Privacy Policy

At PointFive Ltd., its subsidiaries (if any) or affiliated companies ("PointFive US Inc" or "We"), we recognize that privacy is important. This privacy policy ("Privacy Policy") applies to the access to PointFive's website (the "Website") or PointFive's Application (the "App") and the use of the services available through the Website (collectively, the "Services").

"Personally Identifiable Information" ("PII") is information that can be used on its own or with other information to identify, contact, or locate a single person, or to identify an individual in context. When you, the user (the "User") uses the Services, your PII will be processed subject to the terms of this Privacy Policy.

Please read our Privacy Policy carefully to get a clear understanding of how We organize, collect, use, protect or otherwise handle your PII in accordance with our Website. You are not legally required to provide PII, however in order to enable you to access and use the Services We require that you provide PII pursuant to this Privacy Policy. By using the Services you consent to this Privacy Policy, inclusive of the terms described herein.

If you have any questions about this Privacy Policy, please feel free to contact us at: [email protected]

You hereby acknowledge, agree and explicitly consent of your own free will and although not necessarily required to do so under law, that your PII, will be stored, processed, used, held and managed by PointFive and/or on our behalf, inter alia, by magnetic or optical means that are designated for digital processing or in other forms of database(s) in accordance with applicable law.

1. Information and How We Use It

The Website or the App may collect, process and use the data which includes PII, the legal basis of which is your consent, which you give when you use the Services. Types of PII that may be used include the following, without limitation:

1. When registering on our Website you may be asked to enter your full name, email address, and telephone number ("Entered Data"). You are the source of such data, and such data may be processed for the purposes of operating the Website, providing the Services, ensuring the security of the Website and Services, maintaining back-ups of our databases and communicating with you.
2. We may process information that you provide to us for the purpose of subscribing to our email notifications ("Notification Data") provided that you have specifically consented to receive the same.
3. We may process information contained in or relating to any communication that you send to us ("Correspondence Data"), for example, when you sign up for our newsletter or respond to a survey. The Correspondence Data may include communication content and/or metadata associated with such communication.
4. We may collect and retain metadata and statistical information concerning the use of the Services which are not subject to the deletion procedures in this Privacy Policy and may be retained by us for no more than required to conduct its business. You will not be identifiable from this retained metadata or statistical information.
5. We may process any of the types of data described in this Section if We are required to do so by court-order, any legal obligation to which We are subject, or when necessary, for the establishment, exercise or defense of legal claims. The legal basis for this processing is our legitimate interests.
6. Please do not supply any other person's PII to us without the specific and explicit consent of all parties, including the owner of such PII.

2. Providing Your PII to Others

1. We may disclose PII to any member of our group of companies, including subsidiaries (if any), holding companies and all of their respective subsidiaries, insofar as reasonably necessary for the purposes set out in this Privacy Policy.
2. We may disclose your PII to professional advisers insofar as reasonably necessary for the purposes of obtaining and maintaining insurance coverage, managing risks, obtaining professional advice and managing legal disputes.
3. We may disclose your PII to third-party service providers, vendors and subcontractors reasonably necessary to provide the Services. Such third-party providers will only use the PII to the extent necessary to allow them to perform the services they provide to PointFive.
4. We will only disclose your PII to third parties who provide sufficient guarantees that they implement appropriate technical and organizational measures in such a manner that their processing of your PII will meet the requirements of Data Protection Regulation and ensure the protection of your rights and with whom We have written contracts that conform to our legal obligations.

3. International Transfers of Your PII

1. Your PII may be transferred to countries worldwide including inside and outside the European Economic Area ("EEA").
2. We have facilities in Israel. "Adequacy decisions" of the European Commission have been made with respect to the data protection laws of Israel. We also have facilities in the United States. We will only transfer your personal data from the EEA, United Kingdom or Switzerland to third countries on the basis of appropriate safeguards or if otherwise authorized by applicable law.
3. Transfers to countries will be protected by appropriate safeguards, namely the provisions of applicable law which relate to the protection of individuals with regards to the Processing of Personal Data including, without limitation, the Israeli Protection of Privacy Law, 5741-1981, the General Data Protection Regulation (EU) 2016/679, the Data Protection Act 2018, and other applicable regulations (collectively "Data Protection Regulation").
4. The hosting facilities for our Website are situated within the EEA, the United States, and Israel.
5. You acknowledge that PII submitted by you for transmission through the Services may be transmitted around the world via the internet for the purpose of performing the Services and subject to the terms of this Privacy Policy.
6. You acknowledge that PointFive may assign its rights and obligations in the event of a sale and/or merger in which control of PointFive and/or most of its assets is transferred to a third party, provided that such third party abides by the terms of this Privacy Policy, and applicable law.

4. Retaining and Deleting PII

1. PII will be retained for the duration of the Services up to a period of seven years following the end of the Services after which period it will be deleted from our systems, unless otherwise required under applicable law.
2. Notwithstanding the other provisions of this Privacy Policy, We may retain your PII 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.

5. Your Rights

Your principal rights under Data Protection Regulation are all or some of the following:

• The right to access
• The right to rectification
• The right to erasure
• The right to restrict processing
• The right to object to processing
• The right to data portability
• The right to complain to a supervisory authority
• The right to withdraw consent

You have the right to confirmation as to whether or not We process your PII and, where We do, access to the PII, together with certain additional information. You can request to access your PII by requesting an e-mail summary from: [email protected]

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

In some circumstances you have the right to the erasure of your PII without undue delay. Those circumstances include: the PII is no longer necessary in relation to the purposes for which they were collected; you withdraw consent to consent-based processing; and the PII have been unlawfully processed.

In some circumstances you might have the right to restrict the processing of your PII. Where processing has been restricted, We may continue to store your PII. However, We will only otherwise process it: with your consent; for the establishment, exercise or defense of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

To the extent that the legal basis for our processing of your PII is consent, and such processing is carried out by automated means, you have the right to receive your PII from us in a structured, commonly used and machine-readable format.

If you consider that our processing of your PII infringes Data Protection Regulation, you have a legal right to file a complaint with a supervisory authority responsible for data protection.

You may exercise any of your rights in relation to your PII by written notice to us at [email protected]

6. Opt-in

When you provide us with PII for a secondary reason, like marketing or other secondary reasons, We will ask for your consent. After you opt-in, you may withdraw your consent at any time, by contacting us at [email protected]

7. Information Security

• We follow generally accepted industry standards to protect against unauthorized access to or unauthorized use, alteration, disclosure or destruction of PII. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure.
• The PII is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required by contract to keep the information confidential.
• We implement a variety of security measures to maintain the safety of the PII.

8. California Consumer Privacy Act (CCPA)

California residents have specific rights under the California Consumer Privacy Act ("CCPA"), as amended by the California Privacy Rights Act ("CPRA"). For more information and to exercise your rights, please see the Privacy Notice for California Residents.

9. California Online Privacy Protection Act

According to CalOPPA, We agree to the following:

• Users can visit PointFive's Website anonymously.
• Once this Privacy Policy is created, We will add a link to it on our home page or as a minimum, on the first significant page after entering our Website.
• Our Privacy Policy link includes the word "Privacy" and can easily be found on the page specified above.

10. COPPA (Children Online Privacy Protection Act)

When it comes to the collection of PII from children under the age of 13 years old, the Children's Online Privacy Protection Act (COPPA) puts parents in control.

We do not market to children under the age of 13 years old, and 13 year olds are prohibited from using this Website without proper consents from guardians.

11. Fair Information Practices

In order to be in line with Fair Information Practices We will take the following responsive action, should a data breach occur:

• We will notify you within the time required by applicable law, but no later than three business days from becoming aware of any such breach.
• We also agree to the Individual Redress Principle which requires that individuals have the right to legally pursue enforceable rights against data collectors and processors who fail to adhere to the law.

12. CAN-SPAM Act

The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations.

We collect your email address in order to:

• Send information, respond to inquiries, and/or other requests or questions
• Send you additional information related to the Services
• Market to our mailing list or continue to send emails to our clients after the original engagement has occurred

To be in accordance with CAN-SPAM, We agree to the following:

• Not use false or misleading subjects or email addresses
• Identify the message as an advertisement in some reasonable way
• Include the physical address of our business or site headquarters
• Monitor third-party email marketing services for compliance, if one is used
• Honor opt-out/unsubscribe requests quickly
• Allow users to unsubscribe by using the link at the bottom of each email

13. Third-Party Direct Collectors

In general, the third-party providers used by us will only collect, use and disclose your information to the extent necessary to allow them to perform the Services they provide to us. However, certain third-party service providers have their own privacy policies in respect to the information we are required to provide to them for your related transactions.

For these providers, we recommend that you read their privacy policies so you can understand the manner in which your PII will be handled by these providers. In particular, remember that certain providers may be located in or have facilities that are located a different jurisdiction than either you or us.

Once you leave our Website or are redirected to a third-party app or website or application, you are no longer governed by this Privacy Policy or our Terms of Service.

14. Third-Party Links

Occasionally, at our discretion, We may include or offer third-party services on our Website. These third-party sites have separate and independent privacy policies. We therefore have no responsibility or liability for the content and activities of these linked sites. Nonetheless, We seek to protect the integrity of our site and welcome any feedback about these sites.

15. Age of Consent

By using our Website, you represent that you are at least the age of majority in your state, province or country of residence, or that you are the age of majority in your state, province or country of residence and you have given us your consent to allow any of your minor dependents to use this site.

16. Law and Jurisdiction

• The law that applies to activity on the Website and the Privacy Policy is the law of the State of Israel alone.
• Exclusive jurisdiction to hear any dispute regarding the Website and/or the Privacy Policy and anything deriving thereunder is conferred to the competent court in the district of Tel Aviv-Yafo, Israel.

17. Changes to the Privacy Policy

• We reserve the right to modify this Privacy Policy at any time, so please review it frequently. Changes and clarifications will take effect immediately upon their posting on the Website. In the event of a material change, We shall notify you via email or by means of a prominent notice on the Website.
• If We are acquired or merged with another company, your information may be transferred to the new owners so that We may continue to provide our Services to you.

18. Contacting Us

If there are any questions regarding this Privacy Policy, you may contact us: