedures, the identity of each person sending a request before answering it.
   4. To proceed with a request, You may contact us as indicated below.



10. EFFECTIVITY AND CHANGE IN OUR POLICY
    1. This Policy shall be effective as of the date mentioned on the first page.
    2. This Policy may be amended from time to time, and the amendments will be effective immediately as from the date indicated within the Policy itself. You may also be notified on the Website of such amendment. Your continued use or visit of our Website following such notification will constitute your agreement to be bound by the Policy in effect. We encourage You to our Website to regularly review our Privacy Policy.



11. WAIVER
    1. Any failure or delay by Us to enforce or exercise a power, a right, or a provision of this Policy will not constitute a waiver of those rights or provisions, and the exercise of a power or right by Us does not preclude our ability to exercise that or any other power or right in the future.
    2. All rights not expressly granted are reserved.



12. GOVERNING LAW
    1. This Policy is governed by the Israeli Law, excluding any conflict of law rules, and the courts of Tel Aviv Jaffa shall have the sole jurisdiction to discuss any dispute relating to the Policy and/or the Website, the use thereof, or arising therefrom.
    2. If a Court and/or another competent authority rules that any of the terms of this Policy is illegal or invalid, such term will be adjusted to comply with the requirement of the law in a manner that will retain its original purpose and meaning and the cancelation and/or change of that term shall not impair, invalidate, derogate, or change the other terms.



13. CONTACT US
    1. If You have any additional questions or concerns about this Policy, please feel free to contact Us any time through the services as indicated in the Website and at the following [email protected] .