AMKIRI PRIVACY POLICY

Last Updated: August 18, 2019

This privacy policy (“Privacy Policy”) governs how we, Amkiri Ltd. and our affiliates (together, “Amkiri” “we”, “our” or “us”) use, collect and store Personal Data we collect or receive from or about you (“User”, “you”) such as in the following use cases:

(i) When you browse or visit our website, www.amkiri.com

(“Website”);
(ii) When you make use of, or interact with, our Website

a. When you create an account
b. When you purchase products
c. When you subscribe to receive newsletters and marketing emails
d. When you contact us (e.g. customer support, help, submit a request)

(iii) When we use the personal data of our customers (e.g., contact details)
(iV) When we use the personal data of our resellers, distributors, agents and/or finders(e.g., contact details)
(V) When we use the personal data of our service providers and suppliers (e.g., contact details)

We greatly respect your privacy, which is why we make every effort to provide a platform that would live up to the highest of user privacy standards. Please read this Privacy Policy carefully, so you can fully understand our practices in relation to Personal Data. “Personal Data” means any information that can be used, alone or together with other data, to uniquely identify any living human being.

Table of contents:

1. What information we collect, why we collect it, and how it is used

2. How we protect and store your personal data

3. How we share your personal data

4. Additional information regarding transfers of personal data

5. Your rights

6. Use by children

7. Public information about your activity on the services

8. How can I delete my account?

9. Links to and interaction with third party services

10. Log files

11. Cookies and other tracking technologies

12. Analytics tools

13. California privacy rights

14. Our California do not track notice

15. Deletion of content from California residents

16. Contact us

This Privacy Policy can be updated from time to time and therefore we ask you to check back periodically for the latest version of the Privacy Policy, as indicated below.  If there will be any significant changes made to the use of your Personal Data in a manner different from that stated at the time of collection, we will notify you by posting a notice on our Website or by other means.

  1. WHAT INFORMATION WE COLLECT, WHY WE COLLECT IT, AND HOW IT IS USED
Data we collect Why is the data collected and for what purposes? Legal basis (GDPR only) Third parties with whom we share your data Consequences of not providing the data
When you browse or visit our Website
Cookies

See more in our Cookies Policy, available at: www.amkiri.com/cookies-Policy/

  • Review or improve the usage and operations of our Website
  • Analyze trends.
  • Administer the Website
  • Track users’ movement around the Website
  • Provide you with customized content, targeted offers, and advertising on the Website and across other third-party sites
  • Gather demographic information
  • Marketing Analytics
  • Statistics
  • Consent
  • Legitimate interest (e.g. essential cookies)
  • Google
  • Facebook
  • Instagram
  • Cannot collect and store the information
  • Cannot use or access some parts of the Website
When you make use of, or interact with, our Website
When you join the create an account
  • First Name
  • Last Name
  • Email address
  • Password
  • You may also log-in with you Facebook or Google Account instead of signing up on the Website, in which case we will collect the user name, email address and account credentials (hashed)
To create an account
  • Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
  • Legitimate interest (e.g. to create your account).
  • Google
  • Facebook
  • Instagram
  • Cannot create an account
When you purchase products
  • First Name
  • Last Name
  • Shipping and billing addresses (country, city, state, street address, zip code)
  • Phone number
  • Payment information:
    • Credit card type
    • Credit card number
    • Credit card expiry date
    • CID
    • PayPal Details
  • To create an account (if you wish to create an account during the purchase process)
  • To process your product purchase order
  • To verify your purchase and perform a product sale/purchase transaction
  • To charge and bill you for your product purchase
  • To ship the product to you
  • To send you a post-sale emails to confirm you order and update you on the status of shipping and delivery.
  • To send you a post-sale request for a review of the product(s) you purchased
  • Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
  • Legitimate interest (e.g. to process your order).
  • Google
  • Facebook
  • Instagram
  • PayPal (for purposes of providing payment processing services to Amkiri)
  • ShipBob
  • Cannot create an account (if you wish to create an account during the purchase process)
  • Cannot process your product purchase order
  • Cannot verify your purchase and perform a product sale/purchase transaction
  • Cannot charge and bill you for your product purchase
  • Cannot ship the product to you
  • Cannot send you a post-sale emails to confirm you order and update you on the status of shipping and delivery.
  • Cannot send you a post-sale request for a review of the product(s) you purchased
When you subscribe to receive newsletters and marketing emails
  • Email address
  • To add you to our mailing list
  • To send newsletters, updates or other marketing communications.
Consent
  • MailChimp
  • Cannot add you to our mailing list
  • Cannot send you newsletters, updates marketing communications
When you contact us (e.g. customer support, help, submit a request)
  • First Name
  • Last Name
  • Email address
  • Content of your message
  • To process and answer questions
  • To provide support (e.g., to solve problems, bugs or issues)
  • Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
  • Legitimate interest (e.g. respond to your request).
  • Google
  • Facebook
  • Instagram
  • Cannot process and answer questions
  • Cannot provide support (e.g., to solve problems, bugs or issues)
When we use the personal data of our customers (e.g., contact details)
  • Full Name
  • Email address
  • Company name
  • Phone number
  • Shipping address
  • To contact our customers
  • To perform the applicable agreement
  • Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
  • Legitimate interest (e.g. contact our customers and engage with them).
  • PayPal
  • ShipBob
  • MailChimp
  • Cannot contact our customers
  • Cannot perform the agreement
When we use the personal data of our resellers, distributors, agents and/or finders (e.g., contact details)
  • Full Name
  • Email address
  • Company name
  • Phone number
  • Shipping address
  • To contact our customers
  • To perform the applicable agreement
  • Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
  • Legitimate interest (e.g. contact our resellers, distributors, agents and/or finders and engage with them).
  • ShipBob
  • Fedex or DHL or any other shipping company we may choose from time to time
  • Cannot contact our resellers, distributors, agents and/or finders
  • Cannot perform the agreement
When we use the personal data of our service providers and suppliers (e.g., contact details)
  • Full Name
  • Email address
  • Company name
  • Phone number
  • Shipping address
  • To contact our service providers and suppliers
  • To perform the applicable agreement
  • Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
  • Legitimate interest (e.g. contact our service providers and supplier and engage with them).
  • ShipBob
  • Fedex
  • Cannot contact our service providers
  • Cannot perform the agreement
  1. PERIOD OF STORAGE OF COLLECTED INFORMATION
    1. Personal Data. Your Personal Data (as described above) will be stored until we no longer need the information and proactively delete it or you send a valid deletion request. Please note that we may retain it for a longer or shorter period in accordance with data retention laws. We have an internal data retention policy to ensure that we do not retain your Personal Data perpetually.
    2. Cookies. This depends on the cookie in question. Some cookies (e.g. essential cookies) cannot be disabled. You may also control and delete these cookies through your browser settings. Read more in our Cookies Policy: www.amkiri.com/cookies-Policy/
    3. Security. We have implemented technical, organizational and security measures designed to reduce the risk of accidental destruction or loss, or the unauthorized disclosure or access to personal data that we store. However, please note that we cannot guarantee that the information will not be exposed as a result of unauthorized penetration to our servers. As the security of information depends in part on the security of the computer, device or network you use to communicate with us and the security you use to protect your user IDs and passwords, please make sure to take appropriate measures to protect this information.
  1. HOW WE SHARE YOUR PERSONAL DATA

In addition to the recipients described in Section 1, we may share your information as follows:

  • To the extent necessary, with regulators, to comply with all applicable laws, regulations and rules, and requests of law enforcement, regulatory and other governmental agencies or if required to do so by court order;
  • If, in the future, we sell or transfer some or all of our business or assets to a third party, we will (to the minimum extent required) disclose information to a potential or actual third party purchaser of our business or assets. In the event that we are acquired by or merged with a third party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer or assign Personal Data in connection with the foregoing events.
  • Where you have provided your consent to us sharing the Personal Data (e.g., where you provide us with marketing consents or opt-in to optional additional services or functionality); and
  • Where we receive requests for information from law enforcement or regulators, we carefully validate these requests before any Personal Data is disclosed.
    1. ADDITIONAL INFORMATION REGARDING TRANSFERS OF PERSONAL DATA

Access from Israel: Access from Israel is covered by the European Commission’s Adequacy Decision regarding Israel. You can read more here: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en

Internal transfers: We ensure transfers within the Amkiri group will be covered by an agreement entered into by members of the Amkiri group (an intra-group agreement) which contractually obliges each member to ensure that Personal Data receives an adequate and consistent level of protection wherever it is transferred to;

External transfers: Where we transfer your Personal Data outside of EU/EEA, for example to third parties who help provide our products and services, we will obtain contractual commitments from them to protect your Personal Data.
Some of these assurances are well recognized certification schemes like the EU – US Privacy Shield for the protection of Personal Data transferred from within the EU to the United States.

Where we receive requests for information from law enforcement or regulators, we carefully validate these requests before any Personal Data is disclosed.

  1. YOUR RIGHTS

The following rights (which may be subject to certain exemptions or derogations), shall apply to certain individuals (some of which only apply to individuals protected by the GDPR):

  • You have a right to access information held about you. Your right of access may normally be exercised free of charge, however we reserve the right to charge an appropriate administrative fee where permitted by applicable law;
  • You have the right to request that we rectify any Personal Data we hold that it is inaccurate or misleading;
  • You have the right to request the erasure of the Personal Data that relates to you. Please note that there may be circumstances in which we are required to retain your data, for example for the establishment, exercise or defense of legal claims;
  • The right to object, to or to request restriction, of the processing. However, there may be circumstances in which we are legally entitled to refuse your request;
  • The right to data portability. This means that you may have the right to receive your Personal Data in a structured, commonly used and machine-readable format, and that you have the right to transmit that data to another controller;
  • You have the right to object to profiling;
  • You have a right to lodge a complaint with your local data protection supervisory authority (i.e., your place of habitual residence, place or work or place of alleged infringement) at any time. We ask that you please attempt to resolve any issues with us before you contact your local supervisory authority;
  • The right to withdraw your consent. Please note that there may be circumstances in which we are entitled to continue processing your data, in particular if the processing is required to meet our legal and regulatory obligations.
  • You also have a right to request details of the basis on which your Personal Data is transferred outside the European Economic Area, but you acknowledge that data transfer agreements may need to be partially redacted for reasons of commercial confidentiality.

You can exercise your rights by contacting us at GDPR@amkiri.com. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly or inform you if we require further information in order to fulfil your request. When processing your request, we may ask you for additional information to confirm your identity and for security purposes, before disclosing the Personal Data requested to you. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive.

In the event that your request would adversely affect the rights and freedoms of others (for example, would impact the duty of confidentiality we owe to others) or if we are legally entitled to deal with your request in a different way than initial requested, we will address your request to the maximum extent possible, all in accordance with applicable law.

    1. USE BY CHILDREN

We do not offer our products for purchase by children under the age of sixteen (16). If you are under the age of eighteen (18) years then, prior to accessing the Website, you must first review this Privacy Policy with your parent or guardian to make sure that you and your parent or guardian understand it. If you are under 18, you may not provide any information to the Website without involvement of a parent or a guardian.

    1. HOW CAN I DELETE MY ACCOUNT?

Should you ever decide to delete your Account, you may do so by emailing GDPR@amkiri.com. If you terminate your Account, any association between your Account and information we store will no longer be accessible through your Account. However, given the nature of sharing on the Services, any public activity on your Account prior to deletion will remain stored on our servers and will remain accessible to the public.

    1. LINKS TO AND INTERACTION WITH THIRD PARTY SERVICES

The Website may enable you to interact with, or contain links to, your account on third party websites or services (such as Facebook) as well as other third party websites, mobile software applications and services that are not owned or controlled by us (each a “Third Party Service”). We are not responsible for the privacy practices or the content of such Third Party Services. Please be aware that Third Party Services may collect Personal Data from you. Accordingly, we encourage you to read the terms and conditions and privacy policy of each Third Party Service that you choose to use or interact with.

    1. LOG FILES

We may make use of log files. The information inside the log files includes internet protocol (IP) addresses, type of browser, Internet Service Provider (ISP), date/time stamp, referring/exit pages, clicked pages and any other information your browser may send to us. We may use such information to analyze trends, administer the Website, track users’ movement around the Website, and gather demographic information.

    1. COOKIES AND OTHER TRACKING TECHNOLOGIES

Our Website may utilize “cookies”, anonymous identifiers and other tracking technologies in order to for us to provide our Website and present you with information that is customized for you. A “cookie” is a small text file that may be used, for example, to collect information about activity on the Website. Certain cookies and other technologies may serve to recall Personal Data, such as an IP address, previously indicated by a user. Most browsers allow you to control cookies, including whether or not to accept them and how to remove them. You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser.

  1. ANALYTIC TOOLS
  • Google Analytics. The Website may use a tool called “Google Analytics” to collect information about use of the Website. Google Analytics collects information such as how often users visit this Website, what pages they visit when they do so, and what other websites they used prior to coming to this Website. We use the information we get from Google Analytics to maintain and improve the Website and our products. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Google’s ability to use and share information collected by Google Analytics about your visits to this Website is restricted by the Google Analytics Terms of Service, available at https://marketingplatform.google.com/about/analytics/terms/us/ , and the Google Privacy Policy, available at http://www.google.com/policies/privacy/. You may learn more about how Google collects and processes data specifically in connection with Google Analytics at http://www.google.com/policies/privacy/partners/. You may prevent your data from being used by Google Analytics by downloading and installing the Google Analytics Opt-out Browser Add-on, available at https://tools.google.com/dlpage/gaoptout/.
  • Facebook Pixels and SDKs. We use Facebook pixels or SDKs, which are tools that provide help to website owners and publishers, developers, advertisers, business partners (and their customers) and others integrate, use and exchange information with Facebook, as such the collection and use of information for ad targeting. Please note that third parties, including Facebook, use cookies, web beacons, and other storage technologies to collect or receive information from your websites and elsewhere on the internet and use that information to provide measurement services and target ads. Facebook’s ability to use and share information is governed by the Facebook Tools Terms, available at: https://www.facebook.com/legal/technology_terms/. You can prevent your data from being used by Facebook Pixels and SDKs by exercising your choice through these mechanisms: http://www.aboutads.info/ choices or http://www.youronlinechoices.eu/.
  • We reserve the right to use other analytic tools in the future.
    1. CALIFORNIA PRIVACY RIGHTS

California Civil Code Section 1798.83 permits our customers who are California residents to request certain information regarding our disclosure of Personal Data to third parties for their direct marketing purposes. To make such a request, please send an email to GDPR@amkiri.com. Please note that we are only required to respond to one request per customer each year.

    1. OUR CALIFORNIA DO NOT TRACK NOTICE

We collect personally identifiable information about an individual consumer’s online activities over time and across different websites when a consumer uses the Services. If you choose to operate your web browser “do not track” signals or any other mechanism that provides consumers the ability to exercise choice regarding the collection of such information, we will abide by your request and stop collecting such information. We may allow third parties such as such as companies that provide us with analytics tools, to collect personally identifiable information about an individual consumer’s online activities over time and across different websites when a consumer uses the Services.

  1. CONTACT US

If you have any questions, concerns or complaints regarding our compliance with this notice and the data protection laws, or if you wish to exercise your rights, we encourage you to first contact us at GDPR@amkiri.com