This website (the “Website”) provides information about products marketed by liberDi Ltd. and its operations (“liberDi”, “we“, “our”, or “us”, as appropriate). liberDi is committed to protecting and respecting your privacy in accordance with applicable laws. This privacy policy provides comprehensive information about our processing activities in liberDi (the “Privacy Policy”), though the particular processing activities and privacy practices may vary in different companies and jurisdictions.

  1. IMPORTANT INFORMATION AND WHO WE ARE 

This Privacy Policy (together with the Terms of Use) sets out the basis on which any Personal Data (as defined below) we collect from you, or that you provide to us, will be processed, stored and shared by us. We process Personal Data in accordance with “Applicable Data Protection Laws” (which means the General Data Protection Regulation 269/2016 (“GDPR”) and any data protection and privacy laws and regulations applicable to us). Please read the following carefully to understand our practices regarding your Personal Data, before you access or use the Website. By browsing this Website, you consent to the processing of your Personal Data as detailed in this Privacy Policy. If you have read this Privacy Policy, and remain opposed to our practices, you must immediately leave this Website, and avoid or discontinue all use of the Website. If you have further questions or concerns regarding this Privacy Policy, please contact us at: info@liberDi.com.

This Website is not intended for persons under 18 and we do not knowingly collect data relating to minors under 18. Insofar as Personal Data may be collected based on your consent, you must be above the age of 18. If these age requirements are not met, you are required to avoid using the Website.

  1. WHAT IS PERSONAL DATA? 

“Personal Data” means information that can directly or indirectly identify you. Personal Data may include:

  • “Identifiers” such as your real name, postal address, unique personal identifier, online identifier, Internet Protocol address, account name, and other similar identifiers;
  • “Contact Details” such as your name, address, email address, and telephone number;
  • other information such as an IP address.

The term Personal Data shall also include and refer to similar terms in Applicable Data Protection Laws.

  1. THE CATEGORIES OF PERSONAL DATA WE COLLECT AND HOW DO WE COLLECT IT 
    • We use different methods to collect data from and about you, including through:
      • Direct interactions: You may give us your Personal Data by filling in forms or by corresponding with us by email, Website or otherwise.
      • Automated technologies or interactions: As you interact with our Website, we may automatically collect data about your equipment, browsing actions and patterns. We collect this Personal Data by using technologies of third party providers.
      • Cookies and similar technologies: We use cookies (small, often encrypted, text files that are stored on your computer or mobile device) and similar technologies (“Cookies”) to help collect data.
      • When you provide us data, you are requested not to submit sensitive data or Health Data through the “contact us” form on our Website.
        • We may collect information on the handling of your request and/or the relationship with you and any other Personal Data you voluntarily provide to us; ii) You represent the Personal Data you provide is accurate, complete and up to date and that you are legally authorized to provide it.
  2. HOW WE USE THE PERSONAL DATA AND WHAT ARE THE LEGAL BASES OF PROCESSING?

We collect and use your Personal Data for the following purposes and under the following legal bases:

  • In order to enter into and/or perform a contract with you, we may: provide you with the information that you request from us; and maintain your Contact Details in our customer relations database.
  • To fulfill our legal and regulatory obligations, we may: take action to prevent, investigate and detect crime, fraud or anti-social behavior and prosecute offenders (including working with law enforcement agencies or the regulators).
  • To exercise tasks under our legitimate interests such as to:
    1. enforce our Terms of Use;
    2. handling customer contacts, queries and complaints or disputes;
    3. ensuring our Website operate effectively;
    4. to administer our Website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.
    5. to improve our Website to ensure that content is presented in the most effective manner for you and for your computer.
  1. NON-PERSONAL DATA WE COLLECT OR GENERATE
    • In addition to the categories of Personal Data described above, we will also process “Non-Personal Information”, meaning information that does not personally and specifically identify a natural person, such as anonymized information, which may be collected through the Website in the following ways:
      • Information that your browser sends (“Log Data”). This Log Data may include, but is not limited to, non-identifying information regarding the User’s device, operating system, internet browser type, screen resolution, language and keyboard settings, internet service provider, referring/exit pages, date/time stamps, the web page you were visiting, information you search, etc.
      • We may collect further Non-Personal Information through use of automated devices and applications to evaluate usage of our Website and through cookies. We use these tools to help us improve our Website, performance and user experience. We may also engage third parties to track and analyze data or provide other services on our behalf. Such third parties may combine the Non-Personal Information that we provide about you with other information that they have collected from other sources. This Privacy Policy does not cover such third parties’ use of the data and such use is governed by such third parties’ privacy policies.
  1. DATA RETENTION – FOR HOW LONG IS THE DATA STORED? 
    • We retain Personal Data as long as we are required to keep the information by applicable laws, or in accordance with our legitimate interests. The information is located in Israel. 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 whether we can achieve those purposes through other means, and the applicable legal requirements.
  2. WHO MAY THE INFORMATION BE SHARED WITH? 

We may share Personal Data that we receive from you with the following third parties:

  • Our service providers – such as accountants, auditors, experts, lawyers, credit reference agencies, IT systems providers, manufacturers, support and hosting service providers; printing, advertising, marketing and market research and analysis service providers; document and records management providers; technical engineers; data storage and cloud providers and similar third-party vendors and outsourced service providers that assist us in carrying out business activities.
  • Government or other public authorities – including, but not limited to, law enforcement or other agencies to which we are required to disclose Personal Data by law, or by a warrant, subpoena or court order.
  • Other third parties – In the event that we sell or buy any business or assets, we may disclose your Personal Data to the prospective seller or buyer of such business or assets. If liberDi or substantially all of its assets are acquired by a third party, Personal Data held by it about its customers will be one of the transferred assets.
  • We do not sell, share or rent any information collected to third parties except for those detailed in this privacy policy.
  • Applicable law may require us to disclose your Personal Data if: (i) reasonably necessary to comply with legal process (such as a court order, subpoena or search warrant) or other legal requirements; (ii) disclosure would mitigate our liability in an actual or threatened lawsuit; (iii) necessary to protect legal rights of our Group, our users, customers, business partners or other interested parties; or (iv) necessary for the prevention or detection of crime (subject in each case to applicable law). For residents of the European Economic Area (“EEA”), we will disclose Personal Data only when permitted to do so under applicable European and EU Member States’ national data protection laws and regulations.
  1. SECURITY 
    • We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Data on our instructions and they are subject to a duty of confidentiality.
    • We have put in place procedures to deal with any suspected “Personal Data Breach” (as this and similar terms are defined in the Applicable Data Protection Laws) and will notify you and any applicable regulator of a Breach where we are legally required.
    • Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your Personal Data, we cannot guarantee the security of your data transmitted to our Website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.
  2. SOCIAL MEDIA PLATFORMS AND LINKS TO THIRD PARTY WEBSITES

When you use our page on a social media platform, you do so at your own discretion and subject to the terms and conditions as well as the privacy policies of each social media platform respectively. Please note that we do not accept any responsibility or liability for these policies and that these social media platforms or websites may track your activity.

  1. YOUR RIGHTS
    • Different privacy rights may apply in various jurisdictions. In some jurisdictions, you may have a right to receive information about the processing of your Personal Data by us, the right to rectify your Personal Data and/or to request deletion of your Personal Data.
    • General conditions for complying with Personal Data inquiries: When you contact us about your Personal Data, we may need to ask you to provide us 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 questions to better understand the nature and scope of data that you request to access. We may redact from the data which we will make available to you, any Personal Data related to others. In addition, we may delete your Personal Data, if required by Applicable Data Protection Laws.
    • At any time, you may contact us at: info@liberDi.com in order to inquire about your Personal Data rights. We will make good-faith efforts to assist you as we are required under the Applicable Data Protection Laws.
  2. INFORMATION FOR EUROPEAN UNION RESIDENTS:
        • Data Location and International Data Transfers:
          1. Your Personal Data may be stored on our servers outside the EEA and may be processed by liberDi and service providers outside the EEA. We transfer and process your Personal Data outside the EEA, and we do so in a manner commensurate with Applicable Data Protection Laws.
        • Your EU Privacy Rights
          1. If you are a European resident, in addition to the rights mentioned above, under the GDPR and subject to its conditions, you have the following additional rights:
        • Erasure of Personal Data;
        • Objection to the processing of Personal Data;
        • Restriction of processing of Personal Data; and
        • Portability of Personal Data – to receive the Personal Data you have provided to us in a structured, commonly used and machine-readable form and transmit it to another data controller.
          1. In some instances, our legal obligations may override your rights under data protection laws. We are also legally required to identify you before we process your request.
          2. Normally, you will not have to pay a fee to access your Personal Data (or to exercise any of your rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
          3. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
  1. CHANGES TO OUR PRIVACY POLICY 

Any changes we may make to our Privacy Policy in the future will be posted on this page. Please check back frequently to see any updates or changes to our Privacy Policy.

  1. CONTACT US
    • Questions, comments and requests regarding this Privacy Policy are welcomed and should be addressed to: info@liberDi.com.
    • Note to EU residents: for the purpose of the GDPR, the data controller may be liberDi.