1. General
    1.  This website, which is managed at the address gmtonline.co.il (hereinafter: ‘the site’ or ‘the website’), is operated and managed by GMT Tech Innovation Ltd. (hereinafter: ‘GMT’ or ‘the company’).
    2. The purpose of this Privacy Policy is to explain how the company collects information about and/or regarding the users of its services, as they are defined below, and how and for what purposes the company collects such information. The document is written in the masculine for the sake of convenience only but relates equally to both sexes.
    3. The terms of the Privacy Policy stated below constitute an integral part of the Terms and Conditions. The company may change the Privacy Policy and the Terms and Conditions, jointly or severally, from time to time, so that they reflect technological, business, legal or regulatory changes. Updates relating to the Privacy Policy as aforesaid will be published in this document, which can be found in its current version on the website.
    4. Before using the company’s services, please make sure that you have read the terms of the Privacy Policy carefully and that you understand them. Your use of the company’s services, including browsing the site, will be considered your express and informed consent to all the terms, conditions and notices contained in the Privacy Policy. If you do not agree to the terms of the Privacy Policy, in whole or in part, do not use the company’s services, including browsing the website and/or the application.
  2. Definitions
    1.  ‘The Law’ – Any legislation applicable to the company regarding privacy
    2. ‘The services’ or ‘the company’s services’ – all the services provided to the user through the company and/or its agents, whether services that involve providing information or services that do not involve providing information, including browsing the site.
    3. ‘Personal information’ – means any data or information that you will provide to the company voluntarily on the site according to the purpose of your request to the company, which identifies or makes it possible to identify you personally (such as your name, email address, ID no., means of payment, etc.), and any information that constitutes ‘information’ and/or ‘sensitive information’ according to their definition in the Law.
    4. ‘Anonymous information’ – means statistical information, which does not identify or allow the identification of the user personally, which is related to the terminal device through which the user makes use of the site (such as the manner of using the site, the type of the user’s browser, the date and time when the user entered the site, etc.).
    5. ‘You’ or ‘user’ – any person who makes use of the company’s services (as defined above), including through a computer and/or another terminal device for any purpose whatsoever.
  3. Collection of personal information
    Within the framework of using the services, you may be required to provide, and the company may collect, your personal information or personal information about you through various technological means, including by recording the actions performed by you on the company’s website. The type of personal information that you will provide and/or that will be collected by us may vary, depending on the reason and/or purpose for which you are contacting us.

    It is clarified that you are not required to provide these details according to law, and providing them depends solely on your free will and consent, in order to receive the requested services of the company. However, the provision of some of them is required by the provisions of the law, as well as in order to provide you with the services requested by you, in whole or in part. 

    By using the site and providing information to the company, you hereby declare and undertake as follows: (a) the personal information you provide on the site is true and accurate and the information provided is provided only for you and on your behalf. You are aware that knowingly providing incorrect or false information may amount to a criminal offense; (b) you hereby grant the company a right of use that is irrevocable, non-exclusive, unlimited by time and transferable, for no consideration or without any right to receive royalties, to make any use of the information as stated in the Terms and Conditions and the Privacy Policy, subject to any law and at the company’s discretion, without obtaining additional authorization and without having any financial and/or other complaint and/or demand and/or any claim in connection with the aforesaid right of use.
    1. Personal information within the framework of the services
      1. In order to perform operations on the site, you will be required to provide various types of personal information, such as an ID or passport number, a telephone number, address and email address.
      2. Personal information that you provide within the framework of submitting various requests for the use of the company’s services (including by completing forms): the personal information that you will be required to provide may vary according to the nature of the operation that you wish to perform through the company. Thus, for example, operations relating to the transfer of money will require you, inter alia, to provide details about the name of the beneficiary to whom you wish to transfer money, the destination country for the transfer of money, etc. If you give another person a power of attorney to act on your behalf, you will be required to provide your details and the details of the person having a power of attorney.
      3. Additional information about you may be collected and stored within the framework of using the services, such as correspondence with representatives and/or automated representatives, personal content (such as the subjects of the transfer of the payment to the beneficiary), in-application chat, your bank account number and any information related to your use of the services, for the purpose of providing them and according to your request.
    2. Personal information that you provide about another person

      If within the framework of the services you are required to provide information about another person (such as when making money transfers, you are required to provide details about the beneficiary), you declare and undertake that you are authorized and have the consents required by law to provide his personal information to the company for the uses that the company makes of such information according to this Privacy Policy.
    3. Use of personal information

      According to the Law, you are aware and give your informed consent that the company may receive and collect personal information about you for the following purposes and uses (which may be updated from time to time):
      1. Use of the information to improve, manage and operate the services offered to you, to contact you, to make decisions about you or others, including on matters of fraud prevention, fraud detection and/or other illegal activity, the security of the services, operational purposes, and risk assessment and management.
      2. If you tried to register on the site in order to use our services and your attempt failed, the company may contact you in order to help solve any problem you encountered in the registration process.
      3. For direct mailing purposes: the company can use, process, streamline and improve the aforementioned information, including through an information provider, for the purposes of managing, streamlining, adapting and marketing the company’s services and products, inter alia by creating a characterization about you, including by offering marketing offers that are customized for you personally, and for making use of statistical data, as stated in section 5 below.
      4. The company may send you operational and/or service messages and warnings in various ways, including by email or text messages, such as a text message containing an identification code for access to the site, and various uses of the services.
      5. The company will be entitled to contact you, including by way of sending advertising mail, and offer you special offers, benefits and promotions, in connection with its products and services, by email, text messages, telephone or other means. You can request to have your details removed from the distribution of marketing communications in general by contacting the email address [email protected] with a message entitled ‘Removal request.’
      6. GMT will only delete the Information which is required to contact you for marketing communications, while the rest of the Information you submitted to us which is necessary to provide you with the Service will continue to be processed and used.
  4. Transfer of information to third parties
    The company may transfer information about you to third parties, from time to time, in several cases as stated below and/or in any other case where a transfer will be required, including a transfer of information outside the borders of Israel:
    1. Within the framework of operations with third parties to complete the operations requested by you and/or when necessary for the operation of the services, including a cloud service provider. In this context, the provision of information is also expected to be required by any other party involved in payment services, including banks, credit card companies or other issuers of means of payment, clearers, consortiums and payment service providers, or beneficiaries of payments.
    2. Within the framework of outsourcing the company’s operations and/or receiving services from various suppliers, including financial service providers, cloud service providers, payment processors, customer relationship management (CRM) software providers, email/SMS marketing service providers, IT support and maintenance contractors, document management and storage service providers, accounting and financial services providers and call center firms.
    3. Within the framework of its operations with business-related companies, for the use purposes declared and permitted under any law, for the provision of the services.
    4. The company will be entitled to transfer personal information to competent authorities in Israel or outside Israel and/or according to a court order and/or to the extent necessary for protecting the company’s rights and assets and/or insofar as the provision of such information is required by law, such as the details required under anti-money laundering laws or the sending of (current and/or special) reports that the company is required to make about its operations and the operations of the users of its services, even without it needing to notify you before and/or after making the report, at its discretion.
    5. Without derogating from all the aforesaid, the company will be entitled to transfer anonymous information to third parties as stated in section 7.4 below, without limitation. Since this is information that does not identify you personally, you release the company from any claim and/or demand and/or complaint against the company for this.
    6. You are aware that information may be transferred to third parties located outside Israel, including countries that provide less privacy protection than the protection afforded under the laws of the State of Israel. By using the company’s services, you give your informed consent to this according to the terms and conditions stated in this policy document.
    7. The company undertakes that the transfer of information to third parties will be limited solely to the purposes listed in this policy and only to the extent and degree required according to the company’s discretion.
    8. The company will make appropriate efforts to ensure that the recipients of the information will be subject to a duty of confidentiality and information security regarding the information, according to every law. Notwithstanding this, the user declares and agrees that the company cannot guarantee absolute immunity against unauthorized penetration of the site and/or prohibited use by third parties of the user’s details and information about him stored by the company, and the company will not be liable for any damage caused because of unauthorized penetration and/or prohibited use as aforesaid.
  5. Collection of anonymous information
    1. When you use the site and/or the application, the company collects information that is sent to it by the computer, mobile phone or another device that you use for using the site and/or the application, which is anonymous information, i.e., information that does not identify you personally and cannot be associated with you.
    2. The anonymous information sent to us may include, inter alia, data about the pages visited by users, the device type, details of the computer and connection, network details for mobile devices, statistical data about page views, interface language, traffic to and from the site, the URL address from which the browser came to the site, etc.
    3. The company analyzes and uses anonymous information itself or through someone acting on its behalf for the purposes stated below (insofar as they will change from time to time): (a) evaluating how the users use the site for the purpose of managing, improving and promoting the site; (b) repair of malfunctions; (c) improving the experience of using the site; (d) analysis and breakdown of browsing patterns on the site; (e) customizing advertisements according to browsing habits; (f) any other lawful purpose that we think fit.
    4. The company will be entitled to transfer anonymous information to third parties acting on its behalf for the purpose of realizing the above purposes and for any other lawful purpose that it thinks fit. Since this is information that does not identify the user personally, the user hereby waives any claim and/or complaint and/or demand against the company regarding the aforesaid.
  6. Cookies
    1.  Cookies are text files that the user’s browser creates according to a command from the company’s computers. Some cookies will expire when you close the browser or the relevant application, whereas others are stored in the memory of your device or computer.
    2. Please note that for the purpose of providing some of the services, the company uses information-accumulating software, such as cookies, pixels and tags (hereinafter collectively referred to by the generic name ‘cookies’) for their current and proper operation, for the purpose of securing the data in them and the information provided, including to collect statistical data about the use of the services, for making decisions about the services and/or your activity, for the purpose of verifying details and identification, preventing fraud and deceptions, in order to improve the browsing experience, while adapting the content and services to your personal preferences, for the purpose of characterizing the products that are suitable for you, to customize advertisements that are relevant to you, even when browsing other sites, all of which for statistical, research, marketing and commercial purposes, and of course for information security purposes.
    3. The cookies contain and collect a variety of information such as the pages that you visited, the length of time you were on the site and/or the application, from where you came to the site and/or page, your IP address, the characteristics of your device, and information you want to see when entering the site, etc. Moreover, the cookies may store information about your browsing habits on other websites, including the sites that you browsed, the pages on the sites and any other action on them. The information in cookies is encrypted, and the company takes precautions to ensure that only its computers or someone acting on its behalf can read and understand the information stored in them.
    4. The services may also use third-party cookies, such as Google cookies that are embedded in Google Analytics, which help us customize the browsing or use experience for you and derive statistical insights about all the uses of the services. More information about these cookies can be found on Google’s site at the address https://www.google.com/intl/en/policies/technologies/ads/ and in Facebook’s cookie policy at the address https://www.facebook.com/policies/cookies/.
  7. Information security
    1. In order to create a personal area on the site, you must enter, inter alia, a password according to the instructions that appear on the site and/or the application. Entry to the site is by means of personal details and a one-time password (OTP) that will be sent to the mobile number that appears in the company’s systems. You need to report to the company any unauthorized use of your details.
    2. Please note that any entry to the site that will be made with your identifying details (for example, your ID number and/or password, including any personal information that will be provided when using them) will be considered an entry made by you, and you release the company and everyone acting on its behalf from any liability or responsibility for unauthorized use that will be made of your name, your details and the results of the use as aforesaid.
    3. The company uses generally accepted information security technologies and will make reasonable efforts to ensure that the site is free of ‘viruses,’ ‘worms’ and ‘Trojan horses.’ The company will operate and implement market-accepted procedures (including encryption techniques) for securing your personal information against unauthorized access, use or disclosure. However, you are aware that despite the aforesaid, this does not provide absolute security for the information that you will provide to the company (whether it is actually stored in the company’s data systems or is saved and stored with a cloud provider or providers).
    4. Therefore, it is your responsibility to take basic safeguards on your computer or terminal device that you are using (including installing antivirus software, locking a computer, changing passwords, etc.) in order to protect your personal information.
  8. Saving of information, right of inspection, correction and deletion of information
    1. As a rule, your personal information or personal info about you will be stored in the company’s database(s) for the period of time necessary for the company to provide the services requested by you, as applicable, and as long as the company has a legitimate need or legal or other obligation to keep it under any law. Anonymous information will be stored in the company’s information systems indefinitely (as long as this is not prohibited by law).
    2. You are entitled to inspect the information about you stored by the company. Someone who wishes to inspect such information will contact the company in writing, and the company will allow any user about whom information is stored to inspect this information. A user interested in inspecting such information should contact the company’s offices by mail or by email to the address [email protected]. A user who has inspected the information about him that is stored by the company and found it to be incorrect, incomplete, accurate or out of date may ask the company to correct or delete the information by contacting the company’s offices by mail or by email to the address [email protected]. For the avoidance of doubt, the transfer of a request to correct or delete such information does not obligate the company to act according to the user’s request. Personal information that is required by the company for the purpose of continuing to conduct its business and/or necessary for a legitimate purpose such as defending itself against claims (all of which to the extent necessary) will continue to be kept by the company for the time required by it according to law.
  9. Duration of holding the information
    1. We take appropriate steps to ensure that the information in our possession is reliable for the purpose of using it, and accurate and complete as required for implementing the purpose of this Privacy Policy. We will retain information about you for the period necessary to ensure the purposes stated in this Privacy Policy, unless a longer holding period is required or permitted by law and/or the terms of the concession.
    2. Information that we need for conducting our business, including documentation of operations that you made in connection with the site and/or the services or for the purpose of continuing to provide the services in the future will continue to be stored by us according to law.
  10. Miscellaneous
    1. The company may change the Privacy Policy at any time, at its sole discretion and without giving notice thereof. The binding and effective version of the Privacy Policy is the version published on the site at the relevant time of use.
    2. Insofar as it will be determined by a court and/or any other agreed authority that any term or condition of the Privacy Policy is illegal or invalid, that term or condition will be modified to the requirements of the law in a manner that preserves its original purpose and meaning, and the cancellation and/or modification will not prejudice, derogate from or modify the other terms of the Privacy Policy.
  11. Contact us

    If you have any questions or requests concerning your personal data or about our privacy practices and policies, you may contact the company’s representative for privacy matters, the supervisor for fulfilling the obligations of the prohibition of money laundering and terrorist financing at: [email protected] and/or by telephone number 03-3722800 and/or by WhatsApp number 054-7228005. 

    If you have any complaints about any service you received from the company, you can contact the person in charge of handling public complaints at the company, whose name is Shir Tamuz. You can contact the supervisor using the following means of communication: by phone at 03-3722800 extension 734; by email at [email protected]; or by mail at Raul Wallenberg 18, Building C, 1st floor, Tel Aviv.

Version: March 2024

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