Last updated: May 17, 2022
Simetria Personal Data Protection Policy and Cookies Policy
Simetria Trading Solutions LTD (“Simetria” or “we”) Ltd. is a limited private company, located at 1 Noah Mozes st., Rishon Lezion, Israel, and incorporated under the laws of Israel.
1. General Principles
1.2. Your personal data is collected and stored lawfully, fairly and transparently by Simetria. In processing your data, we act in good faith, in a proportionate manner, and with the appropriate technical and organizational measures; and to mitigate the risks represented by the processing of the data.
1.3. Please be aware that the collection, processing and use of your personal data may, in the course of Simetria’s ongoing activities, be carried out by external data processors or joint controllers on our behalf. Within the framework of our contracts with such external processors, we inform them of the requirement to duly comply with relevant legal data protection rules and legislation applicable to the services they provide to us, and make reasonable efforts to communicate any changes to them with respect to such rules and legislation.
1.4. We may revise this Policy from time to time, and such changes shall come into effect from the moment we notify you of such changes and/or updates, either through the Websites or in some other reasonable manner.
1.5. For data subjects of the European Union, your rights under the General Data Protection Regulation (GDPR) are safeguarded by Simetria in accordance with the principles detailed below. Any questions regarding GDPR-related rights may be referred to us via the email address: firstname.lastname@example.org.
2. Why Simetria Uses Your Personal Data
2.1. Simetria uses your personal data to provide the services requested by you and to process your requests and inquiries. Your personal data is also used for the cookies and tracking utilized in the Websites to distinguish you from other users, to improve your use of these interfaces, and to ensure that content in the Websites and other relevant interfaces is presented in the most effective manner for you.
3.What we collect
The rights detailed below are subject to the applicable law that determines your status as a data subject in the jurisdiction in which you are located. Depending on the applicable law, you may have some or all of the following rights in respect of your personal data that we process. For any questions, please contact us at: email@example.com.
We get information about you in a range of ways:
3.1. Information You Give Us
We may collect your name, postal address, email address, phone number, username, password, demographic information (such as your occupation), social security number, tax ID number, bank account information, as well as other information you directly give us on our Services, which may include marketing, promotions and when communicating to you about new features.
For customers who have paid software services, we collect your billing details such as credit card information, banking information, and/or billing address.
3.2. Information We Get From Others
We may get information about you from other sources, such as your employer when they issue you options or shares. We may add this to information you provide us through our Services.
3.3. Information Automatically Collected
3.3.1. Device Information
We may collect information about the devices accessing our Services. Some examples are: type of device, operating system used, application information, unique device identifiers and crash data. The type of information we collect depends on the type of device used and its settings.
3.3.2.Transactional and Usage Information
We may automatically log information about you and your computer \ device, subject to your consent where required by law. For example, like most services when using our Services, we log your computer operating system type, browser type, browser language, pages or screens you viewed, how long you spent on a page or screen, location (your IP address), access times and information about your use of and actions on our Services. This is information we collect from every user of the Services, whether they have an account or not. This information may include personal information.
3.3.3. Cookies and Similar Technologies Information
As further described below, and subject to your consent where required by law, we automatically collect information from cookies and similar technologies as described in our Cookies Policy below.
4. Use and disclosure of personal information
4.1. The personal data collected and used by Simetria is limited to the data necessary for us to provide you with services we supply in the course of our ongoing activities, while operating under the relevant data protection and other regulatory obligations for each data subject and combating fraud. Access to your data, including physical access, is limited to only those employees of Simetria and third parties who have contracted with us and who utilize it exclusively for the purposes outlined below.
4.2. We may use, process and/or disclose personal information for the following purposes:
- To operate, maintain, and improve the Services. This includes use of other information to support delivery of our services, assist with service requests, monitor for errors, remedy security or technical issues, analyze website and application performances.
- To respond to comments and questions, verify permission access, and provide customer service.
- To send information including confirmations, invoices and billing, technical notices, updates, security alerts, and administrative messages.
- To communicate upcoming events and other news about products and services offered by us.
- To communicate and inform you about system updates and important services-related notices, such as privacy and policy update notices or changes in our terms of service. These communications are administrative and you may not opt out of them.
- To send marketing emails related to the Services, which you may opt out of using provided unsubscribe links or the opt-out mechanism in those communications.
- To link or combine user information with other personal information. An example is when we combine the information a company has provided about their shareholders with the information entered by shareholders in their personal portfolios to improve the user experience.
- To protect, investigate, and deter against fraudulent, unauthorized, or illegal activity.
- To provide and deliver products and services to our business customers with respect to their employees or investors. An example is when an employee exercises their employee stock options and we provide a tax form to their employer to facilitate compliance with tax laws.
4.3. We may also use and disclose personal information as follows:
- To comply with laws, lawful requests and legal or regulatory processes.
- You agree to your personal and financial information being stored and processed by Simetria.
4.4. We may create, use and share aggregated or anonymized data for any lawful purpose, such as marketing, analytics or research purposes permitted by law.
4.5. We may share personal information with acquirers and other relevant participants in business transactions (or negotiations for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in Simetria (including, in connection with a bankruptcy or similar proceedings).
4.7. We may share personal information with third party companies or individuals that we engage as service providers to process information and support our business and services. Examples include (but not limited to) providers of cloud hosting and storage services, analytics, services, email delivery services and customer support services. Third Party Services - in its efforts to enhance its user experience, Simetria may use third party services such as:
4.8. We may share personal information with our lawyers, accountants and other professional advisors in the course of the services they render to us.
5.1. We generally retain personal information to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes. To determine the appropriate retention period for personal information, we may consider factors such as the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
5.2. When we no longer require the personal information we have collected about you, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible. If we anonymize your personal information (so that it can no longer be associated with you), we may use this information indefinitely without further notice to you.
6. Age Limitations
6.1. Simetria does not allow the use of our services by anyone younger than 18 years old. If you learn that anyone younger than 18 has unlawfully provided us with personal data through our services, please contact us at: firstname.lastname@example.org and we will take steps to delete such information.
7. Information choices and changes
7.1. Our marketing emails tell you how to “opt out”. If you opt out, we may still send you non-marketing emails. Non-marketing emails include emails about your accounts and our business dealings with you. If at any time you would like to change your communication preferences, we provide unsubscribe links and an opt-out mechanism in those communications for your convenience.
7.2. You may send requests about personal information to our Contact Information below. You can request to change contact choices, opt out of our sharing with others, and update your personal information.
7.3. You can typically remove and reject cookies from our website with your browser settings, as described above.
7.4. You can update or correct certain personal information in your Simetria account. If you are unable to do so on your own, you may contact us: email@example.com.
8. Legal Basis
We may process Personal Data under the following conditions:
8.1. Consent: You have given Your consent for processing Personal Data for one or more specific purposes.
8.2. Performance of a contract: Provision of Personal Data is necessary for the performance of an agreement with You and/or for any pre-contractual obligations thereof.
8.3. Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which the Company is subject.
8.4. Vital interests: Processing Personal Data is necessary in order to protect Your vital interests or of another natural person.
8.5. Public interests: Processing Personal Data is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Company.
8.6. Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by the Company.
8.7. In any case, the Company will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
9. Data Subject Rights
9.1. The rights detailed below are subject to the applicable law that determines your status as a data subject in the jurisdiction in which you are located. Depending on the applicable law, you may have some or all of the following rights in respect of your personal data that we process. For any questions, please contact us at firstname.lastname@example.org.
9.2. Consent: For data subjects for which processing by explicit consent is relevant, we will only process personal data if you have consented to such processing, unless we are otherwise legally authorized or obliged to collect and further process personal data relating to you; and data will be processed solely based on your informed consent, used only for the purposes stated in the consent procedure (for example, in order to send Simetria updates, newsletters, and the like), and within the scope outlined below.
9.3. Withdrawal of consent – You may revoke or withdraw your consent at any time by notifying us directly via the email address email@example.com. Upon receipt of your request, and subject to applicable laws, we will delete your data unless we are legally obliged or authorized to retain it, including for ongoing legitimate business interests of Simetria. Withdrawal of your consent shall not have any influence over the legality of processing of your personal data carried out prior to said withdrawal.
9.4. Minimization of data processing – We process and store a minimum of your personal data, only as needed for providing Simetria services to you.
9.5. The “right to be forgotten” – Subject to any relevant laws, you may also request the erasure of all or part of your personal data held by Simetria. Upon receiving your request via the email address firstname.lastname@example.org, we will remove your personal data from all of our records, as soon as reasonably possible and when technically feasible, unless there is an overriding legal interest or other legal basis for the continuation of the data processing. Please understand that in the event of deletion of personal data upon your request, Simetria may not be able to further provide services via the Websites, in whole or in part. In requesting data deletion, you irrevocably agree and waive any claim against Simetria’s inability to provide said services, or any interruption or malfunction resulting therefrom. Note that your request for deletion may also be rejected by Simetria due to a lack of sufficient relevant information provided by you.
9.6. The “right to data correction” – You may also request the correction of all or part of your personal data held by Simetria. Upon receiving your request via the email address email@example.com, we will correct your personal data, as soon as reasonably possible and when technically feasible, unless there is an overriding legal interest or other legal basis for refraining from the requested correction. In requesting data correction, you irrevocably agree and waive any claim against Simetria’s inability to provide the said services, or any interruption or malfunction resulting therefrom. Note that your request for correction may also be rejected by Simetria for lack of sufficient and/or relevant information provided by you and/or if it is not in compliance with the law.
9.7. Transparency and portability of personal data – You are entitled to ask Simetria for information about the type of personal data about you that we process. You may also be entitled to obtain it in a commonly-used and machine-readable form, subject to technical feasibility and lawfulness considerations. Please forward your request via the email address firstname.lastname@example.org.
9.8. Automated decision-making on the basis of your personal data – Although the situation will be rare, we may make decisions concerning our business relationship with you based on automated processing activities without human intervention. We commit to giving you the opportunity to obtain human intervention in such a decision, express your point of view, and obtain an explanation of the decision. Please send your request regarding automated decision-making via the email address email@example.com.
9.9. Personal data relating to children and minors – We do not knowingly collect or process personal data relating to children and minors under the age of 13 years, unless we are legally obliged to do so. If we become aware that personal data was transferred to us or collected by us relating to children under the age of 13 years without the informed consent of a parent or legal guardian, we will delete such personal data without undue delay on our own initiative. Note that data subject requests from minors must be accompanied by valid consent of a parent or legal guardian and his/her identification. Please forward any requests in this respect via the email address firstname.lastname@example.org.
9.11. Sensitive personal information. We ask that you not provide us with any sensitive personal information (e.g., information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through our services, or otherwise to us.
9.12. In the implementation of these data protection rights, Simetria is committed to providing a timely and transparent response to your requests. For any questions regarding these rights, please contact us via the email address email@example.com.
9.13. Cross-border data transfer. If we transfer your personal information out of Israel, the transfer will be performed as permitted by applicable laws.
10. Contact information
11. Cookies Policy
Use of the Websites by you indicates your acceptance of this Cookies Policy.
This Cookies Policy applies to all activities of Simetria with respect to the cookies that we collect and store in the course of our activities, including through the Websites and other electronic interfaces with data subjects that we operate.
11.2. What’s a cookie? A cookie is a small simple file that is sent along with pages of this website and stored by your browser on the hard drive of your computer or another device. However, when it is read by a server via a web browser it can help a website deliver a more user-friendly service by, for example, remembering previous account details. Cookies cannot install malicious software such as viruses on your device, and they do not store any of your personal data or account information.
11.4. Where do cookies come from? Cookies originate from two types of sources: 1st -party and 3rd -party. This classification refers to the internet domain that is placing the cookie.
11.4.1. 3rd- party cookies are cookies that are set by a domain other than that of the site being visited by the user. If a user visits a website and another entity sets a cookie through that site this would be a 3rd -party cookie.
11.4.2. 1st-party cookies are those set by a website that is being visited by the user at the time.
11.6. If you do not opt in to cookies, you may still use the Websites, but your ability to use some features may be limited or unavailable. Many browsers allow a private mode to be activated through which the cookies are always erased after the visit, and you hereby irrevocably and unconditionally waive any claim or demand in this regard.
11.7. Do Not Track/Privacy Mode is a function that allows users to opt out from being tracked by websites for any purpose, including the use of analytics services, advertising networks and social platforms.
11.8. We do not currently take actions to respond to Do Not Track signals because a uniform technological standard has not yet been developed. We continue to review new technologies and may adopt a standard once one is created.
11.9. If you have enabled the “do not track” function in your browser, you will not be tracked. This is in addition to your opting-out of data aggregation and analysis for Website statistics.
11.10. Categories of cookies we use – Simetria places a high priority on the security and confidentiality of the information stored in the persistent cookies we use. The categories we use are as follows:
11.10.1. Performance cookies – These cookies allow publishers to track your behavior as a site visitor, measure site performance, and improve your user experience.
11.10.2. Functionality cookies – There are different types of cookies in this category, and they are used to customize the site for your personal use using the options you specify, such as your language preference.
11.10.3. Targeting cookies – These cookies help you track relevant ads for you. They help record your use of these ads, including limits on how often you view them.