Privacy Policy – “Cycles-Trader”

Date: 18 March 2019

This privacy policy (the "Privacy Policy") is an integral part of the terms of use and both documents should be read together.

The Operator respects the privacy of its users. In order to improve the protection of the Users, the Operator publishes this Privacy Policy regarding how the Operator collects Your information from Your use of the Website.

The processing and collection of personal data is governed by the Israeli law and by the General Data Protection Regulation (the “GDPR”), and whenever you’ll provide the Operator such information, the Operator will only use your information in line with all applicable data protection laws, including the GDPR. At all times You are in control of Your information, and You can withdraw Your consent to provide Your information to the Operator.

The data controller of the Website is Alon Avramson (the “Operator") which is the entity which decides how Your personal information is processed and for what purposes as detailed in the Privacy Policy.

  • General
  • During Your use of the Website, the following information about You will be collected:
  • Forecasts you have purchased;
  • Email, Name, address, phone.

  • Your Rights Regarding Your Personal Information
  • Under the GDPR and subject to different exemptions, You have the following rights:

To access Your personal data and receive a copy of Your personal data upon Your request;

To rectify, erase or restrict Your information upon Your request (right to be forgotten);

To object to the processing of Your information;

To request that the Operator will provide the You with Your personal information and, if possible, to transmit Your data directly to another data controller (right to data portability).

To withdraw Your consent to processing and the processing at any time;

  • No fees are required for exercising any of the above rights. However and subject to the GDPR, the Operator may charge You a reasonable fee including administration fees if Your request is repetitive or excessive or demands the Operator to bear excessive and/or expensive efforts.
  • To exercise your rights, please contact the Operator’s Data Protection Officer at the following contact details: Alon Avramson, 26 Rosh-Pina Street, Petach-Tikva, Israel,
  • Database and Use of Information
  • All collected information as stated above is stored in the Operator’s database. With accordance to Your consent, the Operator warrants to use such information for the following purposes:

Enabling convenient and efficient use;

Improve and enrich existing services and content;

Modify and/or remove existing services and content;

Perform research and provide statistic information to third parties (in such case, the provided information will not identify You);

Enforce the Operator’s Terms;

Providing You unique services including sending you newsletters upon providing Your email address;

Sending You any Forecasts purchased by You;

Any other purpose detailed in the Terms and this Privacy Policy.

Subject to Your consent, the Operator will transfer and/or share Your information in the following events and circumstances and, when applicable, will give you reasonable notice upon doing so:

When You have permitted the Operator to transfer and/or share Your information;

When You violate the Terms of the Website or act illegally;

To enforce the Terms or the Privacy Policy;

In response to a subpoena or similar investigative demand, a court order, or a request for cooperation from law enforcement or other government agency;

To establish or exercise the Operator’s legal rights;

To defend against legal claims; or as otherwise required by law. In such cases, the Operator may raise or waive any legal objection or right available to the Operator, in the Operator's sole discretion;

When the Operator believes disclosure is appropriate in connection with efforts to investigate, prevent, report or take other action regarding illegal activity, suspected fraud or other wrongdoing;

To protect and defend the rights, property or safety of the Operator, its Users, employees or others;

In connection with a substantial corporate transaction, such as the sale of the Operator’s business, a divestiture, merger, consolidation, or asset sale, or in the event of liquidation.

  • Third-Parties
  • There are a number of places on the Website where You may click on a link to access other websites that do not operate under this Privacy Policy and are not related to the Operator including, but not only, links leading to Third Party Websites. These links may independently solicit and collect information, including personal information, from You and, in some instances, provide the Operator with information about Your activities on those links.
  • Every third party such as detailed above may have its own privacy policy describing its use of personal information, and such policy will regulate the use, handling and disclosure of such personal information of the User. Should You require additional information regarding any privacy policy of third parties, The Operator recommends that You visit these third-party websites and read their privacy policies.
  • Your information will be handled and used by the Operator’s trusted third parties including the following recipients in order to deliver services provided by the Operator:

Providers, partners and sub-contractors on behalf of the Operator;

Analytics and search engine providers that may assist the Operator in improving the optimization and performance of the Website.

  • Retaining Your Information
  • The Operator will only retain Your personal information for as long as necessary to fulfil the purposes it was collected for including, but not only, for the purposes of complying with legal, accounting, or reporting requirements. The retention period is determined based on the amount, nature, and sensitivity of Your personal information, the potential risk of harm from unauthorized use or disclosure of Your information, the purposes for which the Operator processes Your information and whether such purposes can be achieved through other means with accordance to any applicable law.
  • Your personal information will be retained for a period of 1 (one) Year from the date of providing Your consent to collect Your information, thereafter all of Your information is removed from the Operator’s systems.
  • Your details for marketing communications will be retained for a period of 2 (two) years from the date of your last interaction with the marketing communication (i.e. opening an email or clicking on a link within the email) at which point all of your personal details will be removed from the Operator’s systems unless You will address the Operator and request that You no longer wish to receive marketing messages from the Operator.
  • Use of Cookies
  • Upon Your consent, the Operator uses various technologies to collect information from Your device and about Your activities while using the Website in order to improve and personalize Your online experience of the Website including by means of storing cookies to Your device. Please note that without these cookies, The Operator will not be able to provide You its services and You will be requested to leave the Website. Such necessary cookies include cookies which are essential for providing services of the Website.
  • During your use of the Website, third-party websites may store cookies to Your device, e.g. when some content of the website is embedded from the Third Party Websites. Please note that the Operator has no control over these cookies and You should check such third party’s cookie policy.
  • Data Security
  • The Operator takes appropriate security measures for data security purposes to help prevent unauthorized persons from gaining access to Your personal information. However, no system can be completely secure. Therefore the Operator does not warrant that its services will be totally immune to any breaches of security and/or unauthorized access, including access to the data stored in the Website, although the Operator will contact You upon a breach of Your data security with accordance to any applicable law.
  • The Operator inspects, from time to time, the data security of the Website and performs modifications and upgrades accordingly in order to keep the Website’s security. Nonetheless, the Operator will not be liable for any direct or indirect damage caused to You due to exposure of Your information by an unauthorized access to the Operator’s database and/or due to any negligence or act not controlled by the Operator.

  • Email Updates
  • The Operator may offer to all its users to receive email messages and/or newsletters about updates, improvements and other user notifications regarding the Operator’s activity, including via emails and SMS (the “Mailings”).
  • It is clarified that at any stage You will have the ability to opt out of receiving the Mailings by contacting the Operator and/or by clicking on a link available on the Mailings sent to You by the Operator.

  • Changes to This Privacy Policy
  • The Operator may occasionally update this Privacy Policy. The Operator will notify You by sending an email to the email address You most recently provided the Operator and/or by prominently posting notice of the changes and will state at the heading of the Privacy Policy the date of change.