[Last Updated:  December, 2021]

 

This Privacy Policy (“Privacy Policy”) describes APMakers Innovative Capital Ltd.(“APM”, “we”, ”our”, or “us”) practices of collecting and processing Personal Data (as such term is defined below) from users who access, browse, or otherwise interact with our website (“user(s)”, “you” or “your”), available at: [implement link to website] (“Website”).

This Privacy Policy explains what data we may collect from you, how such data may be used or shared with others, how we safeguard it, and how you may exercise your rights related to your Personal Data.

We want to enable you to freely decide whether you wish to provide us with any information which may be required or obtained and therefore, we encourage you to read this Privacy Policy carefully and use it to make informed decisions.

If you have any questions about this Privacy Policy, please contact us at: [implement applicable email address], or as described below.

 

  1. Information We Collect

We may collect the following types of data:

  • Non-Personal Data” – non-personal and anonymized information which may be gathered or made available through your access to our Website and interaction with us, including: type of browsers; type of operating system; type of device; time and date of access to the website; language preference; country-level location, etc.
  • Personal Data” – individually identifiable information, namely information that identifies an individual or may, with reasonable effort, identify an individual.

For the avoidance of doubt, any Non-Personal Data connected or linked to any Personal Data shall be considered as Personal Data for as long as such connection or linkage exists.

Please note that you are not required by law to provide us with any Personal Data and you can avoid from doing so and object to the processing of certain of your Personal Data.

 

The table below details the types of Personal Data we collect:

Type of data Purpose of use and the lawful basis

Contact us information

If you voluntarily contact us whether, through the “Contact Us” page on the Website, by sending us an email, or any other request or notification by any means of communication, you may be required to provide us with certain information such as your name and email address, and any other voluntarily information you will provide us.

We will process your contact information and contact history with us, under our legitimate interest, to provide you with the information you have requested and respond to your inquiry.

We may retain our contact history and correspondence, in the event we find it applicable (e.g., in the event of a future claim).

Recruitment

If you are interested in working with us, you may voluntarily send us your CV via our Website, as well as additional information such as your contact information (name, email address, and phone number).

We will obtain and process such information, under our legitimate interest, to examine your resume in the context of managing our recruiting and hiring process.

In addition, we will use such information, under our legitimate interest, to demonstrate compliance with corporate governance and legal and regulatory requirements.

Please note, in the event, you send us your CV, your provision of Personal Data in connection with recruiting is voluntary, and you determine the extent of information you provide us. We do not request or require sensitive personal information concerning religion, health, sexual orientation, or political affiliation in connection with recruiting.

If you are hired, the information may be used in connection with employment and corporate management.

 

  1. Sharing Data with Third Parties

We will not share your Personal Data with third parties, except as specifically mentioned herein:

  • Compelled Disclosures – to satisfy any applicable law, regulation, legal process, subpoena, or governmental request, solely to the extent required;
  • Enforcement of our Rights and Security – to enforce this Privacy Policy, including the investigation of potential violations thereof, solely to the extent required, and to detect, prevent, or otherwise address fraud, security, or technical issues, solely to the extent required;
  • Business Transfers and Affiliated Companies – we may share your information with any joint ventures or other companies under a common control (“Affiliated Companies”) solely if and when applicable or necessary for the purposes described in this Privacy Policy, or in the event of a corporate transaction (e.g. sale of a substantial part of our business, merger, consolidation or asset sale). In the event of the above, our Affiliated Companies or acquiring company will assume the rights and obligations as described in this Privacy Policy;
  • Third Party Service Providers – where applicable, to collect, hold or manage your Personal Data through our authorized third party service providers, as reasonable for our business purposes (e.g., hosting service, etc.).
  • Explicit Consent – if you specifically request us to provide a third party with your Personal Data.

 

  1. Data retention

We retain the Personal Data we collect for as long as it remains necessary for the purposes set forth above, all under the applicable regulation, or until you will express your preference to opt-out, where applicable. We may at our sole discretion, rectify or erase information from our systems, without prior notice to you, once we deem it is no longer necessary for such purposes.

 

  1. User Rights

Individuals have certain rights under applicable privacy laws with regards to their Personal Data. Subject to your jurisdiction (and additional conditions), these rights may include might include:

  • The right to be informed – you have the right to be provided with information regarding our data collection and privacy practices, as detailed in this Privacy Policy;
  • The right to access your Personal Data – you have the right to request a confirmation from us that we process your Personal Data, and in some cases, be provided with a copy of the Personal Data we process.
  • The right of rectification – you have the right to require to update Personal Data which is not correct;
  • The right to the erasure of your Personal Data – you have the right to require the erasure of certain Personal Data if specific conditions are satisfied. This right is not absolute. We may reject your request under certain circumstances, including where we must retain the data in order to comply with legal obligations or defend against legal claims, etc.;
  • The right to restrict the processing of your Personal Data – you may be entitled to limit the purposes for which we process your Personal Data if specific conditions are satisfied;
  • The right to object to the processing of your Personal Data – you have the right to object to the processing of certain Personal Data, in the event the basis for processing is our legitimate interests, however, we will be permitted to continue the processing if our legitimate interests override your rights, or when processing is necessary to establish, exercise or defend a legal claim or right, etc.;
  • Data portability – you have the right to have your Personal Data “port” to a third-party;
  • The right to file a complaint to a supervisory authority; and
  • The right to withdraw your consent – when the lawful basis for the processing of your Personal Data is your consent.

If you wish to exercise any or all of the above rights, please contact us at: [implement applicable email address], or as described below.

Subject to the applicable regulation, where we are not able to provide you with the information for which you have required, or to the extent you have required, whatever that reason might be, we will endeavor to explain the reasoning for this and inform you of your rights. We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any such information. Please note that in the event you have asked us to exercise your data rights herein, we will respond to your request within the timeframes set forth under applicable regulation.

 

  1. Security & Data Transfer

We take great care in implementing physical, technical, and administrative security measures that we believe comply with applicable regulation and industry standards to prevent your information from being accessed without the proper authorization, improperly used or disclosed, unlawfully destructed, or accidentally lost. You need to remember, however, that unfortunately, the transmission of information via the internet cannot be 100% secure. As such, although we will do our best to protect your Personal Data, we cannot guarantee the full security of data transmitted via our website, and any transmission of your data shall be done at your own risk.

Note that, as we may use third party service providers as described above, your Personal Data might be processed in other territories outside your jurisdiction. We will take appropriate measures to ensure that your Personal Data receives an adequate level of data protection upon its transfer, in accordance with applicable law. You may exercise your rights, where applicable, to receive information on such a transfer mechanism.

  1. Amendments

We reserve the right to periodically amend or revise this Privacy Policy which will be effective immediately upon the implementation of the revised Privacy Policy on our Website. The last revision date will be reflected in the “Last Updated” heading located at the top of the Privacy Policy. We will make a reasonable effort to post notification in the event that we implement any changes that substantially change our privacy practices. We recommend that you review this Privacy Policy periodically to ensure that you understand our privacy practices and to check for any amendments.

 

  1. Protecting Children

Our Website is not directed nor is it intended for use by children under the age of sixteen (16) and we do not knowingly process a child’s information. We will immediately discard any information that we receive from a user that is considered a “child” upon our discovery that such a user shared Personal Data with us. If you are under the age of eighteen (18), please be sure to read the terms of this Privacy Policy carefully with your parents or other legal guardians. Please contact us or as described below if you have reason to believe that a child has shared any information with us.

 

  1. Contact us

If you have any questions about this Policy, please contact us at:

APM House, 18 Raoul Wallenberg St.,
Building D, 6th floor, Ramat Hachayal,
Tel Aviv, 6971915, Israel

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