FIRST TO INVEST- Privacy policy

Introduction

Your privacy and trust are important to us and this Privacy Statement (“Statement”) provides important information about how FIRST TO INVEST LTD and its affiliated companies and subsidiaries (together “FIRST TO INVEST,” “we,” or “us”) handle personal information. This Statement applies to any FIRST TO INVEST website, application, product, software, or service of our that hyperlinks to this Statement (collectively, our “Services”).

It does not generally apply to individuals whose personal information forms part of the content included within our products, although you can find further information on that topic here.

Please read this Statement carefully and contact our Data Protection Officer if you have any questions about our privacy practices or your personal information choices. It is important that you check back often for updates to this Statement. If we make changes we consider to be important, we will let you know by placing a notice on the relevant Services and/or contact you using other methods such as email.

This Statement was last updated on August 01, 2021

Personal Information

FIRST TO INVEST is committed to the responsible handling and protection of personal information.

Personal information means any information relating to an identified or identifiable natural person; an identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that person.

We collect, use, disclose, transfer, and store personal information when needed to provide our Services and for our operational and business purposes as described in this Statement. We want to be clear about our privacy practices so that you can make informed choices about the use of your information, and we encourage you to contact us at any time with questions or concerns.

The types of personal information we collect

We collect personal information from you, for example, if you purchase or use our Services, or request customer support. We may ask you to provide information such as your name, address, phone number, email address, username and password, and information about your device. Not all of the personal information FIRST TO INVEST holds about you will always come directly from you. It may, for example, come from your employer, other organizations to which you belong, or a professional service provider such as your tax or accounting professional or attorney, if they use our Services.

In addition, our servers, logs, and other technologies automatically collect certain information to help us administer, protect, and improve our Services; analyze usage; and improve users’ experience.

How we use personal information

We process personal information for these service-and business-related purposes

• Account setup and administration: We use personal information such as your name, email address, phone number, and information about your device to set up and administer your account, provide technical and customer support and training, verify your identity, and send important account, subscription, and Service information.
• Personalization: We use personal information to deliver and suggest tailored content such as news, research, reports, and business information and to personalize your experience with our Services.
• Marketing and events: We use personal information to deliver marketing communications to you across various platforms, such as email, telephone, text messaging, direct mail, and online. If we send you a marketing email, it will include instructions on how to opt out of receiving these emails in the future. We also maintain email preference centers for you to manage your information and marketing preferences. Please remember that even if you opt out of receiving marketing emails, we may still send you important Service information related to your accounts and subscriptions.
  • Contact Forms: The User can contact FIRST TO INVEST, through the forms established for this purpose on the Website. To this end, the User must provide FIRST TO INVEST information about the type of query, their name and surname, country from which the query originates, their e-mail, telephone number as well as the purpose for the inquiry they wish to perform. FIRST TO INVEST will use this data to process the query and contact the User.
    The legal basis for the processing of such data is based on the User’s consent.
  • Request a trial: The User can request a trial of FIRST TO INVEST services online. To do so, the User must provide their personal data, such as name, surname and corporate e-mail. FIRST TO INVEST will use this data to process the query and contact the User to supply its services. The legal basis for the processing of such data is based on the User’s consent. The retention period of this data will be adequate to comply with the contractual obligations and, in any case, up to five more years for tax procedures and to cover possible liabilities, unless other terms are applicable.
• Advertising purposes and special treatments:
  • Surveys and polls: If you choose to participate in a survey or poll, any personal information you provide may be used for marketing or market research purposes.
• Research and development: We use personal information for internal research and development purposes and to improve and test the features and functions of our Services.
• Legal obligations: We may be required to use and retain personal information for legal and compliance reasons, such as the prevention, detection, or investigation of a crime; loss prevention; or fraud. We may also use personal information to meet our internal and external audit requirements, information security purposes, and as we otherwise believe to be necessary or appropriate: (a) under applicable law, which may include laws outside your country of residence; (b) to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include such authorities outside your country of residence; (c) to enforce our terms and conditions; and (d) to protect our rights, privacy, safety, or property, or those of other persons.

When we share personal information

FIRST TO INVEST shares or discloses personal information when necessary to provide Services or conduct our business operations as described below. When we share personal information, we do so in accordance with data privacy and security requirements. We may occasionally share non-personal, anonymized, and statistical data with third parties. Below are the parties with whom we may share personal information and why.

• Within FIRST TO INVEST: Our businesses around the world are supported by a variety of FIRST TO INVEST teams and functions, and personal information will be made available to them if necessary for the provision of Services, account administration, sales and marketing, customer and technical support, and business and product development, for instance. All of our employees and contractors are required to follow our data privacy and security policies when handling personal information.
• Our business partners: We occasionally partner with other organizations to deliver co-branded Services, provide content, or to host events, conferences, and seminars. As part of these arrangements, you may be a customer of both FIRST TO INVEST and our partners, and we and our partners may collect and share information about you. FIRST TO INVEST will handle personal information in accordance with this Statement, and we encourage you to review the privacy statements of our partners to learn more about how they collect, use, and share personal information.
• Our third-party service providers: We partner with and are supported by service providers around the world. Personal information will be made available to these parties only when necessary to fulfill the services they provide to us, such as software, system, and platform support; direct marketing services; cloud hosting services; advertising; data analytics; and order fulfillment and delivery. Our third-party service providers are not permitted to share or use personal information we make available to them for any other purpose than to provide services to us.
• Third parties for legal reasons: We will share personal information when we believe it is required, such as:
  • To comply with legal obligations and respond to requests from government agencies, including law enforcement and other public authorities, which may include such authorities outside your country of residence.
  • In the event of a merger, sale, restructure, acquisition, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings)
  • To protect our rights, users, systems, and Services.
• applied. In order to consider an application fully, your personal information may be forwarded to an organization’s global offices.

Where we store and process personal information

FIRST TO INVEST is a global organization, and your personal information may be stored and processed outside of your home country. We take steps to ensure that the information we collect is processed according to this Privacy Statement and the requirements of applicable law wherever the data is located.

FIRST TO INVEST has networks, databases, servers, systems, support, and help desks located around the world. We collaborate with third parties such as cloud hosting services, suppliers, and technology support located around the world to serve the needs of our business, workforce, and customers. We take appropriate steps to ensure that personal information is processed, secured, and transferred according to applicable law. In some cases, we may need to disclose or transfer your personal information within FIRST TO INVEST or to third parties in areas outside of your home country.

When we transfer personal information from Israel to other countries in which applicable laws do not offer the same level of data privacy protection as in your home country, we take measures to provide an appropriate level of data privacy protection. In other words, your rights and protections remain with your data. For example, we use approved contractual clauses, multiparty data transfer agreements, intragroup agreements, and other measures designed to ensure that the recipients of your personal information protect it. If you would like to know more about our data transfer practices, please contact our Data Protection Officer.

How we secure personal information

FIRST TO INVEST takes data security seriously, and we use appropriate technologies and procedures to protect personal information. Our information security policies and procedures are closely aligned with widely accepted international standards and are reviewed regularly and updated as necessary to meet our business needs, changes in technology, and regulatory requirements.

For example:

• Policies and procedures
  • We have measures in place to protect against accidental loss and unauthorized access, use, destruction, or disclosure of data
  • We have a Business Continuity and Disaster Recovery strategy that is designed to safeguard the continuity of our service to our clients and to protect our people and assets
  • We place appropriate restrictions on access to personal information
  • We implement appropriate measures and controls, including monitoring and physical measures, to store and transfer data securely
  • We conduct Privacy Impact Assessments in accordance with legal requirements and our business policies
• Training for employees and partners
  • We require privacy, information security, and other applicable training on a regular basis for our employees and contractors who have access to personal information and other sensitive data
  • We take steps to ensure that our employees and contractors operate in accordance with our information security policies and procedures and any applicable contractual conditions
• Vendor risk management

How long we keep personal information

FIRST TO INVEST has a Records Management team that works in conjunction with the Privacy Office to implement policies and rules relating to the retention of personal information. We have an Enterprise Records Retention Schedule that is based upon a classification scheme consisting of Business Functions, Record Classes, and Record Types. We retain personal information for as long as we reasonably require it for legal or business purposes. In determining data retention periods, FIRST TO INVEST International takes into consideration local laws, contractual obligations, and the expectations and requirements of our customers. When we no longer need personal information, we securely delete or destroy it.

Your right to access and correct your personal information

We respect your right to access and control your information, and we will respond to requests for information and, where applicable, will correct, amend, or delete your personal information.

• Access to personal information: If you request access to your personal information, we will gladly comply, subject to any relevant legal requirements and exemptions, including identity verification procedures. Before providing data to you, we will ask for proof of identity and sufficient information about your interaction with us so that we can locate any relevant data.
• Correction and deletion: You have the right to correct or amend your personal information if it is inaccurate or requires updating. You may also have the right to request deletion of your personal information via email to [email protected].

Please contact our Data Protection Officer with any requests related to your personal information.

At any time, the User may lodge a complaint with the control authority.

Cookies

The Website has the technology for the implementation of files called cookies on the computer that is used for accessing and browsing the Website. Cookies can be blocked or disabled at any time through the browser’s configuration options, and are used to improve your browsing experience on our website, analyze user navigation and be able to offer personalized content.

The legitimation base for the treatment of such data is based on the consent of the User.

Other tracking technologies

• Web server & application logs: Our servers automatically collect certain information to help us administer and protect the Services, analyze usage, and improve users’ experience. The information collected includes:
  • IP address and browser type
  • Device information including Unique Device Identifier (UDID), MAC address, Identifier For Advertisers (IFA), and similar identifiers we or others may assign
  • Device operating system and other technical facts
  • The city, state, and country from which you access our website
  • Pages visited, and content viewed, stored, and purchased
  • Information or text entered
  • Links and buttons clicked
  • URLs visited before and after you use our Services

FIRST TO INVEST provides information solutions for professionals, and our Services are generally not aimed at children. If, however, we collect and use information about children, such as to develop an educational resource, we will comply with industry guidelines and applicable laws.

Modification of the Privacy Policy

FIRST TO INVEST reserves the right to modify its privacy policy at any time, respecting the current legislation on data protection and after due notice to the relevant parties.

How to contact us

We understand that you may have questions or concerns about this Statement or our privacy practices or may wish to file a complaint. Please feel free to contact us in one of the following ways:

Email:  [email protected]

Phone: New-York 646.661.2850 | Israel 972.532.444.984