Cookie Policy
1. POLICY AMENDMENTS
We reserve the right to amend this Privacy Policy from time to time, at our sole discretion. The most recent version of this Privacy Policy will always be posted on the Website and the update date will be reflected in the “Last Updated” heading. We will provide notice if these changes are material, and, where required by applicable law, we will obtain your consent for such changes. Any amendments to the Privacy Policy will become effective immediately, unless we notify otherwise.
2. CONTACT INFORMATION
For any question, inquiry or concern related to this Privacy Policy or the processing of your Personal Information, you may contact us at contact@shalemplatform.com..
3. WHAT INFORMATION DO WE COLLECT AND WHY?
You are not required to provide us with any Personal Information. However, using our Services require processing of Personal Information, or otherwise sensitive information.
“Personal Information”: is individually identifiable information, namely information that identifies an individual or may with reasonable efforts or together with additional information we have access to, enable the identification of an individual, identification of an individual also includes the association of such individual with a persistent identifier such as a name, an identification number, persistent cookie identifier, etc. Personal Information also includes Sensitive Personal Information which is Personal Information that reveals an individual’s sensitive identity, such as financial records, social security, etc.
“Non-Personal Information”: is information that does not personally identify an individual and includes technical information such as the type of device, time stamp, ISP or Personal Information that has been anonymized or aggregated, provided that such information can no longer be used to identify a specific natural person. For the avoidance of doubt, any Non-Personal Information connected or linked to Personal Information shall be deemed as Personal Information as long as such connection or linkage exists and identifies a natural person.
The table below details the types of information we collect, access, share or use, and the purposes for processing such information:
VISITORS | |
Information we Collect | Why do we Collect this Information |
Contact Communications: Where you contact us with any inquiries, through any means of communications we make available (e.g., an online form available on the Website, email correspondence, chat, social media chats, toll free number, customer support, etc.), you will be requested to provide us with your contact information such as your name, email address telephone number, and any other information needed to identify you, or any information you choose to share with us through your correspondence or other communications with us (collectively “Contact Communications”). | We will use your Contact Communications for the purpose of responding to your inquiries and provide you with the support or information you have requested. Our correspondence with you, and its content, may be further processed and stored by us in order to improve our customer services as well as in the event we reasonably determine it is needed in order to comply with any regulatory requirement, or for handling and defending against any dispute you might have with us. |
Newsletter: In the event you sign up to receive our newsletter, blogs, updates or other marketing materials, you will be requested to provide your contact details, such as your email address. | We use this information in order to send you the content you requested or other marketing materials. We will further store this information in order to include you in our marketing lists, as well as the “opt-out” list (solely the necessary information for such purpose), and to ensure we respect your choice and comply with applicable laws in this regard. |
Demo Session: In the event you choose to book a demo session for our Services you will be requested to provide us with certain information such as your name and additional information regarding your business (e.g., email address, phone number, state, etc.) (“Demo Session Information”). | We will use your Demo Session Information for the purpose of providing you with the demo services you have requested. We will also use your Demo Session Information for Direct Marketing. |
Direct Marketing: When registering for a demo session or other similar forums, we will send you service communications and marketing promotions, such as additional offerings, special opportunities or any other information we think you will find valuable (“Direct Marketing”). | We will use your information in order to keep you updated with offers and content such as service updates, new capabilities and features, surveys, etc. |
RETAILERS | |
Retailer Onboarding: If you register as a Retailer to our Services and created an account, we will collect your information provided during the registration process, such as your full name and additional Business contact details such as phone number, email address, etc. (“Contact Information“) Following such registration process, Retailer will designate additional users as its authorized users using the account, how will be required to provide their contact details such as names, user names and passwords. (collectively with the Contact Information, “Retailer Onboarding Information“) | We use your Retailer Onboarding Information to create and designate your account, authentication and validate access, enable log-in for additional authorized users, access and use of your account as well as to send you needed information related to our engagement (e.g., billing and invoicing). In addition, we use this information for Direct Marketing purposes (as defined above), meaning, as a Retailer we may send you marketing related communications (by email or other contact details you have provided), materials and content regarding the Services you are currently using or any services we may offer in the future to keep you up to date, and for example, offers and content such as updates, new capabilities and features, surveys, etc. |
Retailer Support: When you contact us for support, we will process your Contact Information. | We will use the Contact Information to provide you with the customer support needed. We will retain such correspondence for as long as needed, and to evidence the support was provided. |
BUYER | |
Information Provided By The Retailer: In order to use the Services, the Retailer is required to provide certain information regarding the Buyer, including its full name, email address, a photocopy of his driver license or ID card, address including state, date of birth, SSN, etc. | We will use the information provided by the Retailer regarding the Buyer in order to provide the Services and obtain a Credit Check as detailed below under Section 7. We will further retain such information as necessary in order to comply with our legal obligation as imposed by applicable laws, such as reporting to credit bureaus, third party collecting companies, etc. |
Credit Check Report: In order to use the Service Shalem, through third party service providers, obtains a Credit Check (as defined below) regarding the Buyer, which will include, inter alia, the types of credit accounts you have had, your payment history and certain other information such as your credit limits (“Credit Check Information“). | We use your Credit Check Information in order to provide our Services and assist the Retailer in determining the Buyer’s suitability for an installment plan. |
Please note that the actual processing operation per each purpose of use detailed in the table above may differ. Such processing operation usually includes a set of operations made by automated means, such as collection, storage, use, disclosure by transmission, erasure, or destruction.
In addition, we may use certain Personal Information to prevent potentially prohibited or illegal activities, fraud, misappropriation, infringements, identity thefts, and any other misuse of our services and to enforce our terms of use and other policies, as well as to protect the security or integrity of our databases and Service, and to take precautions against legal liability.
4. HOW WE COLLECT YOUR INFORMATION
Depending on the nature of your interaction with us, we may collect Personal Information as follows:
- Automatically – we use cookies or similar tracking technologies to gather some information automatically when you interact with our Services and Website (as elaborated under Section 5 “Cookies and Similar Tracking Technologies” below).
- Provided by the Retailer – we will collect information as provided to us by the Retailer in order to obtain a Credit Check.
- From third parties who assist us in the performance of our Services – for example, from third party service providers who perform the Credit Check.
- Provided voluntarily by you – we collect information as provided to us by you, for example, when you, as a Retailer, create an account or contact us for support, or when you, as our Website Visitor, contact us directly through any online form available through the Website, etc.
5. COOKIES AND TRACKING TECHNOLOGIES
We may use data files such as cookies, pixel tags or similar tracking technologies when you access to, interact with, or use our Website. The use of cookies is a standard industry-wide practice. A “cookie” is a small piece of information that a website assigns and stores on your computer while you are viewing a website. Cookies can be used to recognize you as a user; customize our Website and the services therein, content, and advertising; measure promotional effectiveness; help ensure that your account security is not compromised; mitigate risk and prevent fraud; and to promote trust and safety across our Website. Please read our cookies list page here for more information about the cookies we use.
You can find more information about cookies here: www.allaboutcookies.org.
Please note that, most browsers will allow you to erase cookies from your computer’s hard drive, block acceptance of cookies, or receive a warning before a cookie is stored. You may set your browser to block all cookies, including cookies associated with our Website, or to indicate when a cookie is being used by us, by adjusting the privacy and security settings of your web browser. Please refer to the support page of your browser to learn more about how you can adjust your privacy and security settings. Please note that once you choose to opt out or disable cookies, some features of our Website may not operate properly and your online experience may be limited. In addition, even if you do opt-out, you may still receive some content and advertising, however, it will not be targeted content or advertising.
Where we use third-party advertising cookies, such third-party may independently collect, through the use of such tracking technologies, some or all types of Personal Information detailed above, as well as additional data sets, including to combine such information with other information they have independently collected relating to your online activities across their network of websites, for the purpose of enhanced targeting functionality and delivering personalized ads, as well as providing aggregated analytics related to the performance of our advertising campaign you interacted with. These third parties collect and use this information under their own privacy policies, and are responsible for their practices.
6. SHARING PERSONAL INFORMATION WITH THIRD PARTIES
We may share your Personal Information with third parties (or otherwise allow them access to it) only in the following manners and circumstances:
- Trusted Third Party Service Providers: We partner with a number of selected service providers or business associates, whose services and solutions complement, facilitate and enhance our own. These include credit check agencies, hosting, cyber security services, fraud detection and prevention services, website and platform functionality, account maintenance, email marketing and telemarketing services, advertising, data optimization, affiliation and related analytics services, customer support, as well as our business, legal and financial advisors, and others. Any disclosure or access to Personal Information is strictly subject to the recipient’s or user’s undertaking of confidentiality and appropriate safeguards obligations. These third-party service providers have limited access to your Personal Information solely as needed to perform their services.
- Debt collection agencies or credit bureaus: when you fail to provide payments to the Retailer, we may, as permitted by applicable laws, share your Personal Information with debt collection Agencies which will assist Retailer in collecting the applicable payments.
- Other third parties with your consent or direction to do so.
- Governmental/Law Enforcement Agencies and Legal Requests or Duties: We may disclose or otherwise allow access to Personal Information pursuant to a legal requirement or request, such as a subpoena, search warrant, court or administrative order, or in compliance with applicable laws and regulations. Such disclosure or access may occur with or without notice to you, if we have a good faith belief that we are legally required to do so, or that disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, adverse event or other wrongdoing.
- Enforcement: We may disclose Personal Information to enforce our policies and agreements, as well as defend our rights, including the investigation of potential violations thereof, alleged illegal activity or any other activity that may expose us, you, or other users to legal liability, and solely to the extent required. In addition, we may disclose Personal Information to detect, prevent, or otherwise address fraud, security, or technical issues, solely to the extent required.
- Protecting Rights and Safety: We may share your Personal Information with others, with or without notice to you, if we believe in good faith that this will help protect the rights, property or personal safety of Shalem, of any of our Retailers, or any members of the general public.
