Etrog Systems Ltd. (“Etrog”) is committed to safeguarding your privacy online. We understand the importance of privacy to our customers and visitors to our Website. We collect and store information so that we can efficiently provide the products and services demanded by our customers. This Privacy and Security Policy (“Policy”) describes how we handle the personal information that you provide to us.

PLEASE BE SURE TO READ THIS POLICY BEFORE USING OR SUBMITTING INFORMATION TO US OR USING OUR WEBSITE. THIS PRIVACY POLICY IS SUBJECT TO CHANGE FROM TIME TO TIME, SO PLEASE CHECK BACK PERIODICALLY. YOUR USE OF THIS WEBSITE IS SUBJECT NOT ONLY TO THIS POLICY, BUT ALSO TO THIS SITE'S TERMS AND CONDITIONS - CAPITALIZED TERMS NOT OTHERWISE DEFINED HEREIN SHALL HAVE THE MEANINGS ASCRIBED TO THEM IN THE TERMS AND CONDITIONS. BY ACCESSING AND USING THIS WEBSITE OR ANY OF OUR OTHER WEBSITES THROUGH THIS WEBSITE, AND BY PROVIDING US WITH YOUR INFORMATION, YOU AGREE TO BE BOUND BY THIS PRIVACY POLICY. IF YOU DO NOT AGREE, KINDLY EXIT THIS WEBSITE AS YOU ARE PROHIBITTED FROM ACCESSING IT WITHOUT CONSENTING TO THESE TERMS.

Your Information. In the course of providing its Service, Etrog collects or may otherwise have access to personally identifying information, such as your or your recipients’ names, street and/or e-mail addresses, phone numbers, or any other information which, when used by itself or with other data, might identify a customer, recipient or visitor to our website or their customers or users individually. To protect your and your recipients’ safety, you should not provide Etrog with any personal information that is not specifically requested such as information which Etrog should not possess by applicable law. We may use the information you provide to offer you the opportunity to receive notices regarding Etrog’s products or services. We will not share your or your recipients’ personal information with any other third parties, except as noted below under Disclosure. We may provide aggregate statistics about our customers, their recipients, sales, online traffic patterns and related information to reputable third parties without identifying characteristics of individual customers.

Etrog may receive personal data about you from other individuals, from businesses or third parties acting at your direction, from our partners who work with us to provide our products and services and assist us in security and fraud prevention, and from other lawful sources.

• Individuals. Etrog may collect data about you from other individuals — for example, if that individual has sent you a product or gift card, invited you to participate in an Etrog service or forum, or shared content with you.
• At Your Direction. You may direct other individuals or third parties to share data with Etrog. For example, you may direct your mobile carrier to share data about your carrier account with Etrog for account activation, or for your loyalty program to share information about your participation so that you can earn rewards for Etrog purchases.
• Etrog Partners. We may also validate the information you provide to our partners. For research and development purposes, we may use datasets such as those that contain images, voices, or other data that could be associated with an identifiable person. When acquiring such datasets, we do so in accordance with applicable law, including law in the jurisdiction in which the dataset is hosted. When using such datasets for research and development, we do not attempt to reidentify individuals who may appear therein.

Cookies. As part of offering and improving our services, we may use "cookies" to store and sometimes track information about our online customers and users. A cookie is a small amount of data that is sent to your browser from a web server and stored on your computer's hard drive. Cookies can make use of the web easier by saving status and preferences about a website. Some parts of our Website where you are prompted to log-in or that are customizable may require that you accept cookies. Cookies by themselves cannot be used to find out the identity of any user. Most browsers are initially set to accept cookies but users can change the setting to refuse cookies or to be alerted when cookies are being sent.

Use of Personal Data.

Etrog uses personal data to power our services, to process your transactions, to communicate with you, for security and fraud prevention, and to comply with law. We may also use personal data for other purposes with your consent. Etrog uses your personal data only when we have a valid legal basis to do so. Depending on the circumstance, Etrog may rely on your consent or the fact that the processing is necessary to fulfill a contract with you, protect your vital interests or those of other persons, or to comply with law. We may also process your personal data where we believe it is in our or others’ legitimate interests, taking into consideration your interests, rights, and expectations. If you have questions about the legal basis, you can contact the Data Protection Officer at Etrogsystems.com/legal/privacy/contact.

• Power Our Services. Etrog collects personal data necessary to power our services, which may include personal data collected to personalize or improve our offerings, for internal purposes such as auditing or data analysis, or for troubleshooting.
• Process Your Transactions. To process transactions, Etrog must collect data such as your name, purchase, and payment information.
• Communicate with You. To respond to communications, reach out to you about your transactions or account, market our products and services, provide other relevant information, or request information or feedback. From time to time, we may use your personal data to send important notices, such as communications about purchases and changes to our terms, conditions, and policies. Because this information is important to your interaction with Etrog, you may not opt out of receiving these important notices.
• Security and Fraud Prevention. To protect individuals, employees, and Etrog and for loss prevention and to prevent fraud, including to protect individuals, employees, and Etrog for the benefit of all our users, and prescreening or scanning uploaded content for potentially illegal content, including child sexual exploitation material.
• Comply with Law. To comply with applicable law — for example, to satisfy tax or reporting obligations, or to comply with a lawful governmental request. Etrog does not use algorithms or profiling to make any decision that would significantly affect you without the opportunity for human review. Etrog retains personal data only for so long as necessary to fulfill the purposes for which it was collected, including as described in this Privacy Policy or in our service-specific privacy notices, or as required by law. We will retain your personal data for the period necessary to fulfill the purposes outlined in this Privacy Policy and our service-specific privacy summaries. When assessing retention periods, we first carefully examine whether it is necessary to retain the personal data collected and, if retention is required, work to retain the personal data for the shortest possible period permissible under law.

Etrog’s Sharing of Personal Data

Etrog may share personal data with service providers who act on our behalf, our partners, or others at your direction. Further, Etrog does not share personal data with third parties for their own marketing purposes.

• Service Providers. Etrog may engage third parties to act as our service providers and perform certain tasks on our behalf, such as delivering products to customers. Etrog service providers are obligated to handle personal data consistent with this Privacy Policy and according to our instructions. They cannot use the personal data we share for their own purposes and must delete or return the personal data once they've fulfilled our request.
• Partners. At times, Etrog may partner with third parties to provide services or other offerings. Etrog requires its partners to protect your personal data.
• Others. Etrog may share personal data with others at your direction or with your consent, such as when we share information with your carrier to activate your account. We may also disclose information about you if we determine that for purposes of national security, law enforcement, or other issues of public importance, disclosure is necessary or appropriate. We may also disclose information about you where there is a lawful basis for doing so, if we determine that disclosure is reasonably necessary to enforce our terms and conditions or to protect our operations or users, or in the event of a reorganization, merger, or sale.

Protection of Personal Data at Etrog

At Etrog, we believe that great privacy rests on great security. We use administrative, technical, and physical safeguards to protect your personal data, taking into account the nature of the personal data and the processing, and the threats posed. We are constantly working to improve on these safeguards to help keep your personal data secure. Transfer of Personal Data Between Countries

Your personal data may be transferred to or accessed by entities around the world. Etrog complies with laws on the transfer of personal data between countries to help ensure your data is protected, wherever it may be. The Etrog entity that controls your personal data may differ depending on where you live. Etrog's international transfer of personal data collected in the European Economic Area, the United Kingdom, and Switzerland is governed by Standard Contractual Clauses. Etrog’s international transfer of personal data collected in participating Asia-Pacific Economic Cooperation (APEC) countries abides by the APEC Cross-Border Privacy Rules (CBPR) System and Privacy Recognition for Processors (PRP) System for the transfer of personal data. If you have questions or unresolved concerns about our APEC CBPR or PRP certifications, contact our third party dispute resolution provider

By giving Etrog your and your recipients’ personal identifying information, you grant Etrog and its subsidiaries the right to use this information for reasonable business purposes (for example, sending out your email to your recipients) and in manner consistent with the policies of Etrog. Finally, if disclosure of any information is required by law or by an appropriate government authority, we will comply accordingly. We will neither sell nor trade your and your recipients’ personal identifying information, ever.

Children. We understand the need to protect children's privacy online (we define "children" as minors based on the definition in the applicable jurisdiction. We do not knowingly collect nor use any personal information from children. We do not knowingly allow children to register with us, order our products, communicate with us, or use any of our online services.

Your Use. By using this Website, you agree not to disrupt or intercept our electronic information posted on this Website or on any of our servers. You also agree not to attempt to circumvent any security features of our Website, and to abide by all applicable, local, state, federal and international laws.

Security. Etrog is committed to protecting your and your recipients’ personal identifying information from unauthorized access or disclosure. Personal identifying information is stored and maintained on secure servers in a 24/7 monitored, biometrically secured facility. As such, unauthorized parties should not be able to access or intercept personal identifying information during or after transmission. However, while Etrog has put significant safeguards in place to prevent unauthorized access or interception, there is no absolute guarantee of security. IN THE UNLIKELY EVENT OF AN INTERCEPTION OR UNAUTHORIZED ACCESS DESPITE OUR EFFORTS, ETROG SHALL NOT BE RESPONSIBLE FOR SUCH INTERCEPTION OR UNAUTHORIZED ACCESS, OR ANY DIRECT, INDIRECT, SPECIAL, INCIDENTAL, OR CONSEQUENTIAL DAMAGES (INCLUDING LOST PROFITS) SUFFERED BY A CUSTOMER OR USER OR BULK MAIL RECIPIENT, EVEN IF ETROG HAS PREVIOUSLY BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES. ETROG DOES NOT WARRANT, EITHER EXPRESSLY OR IMPLIEDLY, THAT THE INFORMATION PROVIDED BY ANY CUSTOMER OR THEIR CUSTOMERS OR BULK MAIL RECIPIENTS SHALL BE FREE FROM INTERCEPTION OR UNAUTHORIZED ACCESS, AND DOES NOT PROVIDE ANY IMPLIED WARRANTIES OF MERCHANTABILITY AND FITNESS FOR A PARTICULAR PURPOSE. EACH CUSTOMER IS RESPONSIBLE FOR MAINTAINING THE CONFIDENTIALITY OF HIS OR HER OWN PASSWORD.

Opt Out. You can also make choices about the collection and use of your data by Etrog. You can control your personal data that Etrog has obtained, and exercise your data protection rights, by contacting Etrog or using various tools we provide. In some cases, your ability to access or control your personal data will be limited, as required or permitted by applicable law. How you can access or control your personal data will also depend on which products you use. For example, you can:

• Control the use of your data for interest-based advertising from Etrog by visiting our opt-out page.
• Choose whether you wish to receive promotional emails, SMS messages, telephone calls, and postal mail from Etrog.
• Access and clear some of your data through the Etrog privacy dashboard.

Not all personal data processed by Etrog can be accessed or controlled via the tools above. If you want to access or control personal data processed by Etrog that is not available via the tools above or directly through the Etrog products you use, you can always contact Etrog at the address in the How to contact us section or by using our web form.

Although this Website is intended to be available for viewing by individuals worldwide, certain products or Services offered by ETROG may or may not be approved for distribution in your country. WE CANNOT BE RESPONSIBLE FOR ACCESS TO THIS SITE UNDER THE LAWS OF ANY JURISDICTION. YOU ARE HEREBY ON NOTICE THAT YOUR ACCESS AND USE OF OUR WEB SITE IS AT YOUR OWN RISK, AND IMPLIES NO LIABILITY ON OUR PART.