Privacy Policy – the Israel Diamond Institute

Last updated 2023

We, the Israel Diamond Institute (hereinafter: “the Portal Operator”, “the Israel Diamond Institute”, “We” or “the Company”) honor the privacy of the users (hereinafter: “the User(s)” or “You”) of our website whose address is www.israelidiamond.co.il (including sub-domains and secondary domains with which these terms of use are associated) (hereinafter “the Website”) and of the Israel Diamond Institute’s application (hereinafter: “the Application” and jointly, “the Services”) and are required to protect the private information that the Users share with us in the context of the Website and/or Application. We believe that our Users have the right to know our policy pertaining to the collection and use of the information We receive during usage of the Website and/or the Application. The terms that appear in this privacy policy (hereinafter: “the Privacy Policy” shall be construed in accordance with their definitions set forth in the terms of use, which are available on this link (hereinafter: “Terms of Use”) unless stated otherwise in this Privacy Policy.

We believe that our Users have the right to know our policy pertaining to the collection and use of the information We receive during usage of the Website and/or the Application. The terms that appear in this privacy policy (hereinafter: “the Privacy Policy” shall be construed in accordance with their definitions set forth in the terms of use, which are available on this link (hereinafter: “Terms of Use”) unless stated otherwise in this Privacy Policy.

Please note: The Website and/or Application is intended exclusively for Users over eighteen (18) years old. If You are not over eighteen (18) – You may not use the Website and/or Application.

The Privacy Policy is worded in the masculine form for convenience only, and naturally includes women aswell.

1. Consent

Please read carefully: By entering or connecting to the Website and/or Application, or by using the Website and/or Application, You are consenting to the terms that appear in this Privacy Policy, including Your consent to our collecting and processing Your Personal Information (as defined hereinafter). If You do not consent to any of the provisions specified hereinafter, You may not enter or connect to or use the Website, and You are required to remove and delete the Application from Your mobile device (this goes into effect immediately).

2. What information are We entitled to collect about our Users?

We collect two types of information from Users of the Website and/or Application:

a. The first type of information the Company collects is anonymous, non-identifying information (hereinafter: “Impersonal Information”). Impersonal Information is any unclassified information available to the Company when the User uses the Website and/or Application, which does not enable the identification of this User. Impersonal Information includes anonymous, technical information, and information collected regarding the Users’ behavior, and may include, inter alia, the activity of the User of the Website and/or Application, the identity of the operation system, as well as the User’s browser type, the type and version of the mobile device, the language of the device, the click-stream, the referral URL, the keyboard language, the screen resolution, the geographical location defined as default, etc.

b. The second type of information the Company collects is personal identification information (hereinafter: “Personal Information”). The Personal Information enables the Company to personally identify the User and is generally private or sensitive in nature:

· The Users automatically provide their IP address (or Mac address, whichever is relevant), in accordance with the network or device they are using. This information is collected in order to improve the User experience, to determine geographical location, and for security purposes.

· Moreover, We collect Personal Information provided by Users consciously and of their own free will while using the Website and/or Application. For example, the Personal Information will be collected from among the details provided in the context of registering to the Website as a subscriber or inquirer.

The following information is collected in the context of the registration process: name, address, means of contact including email and Exchange or Association membership number. The mandatory fields will be explicitly indicated. With respect to some of the Services, You may be asked to provide additional details necessary due to the nature of the Service. In the future, additional information may be requested in the context of the form.

· Moreover, the following information is collected in the context of the process of registration to the Application: your cell phone number, and access to the address book associated with the phone on which the Application is installed.

· User content which You provide consciously and of Your own free will in the context of using the Services.

To remove doubt, any Impersonal Information which is connected or tied to Personal Information, shall be deemed Personal Information as long as this connection exists.

Please note: We will not collect Personal Information about You without Your consent, which is provided, inter alia, in the context of Your acceptance of the Terms of Use and Privacy Policy, and by Your using the Website and/or Application. You are not required to provide Personal Information by law, but without providing it, You will not be able to use the Services intended for registered users only. You hereby agree and declare that the Personal Information with which You provide us is rendered of Your own free will to enable us to provide You with the Website and/or Application Services, and You likewise agree that We save the information with which You provide us in the information database (which may be registered in accordance with the requirements of the law).

3. How do We collect information about our Users?

We collect the information independently or by receiving services from third parties who are authorized service providers – through two media:

· By Your entering and using the Website and/or Application. When You visit or use the Website and/or the Application, We are aware of the actual use, and are entitled to collect and document information pertaining to Your use, including products and services You purchased or sought to purchase, information or advertisements You read on the portal, the pages You viewed, the offers and services that interested You, and more.

· We collect information that You voluntarily shared with the Company upon registering for services or filling out the contact form.

4. The goals of collecting and using information

We use Impersonal Information:

· To adapt, develop and improve the Website and/or Application and the Services provided in the context thereof.

· To provide the Services of the Website and/or Application.

· For analytical and research purposes, for instance, to analyze User preferences and Users’ manner of use of the Services (for example, which features are popular among Users).

· For statistical purposes.

We use Personal Information:

· To adapt, develop and improve the Website and/or Application and the Services rendered in the context thereof.

· To create personal areas on the Website and/or Application, for instance: building a personal online area for subscribers, to enable the personal areas to be adjusted to match Your preferences.

· To provide other diamond dealers, bodies in the diamond industry, and registered Users on the Website and/or Application in Israel and abroad with Your details and the means of contacting You, to enable them to be in touch with You.

· To enable Users to use the social programs (specified hereinafter).

· To send push messages to Your device regarding the Application, after Your having provided Your consent to receive push messages from the Company. You may revoke Your consent to receive push messages by changing the message definitions as per the instructions of the operation system installed on the device on which the Application is installed.

· To send promotional messages and/or the newsletter and/or other commercial proposals to registered Users – both on behalf of the Company itself and on behalf of other advertisers, and both directly from us or from third parties sending on our behalf. You will be sent this information if You explicitly consented to this during registration or at any other time. You may revoke Your consent at any time and You will no longer receive these messages.

· To respond to User queries regarding the use of the Website and/or the Application and to provide technical support services.

· To contact You via any of the modes of contact You provided upon registering to the Website and/or Application (including sending text messages).

· To obtain general information regarding the geographical location from which the User is connected to the internet, both for purposes of information security and to learn the general location of the Users of our Website and/or Application.

· To verify the User’s identity upon entry to the Application or parts of the Website intended for registered users, and to deal with complaints about improper interactions on the User’s part and/or unauthorized use of the Website and/or Application and/or Services.

· For any other purposes specified in this Privacy Policy or in the general Terms of Use of the Website and/or Application and in the Terms of Use for subscribers.

5. Sharing Personal Information with third parties

We are entitled to disclose Personal Information to third parties in the following cases:

(a) To satisfy the requirements of any law for purposes of legal proceedings, orders, including orders of disclosure, or on the request of a government authority;

(b) To enforce this Privacy Policy or our Terms of Use, including in the context of possible breaches of the Privacy Policy or Terms of Use;

(c) To expose, prevent or otherwise deal with deceit, fraud, or safety and security issues, as well as technical problems;

(d) To respond to Users’ requests for support;

(e) In any dispute, claim, suit, complaint or legal proceedings, should there be such between You and the Company;

(f) To answer any suit, complaint or claim that the content that appears on the Website and/or Application is, and is used in a manner that is, unauthorized or violates third party rights;

(g) To answer suits, claims or complaints that the contact information (for example: name, address, email address etc.) of a third party was published or transferred without his consent or in a manner that constitutes harassment;

(h) To protect the rights, property, or the personal safety of the Company, the Users or the general public;

(i) When You purchase products and services from the Company’s trade and content partners, or when You take part in other content activity shared by the Company and a third party as said, these partners will be sent the information necessary for them to complete the purchase process, manage the relevant content activity, and keep in touch with You;

(j) In the event of a change in the control of the Company, including by way of a merger, purchase, or the purchase of all the Company’s assets, or of its primary assets;

(k) To collect, hold and/or manage the Users’ Personal Information by way of third parties who provide the Company services (including their interested parties, as necessary in order to provide us with the Services), as necessary in accordance with the Company’s business and operational needs. These third parties may be located in a country in which the laws of information protection and privacy differ from those applicable in Your territory;

(l) Collaboration with third parties for purposes of improving the User experience; and or

(m) On the User’s explicit approval prior to the disclosure.

To remove doubt, the Company may collect, disclose, and transfer Impersonal Information to third parties at its own exclusive discretion.

6. Changing or deleting Personal Information

If for any reason You desire to change, update or delete the Personal Information with which You provided us, please send us an email specifying Your request to [email protected] and We will make reasonable efforts to change, update or delete said Personal Information in accordance with the applicable privacy laws. Please note that there are certain circumstances that will obviate the possibility to delete material on Your request, for example: if You published a message on a discussion group that elicited others’ subsequently published responses. Moreover, Users may save content that You published on their personal computer or mobile device, including in temporary files, and this saved content is beyond the Company’s control.

Please note: Unless You instruct otherwise, We are entitled to hold on to Your Personal Information for as long as it may reasonably be required for the purpose for which Your Personal Information was collected, including, but not limited to, for purposes of satisfying our legal or business requirements, duties or undertakings; to resolve disputes; enforce the provisions; all in accordance with the privacy laws that apply. Moreover, even pursuant to the deletion of content from the Company’s servers, it is possible that this content may be saved on the Company’s backup systems for an additional period. The company may also be required by the law enforcement authorities to suspend the deletion of information from the Company’s server with regard to specific information.

7. Minors

To use the Website and/or Application, You must be over eighteen (18). We reserve the right to demand proof of age at any stage, to ensure that there are no minors under age eighteen (18) using the Website and/or Application. Should it be brought to our attention that a person under age eighteen (18) is using the Website and/or Application, We will prohibit and bar this User from entering the Website and/or Application, and We will take every measure to immediately delete any Personal Information (within this term’s meaning in our Privacy Policy) regarding said User. Please contact us at [email protected] if You believe that We collected Personal Information from Users under age eighteen (18).

8. Security

We take reasonable measures to implement and maintain the security of the Website and/or Application and the Users’ Personal Information (personally and by way of services provided by third parties who are authorized service providers). We implement policies and information security policies as is generally accepted in the industry to ensure the security of the Users’ information and to prevent any unauthorized use of this information.

Notwithstanding the aforesaid, We cannot commit and guarantee that unauthorized access to said information will never occur, and We bear no liability for any said unauthorized access or the results thereof.

9. Third party services

We are entitled to use software or third party services to collect, store and/or process the information collected in the context of the Website and/or Application. We make efforts to contract with third parties that publish privacy policies applicable to the collection, storage, processing and use of personal and Impersonal Information. Third party services include, inter alia, Google Analytics whose Privacy Policies are published on:

www.google.com/policies/privacy/partners/

http://www.google.com/intl/en/analytics/privacyoverview.html

Nonetheless, the Company has no control over these third parties. We recommend that You read the terms of use and privacy policies of these third parties and/or contact them directly to verify what types of information are being collected about You.

10. Cookies

When using the Website and/or Application, We, or other third parties, may use an industry standard technology known as cookies and Flash and/or other tracking technology (hereinafter: “Tracking Technology”). Some of the Tracking Technologies will be disabled when You close the browser, and others will be saved on Your device and enable us to activate specific features automatically (for example, automatic activation of the process of connecting to the Website and/or Application), and to facilitate and simplify the User experience on the Website and/or Application. Tracking Technologies contain diverse data such as the pages You visited, the duration of Your stay on the Website and/or Application, the source from which You arrived on the Website, sections and information You seek to view upon entering the Website and/or Application, etc. They also obviate the need to enter Your details anew each time You visit sections of the Website and/or Application which require registration.

The Tracking Technology can be neutralized. For example, most internet browsers allow users to delete cookies from the user device, block cookies, or receive notifications prior to the storage of cookies.

Nonetheless, please note that should the User delete the Tracking Technologies or disallow the storage thereof and/or if he changes the Flash features, the User’s online experience on the Website and/or Application will be limited. Please read the instructions that appear on Your browser or “help” screen to learn more about these functions. Since these cookies sometimes save You the need to enter usernames and passwords, do not delete them unless You are convinced that You first saved all the details necessary for using the Website and/or Application in a safe place.

Generally, third party Tracking Technologies save Impersonal Information such as internet pages You visited, the duration of Your search etc. For executing operations pertaining to third party tracking options, directions can generally be found in their privacy policies or terms of use.

11. Third party advertisements

The Portal Operator may allow some companies to manage the advertisement campaigns on the Website and/or Application. The advertisements You view on visiting the Website and/or Application come from those companies’ computers. To manage their advertisements, these companies place cookies in Your computer. The cookies enable them to collect information about the Websites You viewed, the advertisements placed, and which advertisements You clicked on. In this manner, they seek to attempt adjusting the advertisements displayed to You in the future to the issues that interest You. The use these companies make of cookies is subject to their privacy policies and not to this Policy of the Website and/or Application. These companies have no access to the Company’s cookies, and the Company has no access to their cookies. If You wish to check out the privacy policies of the companies that manage the advertisement campaign on the Website and/or Application, and prevent them from sending cookies to Your computer and reading cookies therefrom, You may do this through their Websites.

12. Social features

The Website and/or Application may include features of social networks (such as Facebook’s “like” or “share”). The social features operate or enable integration with specific third party social networks or platforms (hereinafter: “Social Networks” or “Platform”). These social networks and platforms are formed and maintained by third parties that are not connected to the Company, or which are not controlled thereby. If said integration with said social networks or platforms is enabled, Your use of these social features shall be subject to the terms of use and the privacy policy of the relevant social network or platform. You must ensure that You have read and understood the terms of use and privacy policy of the relevant social network or platform. You must ensure that You have read and understood the terms of use and privacy policy of the relevant social network to learn what information was collected about You, and to learn about Your options to change Your private definitions in the context thereof. If You do not consent to the practices specified in the terms of the social networks or platforms, you should not enable our Website and/or Application to contact You and/or integrate You (in such an event, please take into account that You will be unable to benefit from the Services which our Website and/or Application offers). You must understand that should integration with a social network or platform be enabled, the Company shall be entitled to provide details about You to Your contact people (and vice versa) to enable You to benefit from the social features. This data may include Your name and Your profile photo on social media. In using the social features, You agree and understand that the relevant social networks or platforms may collect specific Personal Information such as Your IP address, Impersonal Information, and may even plant cookies and/or other online Tracking Technology to enable the social features. The use of these features enables You to share information with Your friends or the general public, taking into account the specifications You set vis ? vis the third party that provides the social networks or platforms. You understand and agree that when You share content through social networks or platforms, Your content may become public and others may publish it.

Your entry to, use of, and reliance on the Websites, Services or third party content, and all Your interactions with third parties, is your own liability, and You, exclusively, shall bear all the related expenses. You agree and affirm that the Company shall not be liable, directly or indirectly, for any damage or loss caused (or allegedly caused) in connection with, or as a result of, any service, content, product or other information available through these Websites or Services.

13. International data transfer

The company may transfer information collected about You, including Personal Information, to related bodies or third party service providers (as specified in this document) from Your country or the jurisdiction in which You are located, to other countries or jurisdictions worldwide. Please note that the Company may transfer information to a country and jurisdiction governed by information protection laws that are not identical to those applicable in the jurisdiction in which You are located, and You agree to this transfer of information.

14. Promotional information

You agree that We may use Your details which Were provided to us of Your own free will, to inform You about the Company’s Services and services of other third parties who are the Company’s commercial partners and send You commercial and promotional information, which We will send to the email address with which You provided us. You may revoke Your consent by sending notice to [email protected] or, alternatively, by following the instructions for removal from the mailing list which appear on the email messages You are sent.

15. Changes in the Privacy Policy

The provisions of this Privacy Policy are an integral part of the Website and/or Application, and of the information collected in the context thereof, and it cannot be divorced, in any manner, from our Terms of Use. The company reserves the right to change this Privacy Policy at any time, and requests that all Users revisit this page as frequently as possible. We will inform the Users of any material change in the provisions of this Privacy Policy on the Website’s homepage and/or We will send the User an email message pertaining to the changes to the email address We were given in the context of the User’s use of the Website and/or Application. Material changes will go into effect seven (7) days after the message was published on our Website and/or Application, or sent by email, whichever is first. Any other changes in our Privacy Policy will go into effect on the date of the most recent update of this Privacy Policy, and the User’s continued use of the Website and/or Application pursuant to most recent date of update, constitute the User’s consent that he will be bound by the revisions. Should the Privacy Policy be amended to comply with any legal requirement, the corrections may go into effect immediately, or as required by law, without any prior notice.

16. Questions

If You have any questions or other comments regarding this Privacy Policy, please email us at: [email protected]. We will do our best to get back to You within a reasonable time.