A. General
1. We, the Melisron Group (hereinafter – “the company” or “us”) respect the privacy of the users (hereinafter “the users”) of the company’s digital assets, including the websites in the various areas of the company’s activity, e-commerce sites, benefit clubs, activity in shopping malls and digital shopping malls including the MY OFFER application of Ofer shopping malls etc. (hereinafter collectively and separately “the digital assets”) and are committed to protecting the personal information that users share with us within 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 the 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 the age of 18, you must read and agree to this policy and the terms of use together with your parents.
3. The terms appearing in this privacy policy (hereinafter the “privacy policy”) will have the meaning given to them in the relevant terms of use of each respective digital asset (hereinafter the “relevant terms of use”) unless explicitly stated otherwise in this privacy policy.
4. When using the digital assets, information is collected about the users. Some of the information identifies them personally, that is, by their name and address, the products and/or services they requested to purchase vouchers for, the means of payment they used, information on the location where they are located or from where they performed various operations on the digital assets, etc. This is the information that the users knowingly provide, including when registering for the digital assets. In addition, it is possible that information about them from third parties will also be attached to the information that the users provide us directly, all in accordance with the agreements they have given to those third parties. Some of the information does not identify the users personally and is not saved together with their details (this is statistical and cumulative 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 personal identifying information collected and/or provided by the users, as part of the personal registration process, transmitted by them while using the services and digital assets, to information collected about them while they are using 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 the users that is not received 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 that participate in the promotions on the digital assets, etc. “b) and which are not under its control. In any case of doubt, users must check the privacy policy and terms of use of that business, merchant, website or commercial entity.
7. It will be emphasized that the details that will be provided and/or that will be collected about the users, can and will be verified against existing information about them and/or against similar information that has been provided and/or against any similar information that is in the possession of any third party, all in accordance with the agreements that the users have given to that third party .
b. Registration for the digital assets
8. By actually entering, downloading and/or connecting and/or installing and/or actually using the digital assets, the users express their consent to the conditions appearing in this privacy policy, including their consent to the collection of their information and its processing. If the users do not agree to any of the conditions listed below, they are obliged, immediately, to refrain from entering and/or connecting and/or using the digital assets, and are also obliged to remove and delete them from their possession.
9. It will be clarified that the details and information that the users will be asked to provide include information that is directly necessary for participation in the activity and/or the provision of the services and/or for the purchase of the products displayed in the digital assets and this information is requested for this purpose and for other purposes as detailed in the privacy policy. It will also be clarified that the delivery of the details and information that the users will be asked to provide depends on their desire and consent, but without the delivery of said 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 within our digital properties:
10. The first type of information we collect as part of our digital properties is information that in itself is anonymous and does not identify users personally (hereinafter “non-personal information”). Non-personal information is any visible information that is available to us while users are using our digital assets, and does not allow their identification. Non-personal information includes anonymous, technical information as well as information collected about the behavior of our users, and may include, among others, their activity on our digital assets, the identity of their operating system and the type of their browser system, use of information collection technologies as detailed in Section H of this privacy policy, device type The mobile phone and its version, the language of the device, the click-stream, the referral URL, the keyboard language, screen resolution, etc., to the extent that these do not identify the user.
11. Another type of information is personally identifiable information (hereinafter “personal information”). The personal information allows us to personally identify the users of our digital assets and is usually of a private or sensitive nature. For example, users automatically provide their IP address, depending on the network or device they use. This information is collected to improve the user experience and for security purposes. We also collect personal information provided by users knowingly and voluntarily during the use of our digital assets, such as: first name, last name, gender, e-mail address, password, mobile phone number, residential address, vehicle number, ID number Identity, credit card information, etc. In addition, we collect information about actions performed by the users on the various digital assets and on their devices, including actions that have begun but not completed, location data of various types, as far as the device allows, in relation to the user, and data received from third parties in accordance with the privacy policies of those third parties and the consent of the users to provide the information, including any information received from the browser in the possession of the users and/or from the smart phone device in their possession, their location as well as all the pages they 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 cross-referenced with personal information, we will treat the cross-referenced information as personal information. It is clarified that the user must allow the company access to location services using the mobile phone, including GPS-based location and a location that can be deduced via wireless networks or Bluetooth transmissions near your device and that in accordance with your consent given within this privacy policy knowingly, freely and voluntarily, 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 canceled through the device settings, although by performing the aforementioned 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 enabled 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 social network friends, date of birth, gender and/or or any other information detailed and shown to them during the integration procedure with that social network account. Please read this message 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 kept by us for the purposes specified in the policy This privacy even after the link between the social network account and their account in 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 must refrain from using this connection option.
13. The information provided and/or collected about the users will be stored in the company’s databases. The users hereby approve the transfer of their information to any entity related and/or affiliated to the company, as well as to service providers to whom the transfer of information is required for 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 according to the terms of use and/or instructions The law, all of which or any of them 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 for the privacy of users. The 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 obliged 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. The 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 of their own free will, including in order for us to provide them with access, products and services offered within our digital assets, and they also agree that we will store such information in our database in accordance with the purposes detailed in the policy This privacy above and below.
d. The use of information
15. The use of the information obtained about the 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;
• establishing contact with them;
• Improve and enrich the services, activities and content offered in the digital assets, including based on the physical location of the users and their activity in the group’s malls;
• cross-reference, characterize, and enrich the data and personal information collected or received about the users for any of the purposes listed above and below;
• change and/or cancel services, activities and content that exist in the digital assets;
• To allow participation in activities and/or purchase and/or supply of products and/or services that appear in the digital assets, including through the group purchases – as well as publication of information and content, including self-collection of the products and entry to parking lots operated by the company or in 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;
• To send operational messages and notifications to users in various ways, including via email, via text messages or via pop-up notifications on their device (push notifications), such as a message containing an identification code to access the digital assets, or to recover a password, or various messages including regarding their actions, confirmations of actions or execution instructions and different uses of the services;
• allow the reuse and repurchase of products and/or services in the digital assets;
• To prevent illegal and/or unauthorized use of the digital assets.
16. The information that will be used will be partly statistical information that is not personally identifiable.
f. Marketing mailing
17. To the extent that the users were interested in and/or purchased products and/or services from the company, or if they agreed to receive marketing mailings from the company in one of our digital assets, as the case may be, the company and/or someone on its behalf will send those users marketing and advertising information including updates, offers, benefits and promotions etc. by digital means, including email, instant messages and SMS messages. To the extent that the users do not wish to receive the aforementioned mailing, they can withdraw their consent at any time within the mailing itself and even remove themselves from the mailing list by sending an email to the address: office@melisron .co.il.
18. The company may make inquiries by direct mail in relation to the users, as this term means in the Privacy Protection Law, that is, personalized inquiries based on the information collected about the users, in connection with the activities, products and services of the
Bera and its business partners. To the extent that the users do not wish to receive personalized inquiries, they can contact the company and request that they no longer receive such personalized inquiries by sending an email to the address: office@melisron.co.il .
g. Provision of information to third parties
19. The company will not sell and/or rent and/or transfer the personal identifying information about the users, as provided by them, in whole or in part, to any third party, except to any related and/or affiliated entity (subsidiary, parent company , sister company, etc.).
20. Notwithstanding the above, the company will be entitled to disclose the personal information about the users, in whole or in part, to any third parties for all the purposes listed in this policy, subject to the existence of one or more of the following conditions:
• The information transmitted is not information that personally identifies the users or is information that has been anonymized in any way.
• The consent of the users to the disclosure of this information was received, including as part of their explicit consent to direct mail operations;
• The disclosure of the information or part of it to 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, including that the company will provide personal information regarding users to clearing service providers, information system providers or cloud computing providers that provide services to the company , to the businesses from which products were purchased through the website and to the delivery company or operator of delivery rooms (lockers) for the products, as well as to the parking lots to which entry is requested by the users in connection with the collection of products or visiting the company’s malls. It must be emphasized that unless stated otherwise, these parties have no right to use this information beyond the purpose for which it was provided; It is clarified that the databases of these entities 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 for the privacy of users. The users expressly authorize the company to transfer the information collected about them, in accordance with the privacy policy, to these countries as well;
• When the delivery of the information is required by law and/or if necessary within the framework of legal proceedings, including in the case where a judicial order is obtained ordering the delivery of the users’ details or the information to a third party;
• In the event of a legal dispute that would require the disclosure of user information;
• In the event that it is found that the actions of the users of the digital assets violate the terms of use or are against the law, including for committing fraud of any kind;
• In the event that the company transfers in any form the activity of one or more of the digital assets to any corporation, as well as in the event that it merges with another body or merges the activity of the digital assets with the activity of a third party, provided that this corporation accepts the provisions of the privacy policy towards the users.
H. Information collection technologies
21. The digital assets of the company and/or third parties can, may and will use the technology accepted in the industry and known as “Cookies” (Cookies) and Flash and/or other information collection technologies (hereinafter “information collection technologies”), for the purpose of the current and proper functioning, Including this to collect statistical data about the use of the digital assets, to verify details, to adjust the digital assets to the personal preferences of the users and for information security purposes.
22. These information collection technologies save information on the users’ device and their computers and sometimes also on the company’s servers or on the servers of the company’s service providers and allow us to activate certain features automatically, as well as facilitate and simplify the experience of using the digital assets.
23. Some of the information collection technologies can be deactivated, for example modern internet 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 the users of the digital assets. Please refer to the instructions in your browser or the “Help” screen to learn more about these functions. Also, it is possible that some of the information collection technologies will transfer information to be collected to the company’s servers or to the servers of the company’s service providers. Information transferred as mentioned above will not be deleted even if you block or delete it from your device.
24. It will be clarified that when it comes to cookies created or activated by third parties, the company has no control over the encryption of the data stored in them and the access to the information, as well as cross-referencing it with additional information, and such uses are subject to the privacy policies of those third parties.
t. Advertisements and third-party websites
25. The company may allow other companies to advertise their products/services on the digital assets. These ads 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 the users’ mobile device. These information collection technologies allow them to collect information about the sites users have viewed, the advertisements they have placed and which advertisements they have clicked on. The use that these companies make of their information collection technologies is subject to their 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 activity resulting from the use of the information collection technologies of those other companies.
26. For example, the company uses the information collection technologies of the following companies: Google Tag Manager is used by us to measure the effectiveness of advertisements and actions carried out 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. Information security systems and procedures are implemented in the company’s digital assets and databases, and it invests reasonable and acceptable efforts in implementing and maintaining the security of the digital assets and the users’ personal information. However, while these systems, procedures and efforts reduce the risks to one
Unauthorized shot, they do not provide absolute security. Therefore, there is no guarantee that the company’s digital assets and databases will be absolutely immune from unauthorized access to the information stored in them. The users agree to the provision of the information and its collection in accordance with the privacy policy and assume the risk of the existence of information security events that will affect the confidentiality, integrity or availability of the said information.
Use by children
28. In order to make use of 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 verify that users under these ages are not using the digital assets. If you are a 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 the deletion of such information. In the event that it is brought to our attention that a person under these ages is using the company’s digital assets, we will be entitled to block a user and will make every effort to immediately delete any personal information regarding said user.
12. 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 such information is kept on them, to request to review this information. If the users are interested in reviewing the aforementioned information, they can contact the company in writing in the ways stipulated in the privacy protection regulations (conditions for reviewing information and the rules of procedure for appealing the refusal of a review request), 1981-1981 or by contacting the email address: office@melisron.co.il.
30. Users who reviewed their information as stated above, and found that the information is not correct, complete, clear or updated, may request to correct or delete the information. If the users wish to do so, they can contact the company in writing in the ways specified in the regulations or by contacting the email address: office@melisron.co.il. There is no In the aforementioned application to oblige the company to correct or delete the information in accordance with the request.
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 should not be separated, in any way, from the terms of use applicable to each of our digital assets. The company reserves the right to change this privacy policy at any time, and requests all users to return and visit 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 e-mail notification regarding changes to the email address provided to us as part of the use of the digital assets. Material changes will take effect seven (7) days after notice is provided on the digital asset applicable or sent by e-mail, whichever is earlier. All other changes to the Privacy Policy will take effect on the date of the last update of this Privacy Policy, and the continued use of the Company’s Digital Assets after the date of the last update will constitute users’ consent to be bound by the changes to the extent that the Privacy Policy is amended to comply with all A legal requirement, the amendments may take effect immediately, or as required by law, and without any prior notice.
hand. Questions
32. If you have any questions, or other comments regarding this privacy policy, you are welcome to send us an e-mail at office@melisron.co.il, and we will do our best to get back to you within a reasonable time.
Last updated: March 10, 2024.