Privacy Policy

 Last revised on August 19, 2019

CURRENGE ISRAEL LTD DATA PRIVACY POLICY    Print Currenge Privacy Policy

 

CURRENGE ISRAEL LTD is a company incorporated in Israel with company number 515455376 and registered with the office of the registrant of companies and/or its successors and/or any person and/or entity to whom it has assigned in writing its rights under this data privacy policy (hereinafter referred to as “Currenge” or “We” or “Our” or “Us“).

For any questions regarding this Privacy Policy, please contact Us as follows:

 

Currenge Israel Ltd.

PO Box 6033

Haifa, 3106001

Israel

Phone: +972-3-600-5433

Email: support@currenge.com

 

This is the Currenge data privacy policy (“Privacy Policy“) that governs how We, use Personal Information, as defined below, that We collect, receive and store about Clients and/or users in connection with the use of:

i) the website currenge.com, and any other website that We operate (each, together with its sub-domains, content and services, a “The Website” or “Website“); and

ii) Currenge offered services and/or Currenge provided information (hereinafter to be referred to as “Service” or “The Service“). The Website and/or The Service are individually and collectively referred to herein as the “Services” or “The Services“.

This document also outlines our approach to Data Privacy to fulfil our obligations under the General Data Protection Regulation (2018).

Please read this document carefully. It contains important information about Your rights and obligations relating to Your privacy. It also contains a disclaimer of Our Currenge warranty and a limitation of liability clauses.

 

1.      INTRODUCTION

1.1 There are a number of reasons for Us gathering information about You. For instance, with no limitation, We need to know how to get in touch with You, We need to be certain of Your identity and We need to understand Your financial circumstances combined with economic rationale for conducting transactions. We need this information so that We can offer You products and Services and give You the best possible customer experience. Information We collect falls into various categories.

1.2 We have implemented this Privacy Policy because Your privacy, and the privacy of other users, is important to us. This Privacy Policy explains Our on-line information practices and the choices You can make about the way Your Personal Information is collected and used in connection with The Services. “Personal Information” means any information that may be used, either alone or in combination with other information, to personally identify an individual and/or entity, including, but not limited to, a first and last name, a personal profile, an e-mail address, a home or other physical address, or other contact information.

1.3 The Privacy Policy explains Our policy regarding the type of information, which includes but is not limited to the Personal Information (hereinafter referred to as “Information”), We collect from You when You use Our Services, why We collect it, and how We use it.

1.4  All conversions and/or payments and/or other financial transactions served by Bank HaPoalim (hereinafter referred to as “BNHP”), an Israeli licensed Bank are subject to BNHP’s Privacy Policy, which BNHP maintains and may be found at the BNHP website. Users and/or Clients using the Services are also subject to the Privacy Policy and disclosures of BNHP.  Currenge is not responsible for the privacy practices of BNHP and does not exercise control over BNHP’s sites.

 

2.      TERMS OF USE

2.1 This Privacy Policy forms part of and should be read in conjunction with Our Terms of Business (hereinafter referred to as “Terms of Business“). Any capitalized but undefined term in this Privacy Policy shall have the meaning given to in the Terms of Business, unless defined otherwise specifically in this Privacy Policy.

2.2 When You access or use Our Services, You express Your approval of any use made of the Information, which with no limitation may be information collected from or about you, as contemplated in this Privacy Policy.

2.3 By using the Services, You acknowledge and consent to the terms of this Privacy Policy and to Our collection, processing and sharing of Personal Information for the purposes set forth herein. If you do not agree to this Privacy Policy, please do not access or otherwise use the Services.

2.4 We reserve the right, at our discretion, to change, modify or cancel this Privacy Policy at any time. Such change will be effective beginning of the moment of the posting of the revised Privacy Policy on The Website, and Your continued use of The Services thereafter means that you accept those changes.

2.5 At all times, You may choose whether or not to provide or disclose Personal Information. If You choose not to provide mandatory Personal Information, You may still visit parts of the Services but You may be unable to access and/or use certain parts of the Services, programs, offers, and/or Services that may involve and/or require Our interaction with You.

2.6 We may transfer or allow the transfer of Information about You and Your Services with Us to Our Services providers and other organizations outside the European Economic Area (EEA).

2.7 Some of Our service-providers, for example with no limitation IT, telecommunication, credit reference agencies, payment processors, custodians and/or providers of administration services, tracing agents and contractors are based outside of the EEA.

2.8 You have the right to:

a) Find out if We use Your Information, to receive a copy of some of Your Information held by Us.

b) Request that inaccurate Information is corrected and incomplete Information updated.

Express objection to particular uses of Your Personal Information where the legal basis for Our use of Your Information is Our legitimate business interests (for example, profiling we carry out for our legitimate business interests) or the performance of a task in the public interest. However, doing so may have an impact on The Services we can and/or are willing to provide You.

c) Express objection to use of Your Personal Information for direct marketing purposes.

d) Under certain circumstances You may request Your Information deleted or its use restricted.

e) Obtain an electronic transferable copy of certain Information that can be transferred to another service-provider of Yours, known as “the right to data portability”.

f) This right applies where personal information is being processed based on consent or for performance of A Contract and the processing is carried out by automated means. You may not be able to obtain through the data portability right all of the Personal Information that You can obtain through the right of access. This right also permits the transfer of Information from Us directly to another provider where technically feasible. Therefore, depending on the technology involved, We may not be able to receive Personal Information transferred to Us and We will not be responsible for the accuracy of same.

g) Withdraw consent at any time, where any processing is based on consent. If You withdraw Your such consent, it will not affect the lawfulness of processing based on Your consent which occurred before its withdrawal and/or 21 days after We have acknowledged receiving such consent withdrawal.

2.9 The Services are not structured to attract children under the age of 14 years. Accordingly, We do not intend to collect Personal Information from anyone We know to be under 14 years. If We learn that We have collected Personal Information from a child under 14 years, We will delete that information as quickly as possible, unless required otherwise by any law and/or regulation. If you believe that We might have any such information, please contact us at support@currenge.com .

2.10 In the event that We are acquired by or merged with a third-party entity, or sell any of Our operations, or in the event of bankruptcy or a comparable event, We reserve the right to transfer or assign Personal Information in connection with the foregoing events.

Protecting Your privacy on-line is an evolving task, and We may be constantly evolving Our Services to meet these demands. If You have any comments and/or questions regarding Our Privacy Policy, or Your Personal Information that We may be storing and using, please contact Us at: support@currenge.com

 

3.      COLLECTION OF INFORMATION

3.1  We do not currently require You to provide identifying information in order to have access to general information available on the Website.

3.2  With no limitation, We may collect the following Information about You:

a) If You have criminal convictions, We may process this information in the context of compliance with Our anti-money laundering and counter terrorist financing obligations.

b) Information which You have consented to Us using.

c) Your agreement to allow Us contact You through certain channels to offer You relevant products and/or Services.

d) Information from on-line activities.

e) Information related to Your requested Trade and/or Your Contract and/or sent to You Contact Note.

f) We collect information about Your Internet activity using technology known as “cookies”, which can often be controlled through Your Internet browsers. For detailed information on the cookies We use and the purposes for which we use them, see both section 7 of this Privacy Policy and/or Our Cookies Policy, which is to be available on Our Website.

g) We collect information about Your Internet browser settings and/or computer type and/or otherwise Internet Protocol (IP) and other relevant Information to help Us identify Your geographic location when providing You with Our Services.

h) Other Personal Information.

i) Telephone and image recordings.

j) CCTV images at Our offices, only for security reasons and to help prevent fraud or crime.

k) Information in relation to data access, correction, restriction, deletion, porting requests and/or complaints.

3.3 Sometimes We may collect and use Your information even though You are not A Client of Ours. For example, with no limitation, You may be a beneficiary, guarantor, director, cardholder or representative of one of Our Clients, or You may be in the process of making an application for a Currenge Services. In other cases, Your own circumstances may have a material impact on the ability of Our customer to perform their obligations to Us, and We will need to consider these. If so, We will apply the principles outlined in this Privacy Policy when dealing with Your information.

3.4  We do receive and/or collect Personal Information from You and/or about You, in various circumstances among them with no limitation the following circumstances:

a) Surfing Our Website: IP and/or computer system related information, collected for any user accessing the Services, mainly with no limitation for security reasons and/or understanding patterns of usage of the Services.

b) Registration: In order to participate in the Service, You are required to register We may offer different options to register, including an Online registration form, where You may choose to complete and submit an online registration form. Among other information, with no limitation You will be asked to provide Us with an e-mail address that will serve Us.

c) Transaction: In order to ask as for A Trade you will fill out a transaction form, where You with no limitation identify Yourself, and possible provide identification proof for Your identity.

d) Contact Forms: In order to be in touch with Us, You may use various contact and/or support forms on The Website and/or use e-mail and/or any other communication format, which may be documented by Us.

3.5  With no limitation We may collect information provided by You at any of the above circumstances, even if You have not finalized a process in which You have provided any Information. We may do so, with no limitation, for security reasons of protecting Our System and/or Website and/or for supporting You in asking for A Trade and/or for marketing purpose contact You offering Our assistance.

3.6  We may also computerize any paper format of registration and/or other forms and/or documents provided by You.

3.7  You acknowledge and agree that You must provide all the required information in order to use the Services. Further, some of the Information is legally required in order for Us to provide You with the Services.

3.8  You acknowledge and agree that regardless of which method you choose to register with Us, We may send an e-mail/s and/or a mobile text message to Your nominated e-mail address and/or Your mobile telephone number and/or device associated with it, or to the e-mail address that You have designated in your registration, among other reasons, with no limitation, to instruct You how to confirm Your registration.

3.9  Information You provide Us or such We have collected about You will be used for Currenge’s purposes, including providing You with the Services. Currenge may use the services and data storage of its affiliates and You hereby consent to the sharing of Your Information between Currenge and its affiliates.

3.10  In addition to the Information provided by you, Currenge may collect and/or receive additional personal information from third parties. Currenge will consider such information as Personal Information.

3.11  You are responsible for ensuring the accuracy of Your Personal Information and all other Information You submit to Us. It is hereby clarified that providing false information constitutes a criminal offence and the perpetrator would be liable for sanctions in accordance with the law.

3.12  Currenge undertakes that, if relevant, the Information shall be kept in a database in accordance with the provisions of the Israeli Privacy Law, 1981 (hereinafter referred to as “Israeli Privacy Law”)

3.13       The aforesaid constitutes a notice under Section 11 of the Israeli Privacy Law.

3.14       You may ask for a copy of Your Information provided by You to Currenge.

3.15       If You would like to update Your Personal Information and/or have any complaint regarding Our use of Your Personal Information, You may e-mail Our customer service at support@Currenge.com

3.16       For the avoidance of doubt, nothing in this Privacy Policy shall prevent Us from retaining Your Personal Information (including Personal Information that You asked to update or restrict) where We are required to do so by law.

3.17       In addition, We may collect additional information, such as the IP address from which You applied, time and date of access, type of browser used, language use, software crash reports, preferences using the Website, and feedback regarding the Services. Such information may also be stored by Currenge through an activity log unique to you. The aforesaid information is delivered to Us by You and collected when You visit or use the Website. This information allows Us to improve and to enrich the content and the Services offered on the Website, to adapt the Website, its content, and Services to users’ preferences, and also to prevent and/or detect criminal activity as for example fraud.

3.18       If You wish to use the Service for a business-related financial service, with no limitation a payment and/or a conversion of currency/ies, then You may be required to provide Us with certain information about Your business and business personnel (“Business Information“). Such information may include, with no limitation, Personal Information about Yourself and/or You and/or Your business personnel. If You provide, or make available, any Personal Information about any business personnel You acknowledge and declare that You had first notified him/her/them and obtained his/her/their consent to disclose such information to Us. Your participation in the Service is optional and You at all times have the choice of choosing whether to provide any Personal Information. Please be aware though that any failure to provide requested information may preclude Your business from being approved to transact with Us and/or use Services and/or submit A Trade and/or engage in A Contract with Us.

3.19       The Services may include the option to transact with Us, for example with no limitation, to convert currency. If You choose to transact with US, We and/or one of Our affiliated companies will require sufficient information from You to complete the transaction. Such information could include bank account/s numbers and/or any payment card number and related account and billing information, and other data required for any reason to process such requested Trade. We may also update such information should You grant Us permission to bill You and/or Your payment account, with no limitation a bank acount and/or a payment card for recurring charges. We may use the tools, software and/or Services of third-party service providers to process transactions on Our behalf, in which case You acknowledge and agree to review and be bound by the terms of use and privacy policy of such third-party service provider.

3.20       If you send Us a “Contact Us” and/or “Support” request, whether by submitting an on-line form that We make available on the Website and/or by sending an e-mail to an e-mail address that We display on the Website, You may be required to provide Us with certain information such as Your name and/or e-mail address.

3.21       We may make use of log files. The information inside the log files includes internet protocol (IP) addresses, type of browser, type of computer operating system, type of computer, Internet Service Provider (ISP), date/time stamp, referring/exit pages, clicked page/s and/or any other information Your browser may send to Us. We may use such information, for reasons with no limitation as to analyze trends, administer the Services, track user’s movement around the Services, and gather demographic information.

3.22       To the extent that You do provide Us with Personal Information, We would like to maintain the accuracy of the Personal Information. You may use the tools that We make available on the Service to request the removal and/or modification of certain information in Your Account, as held by Us and/or Our behalf. If you would like to ask for a correction any of Your other Personal Information that We may be storing, You may submit a request by sending Us an email to support@currenge.com . Your such e-mail should include adequate details of your request.

3.23       We may retain and/or archive information that You have provided in the course of obtaining and/or attempting to obtain Services through Our Currenge Services and/or System in order, with no limitation to comply with applicable law, regulation, legal process, partner contractual obligations and Our own internal policies.

3.24       If You give Us Information about someone else (for example with no limitation, Information about a spouse, family member, beneficiary, or financial associate provided during the course of a an application and/or registration and/or requesting A Trade, for example with no limitation to explain the economic rationale for a specific transaction with that person, beneficiary), and/or someone gives Us Information about You, We may add it to any Personal Information We already hold and We will use it in the ways described in this Privacy Policy.

3.25       Before You disclose Information to Us about another person, You should be sure that You have his/her/their agreement to do so. You should also show them this Privacy Policy. You need to ensure he/she/they confirm that they know You are sharing their Personal Information with Us for the purposes described in this Privacy Policy.

3.26       The length of time We hold Your Information depends on a number of factors, such as regulatory rules and the type of Services We have provided You with.

3.26       You can choose not to share Information, however by doing so We may limit the Services We are able and/or willing to provide to You.

 

4.      USE OF INFORMATION

4.1  Your Information may be stored in Currenge’s Database (hereinafter referred to as “Database”).

4.2  Personal Information that You submitted and/or We collected, possibly with no limitation via the Services and/or scanning and/or taking picture of related to You document/s, may be used by Us, possibly with no limitation via the usage of  the Database with no limitation for the purposes for which the Database was established in accordance with the provisions of this Privacy Policy or any law, possibly with no limitation for the following subsequent way/s and/or purpose/s:

a) to provide and/or improve Our Services, to contact You regarding to the Services and/or certain program/s and/or offerings that You may have registered for, and/or to identify and authenticate Your access to the parts of the Services that You are authorized to access, and/or to authenticate Your communication and/or payment/s;

b) We may use Your designated communication details, with no limitation Your e-mail address and/or Your telephone number and/or Your fax number and/or Your address to among others, with no limitation, send You updates and/or news regarding the Services and/or Our to be offered products and/or services; and/or respond to a “Contact Us” and/or other request, such as with no limitation an administrative request, for example to reset Your Services password.

c) Process Your applications for products and/or Services.

d) Establish Your eligibility for our products and Services.

e) Establish Your identity.

f) Manage and administer Your accounts, policies, transactions, benefits and/or other products and Services that We and/or Our partners may provide You with.

g) Conduct Our regulatory requirement of ongoing due diligence.

h) Carry out account reviews, including some semi-automated decision processes, which may have a legal or similarly significant effect on You, and to search for details of Your identity at identification verification firms and/or governmental such services, credit bureaus/agencies. Where We make these searches, all these companies/agencies may keep a record of the search.

i) Process payments that are paid to You or by You or effectuated by You. For example, with no limitation, if You are making international payments, We may need to share information with Our banking partners in order for the payment to be completed.

j) Run loyalty, refer a friend and other such reward programs You have signed up to and/or were referred to and/or used.

k) Contact You by any communication method, that with no limitation may be post, phone, text message, WhatsApp message, Facebook messenger, e-mail, social media, fax, using our on-line Website and/or other means, but not in a certain way contrary to Your instructions to Us given that You do allow Us to contact You or contrary to law.

l) Monitor and record Our conversations when we speak on the telephone (for example, with no limitation, to check Your requests and/or instructions to Us, to analyze, to assess and improve customer service and/or for training and quality monitoring purposes.

m) Recover debts You may owe Us.

n) Manage and respond to a complaint or appeal.

o) We may use the Business Information and/or Your Information received from a third-party that We may collect to provide Our Service to You, including with no limitation to determine if You should receive from Us an obligo and/or line of credit, possibly for transacting with Us.

p) We may collect and/or use Your Personal Information, the Business Information and/or any similar information as otherwise set forth in Our Terms of Business.

q) We may transfer Your Personal Information to Our subsidiaries and/or affiliated companies and/or or a Currenge’s Companies Group Member and/or a Currenge’s Companies Group Member employee for purposes, with no limitation, as storing and/or processing such information on Our behalf. Such information may be transferred to other countries around the world. We require that such these parties agree to process and/or hold such information in compliance with Our Privacy Policy.

r) We may disclose Your Personal Information and/or any information You submitted via the Service and/or We collected legally if We have a good faith belief that disclosure of such information is helpful or reasonably necessary to:

i) comply with any applicable law, regulation, legal process or governmental request;

ii) enforce Our Terms of Business, including with no limitation investigations of potential violations thereof;

iii) detect, prevent, and/or otherwise address fraud or security issues; or

iv) protect against harm to the rights, property or safety of Currenge, any of Our users and/or Clients, Yourself and/or a public.

s) offer Our Services and to provide customer support;

t) provide You notices with respect to the Services;

u) transfer of funds to the Recipient;

v) track Your use of the Website and for other internal purposes, such as evaluating the Website and improving Our Services;

w) Gather statistical information regarding the activity on Our Website for the purpose of improving the Services offered on Our Website;

x) Monitoring the use for the prevention of misconduct;

y) Storage of the Information in accordance with the Israeli Privacy Law;

z) Distribution of marketing materials, including through Direct Marketing, general and personalized notices to those users who consented to the receipt of such;

aa) Sending notices with respect to any breaches of the Terms of Use.

4.3  We may also, with no limitation, use Your Personal Information, as part of Our daily operating Our business, in the following ways:

a) Carry out planning and/or for portfolio management.

b) Compile and process Your Information for audit, statistical or research purposes (including, in some instances, making your data anonymous) in order to help Us understand trends in Our customer behavior and/or to understand Our risks better, including for providing management information, operational and data risk management.

c) Protect our business, reputation, resources and equipment, manage network and information security (for example, with no limitation, developing, testing and auditing Our Website and/or The Systems, dealing with accidental events or unlawful or malicious actions that compromise the availability, authenticity, integrity and confidentiality of stored or transmitted personal data, and the security of the related services) and prevent and detect fraud, dishonesty and other crimes (for example, to prevent someone trying to steal Your identity), including using CCTV at Our premises.

d) Manage and administer Our and/or any Currenge’s Companies Group Member legal and/or compliance affairs, including complying with Our obligations to banking partners, payment card providers, compliance with regulatory guidance and voluntary codes of practice to which we have committed.

e) Enable Us to share or access Your Information for internal administrative purposes, audit, prudential, statistical or research purposes (including making your data anonymous) to help us understand trends in customer behavior, for helping Us to understand Our risks better and for the purposes set out in this Privacy Policy, but not for the purposes of direct marketing where you have objected to this.

f) To buy and/or sell assets of Ours and/or the Currenge’s Companies Group Member may in the future wish to sell, transfer or merge part or all of its business or assets or to buy a new business or the assets of another business or enter into a merge with another business. If so, We may disclose Your Personal Information under strict duties of confidentiality to a potential buyer, transferee, merger partner or seller and their advisers, so long as they agree to keep it confidential and to use it only to consider the possible transaction. If the transaction goes ahead, the buyers, transferee or merger partner may use or disclose Your Personal Information in the same way as set out in this Privacy Policy.

g) Facilitate a potential or actual transfer of any product and/or Services provided to You to another company or firm.

h) To manage Our legitimate interests

4.4  To manage Our business, We may also, with no limitation, use Your Information to:

a) Engage agencies to trace You, for example, with no limitation where the address you have provided is no longer accurate and the Bank needs to provide You with legal documentation.

b) Provide Services information, to improve Our Services quality and/or for training purposes

c) We may gather Information about Your interactions with Us, for example, with no limitation, where You consent, when You download one of our apps, We may gather location information from Your mobile phone and/or other electronic device You may use to interact with Us.

4.5  To comply with our legal and regulatory obligations, We need to use Your Information to comply with legal and regulatory obligations including:

a) Complying with Your Information rights.

b) Providing You with statutory and regulatory information and statements.

c) Establishing Your identity, residence and tax status in order to comply with law and regulation concerning taxation and the prevention of money laundering, fraud and terrorist financing.

d) We are required by law to screen applications that are made to Us to ensure We are complying with the international fight against terrorism and other criminal activities. As a result, We may need to disclose information to government and other statutory bodies.

e) Preparing returns to regulators and relevant authorities including preparing income tax, capital gains tax, capital acquisition tax and other revenue returns.

f) Reporting to and, where relevant, conducting searches on industry registers.

g) Complying with binding requests from regulatory bodies, including the Israel Capital Market, Insurance and Saving Authority and/or if applicable the Israel Money Laundering and Terror Financing Prohibition Authority and/or if applicable the Israel Tax Authority.

h) Complying with binding production orders or search warrants, and orders relating to requests for mutual legal assistance in criminal matters received from local and/or foreign law enforcement agencies/prosecutors.

i) Complying with court orders arising in civil or criminal proceedings.

j) Performing a task carried out in the public interest.

4.6  To conduct marketing activities, Where You have given Us permission, which You can withdraw at any time, We may also, with no limitation, use your information to:

a) Send electronic messages to You about product and/or Services and/or service offers from Us and/or any any Currenge’s Companies Group Member and/or Our selected trusted by Us partners.

b) Share Your data and/or Information with third-parties so that they may send You electronic messaging about their products and offers.

c) Use transaction history/account information from Your Currenge account to identify Your transactional patterns and habits in order to personalize offers that are exclusive and individual to You, based on Your Information, with no limitation Your previous transactions.

d) Use cookies in accordance with Our Cookies Policy.

e) Use special categories of data, and/or sensitive data.

f) Use Your location data to send You information regarding special offers from Us and/or Our partners possibly with no limitation being close to Your location.

g) Use any information You have made public and combine it with any of the activities outlined above.

4.7  We may use automated statistical analysis of the Information We collect about You as part of our business, with no limitation to make informed business decisions, test and maintain stability and performance of Our systems, and/or carry out long-term statistical modelling, with no limitation in the following ways:

a) Analysis of Your Information helps Us to make automated decisions.

b) When You apply for a financial product and/or Services, We may evaluate the application using statistical analysis to determine whether or not such Services best meets Your needs.

c) We may decide whether or not to provide You a financial Service.

d) We may calculate the specific charges that We need to charge on a specific Service and/or transaction to reflect the risk involved.

e) To manage existing credit agreements You have with Us, such as Your Current Account overdraft. For example, with no limitation, when You or any authorized user seeks to perform a transaction, Information may be sent to Us to evaluate and determine whether to approve, decline or refer a transaction for further review. Where We make solely automated decisions that affect You in a legal or a significant way, You have the right to provide Your point of view and have those decisions reviewed by a member of Our team.

f) Automated analysis of Our customer Information (including Your Information) as a whole helps Us to manage Our business for Our legitimate interests.

4.8  We may use Your Information and/or share that Information where:

a) Its use is necessary in relation to A Service and/or A Trade and/or A Contract that You have entered into or because You have asked for something to be done so You can enter into A Contract with Us.

b) Its use is in accordance with Our legitimate interests outlined in this Privacy Policy and/or Our Currenge Terms of Business.

c) Its use is necessary because of a legal obligation that applies to Us (except an obligation imposed by A Contract). With no limitation, an example of this would be Us sharing Your Information with the Israel Money Laundering and Terror Financing Prohibition Authority.

d) You have consented or explicitly consented to the using of Your Information, possibly including special categories of Information, in a certain way.

e) Its use is necessary to protect Your “vital interests”, as We understand it/them.

f) In exceptional circumstances We may use and/or disclose Information (including special categories of Information as the Private Information) We hold about You to identify, locate or protect You, for example, if it comes to Our attention that You are in imminent physical danger and this information is requested by a police force and/or a security agency and/or Your relative.

g) Where You have made clearly sensitive categories of Information about Yourself public.

h) Where the processing of special categories of data is necessary for the establishment, exercise or defense of legal claims.

i) Where authorized by law or regulation, We may undertake processing of special categories of Information for a substantial public interest.

j) Where the processing of criminal conviction Information is authorized by Israeli law.

 

5.      DISCLOSURE OF PERSONAL INFORMATIO TO THIRD PARTIES

5.1  We may transfer Your Personal Information to a third-party firm providing Us with Hosting and/or content delivery network (CDN) and/or computing services. Such information may be transferred to other countries around the world. We require that such these parties maintain a privacy policy of their own.

5.2  We may share Your Personal Information with Our third-party service providers and/or partners, in aim to assist Us with Our business operations and/or to provide the Services. For instance, information used to determine Your Know Your Customer (KYC) worthiness may be shared with a financial institution related to effectuating Our transaction/s related to You without limitation it being BNHP, if BNHP takes part in facilitating part of Your transaction. Such information may be transferred to other countries around the world. We use commercially reasonable efforts to only engage or interact with third party service providers and/or partners that post a privacy policy governing their processing of Personal Information.

5.3  We may use Anonymous Information, as defined below, and/or disclose it to third-party service providers and/or partners, possibly with no limitation in order to improve Our Services and/or enhance Your experience with the Services. We may also disclose Anonymous Information, with or without compensation, to third parties, including with no limitation advertisers and/or partners. “Anonymous Information” is defined in this Privacy Policy as information which does not enable direct identification of an individual user and/or Client and/or You, such as aggregated information about the use of Our Services and/or Geo Location of an IP address.

5.4  We also, with no limitation, may share Your Information:

a) With Your authorized representative, accountant and/or your primary bank

b) With Your attorney, under a Power of Attorney, and any other party authorized by You to receive Your Personal Information.

c) With Third parties We need to share Your Information with in order to facilitate payments you have requested and/or related to You, for example, Banking Partners, SWIFT, payment card issuers and other banks, and those You ask Us to share Your Information with.

d) With other Currenge’s Companies Group Member company/ies and/or its/their employees.

e) When You open and/or register and/or transact as a business this may mean that Your Personal Information will be shared with the other applicants and/or users and/or representatives related to such business. For example, transactions made by You will be seen by others so authorized to view such business Client transactions.

f) Firms that provide support services for the purposes of protecting Our legitimate interests.

g) Your Personal Information remains protected when Our Services providers use it. We only permit service providers to use Your Information in accordance with Our instructions.

h) Our services providers include marketing and market research companies, analytics companies, banking partners, investment companies, IT and telecommunication service providers, software development contractors, data processors, payment card producers, computer maintenance contractors, printing companies, property contractors, document storage and destruction companies, custodians and providers of administration services, archiving services suppliers, debt collection agencies, budgeting and advice agencies, tracing agencies, receivers, liquidators, examiners, official Assignee for Bankruptcy and equivalent in other jurisdictions, accounting auditors, and consultants, including legal advisors.

i) Statutory and regulatory bodies and/or law enforcement authorities. These include the courts and those appointed by the courts, government departments, statutory and regulatory bodies in all jurisdictions where Currenge operates including: the Israel Capital Market, Insurance and Saving Authority, the Israel Money Laundering and Terror Financing Prohibition Authority, the Israel Tax Authority, possibly the EU Data Protection Commission, Israeli Police, Unites States of America Internal Revenue Service, United States of America’s Financial Crimes Enforcement Network (FinCEN), security organizations, ombudsmen and regulatory authorities, as well as fraud prevention agencies.

j) Third parties in connection with a sale or purchase of assets by Currenge and/or by a Currenge’s Companies Group Member company.

k) Those who are interested in or participating in buying or selling assets of Currenge and/or a Currenge’s Companies Group Member company or in connection with a funding arrangement for Ours and/or a Currenge’s Companies Group Member company.

l) Correspondent banks and other financial institutions engaged to supply status opinions in accordance with banking practice.

5.5  We will not disclose the Information to any third party/ies not specifically mentioned in this Privacy Policy and/or the Currenge Terms of Business, unless We are required to do so in order to provide the Services or required by any law or if We believe in good faith that such action is necessary to:

a) comply with any legal process or in circumstances where We are legally obligated;

b) defend any dispute, claim, action, demand, or legal proceedings, if any, between yourself and Currenge and/or others on its behalf;

c) protect and defend Our rights and property;

d) protect the personal safety of other users or the public;

e) required by any of Our liquidity providers, brokers, banks, or payment service providers in order to provide the Services or comply with their regulatory requirements; or

f) any term allowing Us to do so, in accordance of the Terms of Business agreement.

5.6  Moreover, in the event that We sell, assign, or transfer some or all of Our business or assets to a successor or acquirer, or if We are acquired by or merge with a third party, or if We file for bankruptcy or become insolvent, We may sell, assign, or transfer all of Your Personal Information and other information provided by You or about you, regardless of Your opt out status, to such successor or acquirer.

5.7  Currenge, if going through a merger or acquisition, may attach and/or compare and/or revise any of Your Private Information, with any additional Your information received through such possible merger or acquisition, and also may collaborate Your Private Information with the other side/s for such merger or acquisition. The above clause is also in effect of a possible third-party being the other side of such merger or acquisition activity in addition to Currenge.

 

6.      DIRECT MARKETING

6.1  Your Personal Information will also be used to contact You personally, based on Your affiliation to a population group, as determined by the characterization of one or more persons whose names are included in the Database (hereinafter referred to as “Direct Marketing”). Such contacts constitute a “direct marketing” under the Israeli Privacy Law, and they will be made only if You have given explicit consent. You may opt out and cease to receive direct mailing as stated at any time, by choosing the button “Remove” in the body of the message sent to You or by sending an email to Our Customer Service (at: support@Currenge.com). By doing so, Currenge will only delete the Information which is required to contact You by Direct Marketing, while the rest of the Information You submitted to Currenge which is necessary in order to provide You with the Services will continue to be stored in the Database, but will be no longer be used for Direct Marketing.

6.2  We do not disclose Personal Information to advertisers. However, We may transfer statistical information regarding the activity of Our Website users. Statistical information to be delivered will not identify You personally.

6.3  You may choose not to receive future promotional, advertising e-mails from Us by either selecting an unsubscribe link at the bottom of such e-mails that You receive from Us if existing or by asking Us so in writing and receiving a confirmation. Please note, that even if You opt out of receiving the foregoing e-mails, We may still send You a response to any Your message, with no limitation a “Contact Us” request as well as administrative e-mails (for example, a transaction related e-mail, an e-mail in connection with a password reset request, or a verification e-mail) that are necessary to facilitate Your use of the Services.

6.4  Any information pertaining to minors under 18 years of age will not be used for Direct Marketing.

 

7.      COOKIES

7.1  Some of Our Website and/or The Services page/s may utilize “cookies” and other tracking technologies with no limitation for example in order to for Us to provide Our Services and present You with information that is customized for You. A “cookie” is a small text file that may be used, for example with no limitation, to collect information about Your usage of The Website and The Services. Certain cookies and other technologies may serve to recall Personal Information, such as an IP address, previously indicated by a user. Some browsers allow You to control cookies, including whether or not to accept them and how to remove them. You may set some browsers to notify You if You receive a cookie, and/or You may choose to block cookies with Your browser. The Website and The Services page/s do not respond differently or limit their practices under the terms of this Privacy Policy when you access those on-line Services with a browser that uses a do not track signal and/or similar mechanism.

7.2  We also may use third party cookies on Our Website.

7.3  Other third-party firms may also have cookies set on Our Currenge Website to be downloaded to users and/or Clients browsers, with no limitation companies as Google providing Us among other tools with no limitation analytics abilities. Such other companies that may have cookies on Our Currenge Website will not receive from Us Your name, however may collect information regarding Your IP or if You configured Your browser to allow third parties cookies, also to be placing a cookie within Your browser. The above third-party cookies practices, may allow such third parties to connect various data related to You

7.4  More details about Our using Cookies may be found on Our Cookies Policy to be published on Our Website.

 

8.      SECURITY

8.1  The security of Your Personal Information is important for Us. Please note, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while We strive to use commercially acceptable means to protect your Personal Information, We cannot guarantee its absolute security or confidentiality.

8.2  All Our employees that have access to, and are associated with the processing of Your Personal Information, are obliged to respect the confidentiality of Your Personal Information.

8.3  The security of Your transaction/s history and/or Currenge account if applicable, depends on You keeping Your account password confidential. If You share Your account information with a third party, he or she will have access to Your account and Your Personal Information.

8.4  It is Your responsibility to control access to Your computer and account details, including keeping Your password confidential and not sharing it with anyone. It is also Your responsibility to alert Currenge if You believe that the security of the Information in Your account or Our Website has been compromised.

8.5  If You have any questions about security on the Service, You can contact us at: support@currenge.com .

 

9.      TRANSFER OF INFORMATION OUTSIDE THE JURISDICTION OF THE STATE OF ISRAEL

9.1  In addition to waivers specified in this Privacy Policy and/or Our Currenge Terms of Business, We may transfer Your Information to jurisdictions outside the jurisdiction of the State of Israel and/or outside the European Union. The data protection and privacy laws of the jurisdictions to which the Information will be transferred may not be as comprehensive as those in Israel and/or the European Union; in which case We will take measures to ensure a similar level of protection is provided to Your Personal Information, if possible.

 

10.  LINKS TO OTHER SITES

10.1       Our Website may contain links to other sites on the Internet and/or mobile software applications and services (hereinafter referred to as “Links”), which are not owned and/or controlled and/or operated by Us (hereinafter referred to as “Other Sites”), and thus are governed by different privacy policies.

10.2       Although We aim to be linked to reliable and trusted websites only, We are not responsible for the privacy practices and/or systems and/or procedures and/or content and/or for the security and/or the protection of Information applied on the Other Sites, and/or of the information collected by the Other Sites and/or third parties who are not governed by this Privacy Policy, and We assume no responsibility or liability whatsoever for the policies (including privacy policies), practices, actions, or omissions of such third parties.

Please be aware that the such Other Sites may collect Personal Information from You and/or about You. Accordingly, We encourage You to read the terms and conditions and privacy policy and/or cookies policy of each Other Sites service that You choose to use and/or interact with.

 

11.  LEGAL DISCLAIMER

11.1       We are not responsible for events beyond Our direct control. We cannot guarantee, nor do We represent, that there will be error-free performance regarding the privacy of Your Personal Information, and We will not be liable for any what-so-ever indirect, incidental, consequential, or punitive damage/s and/or loss/es relating to the use or release of Personal Information including, but not limited to, disclosure of Personal Information due to errors in transmission, unauthorized third-party access, or other causes beyond Our reasonable control.

11.2       You acknowledge and agree to all of the above.

 

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