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
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
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
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?
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.
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:
3.2.2. Personal Information collected via technology:
3.2.3. Information from other sources:
3.3. Please note:
How do we collect information about our Users?
There are two main methods we use to collect information:
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:
5.2. Personal Information is processed in order to:
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
· 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
6.2. 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:
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:
· 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 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
8. Location of Your Data
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
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.
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
11.3. 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
● 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/).
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.
12.3. 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
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.
14.1. 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
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.
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?
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