Effective as of 28.8.2024
We at IDM Capital (together with its affiliated companies – “IDM Capital”, “we”, “our” or “us”) develop and operate a website that helps interested prospects to gain a better understanding of our activities and offerings.
The purpose of this Privacy Policy is to describe our practices regarding the collection, storage, use and disclosure of data which relates to identified or identifiable individuals (“personal data” and “data subjects” respectively).
- Visitor Data: data relating to visitors of our website, and any other prospective customer, user or partner (collectively, “Visitors”) who visits or otherwise interacts with our website and content, emails, various sales and marketing channels, and integrations or communications under our control (collectively – “Website”).
If you are a Visitor, please read this Privacy Policy carefully and make sure that you fully understand it.
You are not legally required to provide us with any personal data. If you do not wish to provide us with your personal data, or to have it processed by us or any of our Service Providers (as defined below), please do not provide it to us and avoid any interaction with us or with our Website.
1. Data Collection & Processing
When we use the term “personal data” in this Privacy Policy, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to an individual. The term excludes aggregated, de-identified, or anonymized information in a form that cannot reasonably be associated with or linked to an individual.
We may collect personal data automatically when individuals interact with our Website, or we may collect personal data directly from them. We may collect personal data about an individual even before our first interaction with them from other sources and third parties (such as our Service Providers).
We may collect or generate the following types of personal data about individuals through the Website:
- Device information concerning Visitors (connectivity, technical and aggregated usage data, such as user agent, IP addresses and approximate location based upon such IP addresses, device data (like type, OS, device id, browser version, locale and language settings used), activity logs, session recordings, the cookies and pixels installed or utilized on their device, and inferred or presumed data on generated from their use of the Website);
- Information concerning our Visitors such as contact and business details such as name, email, phone number, our communications with such individuals (correspondences, sensory information including call and video recordings, and transcriptions and analyses thereof), contact forms received and their content.
Data Collection
We collect various types of personal data regarding our Visitors. Such data is typically collected or generated through your interaction with us or our Website, through automatic means, or directly from you or through third parties (including via Service Providers, as defined in Section 4 below).
Specifically, we may process the following categories of your personal data:
Data automatically collected or generated: When you visit or interact with our Website, we may collect, record or generate certain technical data about you. Depending on the circumstances, we may do so independently or in conjunction with third-party Service Providers (defined in Section 4 below), including using cookies and other tracking technologies (as described in Section 5 below).
Data such as these include connectivity, technical, and aggregated usage information, such as IP addresses and general locations, device and application information (such as type, operating system, mobile device ID, browser version, locale and language settings used), date and time stamps of usage, cookies and pixels installed or utilized on the device and your recorded activity in conjunction with our Website. In addition, communication data through our contact forms may be stored.
Data obtained through Analytics Tools: We might use analytics tools to collect data about the use of our Website. Analytics tools collect data such as how often Visitors visit the Website, which pages they visit and when, and which website, ad or e-mail message brought them there.
2. Data Uses
We use your personal data as necessary for the following purposes and in reliance on the lawful basis as further detailed in the chart below:
|
Visitors, Prospects & Admins Data |
|
|
Purpose |
Lawful basis for processing |
|
To facilitate, operate and provide our Website. |
▪ Legitimate Interest ▪ Performance of a Contract (to the extent applicable) |
|
To monitor, study and analyze use of the Website. |
▪ Legitimate Interest ▪ Performance of a Contract (to the extent applicable) |
|
To gain a better understanding on how individuals use and interact with our Website. |
▪ Legitimate Interest |
|
To provide customer service, collect contact forms and provide technical support. |
▪ Legitimate Interest
|
|
To support and enhance our data security measures, including for purposes of preventing and mitigating the risks of fraud, error or any illegal or prohibited activity. |
▪ Legitimate interest ▪ Compliance with legal obligations |
|
To comply with court orders and warrants, and prevent misuse of the Website, and to take any action in any related legal dispute and proceeding. |
▪ Legitimate interest ▪ Compliance with legal obligations |
|
To comply with applicable laws and regulations. |
▪ Compliance with legal obligations |
We do not sell your personal information for the intents and purposes of the California Consumer Privacy Act (CCPA).
If you reside or are interacting with the Service (i) in a territory governed by privacy laws under which “consent” is the only or most appropriate legal basis for processing personal data (in general, or specifically with respect to the types of personal data you choose to share via the Website), your acceptance of our Terms (“Terms”) and of this Privacy Policy will be deemed as your consent to the processing of your personal data for all purposes detailed in this Privacy Policy. If you wish to revoke such consent, please contact us by e-mail at info@idmcapitallimited.com
3. Data Location
We and our authorized Service Providers (defined below) maintain, store and process personal data in Europe and Israel and other locations, as reasonably necessary for the proper performance and delivery of our Website, or as may be required by law.
While privacy laws may vary between jurisdictions, IDM Capital is committed to protect personal data in accordance with this Privacy Policy, and such appropriate lawful mechanisms and contractual terms requiring adequate data protection, regardless of any lesser legal requirements that may apply in the jurisdiction to which such data is transferred.
IDM Capital is headquartered in Israel, which is considered by the European Commission, the Swiss Federal Data Protection and Information Commissioner (FDPIC), and the UK Secretary of State to be offering an adequate level of protection for the personal data of residents of the EEA, Switzerland and the UK, respectively.
Data Retention
We retain personal data for as long as we deem it as reasonably necessary in order to maintain and expand our relationship and provide you with our Website and offerings; in order to comply with our legal and contractual obligations; or to protect ourselves from any potential disputes (i.e. as required by laws applicable to log-keeping, records and bookkeeping, and in order to have proof and evidence concerning our relationship, should any legal issues arise following your discontinuance of use), all in accordance with our data retention policy and applicable laws.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and the applicable legal requirements.
Please note that except as required by applicable law or our specific agreements with you, we will not be obligated to retain your personal data for any particular period, and we are free to securely delete, anonymize or restrict access to it for any reason and at any time, with or without notice to you.
If you have any questions about our data retention policy, please contact us by e-mail at info@idmcapitallimited.com
4. Data Disclosure
We disclose personal data in the following ways:
Service Providers: We may engage selected third-party companies and individuals to perform services on our behalf or complementary to our own. Such service providers include website hosting (Hostinger, WordPress), web analytics, contact forms (collectively, “Service Providers“). Our Service Providers may have access to personal data, depending on each of their specific roles and purposes in facilitating and enhancing our Website, and may only use the data as determined in our agreements with them.
Legal Compliance: We may disclose or allow government and law enforcement officials access to your personal data, in response to a subpoena, search warrant or court order (or similar requirement), or in compliance with applicable laws and regulations. Such disclosure or access may occur if we believe in good faith that: (a) we are legally compelled to do so; (b) disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing; or (c) such disclosure is required to protect our legitimate business interests, including the security or integrity of our products and services.
Protecting Rights and Safety: We may share personal data with others if we believe in good faith that this will help protect the rights, property or personal safety of the general public.
Subsidiaries and Affiliated Companies: We may share personal data internally within our group, for the purposes described in this Privacy Policy.
5. Cookies and Data Collection Technologies
We and our Service Providers may use “cookies”, anonymous identifiers, pixels, container tags and other technologies in order to provide our Website and ensure that they perform properly, to analyze our performance and marketing activities, and to personalize your experience.
We and our Service Providers use cookies and other technologies for performance, tracking, analytics and personalization purposes in our Website. We may share non-identifiable / aggregated extracts of such information with our partners for our legitimate business purposes.
Cookies are packets of information sent to your web browser and then sent back by the browser each time it accesses the server that sent the cookie. Some cookies are removed when you close your browser session. These are the “Session Cookies”. Some last for longer periods and are called “Persistent Cookies”. We use both types.
We use Persistent Cookies to remember your log-in details and make it easier for you to log-in the next time you access the Platform. We may use this type of cookies and Session Cookies for additional purposes, to facilitate the use of the Website’s features and tools. We may also use HTML5 local storage or Flash cookies for the above-mentioned purposes. These technologies differ from browser cookies in the amount and type of data they store, and how they store it.
Whilst we do not change our practices in response to a “Do Not Track” signal in the HTTP header from a browser or mobile application, you can manage your cookies preferences, including whether or not to accept them and how to remove them, through your browser settings. Please bear in mind that disabling cookies may complicate or even prevent you from using the Website.
Please note that if you get a new computer, install a new browser, erase or otherwise alter your browser’s cookie file (including upgrading certain browsers), you may also clear the opt-out cookies installed once you opt-out, so an additional opt-out will be necessary to prevent additional tracking.
6. Data Security
We implement industry-standard physical, procedural and technical security measures, designed to secure your personal data, to minimize the risks of theft, damage, loss of information, or unauthorized access or use of information. However, we cannot guarantee that our Website will be immune from any wrongdoings, malfunctions, unlawful interceptions or access, or other kinds of abuse and misuse.
7. Data Subject Rights
Individuals have rights concerning their personal data. Please contact us by e-mail at info@idmcapitallimited.com if you wish to exercise your privacy rights under any applicable law, such as – to the extent applicable – the right to know/request access to (specific pieces of personal data collected; categories of personal data collected; categories of sources from whom the personal data was collected; purpose of collecting personal data; categories of third parties with whom we have shared personal data), to request rectification or erasure of your personal data held with us, or to restrict or object to such personal data’s processing (including the right to direct us not to sell your personal data to third parties now or in the future), or to port such personal data, or the right to equal services and prices (e.g. freedom from discrimination) (each to the extent available to you under the laws which apply to you).
Under some regulatory frameworks, such as the GDPR, you may also have the right to lodge a complaint with the relevant supervisory authority, as applicable.
Please note that when you ask us to exercise any of your rights under this policy or applicable law, we may need to ask you to provide us with certain credentials to make sure that you are who you claim you are, to avoid disclosure to you of personal data related to others and to ask you to provide further information to better understand the nature and scope of data regarding which you request to exercise your rights. Such additional data may be then retained by us for legal, compliance and auditing purposes (e.g., as proof of the identity of the person submitting the request or proof of request fulfillment).
8. Data Controller/Processor
IDM Capital is the “data controller” of Visitor Data. With respect to such data, we assume the responsibilities of data controller (solely to the extent applicable under law), as set forth in this Privacy Policy.
9. Additional Notices
Updates and Amendments: We may update and amend this Privacy Policy from time to time by posting an amended version on our Website. The amended version will be effective as of the date it is published.
External Links: While our Service may contain links to other websites, we are not responsible for their privacy practices.
Our Service is not designed to attract children who are minors: We do not knowingly collect personal data from children and do not wish to do so. If we learn that a person who is to be considered as a minor according to the law applicable to him is using the Website, we will attempt to prohibit and block such use and will make efforts to promptly delete any personal data stored with us with regard to such minor.