Privacy Policy of CRYPTOC Financial Solutions Ltd.
Last updated: [update date to be completed before publication]
CRYPTOC Financial Solutions Ltd. (hereinafter "we" or "the company") respects the privacy of users of the site available at tinq.co.il and/or the services it provides (hereinafter: "users" or "you"), and is committed to protecting the personal information users share with the company. We believe our users have the full right to know our policies and procedures regarding the collection and use of information we receive when they use the site and/or services.
Terms appearing in this privacy policy (hereinafter: the "Privacy Policy") shall have the meaning ascribed to them in the Terms of Use, available at https://tinq.co.il/terms (hereinafter: "the Terms of Use") unless expressly stated otherwise in this Privacy Policy.
The terms are phrased in the masculine form for convenience only, and of course also apply to women.
1. Consent
Please read carefully: by entering and logging into the site and/or by using the site and/or services and/or by opening an account (as this term is defined in the Terms of Use), you express your consent to the terms appearing in this Privacy Policy, including your consent to the collection of your personal information (as defined below) and its processing. If you do not agree to any of the terms detailed below, you are obligated to immediately refrain from entering or logging into the site or accessing it; you may not make any use whatsoever of the site and/or services.
Please note: use of the site and services is intended for users over the age of 18 only. If you are not over 18, you may not use the site and/or services.
2. What Information May We Collect About Our Users?
The company collects two types of information:
- The first type of information the company collects is anonymous, non-identifying information (hereinafter: "non-personal information"): the company is not aware of the identity of the user from whom it collected non-personal information. Non-personal information is any visible information available to the company while the user uses the site and/or services, that does not allow their identification.
Non-personal information collected by the company via Google Analytics includes anonymous, technical information and information about user behavior, and may include, among other things, the identity of the user's operating system and browser, screen resolution, visits to certain pages via Facebook Pixel, keyboard language and other connectivity data.
This information is processed by the company anonymously and in aggregate.
- The second type of information the company collects about users via "Contact Us" and "Newsletter" forms is personal identifying information (hereinafter: "personal information"): personal information allows the company to personally identify the user or is of a private or sensitive nature.
- Site users automatically provide their IP address, based on the network they use. This information is collected to improve the user experience, for security purposes, and for Google systems.
- As part of the account opening and Newsletter registration process (at https://tinq.co.il/login.html) the user is required to provide the company with the following details: full name, ID number, phone number, password, and email address.
- In addition, we will collect personal information provided by you knowingly and voluntarily, during use of the site and/or services, for example personal information provided by you included in user content in accordance with the terms.
- To the extent the user is required to pay for the services or part of them via clearing service providers (as defined below), the user will be required to provide the clearing service provider with certain personal information (such as credit card number, etc.) (see Section 9 below for more information on this matter).
Please note: we will not collect personal information about you without obtaining your consent, which is given, among other things, as part of your acceptance of the terms.
You are not legally obligated to provide personal information. You hereby agree and declare that the personal information you provide us is given of your own free will, so that we can provide you with the services, and accordingly you agree that we will store the information you provided us in a database that may be registered, in accordance with legal requirements.
For the avoidance of doubt, any non-personal information connected or linked to personal information shall be considered personal information, as long as this connection exists.
3. How Do We Collect Information About Our Users?
- How do we collect "non-personal information"?
- When you visit or use the site and/or services, we are aware of the use and may collect and document information related to such use, either independently or through receiving services from third parties that are certified service providers, as detailed below.
- How do we collect "personal information"?
- We collect personal information you voluntarily shared with the company as detailed above.
- In the process of opening a user account and registering for the Newsletter, the user is required to provide various information details that may include personal information as detailed above.
A user's personal information provided to us knowingly and voluntarily is retained by us for the purposes detailed below. We may collect and store this personal information, both independently and through third parties approved by us, as detailed below.
4. Purposes of Information Collection and Use
- What use is made of "non-personal information": the company may use non-personal information to: (i) use it for statistical, analytical and research purposes, and for adapting, developing and improving the company's and site's services; (ii) provide the services to users and enable the development of related services in the future; (iii) develop and improve the company's services by upgrading the user experience; (iv) collect aggregate business information for various commercial purposes; and (v) collect statistical information for advertising purposes, and even provide advertising content that may interest users.
- What use is made of "Personal Information": The Company may use Personal Information in order to: (i) provide the Services to the User, tailor them to the User's specific needs and enable the development of related services in the future; (ii) respond to the User's questions about use of the Website and/or the Services and provide technical support services; (iii) customize, develop and improve the Company's services, including the Website and the Services; (iv) make various payments for the Services via clearing service providers (as detailed below); and (v) verify the User's identity when logging into the Services, and identify the User in cases of inappropriate or unlawful conduct reported within the Services.
5. Sharing Personal Information with Third Parties
The company may disclose personal information only in the following cases: (a) to comply with any legal requirements, for legal proceedings, orders, including discovery orders or a government authority's request; (b) to enforce this Privacy Policy or the company's Terms of Use, including in the context of investigating possible violations of the Privacy Policy or Terms of Use; (c) to detect, prevent or otherwise address fraud, deception, security and safety issues, and technical problems; (d) to respond to user support requests; (e) to respond to a claim, demand or allegation that content appearing on the site and/or services and their use was done without authorization and/or infringes third-party rights; (f) to respond to claims, demands or allegations that a third party's contact information (e.g., name, address, email address, etc.) was published or transferred without their consent or in a manner constituting harassment; (g) to protect the rights, property, or personal safety of the company, its users, or the general public; (h) in the event of a change of control of the company, including through merger, acquisition, or acquisition of all or substantially all of its assets; (i) to collect, hold and/or manage users' personal information through third parties providing services to the company (including their related parties as required to provide the services), as required by the company's business and operational needs, where these third parties may be located in a country where data protection and privacy laws differ from those applicable in your territory; (j) collaboration with third parties for the purpose of improving user experience; (k) to enable payments through clearing service providers (as detailed below); or (l) with the user's explicit approval prior to disclosure.
For the avoidance of doubt, the company may disclose and transfer non-personal information to third parties at its sole discretion.
6. Changing or Deleting Personal Information
The user has access to their personal information during the site registration process. However, under Section 13(a) of the Privacy Protection Law, 1981, every person is entitled to review information held about them, so if, for any reason, you wish to change, update or delete the personal information you provided to the company, please do so within your account settings. Alternatively, you can send an email to the following address:info@tinq.co.il, and we will make reasonable efforts to change, update or delete such personal information, in accordance with applicable privacy laws.
We may retain and use personal information for a reasonable period after receiving your instruction to delete the information, in order to comply with our legal obligations and business commitments (including those required by applicable law) for dispute resolution, enforcing the Terms of Use, enabling the user to resume receiving the service, and for research and security purposes.
The company will retain personal information collected from users for a reasonable period in accordance with applicable privacy laws.
7. Third-Party Social Network Features
The site and/or services may contain third-party social network features (such as Facebook's "like" and "share"). Clicking on these features may result in the collection of information about you (such as IP address) as well as non-personal information. Cookies may be used to operate these features. Your use of these features is subject to the privacy policy of the third party that provided the features.
8. Cookies and Local Storage
While using the site, the company or third parties may use technology commonly accepted in the industry and known as "cookies" and Flash (or similar technologies), which store certain information on the user's device such as cache memory, enabling the company to automatically activate certain features and improve the user's experience with the company's services. Cookies will help the company enable an automatic site login process and faster site loading in the future.
The company or third parties may use temporary cookies (which expire upon disconnecting from the site) and persistent cookies (which continue to exist on the user's device until they choose to delete them).
Cookies can be blocked or deleted, among other things, via the device settings. Most web browsers allow users to delete cookies from the user's device, block the receipt of cookies, or receive alerts before cookies are stored. However, please note that if the user deletes cookies or does not allow their storage, or changes Flash settings, the user's online experience through the site will be limited. Please review the instructions found in your browser or the "Help" screen to learn more about these functions. To take action regarding third-party cookies, you can usually find appropriate instructions in their privacy policy or terms of use.
9. Payment Methods
Use of some of the services on the site may involve payment in a manner, amounts and dates as detailed on the site. The company reserves the right to change payment terms at any time (hereinafter: "the Payments"). The payment policy, to the extent relevant, is detailed on the site.
Payments, if any, may be made via online clearing services (hereinafter: "clearing service provider"), which enable various users to send or receive payments securely, using credit card details or a bank account. For more information about these services, please read the terms of use and privacy policy of the relevant clearing service provider.
It is hereby clarified that the company is not affiliated with or linked to the clearing service providers, that they are independent contractors, and that employees or agents of the company or the providers are not responsible for the acts or omissions of the other. Use of the clearing services is solely the user's responsibility. The user is required to comply with the terms of use and privacy policy of the relevant clearing service provider, including regarding user age restrictions.
10. Security
The company invests reasonable efforts in implementing and maintaining the security of the site, services, and users' personal information through industry-standard security measures, including security updates, permission management, SSL/TLS encryption and network protections (Firewall) (either on its own or by receiving services from third parties that are certified service providers). The company implements information security procedures and policies as customary in the industry to ensure the security of its users' information and to prevent any unauthorized use of this information.
Among other measures the company uses, the company stores personal information in a commercial database system with built-in access and information security and implements information security procedures and policies as customary in the industry. Access to a user's personal information is limited to the user themselves and/or a person the user has explicitly agreed may have access to this information. However, the company cannot guarantee that unauthorized access to such information will never occur.
11. Anti-Spam Law
In accordance with Section 30A of the Communications Law (Telecommunications and Broadcasting), 1982 (hereinafter: "the Anti-Spam Law"), the company undertakes not to send you any advertising material without first obtaining your consent (hereinafter: "spam"). If you have given your consent by filling out a details form, we will send you advertising material (as defined in the Anti-Spam Law) by email and/or to your home address and/or to your mobile phone. Once this consent is given, any material sent to you on behalf of the company will not be considered spam of any kind constituting or that may constitute a violation of the Anti-Spam Law. At any time, you can cancel this consent and/or update the company regarding your wish to receive only specific types of information, by notifying the company of your refusal to receive information from the company in the future, by sending an email to:info@tinq.co.il and/or in the same way the said advertisement was sent to you.
12. Third-Party Services
When using the services, including for the purpose of hosting the websites created, the Company may use third-party services or third-party software for various purposes, including for the collection, retention and/or processing of information as described above ("Third-Party Services"). Third-party services include, among others, Google Analytics, whose privacy policy is published at: https://www.google.com/policies/privacy and Facebook Pixel, whose privacy policy is published at: https://www.facebook.com/business/m/privacy-and-data. The information is provided to the company for advertising purposes and to find new potential audiences. If the user chooses not to fill out the details form/contact form/newsletter, only non-personal information will be collected about the user.
13. Links to Third-Party Sites
Certain links included on the site allow users to leave it and enter sites or services not related to the company. These links are offered for your convenience only. These sites and services are not under the company's control, the company is not responsible for their availability, does not endorse them, is not responsible for any content (including advertisements, products and other information) appearing on them or available through them (including links included in them), and is not responsible for the privacy policy or other practices appearing on them or practiced by these third parties. Your entry, use and reliance on such sites, services or content and any interaction between you and these third parties is your responsibility, and you bear sole responsibility for expenses related thereto. The company reserves the right to cancel or delete any link at any time. You agree and confirm that the company will not be responsible, directly or indirectly, for any damage or loss caused (or alleged to have been caused), in connection with or as a result of using any service, content, product or other information available through these sites or services. Most of these contain legal documents, including privacy policies and terms of use, governing their use. We recommend that you carefully read those documents before using these sites or services (among other things, to know what types of information are collected about you).
14. Advertising Information
You hereby approve the use of the contact details you have provided us, as well as the sharing of these details with Google and Facebook systems, for the purpose of sending promotional information that may be of interest to you, and to inform you of significant developments or changes to the Services. Such content will be sent to the email address you provided us during the registration process. You may withdraw your consent by sending an email message to the Company at the following address:info@tinq.co.il, or alternatively follow the unsubscribe instructions available in the message we sent you.
15. Changes to the Privacy Protection Policy
The provisions of this Privacy Policy are an integral part of the site and the information collected on it, and may not be separated in any way from the Terms of Use. The company reserves the right to change this Privacy Policy at any time, and asks all users to return and visit this page as often as possible. We will notify the user of any material change to the terms of this Privacy Policy by replacing the "Privacy Policy" link on the site's homepage with a link named "Terms of Use updated as of ____" and/or by sending an email to the address the user provided while using the site. Non-material changes will take effect within seven (7) days from the date of such notice. All other changes to the Privacy Policy will take effect immediately, and your continued use of the site after the last update date will constitute your consent that the changes are binding on you.
16. Questions
If you have any questions or other comments regarding this Privacy Policy, do not hesitate to send us a message to the following address:info@tinq.co.il We will make every effort to get back to you within a reasonable time.