Privacy Policy – 4 Invest L.T.D Social Businesses Ltd.
1. Introduction
4 Invest L.T.D Social Businesses Ltd. (hereinafter: “4 Invest L.T.D”), respects your privacy (hereinafter: the “Privacy Policy”), and helps you protect your privacy,
you (hereinafter: the “User”) are hereby requested to read the following sections and to learn about 4 Invest L.T.D’s Privacy Policy.
This Privacy Policy is drafted in the masculine gender solely for convenience, and it applies equally to men and women.
Please read the Privacy Policy before using 4 Invest L.T.D’s website (hereinafter: the “Website”), and if you do not agree with the Privacy Policy, in whole or in part, you may not use the Website and you are requested not to do so.
Any use and/or activity of any kind or nature on the Website, including, but not limited to, accessing and/or browsing the Website, constitutes full consent, without exception, by the User to the provisions of 4 Invest L.T.D’s Privacy Policy. The Privacy Policy set forth below forms an integral part of the Terms of Use of the Website. Terms that are not defined in the Privacy Policy shall be construed as defined in the Terms of Use. It should be clarified that in the event of any inconsistency between the Privacy Policy and the Terms of Use of the Website, the provisions of the Terms of Use shall prevail.
4 Invest L.T.D. reserves the right, in its sole discretion, to update, modify, add, adjust, amend, or remove parts of the Privacy Policy at all times. You are required to check the Website from time to time to keep informed of any such changes that have been made to the Privacy Policy. By continuing to use the Website, despite the changes to the Privacy Policy, you are agreeing to these changes.
2. Eligibility of use
This Website is not intended for children under the age of 18 years or for users who are not legally competent to engage with 4 Invest L.T.D. under this Privacy Policy or the Terms of Use of the Website. If the user is under the age of 18 years or is not legally competent, as aforesaid, he may not use the Website. If a parent or guardian becomes aware that his child or the ward under his guardianship has provided 4 Invest L.T.D. with personal information, without the consent of the parent or guardian (as applicable), he is required to contact 4 Invest L.T.D., at the address given on the Website’s homepage. If 4 Invest L.T.D. becomes aware that a child or ward has provided 4 Invest L.T.D. with personal information without authorization, 4 Invest L.T.D. will act to cause the deletion of all such information from its files. 4 Invest L.T.D. reserves the right to request proof of age and legal competence from the user to its satisfaction, in its sole discretion, and it may also refuse to register a user or to suspend an existing user account, until such time that the user’s age and/or legal competence shall be proven to 4 Invest L.T.D’s satisfaction.
3. Type of information that is collected and the manner of collection thereof
The information that is due to be collected through the Website is divided into two types:
Personally identifiable information – certain services that are provided on the Website require the provision and input of the Users’ personal information, including, but not limited to, name, age, residential address, email address, telephone number, ID number, occupation, financial information, credit card details, amount of investment/fundraising that the User wishes to make, consumer and entertainment habits, the nature of the transactions and the securities in which the User is interested, and so on. In the event companies wish to raise funds from investors through the Website, this information might include details on the said companies, including name, registered address, company number, financial statements, a business plan, information about its products and/or services, its officers, its intellectual property, its assets, agreements to which it is a party, etc. (all of the foregoing will hereinafter be collectively referred to as: “Personal Information”). The collection of this information will be done only if the information is provided by the User voluntarily, for example, at the time of filling out certain forms on the Website, responding to questions on the Website, and/or making an investment through the Platform on the Website.
Personally non-identifiable information – information of a statistical nature that does not identify the User personally, including, but not limited to, IP addresses, the type of browser, and other technical information of this kind. The methods used to collect this information include, inter alia, the use of communication data, the use of cookies (see details below), the use of an IP address or a numerical code that identifies the computer through which the User browsed the Website (hereinafter: “Statistical Information”).
4. Cookies
The Website uses cookies to ensure that the Website functions properly and continuously, including collecting statistical data about the use of the Website, verifying details, tailoring the Website to suit the User’s personal preferences, and for information security purposes. Cookies are text files, which your browser creates according to a command from the Website. Some of the cookies will expire when the User closes the browser, and others remain on the hard drive on the User’s computer.
You may instruct your browser to stop accepting cookies or to ask the User before accepting a cookie from the website that he is visiting. Eliminating the cookies, however, could cause a situation whereby the User will not be able to use part of the services and the features of the Website or other websites.
5. The purpose for which the information is sought
The information about the Users is kept by 4 Invest L.T.D. in its database, whether directly by 4 Invest L.T.D. or by a service provider.
4 Invest L.T.D may use the Personal Information and/or the Statistical Information of the Website’s Users, inter alia, for the purposes set forth below: improving the Website’s applications, the content and services provided thereon; managing the Users’ accounts; registration for the services that are provided on the Website; supervising and clarifying the restrictions on the fundraising and investment of the Users, providing financial services, including, but not limited to, the collection and reimbursement of the investment funds; managing the investment after the completion of the offering; adjusting the content, services and advertisements that are displayed to the User on the Website; presenting questions and/or the response thereto; conducting research with respect to the use of the Website and its services, including statistical analyses of investments, data with respect to the nature of the transactions performed by the User, protection against acts of deception and/or fraud; direct mailing and contact with the Website’s Users; providing service in connection with the services that are provided on the Website; and managing a user club.
In addition, 4 Invest L.T.D. may use the Personal Information to send the User updates, emails, brochures, marketing materials, or sales promotion materials, and all subject to the User’s right to inform 4 Invest L.T.D., in writing, of his wish that such use not be made.
The use of the information as set forth above may be made by 4 Invest L.T.D. and/or any entity on its behalf and/or a service provider provided that it takes upon itself the provisions of the Privacy Policy.
The Personal Information that will be provided to 4 Invest L.T.D. will be kept on the Company’s database, which has been registered as required by law. The number of the database is 700061578.
The foregoing constitutes notice under Section 11 of the Privacy Protection Law, 5741-1981.
6. Confidentiality, Security, and Privacy of the User’s Information
4 Invest L.T.D. takes means to secure information by the requirements of the Securities Law, 5728-1968, and the Securities Regulations (Offering of Securities through an Offering Coordinator), 5777-2017. Even though these means are intended to reduce the risks of unauthorized hacking into 4 Invest L.T.D.’s computers, 4 Invest L.T.D. and/or any entity on its behalf do not undertake that the Website’s services and the information stored on and through the Website will be entirely immune from unauthorized hacking or harm.
4 Invest L.T.D. cannot provide absolute security for its computers and/or the databases of the Website against unauthorized access and the prohibited use of the information. Therefore, by making use of the Website, the User expresses his consent that he will have no claim and/or demand and/or lawsuit against 4 Invest L.T.D. and/or any entity on its behalf as a result of unauthorized access and/or disclosure and the use of the information that arises from unauthorized access.
Viewing the Website and/or inputting certain content into the Website may require the use of a password (one or more). The User is required to take all of the means as required to keep the password confidential, including not disclosing it to others, not allowing others to access the Website with the said password, using a password that is not easy to guess, and, also, replacing it from time to time. By using the Website, the User expresses his consent that he will be responsible for any damage that is caused to him and/or to 4 Invest L.T.D. or any entity on its behalf as a consequence of his not taking the means as required to maintain the confidentiality of the password and/or any other identifying detail of the User.
7. Precautions against fake email messages
Fake email messages are messages that are sent by 4 Invest L.T.D., in which the recipient of the email is requested to access the website through a link that is provided in the email and to provide or update his identification details (passwords, email address, account numbers, etc.), and the fake email message sets forth the reasons why the update is necessary. The link in the email is likely to be a precise imitation of 4 Invest L.T.D.’s official website, from which the email was sent. In this manner, various entities attempt to obtain, unlawfully, the email recipient’s identification details, to access his account.
For the avoidance of doubt, 4 Invest L.T.D hereby clarifies that the obligation to update data and Personal Information applies solely to the User and that 4 Invest L.T.D does not usually contact the Users by email, asking them to update their details and/or to provide their confidential personal code and, therefore, you should not answer a request to update details that are received by email and you should not provide personal details that pertain to the use of the Website, to any entity whatsoever.
For the User’s convenience, and to protect and secure the details that identify him on the Website, 4 Invest L.T.D. recommends that the User adopt the following rules:
· access the Website directly, by typing in the address, and without using links.
· Carefully examine the email messages that contain a link to the Website, and do not update identifying details or personal details as the result of an email message that has been received.
· If any concern arises concerning an email message that has been received from 4 Invest L.T.D., please notify 4 Invest L.T.D. immediately, at the address given on the Website’s homepage.
8. Sharing, posting, and providing content on the Website
Certain parts of the Website include functions that allow the Users to share, post, or provide content through the Website. The content displayed on the Website is provided “as is,” as it was submitted to 4 Invest L.T.D. and/or as it was posted on the Website by the User or any entity on his behalf, and it should not be deemed to be any kind of representation or undertaking by 4 Invest L.T.D or by any entity on its behalf vis-à-vis the Users. The User undertakes vis-à-vis 4 Invest L.T.D. and vis-à-vis the other Users that the content that he shared, posted, or provided through the Website is precise, complete, and accurate and that he is authorized to share and/or post it, and all subject to the following conditions:
· No content or material that is confidential, defamatory, offensive, violating, pornographic, indecent, or illegal in any other manner or repulsive shall be shared, posted, or provided through the Website, and the Website shall not be used for any chain letters, junk mail, spam or any other form of mass mailing, unless and insofar as lawful authorization has been granted to do so. By sharing, posting, or providing content and/or information to be published, the User confers on 4 Invest L.T.D. a right, which is not limited in time, to present, reproduce, copy, distribute, market, broadcast, publicize, and make any other use of the content and the information in its discretion.
· No content or material that constitutes the intellectual property rights of a third party shall be shared, posted, or provided unlawfully through the Website, unless and insofar as lawful authorization has been granted to do so. By sharing, posting, or providing content and/or information to be published, the User confers on 4 Invest L.T.D. a right, which is not limited in time, to present, reproduce, copy, distribute, market, broadcast, publicize, and make any other use of the content and the information in its discretion.
· No content or material that is prohibited under any legislation for the protection of data and privacy shall be shared, posted, or provided through the Website; and
· Through the Website, the User may share, post, or provide material that is in his sole possession or that the User has the right to provide.
4 Invest L.T.D. may, without prior notice, refuse to upload content that a User has submitted to the Website, it may delete or remove it, in whole or in part, in its sole discretion, whether with or without providing any reason whatsoever, and without being obligated to provide any reason or explanation.
4 Invest L.T.D. does not undertake that the content that has been shared, posted, or provided by the Users of the Website is correct or complete. The process for sharing, posting, or providing content on the Website is conducted without human intervention, and 4 Invest L.T.D. cannot verify the identity of the entity uploading the content and it cannot examine the veracity of the content and the nature thereof before the publication thereof. 4 Invest L.T.D. therefore recommends to the Users of the Website that they conduct independent due diligence concerning the content that appears on the Website, and request clarifications concerning the content or information in addition to that which appears on the Website, before performing any act on the Website or making use thereof.
By using the Website, the User expresses his consent to indemnify 4 Invest L.T.D. for any loss, deficit, liability, claim, damage, or expense that will be caused to it and that arises from a breach of this undertaking by him.
9. Third party data
The User undertakes that if use is made of data that belongs to third parties, he will do so only after providing notice to that effect to all of the said third parties and after obtaining their consent to the use.
10. Providing information to a third party
4 Invest L.T.D. may share information about the User on the Website with various companies that will provide it with statistical analyses regarding the use of the Website. The companies collect and analyze information on the scope of use of the Website, the frequency of use thereof, the sources of access of the Users to the Website, and so on. The information that is collected is statistical, it does not identify the User personally, and it is intended for analysis, research, and control. If 4 Invest L.T.D. shares information about the Users with various companies over that which is set forth above, 4 Invest L.T.D. will update this Privacy Policy, and it will specify the name of the company for which the information was provided and the purposes for which such information was provided.
4 Invest L.T.D. will not transfer to third parties the personal details of any user, except in such cases as set forth below:
· For the purposes outlined in Section 5 above;
· to ascertain and verify the User’s undertakings and declarations;
· to supervise and clarify the restrictions on the fundraising and investment of the Users on the Website;
· For the User’s participation in the offering and the issuance of offered securities in the User’s name;
· If 4 Invest L.T.D. hires the services of a third party to provide and manage the services that are provided on the Website. The said third party will have limited access to the User’s information in such scope as required for performing its services only;
· In the event of a legal dispute between the User and 4 Invest L.T.D. that will require the exposure of details;
· If the User performs activities on the Website in contravention of the law;
· If a judicial order is received that orders that the User’s details or information about the User be provided to a third party;
· If 4 Invest L.T.D. sells or transfers in any manner whatsoever the activities of the Website and/or its assets to any other entity whatsoever – and also if 4 Invest L.T.D. merges with another entity or that it merges the Website’s activities with the activities of a third party, provided that the transferee takes upon itself the provisions of this Privacy Policy or the provisions of other privacy policies that are materially similar.
· In any other event in which 4 Invest L.T.D. is required to transfer information by the provisions of the law.
If 4 Invest L.T.D shares Personal Information about the Users with various companies over that which is set forth above, 4 Invest L.T.D will inform the Users that their details are going to be transferred, and it will inform them of the details of the company to which the information will be provided, and the purposes for which the transfer of such information is required.
11. Deletion of the information
If the User wishes that the personally identifiable information be deleted from 4 Invest L.T.D.’s databases, he is required to contact 4 Invest L.T.D. at the address given on the Website’s homepage, and state, in writing, that he wishes that certain information that he will identify in his notice, which is kept on 4 Invest L.T.D’s databases, be deleted. 4 Invest L.T.D. undertakes to delete the User’s Personal Information that was so identified and not to make any use thereof for the Website. The deletion of this information from 4 Invest L.T.D.’s databases does not prevent the use of Statistical Information that was collected under the foregoing. The User understands and agrees that as a consequence of his request as aforesaid, 4 Invest L.T.D. may not be able to provide its services to the said User, and the User therefore exempts 4 Invest L.T.D. from any responsibility for this.
4 Invest L.T.D. may save a copy of the User’s records as required by law or for legal business purposes.
12. Links to other websites
The Website may display links to other websites that are managed or owned by a third party, as well as features of social networks (hereinafter: “Social Network Features”) that are operated or allow integration with social networks or certain platforms. 4 Invest L.T.D. has no responsibility whatsoever concerning the content that is displayed on other websites and/or in connection with the existence thereof, or for the use of the Social Network Features that exist on the Website. Any use by a User of these websites or of these Social Network Features is done at the User’s sole responsibility, and subject to the privacy policy of the social networks or the other websites that the User visits. The User is required to ascertain that he has read and understood the terms of use and the privacy policies of the said websites.
It should be emphasized that concerning the links that are displayed on the Website, there is no distinction between the marking of internal links and outbound links and that it is the User’s responsibility to check the URL address to which the link refers, before using it.
4 Invest L.T.D may, if the User makes use of Social Network Features, provide data about the User to his contacts, and, conversely, so that he will be able to benefit from the social features. To that end, 4 Invest L.T.D. may provide the User’s name and his profile picture on social media, as well as details and other Personal Information as requested and in keeping with standard practice on the said websites.
The User hereby agrees that in the course of his use of the Social Network Features, the social networks or the platforms that operate these features may collect certain Personal Information, such as the User’s IP address, and statistical information, and they may even install cookies and/or other Internet tracking technologies, and all by the privacy policy that is set forth on the said social network or platform that operates the Social Network Features. Use of the Social Network Features allows the sharing of information with a specific group of people, by the definitions that the User determined vis-à-vis the social network or the platform that provides or operates the Social Network Features.
By using the Website, the User expresses his consent that 4 Invest L.T.D. or any entity on its behalf will not be liable, directly or indirectly, for any damage that will be caused to him, in connection with his use of any service, content, product or any other information that is contained on the websites that are operated by third parties.
13. Databases
The User understands and is aware that there is no legal obligation to provide the information, and that the provision of the information depends on his own free will to receive the services from 4 Invest L.T.D. and/or from any entity on its behalf, and it is being done solely with his consent. The User confirms that the information about him, whether it has been and/or will be provided by him or whether it will be provided from other sources or entities, will be held and kept, in whole or in part, in 4 Invest L.T.D’s databases and/or with any entity on its behalf who will be authorized to make any use of the information for the purposes outlined in this Privacy Policy.
The User agrees that 4 Invest L.T.D. will be entitled to make use of the information to contact him with offers for other and/or additional services and/or products that are provided by 4 Invest L.T.D. and/or by third parties, including by way of direct mailing, text messages, fax, automatic dialing system, and email.
14. Right to inspect information
Under the Privacy Protection Law, 5741-1981 (hereinafter: the “Privacy Protection Law”), any User is entitled to inspect, himself, or by his attorney whom he authorized in writing or by his guardian, information about himself that is held in 4 Invest L.T.D’s database. A User who has inspected the information about himself and found it to be incorrect, incomplete, unclear, or not up-to-date may contact the Company with a request, in writing, that it amend or delete the information. Should 4 Invest L.T.D. find that amendments need to be made due to the foregoing, it will give notice to that effect to the User and/or to any entity from which 4 Invest L.T.D. received the information.
In addition, if the information in 4 Invest L.T.D’s database is used for personal communication to the User, based on his affiliation to a population group, which was determined by one or more characterizations of people whose names are included in 4 Invest L.T.D’s database, then the said User is entitled, under the Privacy Protection Law, to demand, in writing, that the information that pertains to him, which he will identify in his notice, be deleted from 4 Invest L.T.D’s database and that it not be submitted to any person, to any type of people or any particular people, and all for a limited or specified period. 4 Invest L.T.D. will act in connection with the information that was so identified by what is stated in the User’s demand, and it will notify the User that it has acted by his demand. Should 4 Invest L.T.D. fail to notify the User, within 30 days from the date of receipt of the demand, that it has acted by his demand, the User may apply to the Magistrates Court in such a manner as outlined in the Regulations enacted under the Privacy Protection Law, so that the Court will order the Company to act as aforesaid.
The User understands and agrees that as a consequence of his request as aforesaid, 4 Invest L.T.D. may not be able to provide its services to the said User, and the User therefore exempts 4 Invest L.T.D. from any responsibility for this.
15. Application of the Privacy Policy
4 Invest L.T.D.’s Privacy Policy applies to all of the services that are offered by 4 Invest L.T.D. on the Website; however, it does not apply to services or content of third parties.
4 Invest L.T.D.’s Privacy Policy does not cover the information handling practices of third parties that are mentioned on the Website or such that advertise 4 Invest L.T.D.’s services, and they may use cookies and other Internet tracking technologies to offer and display the User relevant notices.
16. Marketing information
4 Invest L.T.D. may send the User, from time to time, by email, marketing information that is tailored to suit the said User’s areas of interest, including ads and the supply of products, and all by the provisions of the Communications Law (Telecommunications and Broadcasts) (Amendment No. 41)The User may, at any time, cancel his consent and cease to receive marketing information as outlined in this section.