Privacy Notice

StePac’s
Website Privacy Policy

Last Revised: October 27, 2021

StePac L.A. Ltd., and its affiliates (“StePac”, the “Company”, “us”, “our” or “we”) respect the privacy of its website
users (“User(s)” or “you”) and is committed to protect its Users’ personal information. We believe that you have a
right to know our practices regarding the information we may collect and use
about you when you use our website at https://www.stepac.com/ and its subdomains (the “Site”). Please read the following carefully to understand StePac’s
views and practices regarding your personal information and how StePac will
treat it.

Table of
Content

1     Who we are

2    Your acknowledgment of this policy

3    Which information may we collect about Users?

4    How do we collect information about our Users?

5    What are the purposes of the collection and processing of information?

6    Sharing Personal Information with Third Parties

7    Your Rights

8    Location of Your Data

9    Social Features

10 Minors

11    Third Party Service Providers and Third Party Software

12   Cookies

13   Links to Third Party Websites

14   Security

15    Data Retention

16   Changes to the Privacy Policy

17   Have any Questions?

 

1. Who we are

In this policy, references to StePac, or to the “Company”, “we”,
“ours” or “us” are to StePac LA Ltd. and its affiliates, which is a registered
company in the state of Israel, having
its principal office at Tefen Industrial Park, P.O.B. 73, Bldg.12, Western
Galilee, 2495900, Israel. Individuals wishing to
contact us about data protection issues may do so by writing to us at the above
address or by emailing us at [email protected].

2. Your acknowledgment of this policy

This Privacy Policy (“Privacy
Policy
”) details how your Personal Information collected via the Site is
used and processed by StePac.

BY ENTERING, CONNECTING TO, ACCESSING OR USING THE SITE, YOU
ACKNOWLEDGE THAT YOU ARE OR HAVE HAD THE OPPORTUNITY TO BECOME AWARE OF AND
AGREE (IN JURISDICTION WHERE SUCH CONSENT IS REQUIRED) TO THIS PRIVACY POLICY
AND STEPAC’S PRACTICES DESCRIBED THEREIN, INCLUDING THE PROCESSING (INCLUDING
COLLECTING, USING, DISCLOSING, RETAINING OR DISPOSING) OF YOUR INFORMATION
UNDER THE TERMS OF THIS POLICY.

3. Which information may we collect about Users?

We collect from Users of our Site,
two types of data and information:

3.1.
Non-personal Information. The first type is non-identifiable and anonymous information.
Non-personal Information, which is being gathered, consists of technical information and behavioral information that does not pertain to a specific individual (“Non-Personal Information”).

You may access and browse the Site without disclosing personal information, although, like most websites, we passively collect certain Non-Personal Information from your devices, including: (i) technical information such as the type and version of your device and its operating system, the type of browser, screen resolution, device browser and keyboard language, Wi-Fi connectivity and the type and name of your device and/or browser, etc.; and (ii) behavioral information which may include the User’s click-stream on the Site, the activities of the User on the Site and additional information of a similar
nature (collectively, “Technical and Behavioral Information”). We may also use third-party service providers, such as Google Analytics, to obtain detailed analytics on the device and the User’s behavior on the Site. Please note that we or our third-party service providers will collect such Technical and Behavioral Information by using certain tracking technologies, such as cookies, as further detailed below.

3.2.
Personal Information. The other type of information we collect is individually identifiable information. To put it simply, this information identifies an individual or is of a private and/or sensitive nature, such as your contact information (“Personal Information”), including:

3.2.1.  Personal Information which is provided voluntarily:

●     Communications with StePac: Personal Information you provide
us as part of any communications with StePac, by any means, including by contacting
us via the Site or email, approaching our customer services, or during sales
calls or through our social network pages (such information may include
marketing and communication data that includes your preferences in receiving
marketing from us and your communication preferences). Please note that we may
record calls for quality assurance purposes and in order to improve our
services.


Contact Details: Personal Information is collected from the details the Users
provide in the “Contact” tab available on the Site. Such Personal
Information includes your full name and email address. You may provide via the
contact form any text you wish to insert into the “message” box. Additional
information may be requested via the contact form in the future.


Consult
An Expert
: Personal
Information is collected from the details the Users provide in the
“Consult an Expert” tab available on the Site. Such Personal
Information includes your full name, phone number, email address and your
representation (inter alia, grower, packager, trader, retailer).
Additional information may be provided by you voluntarily as p[art of such
consultation.

●     Mailing list: you may voluntarily join our
mailing list by providing us with your full name and email address via our
Site.

3.2.2.  Personal Information collected via technology:

●     Geolocation data: during
your visit to the Site we will access, collect,
process, monitor and/or remotely store “geolocation data”, including
through the collection of IP addresses and other similar information to determine
your location for analytics, advertising  and security purposes. Please note that we may
also analyze your IP address and other similar data, using our third party
service providers, in order to determine the name of the company whose IP
address you have used to browse to our Site, for the purpose of locating
prospects and in order to analyze our Site’s traffic.

●     Technical and Behavioral
Information
: to the extent that the Technical
and Behavioral Information detailed above under Section ‎3.1 will be linked to or associated
with a specific individual then such information will be considered as Personal
Information.

●     Identifiers: such as Internet Protocol (IP)
address, your Unique Device Identifier (UDID), or other unique identifiers for security purposes, analytics and in
order to provide you with targeted advertising of our products and services.

3.2.3.  Information from other sources:

●     We also obtain information from
other sources, which may include, but not limited to, publicly-available sources, information provided by third
parties which helps us determine your location based on your IP address and
data providers, such as Google Analytics, from which we obtain demographic,
interest based and online advertising related data.

3.3.   Please note:

●     We may cross-reference your
Personal Information with other Personal Information we may have about you. Any Non-personal
Information connected or linked to or associated with any Personal Information
shall be deemed as Personal Information as long as such connection, linkage or
association exists.

●     We use third-party tracking
services and usage logs, to track and analyze data from Users of the Site and
for purposes of security and fraud prevention. We may also use cookies to
gather information regarding your use of the Site and the information for which
you searched and accessed (for more information please see below).

4.
How do we collect information about our Users?

There are two main methods we use to collect information:

4.1.
We collect information through your entry, connection, access and/or use of the Site. In other words, when you access or use the Site, we are aware of your usage of the Site, and may gather, collect and record the information relating to such usage. For example, when you use the Site, we gather your Technical and Behavioral Information.

4.2.   We collect information which you provide us voluntarily. For example, we collect Personal Information that you provide via the “Contact” form on our Site. We will inform you prior to collecting your Personal Information if it is requested on a voluntary basis and the consequences of not providing voluntary Personal Information.

4.3.   We collect information from public sources. We may supplement personal information that we collect about you with information which you have made public on websites associated with you or your company or on social media platforms such as Facebook.

5.  What are the purposes of the collection and processing of information?

5.1.  Non-personal Information is processed in order to:

●     Enhance the User’s experience on
the Site;

●    Create statistical information and learn about the preferences of Users and general trends on the Site (e.g. understand which features are more popular than others); and

●     Keep the Site safe and secured against fraudulent and criminal activity.

5.2.  Personal Information is processed in order to:

●     Enable the operation and constant improvement of the Site;

●     Register your interest in our products and services;

●     Contact you by telephone and/or by email with further information relating to our products or services which you enquired about via the Site. To ensure we offer a good and responsive service, we consider this use to be proportionate and will not be prejudicial or detrimental to you;

●     Add your contact details to our mailing list for the purposes of sending you information about our products and services by email, SMS, phone or through web-browser notification. You have the
right to opt-out of marketing messages at any time by following the instructions in such messages or by contacting us at: [email protected] For email marketing to an individual subscriber (that is,
a non-corporate email address) with whom we have not previously engaged as a client, we need your consent to send you unsolicited email marketing;

●     Enable our third-party advertising service providers to present you with StePac’s advertisements on websites and platforms across the Internet and across devices. You may opt-out from such
advertising activities by following the directions detailed below;

●     Personalize your experience on the Site;

●     Ensure that content on the Site is presented in an optimal way for you and for your device (e.g. tablet, mobile phone);

●     Conduct internal operations, such as: troubleshooting, data analysis, testing, research, and statistical analysis;

●     Keep the Site safe and secured against fraudulent and criminal activity;

●     Comply with our legal obligations and provide us with the ability to protect our rights and legitimate interests;

●     Maintain our data processing records and general administrative purposes; and

●    Email tracking – we may use tracking technology within the email
we may send you in order to improve interactions with you and to better
understand whether our emails were opened and read, and such tracking may
include capturing the time and date in which you opened our email messages and
the type of device you use to open such emails.

Note to our Users in the EU:

In order for StePac to process your Personal Information, as detailed herein, such processing must be justified by a “basis” for processing. Please note that the Personal Information processing activities detailed herein may be justified on the basis that:

·     the processing is based on your consent – where you provide us with your consent to contact you for marketing purposes or receive targeted advertising, you will be asked to consent to such activities before we can process such information. If you choose not to give us your consent for such processing activities, or if you decide later to remove your consent, this may affect our ability to provide you with the affected services;

·     the processing is necessary for performance of a contract – generally your Personal Information will be provided to us because you are interested in using the Site in accordance with our terms of
use or in order to receive certain services from StePac. As such, we rely on this basis for processing activities that are required in order to enable you to use the Site, to provide our services and to let you know of changes to our terms of use and privacy policy;

·     the processing is necessary to comply with a legal obligation – we may process your Personal Information for disclosure of information to authorities and to comply with our legal obligations (e.g., paying taxes); and

·     the processing is in our legitimate commercial interests – subject to your interests and fundamental rights, under our legitimate interest in marketing our products and services via the Site and offering the public comfortable and safe access to our Site, we shall perform the Personal Information processing activities described herein, such as the processing of your Personal Information in order to personalize the Site, assisting us to prevent crime and fraud, manage our internal operations, gathering statistics and  for marketing purposes. Where we rely on legitimate interests as a lawful basis, we carry out a balancing test to ensure that your interests, rights and freedoms do not override our legitimate interests.

Note to non-EU Users:

BY ENTERING, CONNECTING TO, ACCESSING OR USING THE SITE, YOU CONSENT TO THE COLLECTION AND PROCESSING OF YOUR PERSONAL INFORMATION AS SPECIFIED HEREIN.

6.    Sharing Personal Information with Third Prties

6.1.   StePac respects your privacy and will not disclose, share, rent, or sell your Personal Information to any third party, other than as permitted under this Privacy Policy.

6.2.   In addition to using the information collected by us for the purposes described under Section 5 above, we may also share your information in the following cases:

●     StePac Personnel: Personal Information that we collect and process may be transferred to or accessed by personnel of StePac for the sole purpose of enabling the operation of the Site and to contact you (as detailed in Section ‎5 above). Please note that all StePac personnel that will have access to your Personal Information are under an obligation of strict confidentiality with respect to such Personal Information.

●     Service Providers: we share Personal Information with vendors, commercial software providers, consultants and data processors who perform services on our behalf, including without limitation, companies that provide analysis, messaging services and services which host the Site. Please
note that we collect, hold and manage your Personal Information through a third party’s cloud based services, as reasonable for business purposes, which may be located in countries outside of your jurisdiction. For more information regarding our Service Providers, please refer to Section ‎11 below.

●     In addition, we may share Personal Information in the following cases: (a) to satisfy any applicable law, regulation, legal process, subpoena or governmental request; (b) to enforce this Privacy Policy or any other agreement or terms of service between you and StePac, and to defend against any claims or demands asserted against us by you or on your behalf; (c) to detect, prevent, or otherwise address fraud, security or technical issues; (d) to protect the rights, property, or personal safety of StePac, its Users or the general public; and (e) when StePac is undergoing any change in control,
including by means of merger, acquisition or purchase of all or substantially all of the assets of StePac (while such acquired company or investor may be located in countries outside of your jurisdiction).

6.3.   For avoidance of doubt, StePac may transfer and disclose Non-personal Information to third parties at its discretion including without limitation for statistical, analytical and research purposes and for customization, developing and improvement of our Site.

7.        Your Rights

StePac acknowledges you have the right to access and change the Personal Information we collect and process. If you wish to access or to correct, amend, or delete Personal Information, please send us an email to: [email protected] and we will respond within a reasonable timeframe, but in any event no later than permitted by applicable law.

Note to our Users in the EU:

We
hereby inform you of the following rights (by virtue of EU law), in respect
of your Personal Information:

·       Right to access: you may have the right to request a review of your Personal Information held by StePac. We may refuse to comply with your access request if the request is manifestly unfounded, excessive or repetitive in nature.

·       Right to rectification: if the Personal Information processed by StePac is incorrect, incomplete or not processed in compliance with applicable law or this Privacy Policy, you may have the right to have your Personal Information rectified.

·       Right to erasure: under certain conditions, you may be entitled to require that StePac will delete or “block” your Personal Information (e.g. if the continued processing of those data is not justified).

·       Right to portability: you may have the right to transfer your Personal Information between data controllers (i.e., to transfer your Personal Information to another entity). The right to data portability only applies where your Personal Information is processed by us with your consent or for the performance of a contract and when processing is carried out by automated means.

·       Right to object to or withdraw consent: where that lawful basis for processing your Personal Information is either “public interest” or “legitimate interests”, those lawful bases are not absolute, and you may have a right to object to such processing. Where you object on grounds of legitimate interest, we shall no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims. If the processing of your Personal Information is based on your consent, you have the right to withdraw your consent to such processing at any time.

·       The right to restrict processing – under certain circumstances, you may have the right to object to the processing of your Personal Information due to your particular situation.

·       Right to lodge a complaint: you have the right to lodge a complaint before the relevant data protection authority or supervisory authority of your jurisdiction.

To exercise these rights, where
applicable, please contact us by sending an email to
: [email protected]

8.   Location of Your Data

The information collected from you by StePac, as detailed in this Privacy Policy, may be transferred to, and stored in, servers which may be located in countries outside of your jurisdiction and in countries that are not considered to offer an adequate level of protection under your local laws. It may also be processed by StePac and its suppliers, service providers or partners’ staff operating outside your country.

StePac is committed to protecting your Personal Information and will take appropriate steps to ensure that your Personal Information is processed and stored securely and in accordance with applicable privacy laws, as detailed in this Privacy Policy. Such steps may include, but not limited to, putting in place data transfer agreements and ensuring our third-party service providers comply with StePac’s data transfer protection measures.

BY SUBMITTING YOUR PERSONAL INFORMATION TO STEPAC, YOU ACKNOWLEDGE, AND AGREE, IN JURISDICTION WHERE SUCH CONSENT IS REQUIRED, TO SUCH TRANSFER, STORING AND/OR PROCESSING OF PERSONAL INFORMATION.

Note to our Users in the EU:

If you are located in the EU, you have a right to request further information regarding the data transfer mechanisms used by us with respect to data transfers to third countries.

In order to keep your Personal Information safe, we apply strict safeguards when transferring it outside of the EEA, which may include the following:

·     Transferring your personal information to countries approved by the European Commission as having adequate data protection laws, such as Israel; and

·     Entering into standard contracts, that have been approved by the European Commission and which provide an adequate level of high-quality protection, with the recipients of your Personal Information.

 

9.   Social Features

Our Site may include social media features, such as Facebook, Instagram, Twitter, LinkedIn and YouTube links (“Social Features”). The Social Features are operated or allow for social integration with certain third party social networks or third party Sites (“Social Network“). These Social Networks are created and maintained by third parties who are not affiliated with and/or controlled by StePac. If you enable this integration with such Social Networks, your use of the Social Features is subject to the applicable third party Social Network’s terms of use and privacy policies. You should ensure that you read their terms of use and
privacy policies to understand how they treat your information and in order to understand the methods for changing the privacy or sharing settings on such services. If you do not agree to the practices described in such terms you should not allow the Site to interact with such Social Networks, however you may find that you are not able to enjoy all the features that may be made available via the Site. You understand that where you allow interaction with any third party Social Network, we may share data about you with your contacts
(and vice versa) in order that you may enjoy social elements. This data may include, inter alia, your name and your social media profile picture. By using the Social Features, you hereby agree and understand that the applicable Social Networks may collect certain Personal Information, such as your IP address, Non-personal Information and may set cookies and/or other web tracking technologies to enable the functionality of the Social Features. The use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the third party that provides the Social Features. You hereby
understand and agree that when you share content from Social Networks, your content may become public and others may re-post-it.

10.   Minors

The Site is intended for Users over the age of sixteen (16). Therefore, StePac does not intend and does not knowingly directly collect any Personal Information from children under the age of sixteen (16) and does not
wish to do so. We reserve the right to request proof of age at any stage so that we can verify that minors under the age of sixteen (16) are not using the Site.

11.   Third Party Service Providers

11.1.    During your visit to our Site, we may use third party service providers, who may collect, store and/or process your information, as detailed in this Privacy Policy.

11.2.    Please read such third party service providers’ terms of use and privacy policies to understand their privacy practices.

11.3.    Note, that we collect, hold and/or manage your Personal Information through StePac’s authorized third party vendors of certain products or services (such as hosting cloud services) (including, as applicable, their affiliates) solely and limited to providing us with such requested services, and not for any other purposes.

11.4.    Such vendors may be located in countries that do not have the same data protection laws as the laws applied in your jurisdiction.

11.5.    Such third parties service
providers may include without limitation the following categories of service
providers:

● Web development, lead management and marketing management (such as FocusWeb www.focusweb.co.il)

●       Lead management service providers (such as UpiCRM https://www.upicrm.com/).

●Marketing automation and related services (such as Active Campaign https://www.activecampaign.com/).

12.     Cookies and Tracking Technologies

12.1.    When you access or use the Site, we and/or our third party service providers may use industry-wide technologies such as cookies, web beacons, pixels, clear gifs and other similar tools (or other similar technologies) (collectively, “Cookies“) which may enable us, amongst others, to recognize your device from those of other Users of the Site, to improve the Site’s performance, to deliver a better and more personalized service according to our Users’ individual interests and the device or browser used, to track Users’ use of the Site, to gather information about the Users’ approximate geographic location (e.g. city), to prevent fraud and/or abuse, to estimate our audience size and usage pattern and perform other analytics, to develop our Site and to serve targeted advertisements.

12.2.    Cookies may locally store certain Technical and Behavioral information and other Personal Information on your device and we and/or our authorized third party service providers may access such information for the purposes detailed under this Privacy Policy. We and/or our authorized third party service providers may use both session Cookies (which expire once you close the web-browser) and persistent Cookies (which stay on the User’s device until he/she deletes them).

12.3.    Most devices and browsers will allow you to erase Cookies from your device’s hard drive, block acceptance of Cookies, or receive a warning before a Cookie is stored on your device. However, if you block or erase Cookies, your experience of the Site may be limited.

12.4.    For detailed instructions regarding the blocking of Cookies, please refer to your browser’s ‘help’, ‘tool’ or ‘edit’ sections or see http://www.allaboutcookies.org/manage-cookies/. Below are links to instructions regarding the blocking of Cookies on commonly used web-browsers: Chrome, Internet Explorer and Microsoft Edge, Mozilla Firefox and Safari.

12.5.    It is possible to opt-out of having your browsing activity within the Site recorded by performance cookies. Please note that we use Google Analytics as our service provider in order to track Users’ activities on the Site, including by use such services’ persistent cookies. Google provides a browser-add on which allows users to opt-out of Google Analytics across all websites, which can be downloaded here: https://tools.google.com/dlpage/gaoptout.

12.6.    You can opt out of receiving interest-based advertising on your device by visiting the following sites: www.aboutads.info/choices/,www.networkadvertising.org/choices/,choices.ghosteryenterprise.com/global-opt-out.html, and preferences-mgr.truste.com/. If you wish to opt out of receiving interest-based advertising on your mobile device, please see the advertising preferences information on support.apple.com for iOS devices or support.google.com  for Android devices.

13.  Links to Third Party Websites

The Site may contain certain links permit Users to leave our Site
and enter non-StePac sites or services. Most of such linked sites and services
provide legal documents, including terms of use and Privacy Policy governing
the use thereof. It is always advisable to read such documents carefully before
using those sites and services, inter alia,
in order to know what kind of information about you is being collected.

14.  Security

14.1.    We take reasonable measures to maintain the security and integrity of our Site and prevent unauthorized access to it or use thereof through generally accepted industry standard technologies
and internal procedures.

14.2.    Your Personal Information is hosted on third party servers, which provide advanced strict security standards (both physical and logical).

14.3.    Some of the security measures that we employ include, without limitation: the application of highly secure design and implementation methods to all our Services, including state of the art encryption mechanisms and secure architecture design to all storage and transmission mechanisms used for the processing and transmission of your Personal Information, as well as access control and auditing systems (including firewall and identity management solutions), that restrict access to your Personal Information to authorized personnel only, based on their roles and their need-to-know requirements, needed to process your Personal Information on StePac’s behalf.

14.4.    Please note, however, that there are inherent risks in transmission of information over the Internet or other methods of electronic storage and we cannot guarantee that unauthorized access or use will never occur.

14.5.    StePac will comply with applicable law in the event of any breach of the security, confidentiality, or integrity of your Personal Information and will inform you of such breach as required by applicable law.

14.6.    TO THE EXTENT THAT STEPAC IMPLEMENTED THE REQUIRED SECURITY MEASURES UNDER APPLICABLE LAW, STEPAC SHALL NOT BE RESPONSIBLE OR LIABLE FOR UNAUTHORIZED ACCESS, HACKING, OR OTHER SECURITY INTRUSIONS OR FAILURE TO STORE OR THE THEFT, DELETION, CORRUPTION, DESTRUCTION, DAMAGE, OR LOSS OF ANY DATA OR INFORMATION INCLUDED IN THE
PERSONAL INFORMATION.

15.  Data Retention

StePac will retain the Personal Information for as long as we are confident that it is accurate and can be relied upon. Personal Information which is no longer required for the purpose for which it was initially collected will be deleted unless we have a valid justification to retain it which is permitted under applicable law, such as to resolve disputes or comply with our legal obligations.

16.  Changes to the Privacy Policy

StePac reserves the right to change this Privacy Policy at any time, so please re-visit this page frequently to check for any changes. In case of any material change, we will make reasonable efforts to post a clear notice
on the Site or we will send you an e-mail regarding such changes to the e-mail address that you may have provided us with. Such material changes will take effect seven (7) days after such notice was provided on our Site or sent to you via e-mail, whichever is the earlier. Otherwise, all other changes to this Privacy Policy are effective as of the stated “Last Revised” and your continued use of the Site on or after the Last Revised date will constitute acceptance of, and agreement to be bound by, those changes. In the event that the terms
should be amended to comply with any legal requirements, the amendments may take effect immediately, or as required by the law and without any prior notice.

17.  Have any Questions?

If you have any questions (or comments) concerning this Privacy Policy, please send us an email to the following address: [email protected], and we will make an effort to reply within a reasonable timeframe.

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