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Privacy Policy

Last updated: 06.02.2023

This is the privacy policy of Alsomine Ltd. (the "Company", "We", "Us" or "Our"). The Company is committed to securing the data regarding the members of Our community and to protecting their privacy.

Out of this commitment, We prepared this privacy policy (the “Policy”) so You (“You” or “Your”) can be aware of the types of information that We collect about You, when We collect it, how We use it, share it with third parties, maintain it, etc..

1. The Scope 

This Policy describes what kind of Personal Data We collect about natural persons, and how We collect it, use it, share it with third parties, secure it, process it, etc.. In this Policy, “Personal Data” refers to any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or in combination with additional information that We have or that We have access to. In this Policy, the “processing” of Personal Data refers to any operation or set of operations performed on Personal Data, including the collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction of Personal Data. You must be at least 18 years old to access and/or use Our Services and/or register with Us. We do not knowingly collect Personal Data about any person under the age of 13.

2. Data Controller 

The Company: The Company is the data controller in respect of the Personal Data provided to the Company by You. 

3. When Do We Collect Personal Data About You 

We may collect Personal Data about You in the following circumstances: - When You access or use Our Website or (the “Website”); - When You use the services involved in, or related to, the Website (the “Services”); and - When You interact with Us via Our communication channels.

4. No Obligation To Provide Personal Data To The Company And Its Implications

You are not obligated to provide Us with any Personal Data about You. However, in some instances, not providing such Personal Data will prevent Us from providing You with the products or services You requested Us to provide You, will prevent Your use of the Website and the services involved therein, and/or will cause the malfunctioning of Our Services.

5. What Personal Data About You Do We Collect?  

We (or others on Our behalf) may collect the following types of Personal Data about You: - Registration information – when You register to the Website, You provide Us with some information about You, including Your name, email address, wallet address, Your country of residence, Your areas of interest. - Service activity information – along with the information that You actively provide Us with, We also automatically gather certain data out of Your use of the Services, including the Website. The information that We gather about You in this context includes any interaction that You will make with the Services, including the Website’s pages that You will visit, Your interaction with such pages, the content that You will seek and view, and the like. - Website usage information and log files - as You navigate through and use the Website, We may also use automatic data collection technologies to collect certain information about Your equipment, browsing actions and patterns. This information is used by Us in order to provide Our Service and make it more useful to You, and it includes online activity log, IP address, mobile device ID, browser type, operating system, country location, date and time stamps, web and mobile page(s) visited, clickstream data, configuration data and software crash reports. Some of this information may not identify You personally, and therefore not constitute Personal Data. - Communication information - when You contact Us, including via the Website, social media networks or any other User support channels, You may provide Us with Your name, certain contact information (such as email address and telephone number), the content of Your communication with Us and Your interaction with the content that We shall send You. - Subscription information – We may offer You to subscribe to certain lists of members in order to allow Us to contact You or allow You to join Our community in the future.

6. The Purposes Of The Processing Of Personal Data And Their Legal Basis  

The Company processes Your Personal Data for one or more of the purposes outlined in this section and according to the appropriate legal basis. The Company will not process Personal Data about You unless there is a legal basis for such processing. The legal bases according to which the Company may process Personal Data about You are as follows: a. Processing is necessary for the performance of a contract to which You are party or in order to take steps at Your request prior to entering into a contract. This refers to all the information required for us to provide You with the Services and grant You access thereto, including: - In order to register You with the Services; - In order to provide You with the Services and make the Website available to You; - In order to contact You for the purpose of operational requirements; and - In order to provide You with customer support services. b. Processing is necessary for the purposes of the legitimate interests pursued by the Company or by a third party. By way of example: - In order to respond to Your queries, requests, and/or complaints; - In order to customize the Services to Your Needs and preferences; - In order to adjust the marketing materials transmitted to You to Your needs and preference; - In order to improve the Services, as well as to develop new ones; - Performing and maintaining various activities, supporting the Services (including back-office functions, business development activities, strategic decision-making, etc.); - Analyzing marketing campaign effectiveness; - In order to perform analysis, including statistical analysis; and - Protecting Our and third parties’ interests, rights, and assets, including initiation, exercise, or defense of legal claims. We use various analytical measures (including statistical ones) to make decisions on various issues. For instance, data collected from Users may be put through algorithms to make decisions about User experiences, create and assign User profiles, and provide other services. However, no algorithms shall be used to make adverse decisions about Users unless it is to fulfill an affirmative duty to prevent criminal activity. At any time, You may approach Us by sending a notice to the email address, in order to receive information concerning the review performed by Us. This is so You can conclude that We may process the Personal Data about You on account of such processing being necessary for the purposes of the legitimate interests pursued by the Company or by a third party. c. Your consent that the Company will process Personal Data about You for one or more specific purposes. By way of example, for the purpose of sending marketing materials to You or to subscribe You to Our waiting list. Where the legal basis for the processing of the Personal Data about You is consent, You may at any time withdraw Your consent for the purposes for which You provided Your consent by sending a notice free of charge to the following email address: Where You withdraw Your consent for the processing of Personal Data about You, We might not be able to provide You with some or all of the Services You requested or in the form intended to be provided to You, and You will have no claim in respect of that. d. Processing is necessary for compliance with a legal obligation to which the Company is subject. By way of example, In order to comply with any legal obligations or judicial or administrative orders.

7. Your Right To Object To The Processing of Personal Data About You For Direct Marketing Purposes  

The Company provides You with offers that are tailored for You specifically, in order to connect You to products, services and activities in ways that are related to You. This may include ads, offers and other content related to such products, services and activities of Ours or of third parties. This is done following the processing of Personal Data about You, in order to adjust the materials presented to You, on the basis of Your preferences, behavior, characteristics and interests. For this purpose, We use Personal Data automated analysis techniques that provide Us with analysis and conclusions concerning You in various aspects, including profiling. Similar analysis and conclusions are used to the extent that You agreed to receive marketing materials from Us, as such materials can be tailored to offer You products and services which We think may be of more interest to You. Where Personal Data about You is processed for direct marketing purposes, You shall have the right to object at any time to such processing for this purpose, including profiling to the extent that it is related to such direct marketing, by sending a notice to the following email address:, in which case We shall cease to process Personal Data about You for such direct marketing purposes. In addition, You may withdraw Your consent from receiving marketing materials via email at any time, by sending an email free of charge with the title “unsubscribe” to the following email address: Please note that if You opt out of receiving marketing communications from Us, We may still communicate with You from time to time if We need to provide You with non-marketing information about Our Services or for other legitimate non-marketing reasons.

8. Transfer Of Personal Data To Third Parties 

The Company may share Personal Data about You with third parties that provide Us with the following services: a. Storage and hosting providers, including cloud computing services; b. IP address information; c. Analysis of user experience; d. CRM and mailing list services; e. Payment providers; f. User management and authentication; g. Research, analytical, technical, and diagnostic services. The Company may also share Personal Data about You with its related entities and business partners, which provide it with resources that enable the Company to enrich and improve the level of services and products it provides to its users. The Company may share Personal Data about You with governmental, local, official, and regulatory authorities, as well as if such disclosure is required to protect Our and third parties’ interests, rights, and assets, including initiation, exercise, or defense of legal claims. In addition, We may disclose Personal Data about You to potential purchasers or investors of, or lenders to, the Company and/or any company within the group of companies of which the Company is a part, or in the event of any similar transaction (including the sale of assets of the Company and/or of any company within the group of companies of which the Company is a part), and/or in connection with any merger, reorganization, consolidation, or bankruptcy of the Company and/or any company within the group of companies of which the Company is a part. In the preceding twelve (12) months, We have not sold any Personal Data.

9. Cookies and Third Party Services  

Web Tracking Information: We, and third party service providers that We engage to provide services to Us (“Contractors”), may use web tracking technologies such as cookies, web beacons, pixel tags and clear GIFs in order to operate the Website efficiently and to collect data related to usage of the Website. Such collected data (“Web Tracking Information”) may include the address of the websites You visited before and after You visited Our Website, the type of browser You are using, Your Internet Protocol (IP) address, what pages in the Website You visit and what links You clicked on, and whether You opened email communications We send to You. In order to collect Web Tracking Information and to make Your use of the Website more efficient, We may store cookies on Your computer. We may also use web tracking technologies that are placed in web pages on the Website or in email communications to collect information about actions that users take when they interact with the Website or such email communications, and our Contractors may also do so. We do not correlate Web Tracking Information to individual user Personal Data. Some Web Tracking Information may include data, such as IP address, that is unique to You. You may be able to modify Your browser settings to alter which web tracking technologies are permitted when You use the Website, but this may affect the performance of the Website. Types of cookies: The cookies We may use have been classified according to their functionality, as follows: - Strictly Necessary Cookies Purpose: These cookies are strictly necessary to enable You to navigate the Website and use features You have requested. They are used to provide You with Our content, products, and services that You have requested. Such cookies are essential to help Your device download or stream information so that You can navigate around the Website, use its features, and return to pages You have previously visited. Additional Information: These cookies collect Personal Data about You, such as user name and last login date, and identify You as being logged in to the Website. These cookies are deleted when You close Your web browser (session cookies). - Functionality Cookies Purpose: These cookies are used to recognize You when You return to the Website and allow Us to remember Your choices and preferences. Additional Information: These cookies survive the closing of Your web browser, and last until their applicable expiry time. - Performance Cookies Purpose: These cookies are used to provide aggregated statistics in respect of the performance of the Website and to test and improve such performance, in order to provide better user experience. In addition, they allow Us to carry out analytical functions on the Website. Additional Information: These cookies collect anonymized data that is not related to an identified or identifiable natural person. These cookies are valid for varying periods; some are deleted once You close Your browser, while others have an indefinite validity period. - Third Party Marketing/Targeting Cookies Purpose: These cookies are used to deliver ads and marketing communications, and to display the Website in a manner that is more relevant to You. They are also used to measure the effectiveness of an advertising campaign. These cookies record Your visit to the Website and the pages You have visited. Additional Information: Some of these cookies are provided and used by third parties. These cookies are valid for varying periods; some are deleted once You close Your browser, while others have an indefinite validity period. Blocking and removal of cookies: You can change Your browser settings to block and delete some or all cookies. Please see below links to instructions on how to do this in respect of some of the most popular web browsers: - Firefox - Microsoft Edge - Google Chrome - Safari Please note, however, that if You do so, some or all of the Website's features and functionalities might not perform as intended. We use mobile analytics software to allow Us to better understand the functionality of Our Website on Your device. This software may record non personal information such as how often You use the Website, the events that occur within the Website, aggregated usage, and performance data. ONLINE TRACKING NOTICE: AT THIS TIME, THIS WEBSITE DOES NOT SUPPORT DO-NOT-TRACK SIGNALS.

10. Retention Of Personal Data About You  

The Company shall retain Personal Data about You for as long as is required to fulfill the purposes of the processing of the Personal Data as outlined in this Policy, or for a longer period as required according to the legislation, regulation, policies, and orders that apply to Us. In order to ensure that Personal Data about You is not retained for longer than is required, We periodically review Personal Data retained by Us to examine whether any Personal Data can be erased.

11. Transfers Of Personal Data To A Third Country Or An International Organization 

Personal Data about You may be transferred to a third country (i.e. jurisdictions other than the one You reside in) or to international organizations. In such circumstances, the Company shall take appropriate safeguards to ensure the protection of Personal Data about You and to provide that enforceable data subject rights and effective legal remedies for data subjects are available. If You are an EEA resident, please note that these safeguards and protection will be available if any of the following are met: a. The transfer is to a third country or an international organization that the EU Commission has decided provides an adequate level of protection to the Personal Data that is transferred to it pursuant to Article 45(3) of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 ("GDPR"); b. The transfer is according to a legally binding and enforceable instrument between public authorities or bodies pursuant to Article 46(2)(a) of the GDPR; or c. The transfer is in accordance with standard data protection clauses adopted by the EU Commission pursuant to Article 46(2)(c) of the GDPR. You may request that the Company provide You with details concerning the safeguards employed by it to protect the Personal Data about You that are transferred to a third country or an international organization, by sending an email to the following address:

12. Protection Of Personal Data About You 

We implement appropriate technical and organizational measures to ensure an appropriate level of security to Personal Data, taking into account the risks that are presented by processing, in particular from accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to Personal Data transmitted, stored, or otherwise processed. We do not guarantee however, that Your Personal Data will not be subject to a security event. We may be required, due to legal or other obligations outside Our control, to transfer Personal Data about You to third parties, such as public authorities. In such circumstances, We have limited control over the level of protection provided to the Personal Data about You by such third parties. Any transfer of Personal Data via the Internet cannot be fully secured. Therefore, the Company cannot ensure the protection of Personal Data about You when transferred via the internet to Us.

13. Links To Websites of Third Parties 

The Services may provide links to websites and/or applications of third parties. The Company does not control such websites and applications, nor the collection and/or processing of Personal Data about You by such websites and applications, and We are not responsible for such websites and applications, nor for their privacy and data protection policies and activities. This Policy does not apply to any actions taken via such websites and/or applications. Whenever You access such third parties' websites and/or applications, We recommend that You carefully review their privacy policies prior to using such websites and/or applications and prior to disclosing any Personal Data about You.

14. Your Rights In Respect Of The Personal Data About You 

Generally, You have the right to request that We provide You with confirmation as to whether Personal Data about You is being collected by Us, to ask to review such data, to rectify the content if applicable and to erase the Personal Data no longer required by Us. You may also restrict Your consent to certain processing of Your Personal Data. If You are an EEA resident, please read this section below: You are entitled to the following rights in respect of the Personal Data about You. To exercise such rights, You may send a request to exercise Your rights to the following email address: We will grant Your right to receive information regarding how Personal Data about You is processed by Us; to rectify any inaccuracy in Your Personal Data; to erase Your Personal Data processed and stored by Us; to restrict the processing thereof or object thereto if applicable under the circumstances; and the right to receive the Personal Data about You, which You have provided to the Company, in a structured machine readable manner. We may reject Your requests where the request harms the rights and freedoms of others or comply with legal requirements applicable to Us. We may also charge a reasonable fee where applicable. You will also have the right to lodge a complaint with a supervisory authority established by a Member State to protect the fundamental rights and freedoms of natural persons in relation to the processing of Personal Data within the European Union. If You reside in California, please read below with respect to the California Consumer Privacy Act (CCPA)-related rights You have: 1. Right to know You have the right to receive the following information: - What types of Personal Data collected; - What are the types of sources of the Personal Data collected; - To what end We collect the Personal Data; - Types of third parties with whom We share Personal Data, if any; and - The specific pieces of Personal Data We have collected about You. 2. Right of Erasure You may ask Us to delete Your Personal Data and direct Our service providers to do so. Please note that We may not delete Your Personal Data if it is necessary to complete Our legal obligation to You to provide the Services or otherwise protect Our legal rights, comply with an existing legal obligation; or use Your Personal Data, internally, in a lawful manner that is compatible with the context in which You provided the information. 3. Right to Non-Discrimination for the exercise of Your privacy rights You have the right to not be discriminated against by Us because You exercised any of Your rights under the CCPA. 4. Right to designate an authorized agent to submit CCPA requests on Your behalf You may designate an authorized agent to make a request under the CCPA on Your behalf. To do so, You need to provide the authorized agent written permission to do so and the agent will need to submit to Us proof that such agent has been authorized by You. We will also require that You verify Your own identity, as explained below. In order to exercise Your CCPA right, please contact Us using the following details: +972-526622746 Please note that We may need to receive Personal Data from You in order to verify Your identity prior to allowing You to exercise Your rights.

15. Changes To This Policy 

We may amend, from time to time, the terms of this Policy. Whenever We amend this Policy, We will notify You of such amendments by publishing the updated Policy on the Website. In addition, when We make significant amendments to this Policy, We will strive to inform You about such amendments via means of communication We believe are reasonably appropriate to inform You of such amendments and by publishing a notice about such amendments on the Website. Unless stated otherwise, all amendments will enter into force upon publication of the updated Policy on our Website.

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