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1. General Provisions

The purpose of this Confidentiality Policy (hereinafter referred to as the Policy) is to ensure the personal data (hereinafter also referred to as “PD”) processing process by Private Entrepreneur LACY SOMETHINGS, registered in Israel under number 308609353 at the following address: Kaplan 9, Petah Tikva, Israel (hereinafter referred to as the “Online Store”) in accordance with the rules and principles of the applicable legislation.

The user using the Website (hereinafter referred to as the “Website”) accepts this Confidentiality Policy. The user gives his consent to the processing of his personal data on the terms and conditions specified below. If the user does not agree with the Confidentiality Policy, he shall immediately stop using the Website. By accepting the terms and conditions of this Confidentiality Policy, the user agrees, among other things, to possible cross-border transfer of personal data.

2. Definitions

2.1. Personal data (PD) – any information relating directly or indirectly to a definite or definable individual (personal data subject);

2.2. Operator – a public authority, municipal authority, legal entity or individual, independently or jointly with other persons organizing and (or) carrying out the processing of personal data, as well as determining the purposes of processing personal data, the scope of personal data to be processed, actions (operations) performed with personal data;

2.3. Processing of personal data – any action (operation) or a set of actions (operations) performed with personal data using automation tools or without using such tools, including collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data;

2.4. User – a visitor to the Website

3. Principles and Conditions for PD Processing

3.1. PD processing in the Online Store is carried out strictly in accordance with the following principles:

  • PD processing is carried out on a legal and fair basis.

  • PD processing is limited to the achievement of particular, predetermined and legal purposes.

  • The content and volume of processed PD correspond to the stated processing purposes, the Online Store does not process excessive personal data.

  • During processing, the accuracy, sufficiency and, if necessary, relevance of PD is ensured in relation to the purposes of personal data processing.

  • The processed PD is destroyed upon reaching the processing purposes or in case of loss of the need to achieve these purposes, unless otherwise provided by the federal law.

3.2. The Online Store does not process PD related to race, nationality, political views, religious, philosophical and other beliefs, intimate life, membership in public associations, including trade unions.

3.3. Biometric PD (information that characterizes the physiological and biological characteristics of a person, based on which such person’s identity may be established and which is used by the operator to establish the identity of the PD subject) is not processed in the Online Store.

3.4. The Online Store may transfer PD to third parties in cases provided for by the applicable legislation.

3.5. The Online Store may entrust the processing of PD of PD subjects to third parties based on an agreement concluded with these parties.

3.6. Persons who process PD based on an agreement concluded with the Online Store (operator’s order) undertake to comply with the principles and rules for processing and protecting PD provided for by the Law.

3.7. Consent to PD processing shall meet the following requirements:

  • consent of the subject shall be obtained freely, according to the will of the subject and in his interests;

  • consent shall be given by the PD subject in any form that allows to confirm the fact of its obtaining.

3.8. PD, the processing (storage) period of which has expired, shall be destroyed, unless otherwise provided by the federal law. Storage of PD after the termination of processing is allowed only after its depersonalization.

4. Legal Bases and Purposes of PD Processing

4.1. The processing and maintenance of security of PD in the Online Store is carried out in accordance with the requirements of the applicable legislation.

4.2. The subjects of PD processed by the Company are:

  • representatives of legal entities – contractors of the Online Store;

  • customers – consumers, including visitors to the Website of the Online Store (hereinafter referred to as the “Website”), including for the purpose of placing an order with subsequent delivery to the customer;

4.3. The Online Store processes PD of subjects (Customers – consumers) for the following purposes:

  • providing information on goods/services, promotions and special offers;

  • analyzing the quality of the service provided by the Company and improving the quality of customer services of the Online Store;

  • informing about the order status;

  • performing the agreement, including purchase and sale agreement, including those concluded remotely on the Website, providing paid services;

  • forming a wish-list;

  • delivery of the ordered goods to the customer who made an order on the Website, return of the goods.

4.4. The Online Store may process the personal data of customers received online – on the Internet (Website, e-mail).

5. Rights and Obligations of PD Subjects

5.1. The subject whose PD is processed by the Company shall have the following rights:

  • to receive information from the Online Store regarding the processing of his PD (including confirmation of the fact of PD processing, legal grounds, processing purposes, processing period, storage period, name and address of the person processing PD on behalf of the Online Store, if processing is entrusted or will be entrusted to such a person, other information).

  • to demand that the Online Store clarifies his PD, block or destroy it if PD is incomplete, outdated, inaccurate, illegally obtained or not necessary for the stated purpose of processing, as well as to take statutory measures to protect his rights;

  • to withdraw consent to PD processing at any time.

5.2. Information is provided to the PD subject based on a request. The request shall contain the number of the main identity document of the PD subject or his representative, information on the date of issue of the said document and the issuing authority, information confirming the participation of the PD subject in relations with the Company, or information otherwise confirming the fact of PD processing by the Company, signature of the subject or his representative.

5.3. The request may be sent to the e-mail address: [email protected] in the form of an electronic document.

6. Liability for Violations of the Rules Governing the PD Processing

6.1. Ensuring the confidentiality of PD processed in the Online Store is a mandatory requirement for all employees to whom PD became known, both in connection with work activities, and by accident or mistake.

6.2. Employees shall be personally liable for compliance with the requirements for processing and ensuring the security of PD established in the Online Store.

6.3. In cases of violation of the established procedure for processing and ensuring the security of PD, unauthorized access to PD, disclosing PD and causing material or other damage to the company, its employees, customers and counterparties, the guilty persons shall be liable in accordance with the applicable legislation. 

7. Use of Cookies

7.1. A cookie is a small file of letters and numbers. This file is saved on your computer, tablet PC, phone or other device that you use to visit the Website. Cookies are used by the Online Store to ensure the operation of the Website or to improve the efficiency of its work, as well as to obtain analytical information.

7.2. The Online Store and its service providers may use cookies for various purposes, including to:

  • Facilitate for itself and third parties obtaining information about your visits to the Website;

  • Analyze information about your visits to the pages in order to improve our website;

  • Provide messages and content on this website and websites of others, taking into account your interests;

  • Help users to obtain the necessary information;

  • Determine the number of visitors and how they use the Website – to improve the efficiency of the Website and to better understand the interests of users.

7.3. How to manage cookies?

Most internet browsers are initially set to automatically accept cookies. You may change your settings to block cookies. There are several ways to manage cookies. Please refer to your browser instructions for more information on how to adjust or change your browser settings. If you disable the cookies used by the Online Store, this may affect your activity on the Website, you may not be able to receive personal information when you visit the website. If you use different devices to view and access our website (for example, computer, smartphone, tablet, etc.), you shall ensure that each browser on each device is configured in accordance with your point of view on how to work with cookies.

7.4. The Online Store may use various types of cookies on the Website:

Strictly Necessary Cookies. These cookies are necessary for the website to work correctly, they will allow users to move around the Website and use its capabilities. These cookies do not personally identify the user. If you do not agree to use this type of files, this may affect the performance of the website or its components.

Performance, efficiency and analytics cookies. These files help the Online Store to understand how visitors interact with the Website, providing information about the areas they visited and the amount of time they spent on the Website, they also show problems in the operation of the Internet resource, for example, error messages. This will help the Online Store to improve the website’s performance. Analytics cookies also help the Online Store to optimize the content of the Website. This type of cookies may not be used to identify you. All information that is collected and analyzed is impersonal.

Functional cookies. These cookies are used to identify users returning to the Website. They allow the Online Store to customize the content of the website for users and remember the preferences. If the user blocks this type of files, it may affect the performance and functionality of the website and may restrict access to the content on the website.

7.5. If the user uses several devices (for example, computer, smartphone, tablet) to access the Internet, check the cookie settings on each browser.

8. Final Provisions

8.1. This Policy is a local regulation of the Online Store. This Policy is publicly available. The general availability of this Policy is ensured by its publication on the Website.

8.2. This Policy may be revised due to changes in the applicable legislation or by the decision of the Online Store.

9. For European Union Users

9.1. At the user’s request, the Online Store will provide the European Union resident user with a readable copy of the data collected and processed by you.

9.2. The Online Store provides users with the right to delete, edit and restrict the use of their data as described in details in p. 9.10.

9.3. The user may send a request to Online store to completely delete or change his data.

9.4. The Online Store undertakes to notify users about the leakage of user data, as well as about any violations and leakages of personal data, if any. This notice shall be sent within 72 hours after the problem is detected.

9.5. Online Store process the content you generate and view on the Platform, including preferences you set.

9.6. The Online Store does not process any Special categories of data. Therefore, the DPO is not appointed.

9.7. In terms of GDPR (if applicable) Online Store is considered as Data controller and might involve data operators such as service providers.

9.8. By using the Website Client acknowledges that they understand and agree with the current Privacy Policy. If the Client does not agree, they should immediately stop using Website.

9.9. For execution of right to erasure and other prescribed by law, a Client should contact Online store by phone or email indicated on the Website.

9.10. Client has the following rights:

9.10.1. Access Data: Client can ask Online Store, free of charge, to confirm that Online Store process personal data and for a copy of Client’s personal data.

9.10.2. Delete Data: Client can ask Online Store to delete all or some of Client’ personal data. 

9.10.3. Change or Correct Data: can ask Online Store to change or fix data. 

9.10.4. Portability: Client can ask Online Store for a copy of personal data Client provided in a machine-readable form.

9.10.5. Object or Restrict Use of Data and Withdraw Consent: Client can ask Online Store to stop using some or all of data, e.g. if Online store has no legal right to keep using it. 

9.10.6. Client can ask Online Store to stop processing personal data for direct marketing purposes; withdraw consent or ask Online Store to stop making any automatic individual decisions, including profiling. If you object to such processing, Online Store will ask Client to share the reason for objection in order for Online Store to examine the processing of personal data and to balance Online Store legitimate interest in processing and objection to this processing.



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