Last Updated: November 18, 2020
Core-Tenure Ltd. (“TenureX”, “us”, “we”, or “our”) is the owner and operator of the www.tenurex.com website (the “Website”) and all our services and/or products, ancillary functions, offered/presented by TenureX in the Website or otherwise provided by TenureX ("TenureX Services").
Some types of Personal Information (as defined below) must be collected by TenureX in accordance with applicable law in order to operate the Website and provide TenureX Services to you (such information includes information provided as required by TenureX’s partners and customers such as the various Prohibition of Money Laundering Laws, directives and regulations). With respect to other Personal Information provided/collected, you are advised that you are under no legal obligation to provide us with such Personal Information (however not providing us with certain Personal Information may prevent us from providing you with some of the TenureX Services).
If you provide us information of third parties (whether a person or a corporate entity), you confirm that (a) you have received such third party’s consent to provide us with such information to be used as set forth herein according to applicable law; and (b) you have full authority to act on such person’s or entity’s behalf. For the avoidance of doubt, the term "you" when used herein means both yourself and the third party on behalf of whom you are acting.
2. What Kind of information Do We Collect?
- 2.2 Personal Information we collect may include -
- Contact Details such as address, telephone, fax and email (both private and work related).
- Personal Details such as name, age, occupation, and/or role/position in the corporate entity seeking to use TenureX Services.
- Financial Information such as shareholdings in the corporate entity seeking to use TenureX Services.
- Identity Documents, such as passport, identity card or utility bill.
- Photographs, such as a head and shoulders photograph of you from one of the identity documents specified.
- Pictures and audio, recordings of phone conversations, presentations given by you when interacting with TenureX Services.
- Technical data such as device and usage information, your IP address, browser and device characteristics, operating system and language preferences.
- 3. How May We Collect Personal Information?
- 3.1 TenureX may collect Personal Information when you provide such information and/or when using the Website and/or TenureX Services, for example:
- When you request a demo you may be required to provide us with certain contact details.
- When you contact our representatives and provide us with certain information or make certain inquiries regarding TenureX Services.
- When you fill in certain forms and/or provide TenureX with certain documents.
- 3.2 TenureX may automatically collect technical data when you interact with the Website and/or use TenureX Services.
- 3.3 We may collect information from external resources which may be available to the public, such as governmental authorities (including the Israeli Registrar of Companies and similar authorities outside Israel) business information and rating agencies (such as World Check CofaceBdi and Dun & Bradstreet) and other publicly available information including social platforms such as LinkedIn.
- 4. Purpose of Data Collection and How May We Use Your Personal Information? We use the information we collect for the following purposes:
- 4.1 To provide TenureX Services, as well as for other legitimate business purposes.
- 4.2 To communicate with you, answer questions you may have and provide you with content we believe may be of interest to you (including information with respect to additional products or services, we or third parties with whom we may collaborate with, may provide in the future). For this purpose you hereby provide your consent to receive “Advertisements” as defined in the Communications Law (Telecom and Broadcasts), 5742-1982, including by way of “Direct Mailing” as defined in the Protection of Privacy Law, 5741-1981.
- 4.3 To further develop products and/or services (including the Website and TenureX Services), conduct certain research, identify trends and provide business insights.
- 4.4 To enforce and/or protect our rights, property and safety of the users of TenureX Services and/or the Website or any other person or entity. It is clarified that we are under no obligation to do so.
- 4.5 In order to comply with and/or in order to assess compliance with applicable laws, rules and regulations, and internal policies and procedures.
- 4.6 To secure our systems and data, including by conducting analysis required to detect malicious data and understand how this may affect the user and/or our IT system. For statistical monitoring and analysis of current attacks on devices and systems and for the on-going adaptation of the solutions provided to secure devices and systems against attacks.
- 4.7 We may use technical data for purposes such as calculating the Website and/or TenureX Services usage levels, helping diagnose server problems, and administering the Website. Please note that we treat technical, server log files and related information as non-Personal Information, except where we are required to do otherwise under applicable law.
- 4.8 For Internal record keeping.
- 5. Use of Analytic Information.
- 5.1 We may use the information we collect to generate averaged data, aggregated data, benchmarks, comparisons or recommendations, and other calculations and derivatives, using, containing or referencing the non-identifiable information, and aggregation of such non-identifiable information with or without data relating to third parties (all of the foregoing and the product of such activities referred to collectively herein as “Analytic Information”); provided, however, that if the convergence of such information results in the creation of identifiable information, such information shall be treated as Personal Information hereunder.
- 5.2 We may exploit, transfer, lease, sell or otherwise commercialize Analytic Information for any and all purposes without notice or obligation you, provided that Analytic Information does not identify you, and you shall not have any right (including not to any consideration) in connection with the creation or exploitation of Analytic Information. We may use, exploit, transfer, lease, sell or otherwise commercialize Analytic Information, provided that it does not include Personal Information.
- 6. With Whom May We Share Your Information? TenureX may share your information with third parties as follows:
- 6.1 When the disclosure is made in connection with TenureX Services and/or the Website. For example:
- When you ask us to confirm the transfer of funds from the financial institution you use or represent (“Transferring Institution”) to a third party (“Recipient”) or such third party’s financial institution (“Receiving Institution”), we may provide Personal Information to each of the parties involved in such contemplated transaction (even if not finalized) with respect to the other parties engaged in the said transaction.
- We may share Personal information with rating agencies, persons helping TenureX assess you, the Transferring Institution, the Recipient and/or the Receiving Institution, and in compliance with industry standards and law.
- We may disclose/provide access to Personal Information to third parties who help us operate our Website and/or Services. This may include allowing certain third parties to use tracking technology on the Website and/or Services, which will enable them to collect data about how you interact with the Website and/or use TenureX Services over time. This information may be used, among other things, to analyze and track data, determine the popularity of certain content/services and better understand user activities and market trends.
- We may disclose/provide access to Personal Information to third parties who help us develop new products and services.
- We may disclose/provide access to Personal Information to third parties who help us secure our Website and/or TenureX Services.
- 6.2 When we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
- 6.3 Anonymized or aggregated data may be shared with third parties.
- 6.4 When we believe disclosure is necessary in order to comply with laws, rules and other applicable legal requirements (such as when providing reports to tax authorities, Israel Capital Market, Insurance and Savings Authority, Israel Money Laundering and Terror Financing Prohibition Authority and other authorities worldwide).
- 6.5 We may share Personal information with the attorneys, accountants and auditors of TenureX or otherwise as we may deem necessary in order to establish, exercise or defend our legal rights.
- 6.6 In connection with a proposed or actual investment in our businesses and/or the sale, merger, or transfer of all or a portion of our business or assets, as well as in connection with a due diligence inspection conducted with any of the aforesaid.
- 7. How Do We Secure Your Personal Information?
TenureX takes various measures to protect and secure your Personal Information and ensure your privacy and we update these measures from time to time, in accordance with applicable law.
We implement what we deem as reasonable technical and organizational measures to protect your Personal Information. However, no method of transmission over the Internet, or of electronic storage or processing, is 100% secure. Therefore, you confirm that you provide us with your Personal Information at your own risk. We strongly advise you to access the Website and TenureX Services only from a secured environment. If you feel that the security of your Personal Information may have been compromised, please immediately notify us at email@example.com.
- 8. Cross-Border Transfer.
Personal Information may be stored/processed in Israel, EU Member States, EEA member countries (Norway, Liechtenstein and Iceland) and the United Kingdom (collectively, “EEA”) and in countries that offer an adequate level of data protection under or pursuant to the adequacy decisions published by the relevant data protection authorities, without any further safeguard being necessary. However, in certain cases we may store or have Personal Information processed outside Israel, the EEA or such countries of adequate protection. Please note that such jurisdictions may have legislation that is less protective of your privacy rights, and you hereby provide your consent to such transfer/processing (outside of Israel, the EEA or countries of adequate protection).
- Your Rights.
- In accordance with applicable laws, under certain circumstances you may have the following rights with respect to your Personal Information:
- · Right to Access: you may have the right to inspect Personal Information pertaining you.
- Right to Rectify: you may have the right to have us amend or delete your Personal Information that is not correct, not complete, not clear or not up to date.
- Right to Erase: you may have the right to have us to erase certain Personal Information.
- Right to Restrict Processing: you may have the right to limit the way we use your Personal Information.
- Right to Data Portability: you may have the right to move, copy or transfer Personal Information easily from our system to another in a safe and secure way, without affecting its usability.
- You can exercise your rights by contacting us using the details listed in Section 13 below.
- Cookies and Other Data Collection Technologies
- Cookies are small text files sent from a web server to your device whenever you visit a website. The purpose of Cookies is to allow TenureX to recognize you quickly and efficiently when you return to use our Website, and in this way to provide you a better, more customized experience.
- Links to Other Websites
This policy may be changed from time to time, including to reflect changes in our practices concerning the collection and use of personal information, or where required to comply with applicable law. The revised policy will be effective immediately so please check this policy periodically for changes.
- 13. How to Contact Us?
- Law And Jurisdiction