Last Amended: May 17, 2023
In the event you are a California resident and the CCPA applies to you – please also review our CCPA Privacy Notice.
CONTACT INFORMATION AND DATA CONTROLLER INFORMATION
Fortunet Partners Ltd. incorporated under the laws of the state of Israel, is the Controller (as such term is defined under the GDPR or equivalent privacy legislation) of the Personal Data we collect from you.
Our address is: [Abba Even 8, 1st Floor, Herzliya, Israel]
INFORMATION PROCESSED BY FORTUNET
We may collect two types of information from you, depending on your interaction with us.
The first type of information is non-identifiable and anonymous information (“Non-Personal Data”). We are not aware of the identity of the individual from who we have collected the Non-Personal Data. The Non-Personal Data which is being collected may include your aggregated usage information and technical information transmitted by your device such as: type of browser, internet service provider (ISP), operating system type and version, mobile network information, device settings (e.g., default language), etc.
The second type of information is individually identifiable information, namely information that identifies an individual or may with reasonable effort identify an individual (“Personal Data”).
For the avoidance of doubt, any Non-Personal Data connected or linked to Personal Data shall be deemed as Personal Data as long as such connection or linkage exists.
The table below details the types of Personal Data we process, the purpose, lawful basis, and our processing operations:
|DATA SET||PURPOSE AND OPERATIONS||LAWFUL BASIS|
When you interact with our website, we may collect your online identifiers, such as unique ID, Cookie ID, and IP address.
We process such data when users browse our website through cookies for the proper operation of the website, and fraud prevention purposes.
In addition, the Online Identifiers are processed by analytic tools, for analytic purposes. We process this data to understand how visitors use our website.
Strictly necessary cookies which are required for the proper and basic operation of the website will be processed in our legitimate interest.
Other cookies, including any analytic cookies, will be processed based on your consent which we will obtain through our cookie notice and consent management.
You may withdraw consent at any time by using the cookie preference settings.
If you contact us for support or any other inquiries, either through an online form available on the website (i.e., the contact us page or buying or selling a business questionnaire), by sending us an email or by any other means of communications we may make available to you, you will be requested to provide us certain information such as your name, job title, company name, email address, phone number, etc.
If you are contacting us on behalf of another person, we value your assistance and care for others, please note that it is your responsibility to make sure that any person whose Personal Data you provide is aware of the principles of this Policy and agrees that you will provide Personal Data to us on this basis.
We will use such data solely for the purpose of providing you with the support you requested or responding to your inquiry.
The correspondence and its contents with you may be processed and stored by us in order to improve our customer service and in the event we believe it is required to continue to store it, for example, in the event of any claims or in order to provide you with any further assistance (if applicable).
|We process this information subject to our legitimate interest.|
Seller and Buyer Information:
If you are buying or selling a business ("Business") by using our Services, we will process Personal Data related to inter alia, Business’ shareholders, clients, employees, agents, suppliers or other stakeholders (“Business Data Subjects”), which may include their contact details, financial information, and other Personal Data relating to the Business Data Subject and relevant for the purpose of Business selling.
|We will use such data solely for the purpose of providing our services||We process this information subject to our contractual relationship with the buyers or sellers, as applicable.|
Please note that the actual processing operation per each purpose of use and lawful basis detailed in the table above may differ. Such processing operation usually includes a set of operations made by automated means, such as collection, storage, use, disclosure by transmission, erasure, or destruction. The transfer of Personal Data to third-party countries, as further detailed in the Transfer of Data section below, is based on the same lawful basis as stipulated in the table above.
In addition, we may use certain Personal Data to prevent potentially prohibited or illegal activities, fraud, misappropriation, infringements, identity thefts, and any other misuse of the services and to enforce the Terms, as well as to protect the security or integrity of our databases and the services, and to take precautions against legal liability. Such processing is based on our legitimate interests.
We may collect different categories of Personal Data and Non-Personal Data from you, depending on the nature of your interaction with the website, as detailed above.
HOW WE COLLECT INFORMATION
Depending on the nature of your interaction with the website, we may collect information as follows:
Provided by you voluntarily – we will collect information if and when you choose to provide us with the information such as contact us communications.
COOKIES & TRACKING TECHNOLOGIES
- Essential Cookies – which are strictly necessary for the website to work correctly (usually appear under our name/cookie tag);
- Functional Cookies – designated to save your settings on the website – your language preference or other view preferences (also, under our name/cookie tag);
- Session Cookies – used to support the website’s functionality – such Cookies are usually stored only temporarily during a browsing session and are deleted from your device when you close the browser.
- Social networks Cookies – Social Plug-In Cookies (e.g., Facebook, Twitter, LinkedIn Cookies, etc.) enable sharing information with your social network’s accounts.
- Analytics Cookies – give us aggregated and statistical information to improve the services and further develop it such as Google Analytics.
In addition, Cookie’s data is usually collected through the use of third-party services, like Google, Facebook, etc. In those cases, your Personal Data might be transferred to those third parties, which might link it and use it together with other information they have on you from other sources. Such data is “owned” and processed separately by those third-parties under their terms and conditions and the direct accounts or subscriptions you have with those third parties. For example, if you have a Facebook account, the Personal Data collected through Facebook’s Cookies on the website might be linked to other data that Facebook collects from you as a Facebook user, and might be used by Facebook per the independent agreements between you and Facebook.
The specific cookies we currently use on our website, are detailed here.
SHARING PERSONAL DATA
We share your Personal Data with third parties, including our partners or service providers that help us provide our Services. You can find in the table below information about the categories of such third-party recipients.
|CATEGORY OF RECIPIENT||DATA THAT WILL BE SHARED||PURPOSE OF SHARING|
|Service providers||All types of Personal Data||We employ other companies and individuals to perform functions on our behalf. Examples include: sending communications, processing payments, analyzing data, providing marketing and sales assistance (including advertising and event management), identifying errors and crashes, conducting customer relationship management, and providing training. These third-party service providers have access to Personal Data needed to perform their functions, but they are prohibited from using your Personal Data for any purposes other than providing us with requested services.|
|Potential Buyers and Sellers||All types of personal data related to Business Data Subject||In the course of providing the Services the Company may share information considered as personal data under applicable laws, related to the Business Data Subject|
|Enforcement of our rights and security detections.||All types of data||We may disclose Personal Data to enforce our policies and agreements, as well as defend our rights, including the investigation of potential violations thereof, alleged illegal activity or any other activity that may expose us, you, or other users to legal liability, and solely to the extent required. In addition, we may disclose Personal Data to detect, prevent, or otherwise address fraud, security, or technical issues, solely to the extent required.|
|Legal and law enforcement||Subject to law enforcement authority request.||We may share certain data when we believe it is appropriate to do so in order to comply with the law enforcement, governmental agencies or authorized third parties, or protect the rights, property, or security of Fortunet or others.|
YOUR RIGHTS RELATED TO YOUR PERSONAL DATA
We acknowledge that different individuals have different privacy concerns and preferences. Our goal is to be clear about what information we collect, so that you can make meaningful choices about how it is used. We provide you with the ability to exercise certain choices, rights and controls in connection with your Personal Data. Depending on your relationship with Fortunet, data protection and privacy laws provide you with various rights concerning your Personal Data, including (and depending on your jurisdiction):
- the right to access your Personal Data that we process;
- the right to ensure your Personal Data is accurate, complete and up to date;
- the right to have your Personal Data amended (by correcting, deleting or adding information);
- the right to object to the processing of your Personal Data, to the extent applicable;
- the right to withdraw consent, subject to legal or contractual restrictions and reasonable notice;
- the right to non-discrimination and the right to cease sharing or selling your Personal Data as such term is defined under the CCPA (as further detailed in the CCPA Privacy Notice).
You may exercise any or all of your rights in relation to your Personal Data by filling out the Data Subject Request (“DSR”) form available here, and send it to our privacy team at: email@example.com .
Where we are not able to provide you with the information for which you have asked, we will endeavor to explain the reasoning for this and inform you of your rights, including the right to complain to the supervisory authority (in the event you are EEA resident). We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any such information in accordance with applicable law.
We retain Personal Data we collect as long as it remains necessary for the purposes set forth above, all in accordance with applicable laws, or until an individual expresses a preference to opt-out.
Other circumstances in which we will retain your Personal Data for longer periods of time include: (i) where we are required to do so in accordance with legal, regulatory, tax, or accounting requirements; (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges; or (iii) if we reasonably believe there is a prospect of litigation relating to your Personal Data. Please note that except as required by applicable law, we may at our sole discretion, delete or amend information from our systems, without notice to you, once we deem it is no longer necessary for such purposes.
At Fortunet, security is our highest priority. We design our systems with your security and privacy in mind. We have implemented physical, technical, and administrative security measures for the services that comply with applicable laws and industry standards. Some of the methods that we use to protect your Personal Data includes: maintaining compliance programs that validate our security controls; protecting the security of your information during transmission to or from our website by using encryption protocols and software.
Note that we cannot be held responsible for unauthorized or unintended access beyond our control, and we make no warranty, express, implied, or otherwise, that we will always be able to prevent such access.
TRANSFER OF DATA
We may store or process your Personal Data in the EU, the United States or in other countries. Thus, any information you provide us may be transferred to and processed in countries other than the country from which you accessed our website. We will take appropriate measures to ensure that your Personal Data receives an adequate level of data protection upon its transfer. When Personal Data that was collected within the EEA is transferred outside the EEA, we will take necessary steps in order to ensure that sufficient safeguards are provided during the transferring of such Personal Data. You may exercise your rights, where applicable, to receive information regarding the transfer mechanism that was used during such transfer. Personal Data transferred outside the EEA is transferred, in all cases pursuant to standard contractual clauses approved by the European Union (“SCCs”). Additionally, following the withdrawal of the United Kingdom (UK) from the European Union on January 31, 2020, the UK is no longer considered to be a part of the EEA and therefore, the transferring of Personal Data from the EEA to the UK will also be subject to the SCCs or other contractual clauses that will ensure the security of the Personal Data (pending an adequacy decision from the European Commission)
Our website is not intended for use by children and we do not knowingly collect or maintain information about anyone under the age of 18. Please contact us at: firstname.lastname@example.org if you have reason to believe that a child has shared any information with us.