Melisron Group – Digital Assets Privacy Policy

 

A. General

1. We, the Melisron Group (hereinafter referred to as “the Company” or “we”) respect the privacy of users (hereinafter referred to as “Users”) of the Company’s digital assets, including websites in the Company’s various areas of activity, e-commerce sites, benefit clubs, mall activities and digital malls including the MY OFER application of Ofer Malls, etc. (hereinafter collectively and separately “the Digital Assets”) and are committed to protecting the personal information that users share with us within the framework of our digital assets.
2. We believe that our users have the right to know our policy regarding the collection and use of information received by us while using the digital assets. The privacy policy as detailed below will apply to the use of existing and future digital assets operated by the Company. The use of the digital assets is intended for users aged 18 and over. If you are under 18, you must read and approve this policy and the Terms of Use together with your parents.
3. The terms appearing in this Privacy Policy (hereinafter referred to as the “Privacy Policy“) shall have the meaning given to them in the relevant terms of use of each respective Digital Asset (hereinafter referred to as the “Relevant Terms of Use“) unless expressly stated otherwise in this Privacy Policy.
4. When using the Digital Assets, information is collected about users. Some of the information identifies them personally, namely their name and address, the products and/or services for which they requested to purchase vouchers, the payment methods used, information about the location where they are located or from which they performed various actions on the Digital Assets, etc. This is the information that users knowingly provide, including when registering for the Digital Assets. In addition, information about users from third parties may also be combined with the information that users provide to us directly, all in accordance with the consents they have given to those third parties. Some of the information does not personally identify users and is not stored together with their details (this is statistical and aggregated information, for example the pages they viewed, the offers and services that interested them, the IP address from which they contacted, etc.).
5. The privacy policy applies to the personally identifiable information collected and/or provided by users, as part of the personal registration process, transmitted by them during the use of the services and digital assets, to information collected about them while they use the digital assets and to information received from third parties to whom they have provided the information with their consent.
6. The company does not bear any responsibility for the use of information about users that is obtained not through them, by third parties, including commercial entities and/or websites and/or online merchants, including those that appear in the digital assets (such as businesses participating in the benefit campaigns in the digital assets, etc.) and that are not under its control. In any case of doubt, users should check the privacy policy and terms of use of that business, merchant, website or commercial entity.
7. It should be emphasized that the information provided and/or collected about users can be verified against existing information about them and/or against similar information provided and/or against any similar information in the possession of any third party, all in accordance with the consents that users have given to that third party.

B. Registration for Digital Assets

8. By entering, downloading and/or connecting and/or installing and/or actually using the digital assets, users express their consent to the terms appearing in this privacy policy, including their consent to the collection and processing of their information. If users do not agree to any of the terms detailed below, they are obligated, immediately, to refrain from entering and/or connecting to and/or using the digital assets, and are also obligated to remove and delete them from their possession.
9. It is clarified that the details and information that users will be asked to provide include information that is directly necessary for participating in the activity and/or providing the services and/or purchasing the products displayed in the digital assets, and this information is requested for this purpose and for additional purposes as detailed in the privacy policy. It is further clarified that the provision of the details and information that users will be asked to provide depends on their will and consent, but without providing the aforementioned information and details, they will not be able to join the digital assets and/or participate in activities and/or purchases.

C. Information Collection – We collect various types of information from users across our Digital Properties:

10. The first type of information we collect across our Digital Properties is information that is anonymous and does not personally identify users (hereinafter “Non-Personal Information”). Non-Personal Information is any publicly available information that is available to us when users use our Digital Properties and does not allow them to be identified. Non-personal information includes anonymous, technical information, and information collected about our users’ behavior, and may include, among other things, their activity on our digital properties, the identity of their operating system and browser type, use of information collection technologies as detailed in Section H of this Privacy Policy, mobile device type and version, device language, click-stream, referral URL, keyboard language, screen resolution, etc., to the extent that they do not identify the user.
11. Another type of information is personally identifiable information (hereinafter “Personal Information”). Personal information allows us to personally identify users of our digital properties and is generally of a private or sensitive nature. For example, users automatically provide their IP address, depending on the network or device they are using. This information is collected to improve the user experience and for security purposes. We also collect personal information that users knowingly and voluntarily provide during the use of our digital assets, such as: first name, last name, gender, email address, password, mobile phone number, residential address, vehicle registration number, ID card number.
    A, credit card details, etc. In addition, we collect information about actions taken by users on the various digital assets and on their devices, including actions that have begun but not been completed, various types of location data, to the extent that the device allows it, in relation to the user, and data received from third parties in accordance with the privacy policies of those third parties and the users’ consent to the provision of the information, including any information collected from the users’ browser and/or smartphone, their location, and all pages they have visited. Additional information may be requested in the future. Sometimes, we will use non-personal information together with personal information for the purposes listed in this policy. When we use non-personal information in conjunction with personal information, we will treat the information that is crossed as personal information. It is clarified that the user must allow the Company access to location services via the mobile phone, including GPS-based location and location that can be inferred via wireless networks or Bluetooth transmissions in the vicinity of your device and that in accordance with your consent given within the framework of this Privacy Policy in a conscious, free and voluntary manner, the Company will receive access to information regarding the user’s location as long as the application is activated on his mobile device (even if it is not actively used). Location services can be disabled through the device settings, although by performing such an action you will not be able to benefit from certain services that require the information as stated above.
12. It is clarified that users can connect to some of our digital assets through their account on certain social networks (hereinafter “Social Network Account”). If users have chosen to connect to the enabling digital assets through their social network account, then that social network may provide us with access to personal information stored about them within it, such as full name, email address, login details, list of friends on the social network, date of birth, gender and/or any other information detailed and presented to them in the notice that appears during the integration process with that social network account. Please read this notice carefully to understand what information is available to us through the social network account. For the avoidance of doubt, users hereby agree that the above information will be retained by us for the purposes detailed in this Privacy Policy even after the link between the social network account and their account on our digital assets expires, for any reason. If users do not agree to these terms, including the provisions of the terms of use and the dedicated privacy policy of that social network, they should refrain from using this connection option.
13. The information provided and/or collected about users will be retained in the company’s databases. Users hereby authorize the transfer of their information to any entity related and/or affiliated with the company, as well as to service providers to whom the transfer of information is required for the purpose of participating in the activity and/or providing the services and/or products on a regular basis or for the purpose of fulfilling the company’s obligations under the terms of use and/or legal provisions, all or any of which may be located outside the borders of the State of Israel and therefore be subject to the privacy protection laws of other countries in the world, including countries that do not provide the same protection as that provided by Israeli law to the privacy of users. Users expressly authorize the company to transfer the information collected about them, in accordance with the privacy policy, to these countries as well.
14. Users are not obligated to provide personal information by law, but refusal to provide the information will not allow us to provide the various services offered in the digital assets. Users hereby agree and declare that the personal information collected about them and/or that they provide to us is provided with their consent and free will, including so that we can provide them with access, products and services offered within our digital properties, and they also agree that we will retain such information in our database in accordance with the purposes detailed in this Privacy Policy above and below.

D. Use of Information

15. The use of information received about users due to their use of our digital assets will be done in accordance with the provisions of the privacy policy and/or according to the provisions of the law, among other things, in order to:

• Enable their use of the digital assets;
• Establish contact with them;
• Improve and enrich the services, activities and content offered in the digital assets, including based on the users’ physical location and their activity in the group’s malls;
• Cross-reference, characterize, and enrich the data and personal information collected or received about users for each of the purposes listed above and below;
• Change and/or cancel services, activities and content that exist in the digital assets;
• Enable participation in activities and/or purchase and/or Supply of products and/or services that appear in the digital assets, including through group purchases – as well as publishing information and content, including self-collection of products and entry to parking lots operated by the company or its assets;
• Adapt the ads and/or transactions that will be displayed when visiting the digital assets to the users’ areas of interest or their location;
• Send users operational messages and alerts in various ways, including via email, via text messages or via pop-up notifications on their devices (push notifications), such as a text message containing an identification code for accessing the digital assets, or for password recovery, or various messages including in relation to their actions, confirmations of execution of actions or instructions for execution and various uses of the services;
• Enable reuse and repeated purchase of products and/or services in the digital assets;
• To prevent illegal and/or unauthorized use Licensed in the Digital Assets.

16. The information that will be used will be partly statistical information that does not personally identify you.

F. Marketing Mailing

17. To the extent that users have shown interest in and/or purchased products and/or services from the Company, or if they have agreed to receive marketing mailings from the Company in one of our digital assets, as applicable, the Company and/or someone on its behalf will send those users marketing and promotional information that includes updates,
    Offers, benefits and promotions, etc. by digital means, including by email, instant messages and SMS messages. To the extent that users do not wish to receive the aforementioned mailing, they may revoke their consent at any time within the mailing itself and even remove themselves from the mailing list by sending an email to the following address: office@melisron.co.il.
18. The Company may make direct mailing inquiries to users, as this term is defined in the Privacy Protection Law, that is, personalized inquiries based on the information collected about users, in connection with the activities, products and services of the Company and its business partners. To the extent that users do not wish to receive personalized inquiries, they may contact the Company and request not to receive any more personalized inquiries by sending an email to the following address: office@melisron.co.il.

G. Providing information to third parties

19. The Company will not sell and/or rent and/or transfer the personally identifiable information about the users, as provided to it by them, in whole or in part, to any third party, except for any entity related and/or affiliated with it (subsidiary, parent company, sister company, etc.).
20. Notwithstanding the foregoing, the Company shall be entitled to disclose the personal information about the users, in whole or in part, to any third parties for any of the purposes listed in this policy, subject to the fulfillment of one or more of the following conditions:

• The information transferred is not information that personally identifies the users or is information that has been anonymized in any way.
• The users’ consent to the disclosure of this information has been obtained, including as part of their express consent to direct mailing activities;
• The disclosure of the information or Sharing it with certain parties is required for and/or within the framework of and/or in connection with the provision of the services and/or products and/or participation in the activity, and in particular, the Company will provide personal information regarding users to clearing service providers, information system providers or cloud computing providers who provide services to the Company, to the businesses from which products were purchased through the Site and to the shipping company or operator of delivery cells (lockers) for the products, as well as to parking lots to which entry is requested by users in connection with collecting products or visiting the Company’s malls. It should be emphasized that, unless otherwise stated, these parties do not have the right to use this information beyond the purpose for which it was provided; it is clarified that the databases of these parties may be located outside the borders of the State of Israel and therefore be subject to the privacy protection laws of other countries in the world, including countries that do not provide the same protection as that provided by Israeli law to the privacy of users. Users expressly authorize the Company to transfer the information collected about them, in accordance with the Privacy Policy, also to these countries;
• When the provision of information is required by law and/or if necessary within the framework of legal proceedings, including in the event that a judicial order is received ordering the disclosure of user information or information to a third party;
• In the event of a legal dispute that requires the disclosure of user information;
• In the event that it is found that the actions of users of the digital assets violate the terms of use or are contrary to the law, including for the purpose of committing fraud of any kind;
• In the event that the Company transfers in any way the activity of one or more of the digital assets to any corporation, as well as in the event that it merges with another entity or merges the activity of the digital assets with the activity of a third party, provided that this corporation assumes the provisions of the Privacy Policy towards the users.

H. Information Collection Technologies

21. The Company’s Digital Assets and/or third parties can, may and will use industry-standard technology known as “cookies” and Flash and/or other information collection technologies (hereinafter “Information Collection Technologies”), for the purpose of ongoing and proper operation, including to collect statistical data about the use of the Digital Assets, to verify details, to adapt the Digital Assets to the personal preferences of the users and for information security purposes.
22. These information collection technologies store information on the users’ devices and computers and sometimes also on the Company’s servers or on the servers of the Company’s service providers and allow us to automatically activate certain features, as well as to facilitate and simplify the experience of using the Digital Assets.
23. Some of the information collection technologies can be disabled, for example, modern web browsers include the option to avoid receiving cookies and/or block or delete them. from the user’s device. However, it should be noted that deletion, blocking and any other changes may limit the online experience of users of the digital assets. Please refer to the instructions in your browser or the “Help” screen to learn more about these functions. In addition, some of the information collection technologies may transfer information that will be collected to the company’s servers or to the servers of the company’s service providers. Information that has been transferred as aforesaid will not be deleted even if you block or delete it from your device.
24. It is clarified that when it comes to cookies created or operated by third parties, the company has no control over the encryption of the data stored in them and access to the information, as well as its cross-referencing with additional information, and such uses are subject to the privacy policies of those third parties.

T. Third-Party Advertisements and Sites

25. The Company may allow other companies to advertise their products/services on the Digital Properties. These advertisements come from the computers of those companies, and in order to manage their advertisements, these companies may place information collection technologies such as Cookies on your computer and on the users’ mobile device. These information collection technologies allow them to collect information about the websites that users have viewed, the advertisements they have placed, and which advertisements they have clicked on. The use of these companies’ information collection technologies is subject to their own privacy policies and not to this Privacy Policy. The Company is not and will not be responsible for the privacy policies of these companies or for the content that appears in their advertisements or on the websites or content to which the advertisements link and/or for any
    The Company uses the following data collection technologies: Google Tag Manager is used by us to measure the effectiveness of advertisements and actions taken on the Digital Assets and to optimize the placement of advertisements on the Digital Assets. For Google’s privacy policy, see here: https://policies.google.com/privacy?hl=en.

J. Information Security

27. The Company’s digital assets and databases have systems and procedures for information security, and it invests reasonable and acceptable efforts in implementing and maintaining the security of the digital assets and users’ personal information. However, while these systems, procedures and efforts reduce the risks of unauthorized intrusion, they do not provide absolute security. Therefore, there is no guarantee that the Company’s digital assets and databases will be completely immune from unauthorized access to the information stored therein. Users agree to the provision and collection of information in accordance with the Privacy Policy and assume the risk of information security incidents that will affect the confidentiality, integrity or availability of said information.

K. Use by Children

28. In order to use some of the Digital Assets, users must be over the age of eighteen (18). We reserve the right to request proof of age at any stage, so that we can ensure that users under these ages do not use the Digital Assets. If you are the parent of a child under these ages and you believe that your child has provided personal information to the Company, you may contact us using the contact information provided below and request that the information be deleted. In the event that we are informed that a person under these ages is using the Company’s digital assets, we may block a user and make every effort to immediately delete any personal information regarding that user as aforesaid.

X. Right to Review and Correct Information

29. In accordance with the provisions of the Privacy Protection Law, every person is entitled to review the personal information held about him and stored in a database. Therefore, the Company will allow users, to the extent that information is stored about them as aforesaid, to request to review this information. If users are interested in reviewing the aforementioned information, they may contact the company in writing in the manner prescribed in the Privacy Protection Regulations (Conditions for Reviewing Information and the Procedures for Appealing a Refusal to Review Requests), 5741-1981 or by contacting the email address: office@melisron.co.il.
30. Users who have reviewed their information as stated above and found that the information is not correct, complete, clear or up-to-date, may request to correct or delete the information. If users wish to do so, they may contact the Company in writing in the manner prescribed by the regulations or by contacting the email address: office@melisron.co.il. Such a request does not oblige the Company to correct or delete the information in accordance with the request.

M. Changes to the Privacy Policy

31. The provisions of this Privacy Policy are an integral part of the Digital Assets and the information collected within them, and they may not be separated in any way from the terms of use relevant to each of our Digital Assets. The Company reserves the right to change this Privacy Policy at any time, and asks all users to revisit this page as often as possible. We will notify users of any material changes to the terms of this Privacy Policy within the relevant Digital Asset and/or send users an email notification regarding changes to the email address provided to us within the framework of the use of the Digital Assets. Material changes will be effective seven (7) days after notice is posted on the applicable Digital Asset or sent by email, whichever comes first. All other changes to the Privacy Policy will be effective on the date this Privacy Policy was last updated, and your continued use of the Company’s Digital Assets after the date of the last update will constitute your agreement to be bound by the changes. If the Privacy Policy is revised to comply with any legal requirement, the revisions may be effective immediately, or as required by law, without prior notice.

Questions

32. If you have any questions or other comments regarding this Privacy Policy, please send us an email to office@melisron.co.il, and we will use our best efforts to get back to you within a reasonable time.

 

Last updated: April 3, 2024.