Privacy  policy

 

1. Introduction

1.1 We are committed to safeguarding the privacy of our website visitors and
service users.

1.2 This policy applies where we are acting as a data controller with respect to
the personal data of our website visitors and service users; in other words,
where we determine the purposes and means of the processing of that
personal data.

1.3 We use cookies on our website. In so far as those cookies are not strictly
necessary for the provision of our website and services, we will ask you to
consent to our use of cookies when you first visit our website.

1.4 In this policy, "we", "us" and "our" refer to Free Financial Self employees. For
more information about us, see Section 13.

2. Credit

2.1 This document was created using a template from SEQ Legal
(https://www.contractology.com/website-privacy-policy.html).

3. How we use your personal data

3.1 In this Section 3 we have set out:

(a) the general categories of personal data that we may process;

(b) in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;

(c) the purposes for which we may process personal data; and

(d) the legal bases of the processing.

3.2 We may process data about your use of our website and services ("usage
data"). The usage data may include your IP address, geographical location,
browser type and version, operating system, referral source, length of visit,
page views and website navigation paths, as well as information about the
timing, frequency and pattern of your service use. The source of the usage
data is our analytics tracking system. This usage data may be processed for
the purposes of analysing the use of the website and services. The legal basis
for this processing is our legitimate interests, namely monitoring and
improving our website and services.

3.3 We may process your account data ("account data"). The account data may
include your name and email address. The source of the account data is you
or your employer. The account data may be processed for the purposes of
operating our website, providing our services, ensuring the security of our
website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate
interests, namely the proper administration of our website and business.

3.4 We may process your information included in your personal profile on our
website ("profile data"). The profile data may include your name, address,
telephone number, email address, profile pictures, gender, date of birth,
relationship status, interests and hobbies, educational details and
employment details. The profile data may be processed for the purposes of
enabling and monitoring your use of our website and services. The legal basis
for this processing is our legitimate interests, namely the proper
administration of our website and business.

3.5 We may process your personal data that are provided in the course of the use
of our services "service data"). The source of the service data is you or
your employer. The service data may be processed for the purposes of
operating our website, providing our services, ensuring the security of our
website and services, maintaining back-ups of our databases and
communicating with you. The legal basis for this processing is our legitimate
interests, namely [the proper administration of our website and business.

3.6 We may process information that you post for publication on our website or
through our services ("publication data"). The publication data may be
processed for the purposes of enabling such publication and administering our
website and services. The legal basis for this processing is our legitimate
interests, namely the proper administration of our website and business.

3.7 We may process information contained in any enquiry you submit to us
regarding goods and/or services ("enquiry data"). The enquiry data may be
processed for the purposes of offering, marketing and selling relevant goods
and/or services to you. The legal basis for this processing is our legitimate
interests, namely the proper administration of our website and business.

3.8 We may process information relating to our customer relationships, including
customer contact information ("customer relationship data"). The
customer relationship data may include your name, your employer, your job
title or role, your contact details, and information contained in
communications between us and you or your employer. The source of the
customer relationship data is you or your employer. The customer
relationship data may be processed for the purposes of managing our
relationships with customers, communicating with customers, keeping records
of those communications and promoting our products and services to
customers. The legal basis for this processing is our legitimate interests,
namely the proper management of our customer relationships.

3.9 We may process information relating to transactions, including purchases of
goods and services, that you enter into with us and/or through our website
("transaction data"). The transaction data may include [your contact
details, your card details and the transaction details. The source of the
transaction data is you and/or our payment services provider. The transaction
data may be processed for the purpose of supplying the purchased goods and
services and keeping proper records of those transactions. The legal basis for

this processing is the performance of a contract between you and us and/or
taking steps, at your request, to enter into such a contract and our legitimate
interests, namely the proper administration of our website and business.

3.10 We may process information that you provide to us for the purpose of
subscribing to our email notifications and/or newsletters ("notification
data"). The notification data may be processed for the purposes of sending
you the relevant notifications and/or newsletters. The legal basis for this
processing is the performance of a contract between you and us and/or
taking steps, at your request, to enter into such a contract].

3.11 We may process information contained in or relating to any communication
that you send to us ("correspondence data"). The correspondence data
may include the communication content and metadata associated with the
communication. Our website will generate the metadata associated with
communications made using the website contact forms. The correspondence
data may be processed for the purposes of communicating with you and
record-keeping. The legal basis for this processing is our legitimate interests,
namely the proper administration of our website and business and
communications with users.

3.12 We may process identify general category of data. This data may include
information you were asked to share. The source of this data is you. This data
may be processed for the purposes of operating our website, providing our
services, ensuring the security of our website and services, maintaining back-
ups of our databases and communicating with you and offering, marketing
and selling relevant goods and/or services to you. The legal basis for this
processing is our legitimate interests, namely the proper administration of our
website and business.

3.13 We may process any of your personal data identified in this policy where
necessary for the establishment, exercise or defence of legal claims, whether
in court proceedings or in an administrative or out-of-court procedure. The
legal basis for this processing is our legitimate interests, namely the
protection and assertion of our legal rights, your legal rights and the legal
rights of others.

3.14 We may process [any of your personal data identified in this policy] where
necessary for the purposes of obtaining or maintaining insurance coverage,
managing risks, or obtaining professional advice. The legal basis for this
processing is our legitimate interests, namely the proper protection of our
business against risks.

3.15 In addition to the specific purposes for which we may process your personal
data set out in this Section 3, we may also process any of your personal data
where such processing is necessary for compliance with a legal obligation to
which we are subject, or in order to protect your vital interests or the vital
interests of another natural person.

3.16 Please do not supply any other person's personal data to us, unless we
prompt you to do so.

4. Providing your personal data to others

4.1 We may disclose your personal data to any member of our group of
companies (this means our subsidiaries, our ultimate holding company and all
its subsidiaries) insofar as reasonably necessary for the purposes, and on the
legal bases, set out in this policy.

4.2 We may disclose your personal data to our insurers and/or professional
advisers insofar as reasonably necessary for the purposes of obtaining or
maintaining insurance coverage, managing risks, obtaining professional
advice, or the establishment, exercise or defence of legal claims, whether in
court proceedings or in an administrative or out-of-court procedure.

4.3 We may disclose specify personal data category or categories to our suppliers
or subcontractors insofar as reasonably necessary for namely the proper
administration of our website and business

4.4 Financial transactions relating to our website and services may be handled by
our payment services providers. We will share transaction data with our
payment services providers only to the extent necessary for the purposes of
processing your payments, refunding such payments and dealing with
complaints and queries relating to such payments and refunds.

4.5 We may disclose your enquiry data to one or more of those selected third
party suppliers of goods and services identified on our website for the
purpose of enabling them to contact you so that they can offer, market and
sell to you relevant goods and/or services. Each such third party will act as a
data controller in relation to the enquiry data that we supply to it; and upon
contacting you, each such third party will supply to you a copy of its own
privacy policy, which will govern that third party's use of your personal data.

4.6 In addition to the specific disclosures of personal data set out in this Section
4, we may disclose your personal data where such disclosure is necessary for
compliance with a legal obligation to which we are subject, or in order to
protect your vital interests or the vital interests of another natural person. We
may also disclose your personal data where such disclosure is necessary for
the establishment, exercise or defence of legal claims, whether in court
proceedings or in an administrative or out-of-court procedure.

5. International transfers of your personal data

5.1 You acknowledge that personal data that you submit for publication through
our website or services may be available, via the internet, around the world.
We cannot prevent the use (or misuse) of such personal data by others.

6. Retaining and deleting personal data

6.1 This Section 6 sets out our data retention policies and procedure, which are
designed to help ensure that we comply with our legal obligations in relation
to the retention and deletion of personal data.

6.2 Personal data that we process for any purpose or purposes shall not be kept
for longer than is necessary for that purpose or those purposes.

6.3 We will retain your personal data as follows:

(a) personal data category or categories will be retained a maximum period
of until the individual requests unsubscribes or requests erasion.

6.4 In some cases it is not possible for us to specify in advance the periods for
which your personal data will be retained. In such cases, we will determine
the period of retention based on the following criteria:

(a) the period of retention of [personal data category] will be determined
based on until the individual requests unsubscribes or requests erasion.

6.5 Notwithstanding the other provisions of this Section 6, we may retain your
personal data where such retention is necessary for compliance with a legal
obligation to which we are subject, or in order to protect your vital interests
or the vital interests of another natural person.

7. Amendments

7.1 We may update this policy from time to time by publishing a new version on
our website.

7.2 You should check this page occasionally to ensure you are happy with any
changes to this policy.

7.3 We may notify you of significant changes to this policy by email or through
the private messaging system on our website.

8. Your rights

8.1 In this Section 8, we have summarized the rights that you have under data
protection law. Some of the rights are complex, and not all of the details have
been included in our summaries. Accordingly, you should read the relevant
laws and guidance from the regulatory authorities for a full explanation of
these rights.

8.2 Your principal rights under data protection law are:

(a) the right to access;

(b) the right to rectification;

(c) the right to erasure;

(d) the right to restrict processing;

(e) the right to object to processing;

(f) the right to data portability;

(g) the right to complain to a supervisory authority; and

(h) the right to withdraw consent.

8.3 You have the right to confirmation as to whether or not we process your
personal data and, where we do, access to the personal data, together with
certain additional information. That additional information includes details of
the purposes of the processing, the categories of personal data concerned
and the recipients of the personal data. Providing the rights and freedoms of
others are not affected, we will supply to you a copy of your personal data.
The first copy will be provided free of charge, but additional copies may be
subject to a reasonable fee.

8.4 You have the right to have any inaccurate personal data about you rectified
and, taking into account the purposes of the processing, to have any
incomplete personal data about you completed.

8.5 In some circumstances you have the right to the erasure of your personal
data without undue delay. Those circumstances include: the personal data are
no longer necessary in relation to the purposes for which they were collected
or otherwise processed; you withdraw consent to consent-based processing;
you object to the processing under certain rules of applicable data protection
law; the processing is for direct marketing purposes; and the personal data
have been unlawfully processed. However, there are exclusions of the right to
erasure. The general exclusions include where processing is necessary: [or
exercising the right of freedom of expression and information; for compliance
with a legal obligation; or for the establishment, exercise or defence of legal
claims.

8.6 In some circumstances you have the right to restrict the processing of your
personal data. Those circumstances are: you contest the accuracy of the
personal data; processing is unlawful but you oppose erasure; we no longer
need the personal data for the purposes of our processing, but you require
personal data for the establishment, exercise or defence of legal claims; and
you have objected to processing, pending the verification of that objection.
Where processing has been restricted on this basis, we may continue to store
your personal data. However, we will only otherwise process it: with your
consent; for the establishment, exercise or defence of legal claims; for the
protection of the rights of another natural or legal person; or for reasons of
important public interest.

8.7 You have the right to object to our processing of your personal data on
grounds relating to your particular situation, but only to the extent that the
legal basis for the processing is that the processing is necessary for: the
performance of a task carried out in the public interest or in the exercise of
any official authority vested in us; or the purposes of the legitimate interests
pursued by us or by a third party. If you make such an objection, we will
cease to process the personal information unless we can demonstrate
compelling legitimate grounds for the processing which override your
interests, rights and freedoms, or the processing is for the establishment,
exercise or defence of legal claims.

8.8 You have the right to object to our processing of your personal data for direct
marketing purposes (including profiling for direct marketing purposes). If you

make such an objection, we will cease to process your personal data for this
purpose.

8.9 You have the right to object to our processing of your personal data for
scientific or historical research purposes or statistical purposes on grounds
relating to your particular situation, unless the processing is necessary for the
performance of a task carried out for reasons of public interest.

8.10 To the extent that the legal basis for our processing of your personal data is:

(a) consent; or

(b) that the processing is necessary for the performance of a contract to
which you are party or in order to take steps at your request prior to
entering into a contract,

and such processing is carried out by automated means, you have the right
to receive your personal data from us in a structured, commonly used and
machine-readable format. However, this right does not apply where it would
adversely affect the rights and freedoms of others.

8.11 If you consider that our processing of your personal information infringes
data protection laws, you have a legal right to lodge a complaint with a
supervisory authority responsible for data protection. You may do so in the
EU member state of your habitual residence, your place of work or the place
of the alleged infringement.

8.12 To the extent that the legal basis for our processing of your personal
information is consent, you have the right to withdraw that consent at any
time. Withdrawal will not affect the lawfulness of processing before the
withdrawal.

8.13 You may exercise any of your rights in relation to your personal data by
written notice to us

9. About cookies

9.1 A cookie is a file containing an identifier (a string of letters and numbers) that
is sent by a web server to a web browser and is stored by the browser. The
identifier is then sent back to the server each time the browser requests a
page from the server.

9.2 Cookies may be either "persistent" cookies or "session"cookies: a persistent
cookie will be stored by a web browser and will remain valid until its set
expiry date, unless deleted by the user before the expiry date; a session
cookie, on the other hand, will expire at the end of the user session, when the
web browser is closed.

9.3 Cookies do not typically contain any information that personally identifies a
user, but personal information that we store about you may be linked to the
information stored in and obtained from cookies.

10. Your content: rules

10.1 You warrant and represent that your content will comply with these terms
and conditions.

10.2 Your content must not be illegal or unlawful, must not infringe any person's
legal rights, and must not be capable of giving rise to legal action against any
person (in each case in any jurisdiction and under any applicable law).

10.3 Your content, and the use of your content by us in accordance with these
terms and conditions, must not:

(a) be libellous or maliciously false;

(b) be obscene or indecent;

(c) infringe any copyright, moral right, database right, trade mark right,
design right, right in passing off, or other intellectual property right;

(d) infringe any right of confidence, right of privacy or right under data
protection legislation;

(e) constitute negligent advice or contain any negligent statement;

(f) constitute an incitement to commit a crime[, instructions for the
commission of a crime or the promotion of criminal activity];

(g) be in contempt of any court, or in breach of any court order;

(h) be in breach of racial or religious hatred or discrimination legislation;

(i) be blasphemous;

(j) be in breach of official secrets legislation;

(k) be in breach of any contractual obligation owed to any person;

(l) depict violence in an explicit, graphic or gratuitous manner;

(m) be pornographic, lewd, suggestive or sexually explicit;

(n) be untrue, false, inaccurate or misleading;

(o) consist of or contain any instructions, advice or other information which
may be acted upon and could, if acted upon, cause illness, injury or
death, or any other loss or damage;

(p) constitute spam;

(q) be offensive, deceptive, fraudulent, threatening, abusive, harassing,
anti-social, menacing, hateful, discriminatory or inflammatory; or

(r) cause annoyance, inconvenience or needless anxiety to any person.

11. Cookies used by our service providers

11.1 Our service providers use cookies and those cookies may be stored on your
computer when you visit our website.

11.2 We use Google Analytics to analyse the use of our website. Google Analytics
gathers information about website use by means of cookies. The information
gathered relating to our website is used to create reports about the use of our
website. Google's privacy policy is available at:
https://policies.google.com/privacy.

11.3 We publish Google AdSense interest-based advertisements on our website.
These are tailored by Google to reflect your interests. To determine your
interests, Google will track your behaviour on our website and on other
websites across the web using cookies. You can view, delete or add interest
categories associated with your browser by visiting:

https://adssettings.google.com. You can also opt out of the AdSense partner
network cookie using those settings or using the Network Advertising
Initiative's multi-cookie opt-out mechanism at:

http://optout.networkadvertising.org. However, these opt-out mechanisms
themselves use cookies, and if you clear the cookies from your browser your
opt-out will not be maintained. To ensure that an opt-out is maintained in
respect of a particular browser, you may wish to consider using the Google
browser plug-ins available at:
https://support.google.com/ads/answer/7395996.

11.4 We use RightMessage.com to collect data. This service uses cookies for
displaying the right content for you. You can view the privacy policy of this
service provider at https://rightmessage.com/privacy/.

12. Managing cookies

12.1 Most browsers allow you to refuse to accept cookies and to delete cookies.
The methods for doing so vary from browser to browser, and from version to
version. You can however obtain up-to-date information about blocking and
deleting cookies via these links:

12.2 Blocking all cookies will have a negative impact upon the usability of many
websites.

12.3 If you block cookies, you will not be able to use all the features on our
website.

13. Our details

13.1 This website is owned and operated by Shlomo Freund.

13.2 We are registered in Israel under registration number 037207354, and our registered office is at 20 habotnim st. Pardes Chana, Israel.

13.3 Our principal place of business is at 20 habotnim st. Pardes Chana, Israel.

13.4 You can contact us:

(a) using our website contact form;

(b) by email, using the email address published on our website from time
to time.

14. Data protection officer

14.1 Our data protection officer's contact details are:
[email protected]