PRIVACY POLICY

Last modified on 17 March 2024

General

Your privacy as a user of the Numa NGT Ltd. and its subsidiaries (together the "Company" or “We”) website, any applications and/or platforms (the “Services”), as a contact person of an active customer of the Company or as a subscriber who elected to receive marketing or other materials is important to us. Therefore, we operate by these principles, which are incorporated by reference into the Services’ Terms of Use (the “Terms”). We have created this Privacy Policy in order to inform you of the type of information We may collect and how We may use it.

If you are a resident of the European Union or the European Economic Area, please refer to the section marked “Additional Information for European Residents” at the end of this policy for further information about our compliance with the EU General Data Protection Regulation 2016/679 (“GDPR”).

[California residents, other US. Other regional]

If you do not agree with any of the terms in this Privacy Policy, please contact us for further information.

What information do we collect?

We collect information from you when you browse or register (if the possibility of registering to the Services is offered by the Company now or in the future) on our Services, create a new account, provide us with information via a web form, add or update information in your account, participate in online discussions or otherwise interact with us, subscribe to download or upload any materials, post on the Services or use the Services in any manner.

When browsing and/or using our Services anonymously, we collect non-personal and anonymous information (the “Non-Personal Information”). Non-Personal Information which is being gathered consists of technical information and behavioral information, including, but not limited to, your operating system, type of browser, your “clickstream” on the site, the period of time you visited the Services, etc.

When registering on, filling out a form, using, posting, uploading, or downloading certain materials from the Services you may be asked to enter your: name, e-mail address, mailing address, phone number, your company information, possible future purchase intent, payment related details and other personally identifiable information which We have identified as pertinent to assisting the Company in product development and marketing and in personalizing the Services user experience (the “Personal Information”). It is hereby clarified that you have no legal obligation to share any Personal Information with the Company and you hereby agree and acknowledge that you are doing so willingly and voluntarily and as mentioned above. It is hereby clarified that you may use the Services anonymously, but certain features requiring registration (such as posting, use of marketplace, downloading content, electing to receive newsletters or other marketing materials, etc.) shall not be available. You hereby also agree and acknowledge that We may keep Personal Information in databases which will be kept and operated in accordance with all applicable laws and regulations. We will not collect any Personal Information from you without your consent, which is obtained, inter alia, through your acceptance of the Terms and this Privacy Policy.

It should be noted that due to the social network and interactive nature of the Services, it is possible that you, or others, may post your Personal Information within the interactive portions of the Services (outside of the fields which we have provided for such Personal Information). The information posted in such a way cannot be deemed ‘collected’ by us for the purposes of this Privacy Policy, as We will not be aware that the applicable post contains personal information, and as such the information may not be protected by the safeguards generally put in place by us for personal information which you elect to share through the Services (such as your ability to make personal information public or private or to share it only within limited defined circles, or to easily request its correction or removal). As a result, we strongly advise you not to share, or consent to the sharing of, your own personal information other than through the designated fields, and We forbid you from sharing the personal information of any third party without that third party’s consent. To request the correction or removal of any personal information posted outside of the designated fields please contact us (as provided below) or the applicable post publisher with full and complete details of the personal information posted and its exact location.

Other users have access to the information you share on Services or disclose to other users. For example, other users can see your items for sale, feedback, ratings, reviews, and associated comments. Other users can also see any information you choose to share in your profile and account. When you use our Services, your public username may be displayed and available to the public and associated with all of your public activity. Accordingly, if you use a username that allows others to identify you, these others may be able to identify your activities on the Services.

To help protect your personal data, we allow only limited access to other users' contact, as necessary to facilitate your transactions and collect payments. However, when users are involved in a transaction, they have access to each other's name, username, (alias) email address, and other contact and shipping information. As provided herein, we request that any personal data exchanged between parties to a transaction will be directly among them and/or via the Third-Party Service facilitating the transaction. You are not allowed to share any such personal data with us. We are not responsible in any manner for the use of personal data shared by users with other users.

Please note if you are a resident of the European Union or the European Economic Area, the content as set out in this section does not apply and you should refer instead to the section “Categories of Personal Information & Legal Basis” as set out in the “Additional Information for European Residents” addendum at the end of this Privacy Policy for information on what Personal Information is processed and on what legal basis.

If you buy something on or via our Services or make any payment, we may collect payment information, contact information (address and phone number), delivery details and details of what you bought, and any other information required to enable you to access and use the payment services. This information will be used, among other things, by the payment processing party to:

Process and fulfill your order via third-party services such as PayPal, Stripe, shipping companies, or others.
Detect and prevent fraud, abuse, security incidents, and other harmful activity.
Conduct security investigations and risk assessments.
Conduct checks against databases and other information sources.
Comply with legal obligations (such as anti-money laundering regulations).
Enforce the payment terms and other payment policies.
With your consent, send you promotional messages, marketing, advertising, and other information that may be of interest to you based on your preferences.
Comply with any "know your client" and/or anti-money laundering procedures as applied by our Third-Party Services.

The third-party services process this information given its legitimate interest in improving the payment services and its users’ experience with it, and where it is necessary for the adequate performance of the contract with you and to comply with applicable laws.

We may also collect personal data from other sources (such as other third parties and/or data providers).

What do We use your information for?

We may collect and process your personal data for various purposes and based on several different legal bases that allow this processing. Your name and Personal Information will be used to facilitate communication (including privately and through communities), collaboration (including through work groups), and networking, through the Services.

Information that you voluntarily elect to provide us (whether in profile or business fields, through posts or otherwise in your interactions through the Services) may, pursuant to your selections be visible to certain other members or communities through the Services however we will not use or process your personal information in any way without your express consent except as required for the express purpose of facilitating the collaborative “social network of knowledge” through the Services.

Further, any of the information we receive or collect from you may be used for the following purposes:

Personalize your experience (your information helps us to better respond to your individual needs and present you with more relevant information).
Improve the Services (we continually strive to improve the Services features based on the information and feedback we receive from you).
Provide the Services, including interaction with other users or with us (including as potential buyers of items posted for sale).
Administer a contest, promotion, survey, or other Services feature.
Send periodic emails (information and updates including company news and product developments, reports, invitations, suggestions of interest, and other marketing materials).
Conduct sales and service-related communications (personal emails and phone calls, invitations, etc.).
Provide technical assistance, answer questions or provide specific information, as requested.
Improving the performance and operation of our products and innovating new products, features, solutions, services, and support, including warranty support and timely software updates, bug fixes, and alerts to ensure the continued operation of the device or service.
Administrative communications which may include responses to your inquiries or requests, service completion or warranty-related communications, communications required by law, or applicable corporate updates related to mergers, acquisitions, or divestitures.
Research and analysis, including of markets and fields, including via compiling information and creating a database of non–personal information.
Maintaining the integrity and security of our Services, products, and features and preventing and detecting security threats, fraud, or other criminal or malicious activity that might compromise your Personal Information; and
Conducting ordinary business operations, verifying your identity, conducting business research and analytics, corporate reporting, and for quality assurance purposes (which may include monitoring or recording calls to our customer support).

Direct Marketing

By registering to the Services, subscribing to our newsletter, downloading and/or uploading materials from or to the Services, responding to a survey, filling out a form on the Services, or otherwise providing us with your details, you agree that we may use your contact information for informing you regarding our products and services and send you marketing materials. We may customize such marketing materials to be suitable for your interests and needs.

Unsubscribing and Deletion from Our Databases

Your personal data will be stored by us and our service providers in accordance with applicable data protection laws to the extent necessary for the processing purposes set out herein. Subsequently, We will delete your personal data in accordance with our data retention and deletion policy or take steps to properly render the data anonymous, unless We are legally obliged or permitted to keep your personal data longer (e.g. for legal compliance, tax, accounting or auditing purposes, or to detect and prevent fraudulent or illegal activity). You may withdraw your consent at any time by clicking the unsubscribe link which appears at the end of every communication sent to your email. Kindly note that if you are a contact person of one of our active customers’ accounts, if you elect to unsubscribe unless you specifically request, we will still continue to send you valuable business and operational communications and if relevant, service-related communications, including as part of our contractual obligations. You may ask to be deleted from our database via e-mail or mail (see “contacting us” section below). We will make reasonable efforts to delete your Personal Information within 7 (seven) days. The actual customer account records will not be deleted, unless we receive a request by the authorized principal account person.

How do We protect your Personal information?

We implement a variety of security measures to maintain the safety of your personal information when you enter, submit, or access your personal information.

These security measures include physical, electronic, and procedural measures. Among other things, we offer HTTPS secure access to all applicable areas of the Services. We use network security services and data encryption, for example, as well as physical access restrictions for our data centers and logical access controls for data and systems access. We also regularly monitor our systems for possible vulnerabilities and attacks, and we will promptly notify our users upon learning of any data breach. We also regularly seek new ways and third-party services for further enhancing the security of the Services and the protection of our users’ privacy. It is important to note though that, despite our greatest efforts, no security measures are completely fool-proof. We therefore encourage you to avoid providing us with any sensitive information which you believe its disclosure could cause you substantial or irreparable harm. Furthermore, because certain areas of the Services (public and community pages for example) might be more public and less secure than others, and since e-mail and instant messaging are not recognized as secure forms of communication, we request and encourage you not to share any such sensitive information on any such areas or via any such methods.

We are not processing or facilitating any transactions between users (including any sale or purchase of items posted on the Services). Such transactions are conducted directly between buyers and sellers via a Third-Party Service, such as PayPal, and are subject to the policies and procedures thereof (including, without limitation, "know your client", Anti Money Laundering, and others). We are not exposed to any personal data involved or disclosed during such transaction and are not responsible or liable in connection therewith. Transmission of sensitive payment information (such as a credit card number) is handled through recognized secure payment handlers (such as PayPal) who only provide us with an anonymous ‘token’ indicating a payment made, which is then associated with your account. We will never request that you directly provide us with any sensitive payment information, and we will never receive or retain any such information, except as required for payment via our Billing Agent (such as PayPal).

To ensure the secure storage of your personal information, all of the information used in connection with the Services is retained using state-of-the-art secure cloud storage facilities which employ industry-standard security measures including the ones listed on their sites.

In the event of a data breach that is likely to result in a risk to your rights and freedoms, we will send a notice within 72 hours of first having become aware of such breach.

If you know or have reason to believe that your account credentials or Personal Information stored with us have been lost, stolen, misappropriated, or otherwise compromised, or in case of any actual or suspected unauthorized use of your account, please contact us following the instructions herein.

For how long do we keep your Personal Information?

We will retain your Personal Information for so long as it is necessary in order to fulfill the purposes described in this Privacy Policy, but not more than a period of 6 months after your last communication with us unless you have subscribed or otherwise consented to receive from us marketing information or you are a contact person of an active account, in which case your Personal Information will be held for as long as you are subscribed to our marketing information or have an active registered account with us, subject to the following exceptions:

The law or other regulations of governmental authorities require us to hold your Personal Information for a longer period, or delete it sooner;
You exercise your right to have your Personal Information erased and we do not need to hold it in connection with any of the reasons permitted or required under the law; or
We bring or defend a legal claim or other proceedings during the period we retain your Personal Information, in which case we will retain your Personal Information until those proceedings have concluded and no further appeals are possible.

Please note that your posts on public, community, and other member pages will not be deleted when you terminate your registration with us. Since, as explained above, personal information you elect to share within the interactive portions of the Services (outside of the fields which we have provided for such personal information) cannot be identified by us as personal information, such personal information may remain following your termination. To request removal of any such personal information posted outside of the designated fields please contact us with full and complete details of the personal information posted and its exact location.

Do we use cookies?

We currently do not use cookies (Cookies are small files that a site or its service provider transfers to your device's hard drive through your Web browser (if you allow) that enable the site's or service provider's systems to recognize your browser and capture and remember certain information).

We may embed content from other sites such as YouTube (videos) and social media sites such as Facebook, LinkedIn and Twitter. We have no control over whether embedded content sets a cookie on your browser or not, and you may find information on third-party cookies and similar technologies and how to prevent or disable such on designated sites and/or on the applicable third-party site or platform. You are also free to disable the use of cookies and similar technologies if this is supported by your device. You can manage your cookie settings in your browser or device settings.

Do we disclose any information to outside parties?

We do not generally transfer Personal Information to third parties however we may disclose it in the following circumstances:

We may work with other professionals and providers in providing and delivering our services to you - this may include a server provider, payment processor, or marketing software provider.
We may disclose information to our group or affiliated companies.
If we are sub-contracting services to a third party we may provide information to that third party in order to provide the relevant services to you.
If we are under a duty to disclose or share your Personal Information in order to comply with any legal obligation (for example, if required to do so by a court order or for the purposes of prevention of fraud or other crime).
In order to enforce any terms and conditions or agreements for our Services that may apply.
As part of the sale of some or all of our business and assets to any third party or as part of any business restructuring or reorganization, we will take steps with the aim of ensuring that your privacy rights continue to be protected.
To protect our rights, property, and safety, or the rights, property, and safety of our users or other third parties. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Without limiting the foregoing, we may share Information with selected service providers, whose services and solutions complement, facilitate, and enhance our own. These include hosting and server co-location services, communications and content delivery networks (CDNs), data and cyber security services, billing and payment processing services, domain name registrars, fraud detection and prevention services, web analytics, e-mail distribution and monitoring services, session recording and remote access services, performance measurement data optimization and marketing services, content providers, and our legal and financial advisors (collectively, “Third Party Service(s)”). Such Third-Party Services may receive or otherwise have access to our users’ information, in its entirety or in part – depending on each of their particular roles and purposes in facilitating and enhancing our services and business, and may only use it for such purposes. We are not responsible for such websites or services’ privacy practices and encourage you to be aware when you leave our services and read the privacy statements of each and every website and service you visit. This Privacy Policy does not apply to such linked third-party websites and services.

If we do supply your Personal Information to a third-party, we will take steps to ensure that your privacy rights are protected.

Rights as Data Subject

You may exercise your rights as a data subject (as detailed herein) via our contact provided herein.

Where We rely on consent you can withdraw your consent to the processing of your personal data by us at any time. As a result, we may no longer process your personal data based on this consent in the future. The withdrawal of consent has no effect on the lawfulness of processing based on consent before its withdrawal.
You have the right to obtain access to your personal data that is being processed by us. In particular, you may request information on the purposes of the processing, the categories of personal data concerned, the categories of recipients to whom the personal data have been or will be disclosed, where possible the envisaged period for which the personal data will be stored or the criteria used to determine that period, the existence of the right to request rectification or erasure of personal data or restriction of processing of personal data or to object to such processing, the right to lodge a complaint with a supervisory authority, any available information as to the personal data's source (where they are not collected from you), the existence of automated decision-making, including profiling and, where appropriate, meaningful information on its details. Your right to access shall not adversely affect the rights and freedoms of others. Your right to access may be limited by national law.
You have the right to obtain from us without undue delay the rectification of inaccurate personal data concerning you. Taking into account the purposes of the processing, you have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
You have the right to obtain from us the erasure of personal data concerning you under certain conditions (e.g. when the personal data are no longer necessary in relation to the purposes for which they were processed or when they are no longer required for overriding legitimate grounds, such as the detection/prevention of fraud), unless processing is necessary for exercising the right of freedom of expression and information, for compliance with a legal obligation, for reasons of public interest or for the establishment, exercise or defense of legal claims. The right to erasure may be limited by national law.
You have the right to obtain from us the restriction of processing your personal data to the extent that
the accuracy of the data is disputed by you,
the processing is unlawful, but you oppose the erasure of the personal data,
we no longer need the data, but you need it to assert, exercise, or defend legal claims or
you have objected to the processing.
You have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used, and machine-readable format and have the right to transmit those data to another controller ("right to data portability").
You have the right to lodge a complaint with a supervisory authority.

If your personal data is processed on the basis of our legitimate interests, you have the right to object to the processing of your personal data on grounds relating to your particular situation. This also applies to profiling. If your personal data is processed by us for direct marketing purposes, you have the right to object at any time to the processing of your personal data for such marketing, which includes profiling to the extent that it is related to such direct marketing.

Use of Artificial Intelligence or AI-Powered Tools

We may use artificial intelligence or AI-powered tools and products to improve our Services, to offer you new or enhanced features, a customized and personalized experience, to provide you with enhanced customer service, and to support fraud detection.

Use of Non-Personal Data

By posting or uploading any non-personal data to the Services, you consent to our use of such data for research, statistical, and/or any other purpose designated to improve our services and to retain such data.

Children's Privacy

Our services are not intended for the use by children. We do not knowingly collect personal data from users who are considered children under applicable national laws. Under our Terms of Use, children are not permitted to use our Services.

Terms and Conditions

Please also visit our Terms of Use section establishing the use, disclaimers, and limitations of liability governing the use of our Services, at https://ngtnuma.com/terms-conditions.

Request for Information, Modification, or Deletion of Personal Information

You may request information regarding your Personal Information collected by us, its storage, and the change or deletion of such data, by sending us a written request via email or mail (see “Contacting us” section below). We will make reasonable efforts to respond to your request within 7 days and subject to any applicable law.

Changes to the Company’s Privacy Policy

The Company reserves the right to update this Privacy Policy at any time. If we decide to do so, we will provide a notice on the Services and/or update the Privacy Policy modification date above.

Contacting Us

For further questions or requests (including requests to receive a copy of any Personal Information that we hold about you) regarding this Privacy Policy, you may contact the Company using the information below.

Email: contact@numangt.com

Phone: +972 - 54-954-3655

ADDITIONAL INFORMATION FOR EUROPEAN RESIDENTS

We are in compliance with the requirements of the EU General Data Protection Regulation 2016/679 (“GDPR”) and other applicable data protection legislation. Accordingly, if you are a resident of the European Union or the European Economic Area, then the following paragraphs will apply in addition to the content set out above.

Legal Basis

Below we have set out the categories of personal data we may collect from you (“Personal Information”) and the legal basis we rely on to process the data:

Contact information if, whether as an existing or prospective customer, you register an account with us, download materials from our Services, post and/or use our Services in any manner, respond to a survey, subscribe to our newsletter or other materials, or if we otherwise collect information from you. Contact information may include your name, surname, email address, and telephone number (“Contact Information”).
If you subscribe to our newsletter or other materials, we will process your Personal Information on the basis that you have consented to this and will only send such materials to you for as long as you continue to consent.

Otherwise, we will process your Personal Information on the basis of performing our contract with you or on the basis of our legitimate interest in providing our services to you.

A record of any correspondence or communication between you and us.

We process this information on the basis of the performance of our contract with you or on the basis of our legitimate interest in providing our services to you.

The information which we hold when you order or otherwise subscribe to our Services. Such information includes Contact Information, Financial Information, and address details for the delivery and collection of the services (“Order Information”).

We process Order Information on the basis of performing our contract with you or on the basis of our legitimate interest in providing our services to you.

Financial information which we hold in the context of providing services to you (“Financial Information”) such as billing and banking details.

We process this information when we provide services to you on the basis of the performance of our contract with you or on the basis of our legitimate interest in providing our services to you.

Marketing information. We may hold information about you in order to provide information about our services. This may include names, email addresses, phone numbers, addresses, and other information.

We process this information on the basis of our legitimate interest in communicating with you about our services or on the basis that you have consented to receive the information.

We generally collect information from you directly however in certain circumstances, we may also collect it from a third party. If we do obtain your Personal Information from a third party your privacy rights under this notice are not affected and you are still able to exercise the rights contained within this privacy notice.

Privacy Rights

With respect to your personal data, you have:

The right to be informed - a right to know about our Personal Information protection and processing activities, details of which are contained in this notice
The right to access - the right to request a copy of any Personal Information that we have about you
The right to rectification - the right to request a correction of any errors in or update of the Personal Information that we have about you
The right to erasure (the ‘right to be forgotten’) - the right to request that your Personal Information is deleted from our records
The right to restrict processing - the right to request that we no longer process your Personal Information in certain ways, whilst not requiring us to delete the same data
The right to object to processing - the right to request that your Personal Information will not be processed
The right to data portability - the right to request that your Personal Information be transferred or exported to another organization
The right to withdraw consent - the right to withdraw any permission you have given us to process your personal data
Rights in relation to automated decision-making and profiling-
The right not to be subject to automated decision-making (including profiling) when those decisions have a legal (or similarly significant effect) on you
The right to request that your Personal Information will not be used to contact you for direct marketing purposes

All requests or notifications in respect of your above rights may be sent to us in writing at the contact details listed above. We will endeavor to comply with such requests as soon as possible but in any event we will comply within one month of receipt (unless a longer period of time to respond is reasonable by virtue of the complexity or number of your requests).

Data Breaches

If the Personal Information we hold about you is subject to a breach or unauthorized disclosure or access, we will report this to our data protection manager or officer (if an officer has been appointed) and the applicable authorities (as necessary).

If a breach is likely to result in a risk to your data rights and freedoms, we will notify you as soon as possible.

Data Transfers

Please refer to the section “Do we disclose any information to outside parties?” as set out above for details as to which third parties your Personal Information may be disclosed to.

In addition to this, and as part of the services offered to you, the information you provide to us will be transferred to, and stored in, countries outside of the European Economic Area (referred to as the "EEA").

By way of example, this may happen if:

Some of our data processors (including for instance server providers of third-party providers) are from time to time located in a country outside of the EEA.
If you use our services while you are outside the EEA, your information may be transferred outside the EEA in order to provide you with our services or communicate with you.
We may communicate with individuals or organizations outside of the EEA in providing our services to you. Those communications may include Personal Information (such as contact information).
From time to time your information may be stored in devices which are used by our staff outside of the EEA (but staff will be subject to our cyber-security policies).

If we transfer your information outside of the EEA, and the third country or international organization in question has not been deemed by the EU Commission to have adequate data protection laws, we will provide appropriate safeguards and we will be responsible for ensuring your privacy rights continue to be protected as outlined in this Privacy Policy.

Retention Periods

Please refer to the section “For how long do we keep your Personal Information?” as set out above for details.

In addition to the above, the retention periods stated can be prolonged or shortened as may be required (for example, in the event that legal proceedings apply to the data or if there is an ongoing investigation into the data).

We review the Personal Information (and the categories of personal data) we are holding on a regular basis to ensure the data, we are holding is still relevant to our business and is accurate. If we discover that certain data we are holding is no longer necessary or accurate, we will take reasonable steps to correct or delete this data as may be required.