Privacy Policy

Ziv Keinan (the “Company”) respects the privacy

of its online visitors and customers of its products and services (including,

but not limited to Ziv Keinan) and complies with applicable laws for the

protection of your privacy, including, without limitation, the European Union

General Data Protection Regulation ("GDPR") and the

Swiss and EU Privacy Shield Frameworks.

1. Definitions Wherever we talk about Personal Data below ("Personal

Data"), we mean any information that can either itself identify

you as an individual ("Personally Identifying Information")

or that can be connected to you indirectly by linking it to Personally

Identifying Information, for example: (i) your account registration information on our website and in

our App; (ii) when you request any support from us or report any problem to

us; (iii) information provided from using certain services or

features; (iv) information from completion of survey or questionnaire; (v) technical information, including the Internet protocol (IP)

address used (vi) and your log-in information, browser, time zone setting,

browser plug-in types and versions, operating system and platform; (vii) details of any transactions, purchases and payments you

made; (viii) your general interaction with the website, including the

full Uniform Resource Locators (URLs), clickstream to, through and from our

site, products you viewed or searched for, page response times, download

errors, length of visits to certain pages, page interaction information; (ix) information received from third parties, such as business

partners, sub-contractors, payment and delivery services, referral by other

users. The Company also processes anonymous data, aggregated or not, to

analyze and produce statistics related to the habits, usage patterns, and

demographics of customers as a group or as individuals. Such anonymous data

does not allow the identification of the customers to which it relates. the

Company may share anonymous data, aggregated or not, with third parties. Please

be aware that the Company may choose to permit third parties to offer

subscription and/or registration-based services through the Company's site. The

Company shall not be responsible for any actions or policies of such third

parties and you should check the applicable privacy policy of such party when

providing personally identifiable information. By using the Company's website, you signify your assent to the

Company's privacy policy. If you do not agree to this policy, please do not use

the Company's website(s).

2. Why the Company Collects and Processes Data The Company collects and processes Personal Data for the following

reasons: (a) performing our agreement with you to provide content and

services, including providing, improving and developing our services; (b) researching, designing and launching new features or

products; (c) providing you with alerts, updates, materials or information

about our services or other types of information that you requested or

signed up to; (d) collecting overdue amounts; (e) responding or taking part in legal proceedings, including

seeking professional advice, or for the purposes of the legitimate and

legal interests of the Company or a third party (e.g. the interests of our

other customers); (f) compliance with legal obligations that we are subject to; (g) communicating with you and responding to your questions or

requests; (i) purposes directly related or incidental to the above; or (j) where you have given consent to it. These reasons for collecting and processing Personal Data

determine and limit what Personal Data we collect and how we use it (section 3.

below), how long we store it (section 4. below), who has access to it (section

5. below) and what rights and other control mechanisms are available to you as

a user (section 6. below).

3. What Data We Collect and Process

3.1 Basic Account Data When setting up an Account, the Company will collect your email

address and country of residence. You are also required to choose a user name

and a password. The provision of this information is necessary to register a

User Account. You are responsible for keeping this password confidential. We

ask you not to share a password with anyone.

3.2 Transaction and Payment Data In order to make a transaction online, you may need to provide

payment data to the Company to enable the transaction. If you pay by credit

card, you need to provide typical credit card information (name, address,

credit card number, expiration date and security code) to the Company, which

the Company will process and transmit to the payment service provider of your

choice to enable the transaction and perform anti-fraud checks. Likewise, the

Company will receive data from your payment service provider for the same

reasons. 3.4 Your Use of the Websites We collect a variety of information through your general

interaction with the websites, Content and Services offered by us. Personal

Data we collect may include, but is not limited to, browser and device

information, data collected through automated electronic interactions and

application usage data. Likewise, we will track your process across your

websites and applications to verify that you are not a bot and to optimize our


3.5 Your Use of Services and other Subscriptions In order to provide you with services, we need to collect, store

and use various information about your activity in our Content and Services.

"Content-Related Information" includes your ID, as well as

information about your preferences, progress, time spent, as well as

information about the device you are using, including what operating system you

are using, device settings, unique device identifiers, and crash data.

3.6 Tracking Data and Cookies We use "Cookies", which are text files placed on your computer,

to help us analyze how users use our services, and similar technologies (e.g.

web beacons, pixels, ad tags and device identifiers) to recognize you and/or

your device(s) on, off and across different devices and our services, as well

as to improve the services we are offering, to improve marketing, analytics or

website functionality. The use of Cookies is standard on the internet. Although

most web browsers automatically accept cookies, the decision of whether to

accept or not is yours. You may adjust your browser settings to prevent the

reception of cookies, or to provide notification whenever a cookie is sent to

you. You may refuse the use of cookies by selecting the appropriate settings on

your browser. However, please note that if you do this, you may not be able to

access the full functionality of our websites. When you visit any of our

services, our servers log your global IP address, which is a number that is

automatically assigned to the network your computer is part of.

3.7 Third Party Services This website uses Google Analytics ("Third Party

Service"). Third Party Service uses "cookies",

which are text files placed on visitors' computers, to help the website

operators analyze how visitors use the site. The information generated by the

cookie about the visitors' use of the website will generally be transmitted to

and stored by Third Party Service on servers in the [United States].

Please be aware that Company cannot or does not control the use of cookies

or the resulting information by the Third Party Service. On behalf of the website operator, Third Party Service will use

this information for the purpose of evaluating the website / location /

credentials for its users, in order to compile reports on website activity, and

to provide other services relating to website activity and internet usage for

website operators. Third Party Service will not associate the IP address transferred

any other data held by the Company. You may refuse the use of cookies by

selecting the appropriate settings on your browser. However, please note that

in this case you may not be able to use the full functionality of this website.

3.8 Content Recommendations We may process information collected under this section 3 so that

content, products and services shown on the pages and in update messages

displayed when launching the service can be tailored to meet your needs and

populated with relevant recommendations and offers. This is done to improve

your customer experience. Subject to your separate consent or where explicitly permitted

under applicable laws on email marketing, the Company may send you marketing

messages about products and services offered by the Company to your email

address. In such a case we may also use your collected information to customise

such marketing messages as well as collect information on whether you opened

such messages and which links in their text you followed. You can opt out or withdraw your consent to receive marketing

emails at any time by either withdrawing the consent on the same page where you

previously provided it or clicking the "unsubscribe" link provided in

every marketing email. Notwithstanding any opt out of promotional or marketing

emails by you, we reserve the right to contact you regarding account status,

changes to the user agreement and other matters relevant to the underlying

service and/or the information collected.

3.9 Information Required to Detect Violations We collect certain data that is required for our detection,

investigation and prevention of fraud, cheating and other violations of the

applicable laws ("Violations"). This data is used only

for the purposes of detection, investigation, prevention and, where applicable,

acting on of such Violations and stored only for the minimum amount of time

needed for this purpose. If the data indicates that a Violation has occurred,

we will further store the data for the establishment, exercise or defense of

legal claims during the applicable statute of limitations or until a legal case

related to it has been resolved. Please note that the specific data stored for

this purpose may not be disclosed to you if the disclosure will compromise the

mechanism through which we detect, investigate and prevent such Violations.

4. How We Store Data

4.1 Period of Storage We will store your information as long as necessary to fulfil the

purposes for which the information is collected and processed or — where the

applicable law provides for longer storage and retention period — for the

storage and retention period required by law. In particular, if you terminate

your User Account, your Personal Data will be marked for deletion except to the

degree legal requirements or other prevailing legitimate purposes dictate a

longer storage. All your data and credits will be lost after deletion.

4.2 Deletion of Data In cases where Personal Data cannot be completely deleted in order

to ensure the consistency of the system, the user experience or the community,

your information will be permanently anonymized. Please note that the Company

is required to retain certain transactional data under statutory commercial and

tax law for a period of up to ten (10) years. If you withdraw your consent on which a processing of your

Personal Data, we will delete your Personal Data without undue delay to the

extent that the collection and processing of the Personal Data was based on the

withdrawn consent. If you exercise a right to object to the processing of your

Personal Data, we will review your objection and delete your Personal Data that

we processed for the purpose to which you objected without undue delay, unless

another legal basis for processing and retaining this data exists or unless

applicable law requires us to retain the data.

4.3 Location of Storage The data that we collect from you may be transferred to, and

stored at USA, or a destination outside of your jurisdiction. It may also be

processed by third parties who operate outside of your jurisdiction. By

submitting your personal data you agree to this transfer, storing or processing

of data outside of your jurisdiction. We will take all steps reasonably

necessary to ensure that your data is treated securely in accordance with this

privacy policy.

5. Who Has Access to Data

5.1 The Company and its subsidiaries may share your Personal Data

with each other and use it to the degree necessary to achieve the purposes

listed in section 2 above. This includes our overseas offices, affiliates,

business partners and counterparts (on a need-to-know basis only). In the event

of a reorganization, sale or merger we may transfer Personal Data to the

relevant or proposed transferees of our operations (or a substantial part

thereof) in any part of the world.

5.2 We may also share your Personal Data with our third party

providers that provide customer support services in connection with goods,

Content and Services distributed via us. Your Personal Data will be used in

accordance with this Privacy Policy and only as far as this is necessary for

performing customer support services.

5.3 We may also share your information with our personnel, agents,

advisers, auditors, contractors, financial institutions, and service providers

in connection with our operations or services (for example staff engaged in the

fulfilment of your order, the processing of your payment and the provision of

support services); persons under a duty of confidentiality to us; or persons to

whom we are required to make disclosure under applicable laws and 

regulations in any part of the world. 5.4 In accordance with internet standards, we may also share

certain information (including your IP address and the identification of

content you wish to access) with our third party network providers that provide

content delivery network services and server services in connection with us.

Our content delivery network providers enable the delivery of digital content

you have requested, by using a system of distributed servers that deliver the

content to you, based on your geographic location.

5.5 The Company may allow you to link your User Account to an

account offered by a third party. If you consent to link the accounts, the

Company may collect and combine information you allowed the Company to receive

from a third party with information of your User Account to the degree allowed

by your consent at the time. If the linking of the accounts requires the

transmission of information about your person from the Company to a third

party, you will be informed about it before the linking takes place and you

will be given the opportunity to consent to the linking and the transmission of

your information. The third party's use of your information will be subject to

the third party's privacy policy, which we encourage you to review.

5.6 The Company may release Personal Data to comply with court

orders or laws and regulations that require us to disclose such information.

6. Your Rights and Control Mechanisms You have the right to: (a) check whether we hold personal data about you; (b) access any personal data we hold about you; (c) require us to correct any inaccuracy or error in any personal

data we hold about you; (d) request for the deletion of your personal data through the

deletion of user account. The data protection laws of the European Economic Area and other

territories grant their citizens certain rights in relation to their Personal

Data. While other jurisdictions may provide fewer statutory rights to their

citizens, we make the tools designed to exercise such rights available to our

customers worldwide. As a resident of the European Economic Area you have the following

rights in relation to your Personal Data:

6.1 Right of Access You have the right to access your Personal Data that we hold about

you, i.e. the right to require free of charge (i) information whether your

Personal Data is retained, (ii) access to and/or (iii) duplicates of the

Personal Data retained. You can use the right to access to your Personal Data

through the Privacy Dashboard. If the request affects the rights and freedoms

of others or is manifestly unfounded or excessive, we reserve the right to

charge a reasonable fee (taking into account the administrative costs of

providing the information or communication or taking the action requested) or

refuse to act on the request.

6.2 Right to Rectification If we process your Personal Data, we shall endeavor to ensure by

implementing suitable measures that your Personal Data is accurate and

up-to-date for the purposes for which it was collected. If your Personal Data

is inaccurate or incomplete, you can change the information you provided via

the Privacy Dashboard.

6.3. Right to Erasure You have the right to obtain deletion by us of Personal Data

concerning you by deleting your User Account via the support page. As a result of deleting your User Account, you will lose access to

services, including the User Account, Subscriptions and service-related

information linked to the User Account and the possibility to access other

services you are using the User Account for. We allow you to restore your User Account during a grace period of

30 (thirty) days from the moment you request deletion of your User Account.

This functionality allows you not to lose your account by mistake, because of

your loss of your account credentials or due to hacking. During the suspension

period, we will be able to finalize financial and other activities that you may

have initiated before sending the User Account deletion request. After the

grace period, Personal Data associated with your account will be deleted

subject to section 4. above. In some cases, deletion of your User Account, and therefore

Personal Data deletion, is complicated. In some cases, considering the

complexity and number of the requests, the period for Personal Data erasure may

be extended, but for no longer than two further months.

6.4 Right to Object When our processing of your Personal Data is based on legitimate

interests according to Article 6(1)(f) of the GDPR / section 2.c) of this

Privacy Policy, you have the right to object to this processing. If you object

we will no longer process your Personal Data unless there are compelling and

prevailing legitimate grounds for the processing as described in Article 21 of

the GDPR; in particular if the data is necessary for the establishment,

exercise or defense of legal claims. You also have the right to lodge a complaint at a supervisory


7. Contact Info You can contact the Company's data protection officer at the

address below. While we review any request sent by mail, please be aware that to

combat fraud, harassment and identity theft, the only way to access, rectify or

delete your data is through logging in with your User Account at

ziv@zivkeinan.com. Address Ha’Arba’a

30, Tel-Aviv Yafo​, Israel​ Phone

number +972(0) 54 459 6968​ Attention: Privacy Officer

8. Revision Date This privacy policy was last updated on 16 January 2021 ("Revision

Date"). If you were a user before the Revision Date, it replaces

the existing Privacy Policy. The Company reserves the right to change this

policy at any time by notifying the users of the existence of a new privacy

statement. This policy is not intended to and does not create any contractual or

legal rights in or behalf of any party.