Last updated: December 15th 2021

This Privacy Policy (“Privacy Policy”) describes and governs the information collection, use, disclosure, retention and protection of your personal information by
Studio Mira Zwillinger Ltd, a limited company registered in the State of Israel under company registration number 515175776 with our registered office address at 22 Helsinki St., Tel Aviv and its corporate affiliates, subsidiaries, and divisions as may change from time to time (collectively, “We”, “Us”, and “Our”) with respect to the website www.mirazwillinger.com (the “Website”).

Where you and anyone on your behalf (collectively, “You”) provide us with your personal information in any of the ways described below, You agree that We may collect, store and use it: (a) in order to perform our contractual obligations to You; (b) based on Our legitimate interests for processing (i.e. for internal administrative purposes, data analytics and benchmarking, direct marketing, maintaining automated back-up systems or for the detection or prevention of crime); or (c) based on Your consent, which you may withdraw at any time, as described in this Privacy Policy.

1. HOW WE COLLECT INFORMATION?

To the extent permissible under applicable law, We may collect information about You and any other party whose details you provide to Us when You:

• register to use the Website (open an account); this may include Your name (including business name), address, email address and telephone number. We may also ask You to provide additional information about Your preferences;
• place an order using our Website; this may include Your name (including business name), address, contact (including telephone number and email address) and payment details;
• complete online forms (including call back requests), take part in surveys, post on our message boards, post any blogs;
• interact with Us using social media;
• provide Your contact details to Us when registering to use or accessing the Website  (including to our customers club) or when You update those details; and
• contact Us offline, for example by telephone, fax, SMS, email or post.

We will also collect your information where You only partially complete and/or abandon any information inputted into our Website and/or other online forms and may use this information to contact You to remind You to complete any outstanding information and/or for marketing purposes.

We also collect information from Your devices (including mobile devices) and applications You use to access and use the Website (for example, we may collect the device identification number and type, location information and connection information such as statistics on your page views, traffic to and from the sites, referral URL, ad data, your IP address and your web log information) and we will ask for your permission before we do so. We may do this using cookies or similar technologies (as described below).

We may enhance personal information We collect from You with information We obtain from third parties that are entitled to share that information; for example, information from credit agencies, search information providers or public sources (e.g. for customer due diligence purposes), but in each case as permitted by applicable laws.

2. PROVIDING US WITH INFORMATION ABOUT OTHERS

If You provide Us with personal information of someone else, You are responsible for ensuring that You comply with any obligation and consent obligations under applicable data protection laws in relation to such disclosure. In so far as required by applicable data protection laws, You must ensure that You have provided the required notices and have obtained the individual’s explicit consent to provide Us with the information and that You explain to them how We collect, use, disclose and retain their personal information or direct them to read Our Privacy Policy.

3. BASIS FOR PROCESSING PERSONAL DATA

We will only collect and use your personal information in accordance with data protection legislation. Our legal bases for processing your personal information are as follows:

• Consent – Where necessary, We may collect and process Your personal information if You have confirmed Your consent for Us to do so. For example, We will process certain sensitive information about You only if We obtained Your consent.
• Legitimate Interests – We may collect and use Your personal information for Our legitimate business purposes, For example, for managing Our business and to enable Us to give You the best service/products and most secure experience. We have completed a comprehensive assessment and implemented measures to ensure Our interests do not affect Your right to privacy.
• Contractual – We may process data for the purposes of a contract to which You are party to. 
• Compliance with a legal obligation – We may be under a legal obligation to disclose Your personal data

4. HOW WE USE YOUR INFORMATION

To the extent permissible under applicable law, We may use Your information to:

• provide any information and services that You have requested or any applications or services that You have ordered;
• compare information for accuracy and to verify it with third parties;
• provide, maintain, protect and improve any applications, products, services and information that You have requested from us;
• manage and administer Your use of applications, products and services you have asked us to provide;
• manage our relationship with You (for example, customer services and support activities);
• monitor, measure, improve and protect Our content, Website, applications and services and provide an enhanced, personal, user experience for You;
• undertake internal testing of our website, applications, systems and services to test and improve their security, provision and performance, in which case, we would pseudonymise any information used for such purposes, and ensure it is only displayed at aggregated levels which will not be linked back to You or any living individual;
• provide You with any information that We are required to send You to comply with Our regulatory or legal obligations;
• detect, prevent, investigate or remediate, crime, illegal or prohibited activities or to otherwise protect Our legal rights (including liaison with regulators and law enforcement agencies for these purposes);
• contact You to see if You would like to take part in Our customer research (for example, feedback on Your use of Our Website, products and services);
• to monitor, carry out statistical analysis and benchmarking, provided that in such circumstances it is on an aggregated basis which will not be linked back to You or any living individual;
• deliver targeted advertising, marketing (including in-product messaging) or information to you which may be useful to You;
• deliver joint content and services with third parties with whom You have a separate relationship (for example, social media providers); and
• provide You with location – based services (for example, advertising and other personalized content), where we collect geo-location data.

The Website may contain technology that enables Us to:

• check specific information from Your device or systems directly relevant to Your use of the Website;
• obtain information relating to any technical errors or other issues with the Website;
• collect information about how You use the functions of the features of the website; and
• gather statistical information about the operating system and environment from which You access the Website.

You can manage your privacy settings within Your browser.

In addition to the purposes described above, We may also use information We gather to deliver targeted advertising, marketing (including in-product messaging) or information to You which may be useful, based on Your use of the Website or any other information We have about You (Sections ‎5 and ‎6 of this Privacy Policy provides further details on how we will do this.

We may monitor and record our communications with You, including e-mails and phone conversations. Information which We collect may then be used for training purposes, quality assurance, to record details about our Website and services You order from Us or ask Us about, and in order to meet our legal and regulatory obligations.

Mobile data

We may obtain information through mobile applications that You install on your mobile devices to access and use the Website. These mobile applications may be Our own mobile applications or those belonging to third parties. Where the mobile application belongs to a third party, You must read that third party’s own privacy notice as it will apply to Your use of that third party mobile application. We are not responsible for such third party mobile applications and their use of your personal information.

Mobile applications may provide Us with information related to a user’s use of that mobile application and use of Our Website accessed using that mobile application. We may use such information to provide and improve the mobile application or our own application or services. For example, activity undertaken within a mobile application may be logged.

Data analytics and benchmarking

We may use information generated and stored during Your use of the Website for Our legitimate business interests to enable Us to give You the best service and/or solutions and the best experience. These purposes include to:

• deliver advertising, marketing (including in-product messaging) or information to You which may be useful to You, based on Your use of the Website;
• carry out research and development to improve our Website;
• develop and provide new and existing functionality and services (including statistical analysis, benchmarking and forecasting services); and
• provide You with location based services (for example location relevant content) where we collect geo-location data to provide a relevant experience.

Whenever We use your information for our legitimate interests, We will ensure that Your information is processed on a pseudonymised basis and displayed at aggregated levels, which will not be linked back to You or to any living individual.

You have the right to object to processing based on our legitimate interests, and if You wish to do so, please contact us at [email protected] to discuss this further. If You object, this may affect our ability to provide certain services and/or solutions for Your benefit.

We may share Your information with:

• Our service providers and agents (including their sub-contractors) or third parties which process information on Our behalf (e.g. internet service and platform providers, payment processing providers, delivery services providers and those organizations We engage to help us send communications to You) so that they may help Us to provide You with the products, services and information You have requested or which We believe is of interest to You;
• partners, including system implementers, resellers, value-added resellers, independent software vendors and developers that may help Us to provide You with the products, services and information You have requested or which We believe is of interest to You;
• third parties used to facilitate payment transactions, for example clearing houses, clearing systems, financial institutions and transaction beneficiaries;
• third parties where You have a relationship with that third party and You have consented to us sending information (for example social media sites or other third party application providers);
• third parties for marketing purposes (e.g. our partners and other third parties with whom We work and whose products or services We think will interest You in the operation of your business activities;
• credit reference and fraud prevention agencies;
• regulators to meet Our legal and regulatory obligations;
• law enforcement agencies so that they may detect or prevent crime or prosecute offenders;
• any third party in the context of actual or threatened legal proceedings, provided we can do so lawfully (for example in response to a court order);
• any third party in order to meet Our legal and regulatory obligations, including statutory or regulatory reporting or the detection or prevention of unlawful acts;
• Our professional advisors and auditors for the purpose of seeking professional advice or to meet Our audit responsibilities;
• another organization if We sell or buy (or negotiate to sell or buy) any business or assets;
• another organization to whom We may transfer Our agreement with you; and
• Government departments where reporting is mandatory under applicable law.

5. SHARING YOUR INFORMATION

We may share non-personally identifiable information about the use of Our Website, products or services publicly or with third parties but this will not include information that can be used to identify You.

6. MARKETING

From time to time, We may use Your information to contact You with details about our products and services which we feel may be of interest to You. We may also share Your information with carefully selected third parties so that they may contact You with information about their products or services which We feel may be of interest to You. We or they may wish to contact You for this purpose by telephone, post, SMS or email. You have the right at any time to stop Us from contacting You for marketing purposes. You may also request at any time that We do not share Your information with third parties referred to in this paragraph. If you wish to exercise these rights You can do so by sending us an email to [email protected]. You can also unsubscribe from any email marketing using the links provided in the emails send to you.

7. THIRD PARTY PLATFORM AVERTISING

Where You respond to communications We post on third-party platforms (such as Facebook, Google and Twitter), We may also share your information with those third partiesin order to serve targeted advertising/content to You via the relevant third party platform based on your profile/interests.  Your information is used by the third-party platform provider to identify Your account and serve advertisements to You.  You can control what advertisements You receive via the privacy settings on the relevant provider’s platform and You should consult the third party’s help/support center for more information. 

8. EU/EEA DATA PRIVACY LAW

Residents of the EEA or other jurisdiction having similar data protection laws should read these provisions in addition to the previous sections of this Privacy Policy.

If You are based within the EEA or within another jurisdiction having similar data protection laws, in certain circumstances You have the following rights:

• the right to request information concerning the purpose of the processing; the categories of personal data concerned; who else (other than Us) might have received the data from Us; what the source of the information was (if you did not provide it directly to Us); and how long it will be stored.
• the right of erasure: the right to erasure of personal information that We hold about You if it is no longer necessary in relation to the purpose for which it was originally collected. Please note that We may need to retain certain data required in order to complete transactions, perform refunds, maintain underwriting records or comply with legal obligations, tax and accounting requirements, etc.
• the right to object to the processing of Your information e.g. for direct marketing purposes or where the processing is based on our legitimate interests;
• the right to have any information You provided to us on an automated basis returned to You in a structured, commonly used and machine-readable format, or sent directly to another company, where technically feasible (“data portability”);
• where the processing of Your information is based on your consent, the right to withdraw that consent subject to legal or contractual restrictions;
• the right to object to any decisions based on the automated processing of Your personal data, including profiling; and
• the right to lodge a complaint with the supervisory authority responsible for data protection matters (e.g. in the UK, the Information Commissioner’s Office).

In order to exercise any of these rights please contact us as at [email protected]

If You request a copy of Your information you may be required to pay a statutory fee.

If We hold any information about You which is incorrect or if there are any changes to your details, please let Us know by so that We can keep Our records accurate and up to date.

We will retain your personal information for the duration of our business relationship and afterwards for as long as is necessary and relevant for our legitimate business purposes (but no more than 12 months following the termination of our business relationship) or as otherwise permitted by applicable laws and regulations. Where We no longer need Your personal information, We will dispose of it in a secure manner (without further notice to You).

9. TRANSFERS OUTSIDE OF THE EUROPEAN ECONOMIC AREA

Personal information in the European Union is protected by data protection laws but other countries do not necessarily protect Your personal information in the same way.

Our Website and some of our applications or services or parts of them may also be hosted in the State of Israel or otherwise outside of the EEA (which means all the EU countries plus Norway, Iceland and Liechtenstein) (“EEA”) and this means that We may transfer any information which is submitted by You through the Website outside the EEA to the United States or to other territories outside of the EEA.

We may use service providers based outside of the EEA to help us provide our Website and services to You (for example, platform and payment providers who help us deliver our services, or advertising or execute Your payments) and this means that We may transfer Your information to service providers outside the EEA for the purpose of providing Our services to You.

We take steps to ensure that where Your information is transferred outside of the EEA by our service providers and hosting providers, appropriate measures and controls in place to protect that information in accordance with applicable data protection laws and regulations. In each case, such transfers are made in accordance with the requirements of Regulations (EU) 2016/679 (the General Data Protection Regulations or “GDPR”) and may be based on the use of the European Commission’s Standard Model Clauses for transfers of personal data outside the EEA.

By using Our Website, products or services or by interacting with Us in the ways described in this Privacy Policy, You consent to the transfer of Your information outside the EEA in the circumstances set out in this Privacy Policy. If You do not want Your information to be transferred outside the EEA you should not use the Website.

10. CALIFORNIA PRIVACY RIGHTS

California residents should read these provisions in addition to the previous sections of this Privacy Policy.

Residents of the State of California have additional statutory rights afforded by the California Civil Code, including the California Consumer Privacy Act of 2018 (the “CCPA”).

Please note that We may still need to retain certain data to complete transactions, perform refunds, maintain underwriting records or comply with legal obligations, tax and accounting requirements, etc. If this is the case We will advise accordingly.

The CCPA grants California residents the following statutory rights relating to personal information.

• the right to request disclosure of the categories of personal data held, the categories of the sources of such data, the purposes for which it is held and the categories of personal data is disclosed to third parties.
• the right to request details of the personal information relating to you that has been collected in the prior 12 months.
• the right to request deletion of such data. Certain exceptions may apply.
• the right to request that personal data not be sold to third parties – not applicable to Us at present
• the right not to be discriminated against

Table: Categories of Data Usage, Source, Purpose and Disclosure – CCPA 

Table Categories of Data and Categories of Third Party Disclosure – CCPA

We may collect personal information as set out in the above category tables as designated by the CCPA.

We do not sell, disclose or share Your personal information for valuable consideration. As a result there is no opt-out of sale process.

California residents may make a request relating to statutory rights by completing an online form at [email protected] or by phone service +972-3-6919001.

You will be asked to confirm that You are a California resident and in the process of servicing your request We may require You to verify your identity in accordance with the CCPA.  Verification procedures include: providing details of any relevant purchase such as an order number, product purchase, date of purchase, location, contact information, information submitted, etc.

We shall provide an initial response within 10 days. Your request will normally be completed within 45 days.

A request for a copy of personal information can only be made twice in any 12-month period.

We do not respond to “do not track” (DNT) signals transmitted from web browsers and therefore do not alter any of data collection and use practices upon receipt of such a signal.

11. CHANGES TO THIS PRIVACY POLICY

We may change this Privacy Policy from time to time. However, We will not reduce Your rights under this Privacy Notice. We will always update this Privacy Policy on the Website, so please try to read it when You visit the Website (the ‘last updated’ reference tells you when we last updated this Privacy Policy). 

12. SECURITY AND STORAGE OF INFORMATION

We will keep Your information secure by taking appropriate technical and organizational measures against its unauthorized or unlawful processing and against its accidental loss, destruction or damage. We will do our best to protect your personal information but We cannot guarantee the security of your information which is transmitted to the Website via an internet or similar connection. If We have given You (or You have chosen) a password to access certain areas of the Website please keep this password safe – We will not share this password with anyone.

If you believe your account has been compromised, please contact Us at [email protected] . 

13. OTHER SITES AND SOCIAL MEDIA

If You follow a link from our Website to another site or service, this Privacy Policy will no longer apply. We are not responsible for the information handling practices of third party sites or services and We encourage You to read the privacy policies appearing on those sites or services.

The Websites may enable You to share information with social media sites, or use social media sites to create Your account or to connect Your social media account. Those social media sites may automatically provide Us with access to certain personal information retained by them about You (for example any content You have viewed). You should be able to manage your privacy settings from within Your own third party social media account(s) to manage what personal information You enable Us to access from that account.

14. COOKIES, ANALYTICS AND TRAFFIC DATA

Cookies are small text files which are transferred from the Websites and stored on Your device. We use cookies to help Us provide You with a personalized service, and to help make the Website better for You.

Our cookies may be session cookies (temporary cookies that identify and track users within the Website which are deleted when you close your browser or leave your session) or persistent cookies (cookies which enable the Website to “remember” who You are and to remember Your preferences within the Website services and which will stay on Your computer or device after you close your browser or leave your session.

Find out more about the individual cookies  that we use in our Cookies Policy.

How to disable cookies

You may be able to configure your browser or the Website to restrict cookies or block all cookies if You wish, however if You disable cookies You may find this affects your ability to use certain parts of the Website.

For more information about cookies and instructions on how to adjust your browser settings to accept, delete or reject cookies, see the http://www.allaboutcookies.org/ website.

15. FURTHER INFORMATION

If You have any queries about how we treat Your information, the contents of this Privacy Policy, Your rights under local law, how to update your records or how to obtain a copy of the information that We hold about You, please send an email to [email protected]

COOKIES POLICY

Last updated: October 27, 2020

What are cookies?

Cookies are small text files sent by a website to a web browser and contain information that is transferred to your computer’s hard drive. This enables the website to identify and track the web browser. Cookies can, among other functions, enable a website to recognize a device each time it visits, remember user preferences and recommend content.

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a more personalised user experience when you browse our website and also allows us to improve our website. By continuing to browse and use our website, you are agreeing to our use of cookies.

Different cookies do different things and some are essential to the operation of a website, whilst others are not. The different types of cookie are:

• Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website such as your account profile.
• Analytical/performance cookies. These allow us to recognise and count the number of visitors to our website and to track how visitors move around our website when using it.
• Functionality cookies. These are used to recognise you when you return to our website, enabling us to personalise our content for you, greet you by name and remember your preferences.
• Targeting cookies. These cookies record your visits to our website, the pages you have visited and the links you have followed. We will use this information to make our website and to advertising displayed on (to the extent such displayed) it more relevant to your interests. We may also share this information (in anonymised form) with third parties for this purpose.

To the extent that any personal information is collected through our use of cookies, our Privacy Policy which can be found at Privacy Policy will apply to our processing of that personal information.

We use the following ‘strictly necessary’ cookies:

We use the following Analytical/performance cookies

If you would like to contact us about the Website or any of the items on it, please email us to [email protected]