GLILOT CAPITAL PARTNERS – PRIVACY POLICY
[Last Modified: November 30, 2022]
This privacy policy (“Privacy Policy” or “Policy”) describes how Glilot Capital Partners (collectively shall be referred to as “Glilot”, “we”, “us”, or “our”) collect, use and disclose certain information, including your personal information and the choices you can make about that information.
This Policy applies to all information about you that we collect when you browse our website available at: https://www.glilotcapital.com/ (“website“), register to our events, or, as an investor, when you access, use and register to our portal (“Investor Portal”), all as detailed below.
POLICY AMENDMENTS:
We reserve the right to amend this Policy from time to time, at our sole discretion. The most recent version of the Policy will always be posted on the website. The updated date of the Policy will be reflected in the “Last Modified” heading. We will provide notice to you if these changes are material, and, where required by applicable law, we will obtain your consent. Any amendments to the Policy will become effective within 30-days upon the display of the modified Policy. We recommend you review this Policy periodically to ensure that you understand our most updated privacy practices.
CONTACT INFORMATION AND DATA PROCESSOR INFORMATION:
Glilot Capital Partners is incorporated under the laws of Israel, and it is the controller of your Personal Data.
You may contact us and our privacy team as follows:
- By Email: [email protected]
- By Mail: 6 HaChoshlim St, Herzliya Pituach, Israel
DATA SETS WE COLLECT AND FOR WHAT PURPOSE:
You can find here information regarding the purposes for which we process your personal data as well as our lawful basis for processing, the definition of “personal” and “non-personal” data, and how it is technically processed.
Non-Personal Data
During your interaction with our services, we may collect aggregated, non-personal non-identifiable information, which may be made available or gathered via your access to and use of the services (“Non-Personal Data “). We are not aware of the identity of the user from which the Non-Personal Data is collected. The Non-Personal Data being collected may include your aggregated usage information and technical information transmitted by your device, such as: the type of browser or device you use, language preference, time and date stamp, country location, etc.
Personal Data
We may also collect from you, during your access or interaction with the services, individually identifiable information, namely information that identifies an individual or may, with reasonable effort, be used to identify an individual (“Personal Data” or “Personal Information”). The types of Personal Data that we collect as well as the purpose for processing such data are specified in the table below. For the avoidance of doubt, any Non-Personal Data connected or linked to any Personal Data shall be deemed as Personal Data as long as such connection or linkage exists.
The table below details the processing of Personal Data, the purpose, lawful basis, and processing operations:
| DATA SET | PURPOSE AND OPERATION | LAWFUL BASIS |
| Contact Information If you contact us or register to our events, you may be required to provide us with your contact information such as name, email address and job title and any additional information you choose to provide. | We will use this data to respond to your inquiry.
| We will process this information subject to our legitimate interest. |
| Newsletter Registration In the event you sign up to receive updates, exclusive sales and offers, you will be requested to provide your contact details, such as your email address. | We will use your email to add you to our mailing list and keep you updated with new services, features and capabilities. | We process such contact information subject to your consent. You may withdraw consent at any time through the “unsubscribe” link within the email or by contacting us directly at: |
| Online Identifiers When you access the website, we may, either directly or indirectly (through our third-party service providers) collect your IP address, cookie ID, agent ID or other online identifiers. | We process such information through third party cookies for analytic purposes and marketing purposes. | Consent which we will obtain through our cookie notice. You may withdraw consent at any time by using the cookie preference settings. |
| Investors Account When you register and create an account on the Investors Portal, you will be required to provide us with information such as contact information (name, email address), user name and password or credentials (“Investors Account”). | We use this data to create your account, to perform our contract and enable you to use the Investor Portal. | We process Investors Account information as part of performance of our contract. |
| Financial Information We will collect and process certain financial information from our investors such as financial statements, tax reports, capital account reporting, and notices, or other information or documentation related thereto. | We will collect this information directly from you or from questionnaire, tax and anti-money laundry forms, or similar forms. We may share this information with third party processors, such as banks and third parties (e.g., administrator that assist us in onboarding Investors, managing their documents and providing payments). | We process such financial information subject to your consent and performance of our contract. |
| Direct Marketing We will send you invoices, financial materials and marketing content through the email information you provided during your onboarding to our Investor Portal. | We will use this information to keep you updated with offers and content such as updates and features, and to send you invoices and supporting documentation. | We process such information subject to our legitimate interest. You can opt-out at any time by contacting us, however certain content (such as invoices) will still be sent. |
| Usage Data When you access the Investors Portal, either directly or indirectly (through our third-party service providers or tools) collect certain behavior data to better understand how you use the Investors Portal, including click stream, features used, duration, crash and error data, etc. (“Usage Data”). The Usage Data may include Personal Data. | We will use this data in order to operate, provide, maintain, protect and manage our services.
| We process such information subject to our legitimate interest. |
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 Data Transfer Section, 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 this Privacy Policy, 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 services provided through the website, as detailed above. If we combine Personal Data with Non-Personal Data, the combined information will be treated as Personal Data or for as long as it remains combined.
HOW WE COLLECT YOUR INFORMATION:
Depending on the nature of your interaction with us, we may collect the above detailed information from you, as follows:
- Automatically, when you visit our website, including through the use of Cookies (as detailed below) and similar tracking technologies.
- When you voluntarily choose to provide us with information, such as when you contact us, all as detailed in this Policy.
COOKIES AND SIMILAR TECHNOLOGIES:
As explained above, we use cookies to improve your experience while using the website. Cookies are small text files implemented on the user’s computer or web browser that allow some tracking and identification of the user to collect data regarding its data usage. We may use various types of Cookies, such as:
- 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);
- Analytics Cookies – give us aggregated and statistical information to improve the services and further develop it such as Google Analytics.
Please note that the data collected by the use of Cookies may be linked to and combined with any other data, including Personal Data.
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 in the table below:
| COOKIE NAME | PURPOSE | EXPIRY |
| __hssrc | Analytics Cookies | Session |
| _ga | 2 Years | |
| _gid | 1 Day | |
| __hstc | 5 Months 27 Days | |
| hubspotutk | 5 Months 27 Days | |
| _gat | Analytics Cookies (Performance) | 1 Minute |
| __hssc | Functional Cookies | 30 Minutes |
| __cf__bm | Functional Cookies | 30 Minutes |
DATA SHARING – CATEGORIES OF RECIPIENTS WE SHARE PERSONAL DATA WITH:
We share your data with third parties, including our service providers that help us provide our services. You can find here information about the categories of such third-party recipients.
| CATEGORY OF RECIPIENT | DATA THAT WILL BE SHARED | PURPOSE OF SHARING |
| Service Providers
| All data | We may disclose Personal Data to our trusted agents (legal counselors) and service providers (including, but not limited to, our Cloud Service Provider, our Analytics Service Provider, our CRM provider, etc.) so that they can perform the requested services on our behalf. Thus, we share your data with third party entities, for the purpose of storing such information on our behalf, providing marketing assistance, or for other processing needs. 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. |
| Any acquirer of our business | All data | We may share Personal Data, in the event of a corporate transaction (e.g., sale of a substantial part of our business, merger, consolidation or asset sale). In the event of the above, our affiliated companies or acquiring company will assume the rights and obligations as described in this Policy. |
| Legal and law enforcement
| Subject to law enforcement authority request. | We may disclose certain data to law enforcement, governmental agencies, or authorized third parties, in response to a verified request relating to terror acts, criminal investigations or alleged illegal activity or any other activity that may expose us, you, or any other user to legal liability, and solely to the extent necessary to comply with such purpose. |
We reserve the right to use, disclose or transfer (for business purposes or otherwise) aggregated and processed Non-Personal Data to third parties, including, inter alia, affiliates, for various purposes including commercial use. This information may be collected, processed and analyzed by us and transferred in a combined, collectively and aggregated manner (i.e., your information is immediately aggregated with other users) to third parties.
USER RIGHTS:
We acknowledge that different people 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 allow you to exercise certain choices, rights, and controls in connection with your information. Depending on your relationship with us, data protection and privacy laws provide you with some of the following principal rights regarding 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.
You may exercise any or all of your above rights in relation to your Personal Data by filling out the Data Subject Request (“DSR”) form available here, and send it to: [email protected].
DATA RETENTION:
In general, we retain the Personal Data we collect for as long as it remains necessary for the purposes set forth above, all under the applicable regulation, or until you express your preference to optout, where applicable.
Other circumstances in which we will retain your Personal Information for longer periods of time include: (i) where we are required to do so in accordance with legal, regulatory, tax, or accounting requirements, or (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 will not be obligated to retain your data for any particular period, and we may delete it for any reason and at any time, without providing you with prior notice if our intention to do so.
SECURITY MEASURES:
We work hard to protect the Personal Data we process from unauthorized access, alteration, disclosure, or destruction. We have implemented physical, technical, and administrative security measures for the services that comply with applicable laws and industry, such as encryption using SSL, we minimize the amount of data that we store on our servers, restricting access to Personal Data to Glilot employees, contractors, and agents, etc. 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.
Please contact us at: [email protected] if you feel that your privacy was not dealt with properly, in a way that was in breach of our Privacy Policy, or if you become aware of a third party’s attempt to gain unauthorized access to any of your Personal Data. We will make a reasonable effort to notify you and the appropriate authorities (if required by applicable law) in the event that we discover a security incident related to your Personal Data.
INTERNATIONAL DATA TRANSFER:
Our data servers in which we host and store the information are located in the US, EU and EMEA. The Company is based in Israel in which we may access the information stored on such servers or other systems. In the event that we need to transfer your Personal Data out of your jurisdiction, we will take appropriate measures to ensure that your Personal Data receives an adequate level of protection as required under applicable law.
ELIGIBILITY AND CHILDREN PRIVACY:
Our services are not intended for use by children (the phrase “child” shall mean an individual that is under the age defined by applicable law, which concerning the EEA is under the age of 16, and with respect to the US, under the age of 13), and we do not knowingly process children’s information. We will discard any information we receive from a user that is considered a “child” immediately upon discovering that such a user shared information with us. Please contact us at [email protected] if you have reason to believe that a child has shared any information with us.