SUFRESCA PRIVACY POLICY (“PRIVACY POLICY”)

IMPORTANT: BY VISITING SUFRESCA’S WEBSITE AT: https://www.sufresca.com/ (THE “Website”) AS MADE AVAILABLE BY SUFRESCA LTD. (“COMPANY” OR “WE“) TO YOU, (“YOU“) YOU HEREBY CONSENT TO THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY AND TO THE COLLECTION OF ANY PII (DEFINED BELOW) THAT YOU SUBMIT OR THAT IS PROCESSED THROUGH OR IN CONNECTION WITH YOUR USE OF THE WEBSITE. ALL PII WILL BE PROCESSED BY THE COMPANY IN THE MANNER AND FOR THE PURPOSES DESCRIBED HEREIN.

“PII” MEANS ANY INFORMATION RELATING TO AN IDENTIFIED OR IDENTIFIABLE NATURAL PERSON; AN IDENTIFIABLE NATURAL 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, AN ONLINE IDENTIFIER OR TO ONE OR MORE FACTORS SPECIFIC TO THE PHYSICAL, PHYSIOLOGICAL, GENETIC, MENTAL, ECONOMIC, CULTURAL OR SOCIAL IDENTITY OF THAT NATURAL PERSON.

If you have any questions about this Privacy Policy, please feel free to contact us at: info@sufresca.com

1. Information We Collect and How We Use It.

We collect personal data about visitors of our Website. We use PII to provide and improve our Websites and services, and to meet our contractual, ethical and legal obligations. We may collect and process PII, including the following types of information:

• User Communications. When you send emails or other communications to the Company, we ask you to provide PII, including, your full name, business affiliation, email address, and phone number. We retain those communications in order to process your inquiries, respond to your requests and improve our Webite and services. We may also send you newsletters and promotional communications, you may opt-out of this service, including participation in mailing list, at any time by submitting a request at the following email [info@sufresca.com].
• Usage Information. When you use the Website, we automatically receive and record information from your browser, including without limitation information and statistics about your online/offline status, your IP address, geolocation data (including country and city), device identifiers, internet service provider, connection speed, search history, type of browser, your regional and language settings and software and hardware attributes. Our systems automatically record and store technical information regarding the method and nature of your use of the Website. An IP address is a numeric code that identifies your browser on a network, or in this case, the Internet. Your IP address is also used to gather broad demographic information. The Company uses all of the PII identified in this Section in order to understand the usage trends and preferences of our users, including recent visits to our Website and how you move around different sections of our Website for analytics purposes and in order to make our Website more intuitive.
• Aggregate and Analytical Data. In the effort to produce insights regarding use of the services in order to improve our services and develop and improve automated processes on our Website, other information provided to us. This research is compiled and analyzed on an aggregate basis, and we share this aggregate data with Company’s affiliates, agents and business partners and also disclose aggregated information in order to describe our services to current and prospective business partners or investors. This aggregate information does not identify you or your customers or employees personally.

2. Cookies. In order to collect the data described herein we may use temporary cookies that remain on your browser or device for a limited period of time. We may also use persistent cookies that remain on your browser, in order to manage and maintain the Website and record your use of the Website. Cookies by themselves cannot be used to discover the identity of the user. A cookie is a small piece of information which is sent to and stored on your browser. Cookies do not damage your browser or device. Most browsers and devices may allow you to block cookies but you may not be able to use some features on the Website if you block them. You may set most browsers or devices to notify you if you receive a cookie (this enables you to decide if you want to accept it or not). We may also use web beacons via the Solutions to collect information. Web beacons or “gifs”, are electronic images that may be used in our Solutions or in our emails. We use Web beacons to deliver cookies, count visits and to tell if an email has been opened and acted upon.

We may use remarketing services to inform you of new programs, blogs and opportunities by placing ads on third party web sites to you. We and our third-party vendors, use cookies to inform, optimize and serve ads based on your past visits to our Website.

3. Links to other services, sites and applications are provided by the Company as a convenience to our users. The Company is not responsible for the privacy practices or the content of other sites and applications and you visit them at your own risk. This Privacy Policy applies solely to PII collected by us.
4. If any of your data subjects (e.g. employees or customers) are minors under the age of 18, you must obtain parental consent prior to using our Website. The Company will not knowingly contact or engage with children under the age of 18 without said parental consent. If you have reason to believe that a child has provided us with their PII, please contact us at the address given above and we will endeavor to delete that PII from our databases.
5. Information Sharing. As part of providing the Website our agents, representatives and service providers will have access to your PII. We require these parties to process such information in compliance with this Privacy Policy and subject to security and other appropriate confidentiality safeguards. The Company will also share PII in the following circumstances: (a) as required for providing the Website; (b) for maintenance and improvement of the Website or the Company’s services; (c) if we become involved in a reorganization, merger, consolidation, acquisition, or any form of sale of some or all of our assets, with any type of entity, whether public, private, foreign or local; and/or (d) to satisfy applicable law or prevention of fraud or harm or to enforce applicable agreements and/or their terms, including investigation of potential violations thereof.
6. Data Security. We follow generally accepted industry standards to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of PII. However, 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 PII, we cannot guarantee its absolute security. We retain your PII only for as long as reasonably necessary for the purposes for which it was collected or to comply with any applicable legal or ethical reporting or document retention requirements.
7. Data Integrity. The Company processes PII only for the purposes for which it was collected and in accordance with this Privacy Policy or any applicable service agreements. We review our data collection, storage and processing practices to ensure that we only collect, store and process the PII needed to provide or improve our Website. We take reasonable steps to ensure that the PII we process is accurate, complete, and current, but we depend on our users to update or correct their PII whenever necessary. Nothing in this Privacy Policy is interpreted as an obligation to store information, and we may, at our own discretion, delete or avoid from recording and storing any and all information.
8. Rights of Data Subjects.
   • Right of Access and Rectification. Data subjects have the right to know what PII we collect about them and to ensure that such data is accurate and relevant for the purposes for which we collected it. We allow data subjects the option to access and obtain a copy of their PII and to rectify such PII if it is not accurate, complete or updated. However we may first ask data subjects to provide us certain credentials to permit us to identify their PII.
   • Right to Delete PII or Restrict Processing. Data subjects have the right to delete their PII or restrict its processing. We may postpone or deny such requests if the PII is in current use for the purposes for which it was collected or for other legitimate purposes such as compliance with legal obligations.
   • Right to Withdraw Consent. Data subjects have the right to withdraw their consent to the processing of their PII. Exercising this right will not affect the lawfulness of processing the PII based on consent obtained before its withdrawal.
   • Right of Data Portability. Where technically feasible, data subjects have the right to ask to transfer their PII in accordance with their right to data portability, if required pursuant to applicable law.

Data subjects may exercise the above rights by sending a request to info@sufresca.com

• Right to Lodge Complaint. Data subjects also have the right to lodge a complaint with a data protection supervisory authority regarding the processing of their PII.

9. The Company regularly reviews its compliance with this Privacy Policy. Please feel free to direct any questions or concerns regarding this Privacy Policy or our treatment of PII by contacting us as provided above. When we receive formal written complaints, it is the Company’s policy to contact the complaining user regarding his or her concerns. We will cooperate with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of PII that cannot be resolved between the Company and an individual.
10. Changes to This Privacy Policy. The Company may update this Privacy Policy. We will notify you about material adverse changes in the way we treat PII by sending a notice to the email address provided by you or by placing a prominent notice on the Website. We encourage you to periodically review this Privacy Policy for the latest information about our privacy practices. Our customers and business partners will be notified of such changes and are responsible to inform their data subjects.
11. Legal Justification and Consent To Processing. By providing any PII to us pursuant to this Privacy Policy, all users, including, without limitation, users in the United States, Israel and member states of the European Union, fully understand and unambiguously consent to this Privacy Policy and to the collection and processing of such PII abroad. The server on which the Website is hosted and/or through which the Website are processed may be outside the country from which you access the Website and may be outside your country of residence. Some of the uses and disclosures mentioned in this Privacy Policy involve the transfer of your PII to various countries around the world that may have different levels of privacy protection than your country and will be transferred outside of the European Economic Area. If there is a transfer of your PII outside the EEA we will, in the absence of an EC Adequacy decision relevant to the destination country or to the transfer, seek to rely on appropriate safeguards such as entering into appropriate EC approved standard contractual clauses (see http://ec.europa.eu/justice/data-protection/international-transfers/transfer/index_en.htm). By submitting your PII through the Website, you consent, acknowledge, and agree that we will collect, use, transfer, and disclose your PII as described in this Privacy Policy.
12. Your California Privacy Rights and Do Not Track Notices. California Civil Code Section 1798.83 permits customers of Company who are California residents to request certain information regarding its disclosure of PII to third parties for their direct marketing purposes. To make such a request, please send an email to info@sufresca.com. Please note that we are only required to respond to one request per customer each year. You are also advised that the Company does not respond to “Do Not Track” signals.

Last Date Updated: 16 March 2022