Privacy Policy
Shalem Platform Inc., a company organized under the laws of the State of Delaware (“Shalem”, “our”, “we” or “us”), is the owner, developer and operator of an online platform enabling retailers selling goods or services (“Retailer”), to offer their customers, buyers, and shoppers (collectively “Buyer”) installment sales (collectively “Services“). Each of a Retailer, Buyer and Visitor shall be referred to individually and collectively as “you“.
This Privacy Policy (“Privacy Policy”) describes how Shalem collects, uses and discloses certain information, including Personal Data (as defined below). This Privacy Policy is meant to help you understand what information we collect, why we collect it, how we safeguard it and how you can control it by exercising the rights granted to you by applicable data protection laws.
Applicability: This Privacy Policy applies where a Retailer or a Buyer is accessing to and using the Services, or merely when an individual is visiting or engaging with our website (“Visitor“) available at: https://shalemplatform.com/ and additional landing pages (“Website“).
This Privacy Policy governs the use, processing and sharing of Personal Data that applies to all individuals world-wide, however, certain jurisdictions require that applicable disclosures will be provided in a certain way and format, and therefore additional notices will apply as follows:
Additional Information to California Residents: If you are a California resident – please also refer to our CCPA Notice to learn more about our privacy practices with respect to the California Consumer Privacy Act.
Additional Information to Colorado Residents: In the event you are a Colorado resident – please also review our CPA Notice to learn more about our privacy practices and your rights under the Colorado Privacy Act.
Additional Information to Connecticut Residents: In the event you are a Connecticut resident– please also review our CDPA Notice to learn more about your rights under the Connecticut Data Privacy Act.
Additional Information to Virginia Residents: In the event you are a Virginia resident– please also review our VCDPA Notice to learn more about our privacy practices and your rights under the Virginia Consumer Data Protection Act.
Additional Information to Utah Residents: In the event you are a Utah resident – please also review our UCPA Notice to learn more about your rights under the Utah Consumer Privacy Act.
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. We recommend you review this Privacy Policy periodically to ensure that you understand our most updated privacy practices.
CONTACT INFORMATION
For any question, inquiry or concern related to this Privacy Policy or the processing of your Personal Data, you may contact us at privacy@shalemplatform.com.
INFORMATION COLLECTED BY SHALEM AND PURPUSES FOR USE
You are not required to provide us with any Personal Data. However, using our Services require processing of Personal Data, or otherwise Sensitive Data.
“Personal Data”: 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 Data also includes Sensitive Personal Data which is Personal Data that reveals an individual’s sensitive identity, such as financial records, social security, racial or ethnic origin, religious beliefs, mental or physical health condition or diagnosis, sex life or sexual orientation, genetic or biometric data, etc.
“Non-Personal Data”: is information that does not personally identify an individual, namely technical information such as the type of device, time stamp, and de-identified data (i.e., Personal Data which can no longer be attributed to a specific individual without the use of additional information).
The table below details the types of Personal Data we collect, access, share or use, and the purposes for collecting such information:
| VISITORS | |
| Data Sets We Collect | Why Do We Collect This Data |
| Online Identifiers and Behavior Data: When you interact with our Website we may collect your online identifiers, such as IP address and Cookie ID, unique identifiers, etc. (“Online Identifiers”). We further collect information regarding your use and interaction with our Website, this information includes the referring URL, the webpage directing you to our Website, and other websites you visited in the session, your interests in our competitors, how you interact with our webpage, time, duration of use, pages you have viewed or clicked on our Website. We are further able to track your behavior with other assets, such as- did you open and read the emails we sent (collectively “Behavior Data”) | Operation, Marketing and Analytics: Online Identifiers and cookies are used, in particular, to automatically recognize you the next time you enter the Website, to authorize you are a person, and to operate the website, enable its proper functionality. Behavior Data are indirectly processed by marketing and analytic tools, for analytic and remarketing purposes. You may opt-out or withdraw consent at any time by using the cookie preference settings available through our Website footer or through our Data Subject Request form available here. |
| Contact Communications: Where you contact us with any inquiries (i.e., the contact us page or support ticket), 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 Information”). | Newsletter Registration, Respond to Query: We will use your Contact Information for the purpose of responding to your inquiries. The correspondence and its contents with you may be processed and stored by us in order to improve our customer service and in the event we believe it is required to continue to store it, for example, in the event of any claims or in order to provide you with any further assistance (if applicable). We will use your Contact Information to send you emails and other information you requested. |
| RETAILERS | |
| Contact Information: In order to contact us for support or to use our Services (including the demo session) you will be required to register and open an account. During the registration process you will be requested to provide us with your Contact Information and additional information regarding your business. | Customer Support, Demo Session, Marketing and Account Creation: We will use the Contact Information to provide the customer support needed, the Services and to send you service communications, promotions, such as new features, additional offerings, special opportunities etc. (“Marketing“). We will retain such correspondence for as long as needed. |
| Payment Details: As part of the Services, you may need to provide us with your payment details including credit card and bank account information. | Billing Services: We use this information for billing purpose, for the purpose of enabling you to use the Services. |
| Usage Data: When you use the Services or access your account, we automatically process, generate and collect information on how you use the Services – the click streams within Services, the features used, duration, the credentials (access logs that identify your email, user name, and credentials), crash data and analytics, etc. We record how you interact with our Service. | Safety, Providing/improving the Services, and Operations: We use this information to help us to understand how you are using the Services, and how to better provide and improve our Services. This helps us to better understand our business, analyze our operations, maintain, improve, innovate, plan, design, and develop the Service and our new products. We also use such data for statistical analysis purposes, to test and improve our offers, decide how to improve the Service based on the results obtained from this processing. |
| BUYERS | |
| 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, and zip code, date of birth, SSN, etc. | Perform A Soft Credit Check as Required By Law, Provide the Services: We will use the information provided by the Retailer regarding the Buyer in order to provide the Services and obtain a Soft 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. |
| Payment Plan: When using the Services, we will obtain the Buyer’s installment plan details, including sale price, your down payment, APR, financial charge, type of goods purchased from the Retailer, etc. | Provide The Services: We will use the payment plan details provided to you by the Retailer for the purpose of providing the Services. To the extent applicable, and in accordance with the applicable laws, we will use your payment plan details in order to contact the collection company and obtain its services. |
| Soft Credit Check Report: In order to use the Services, and assist the Retailer determining the Buyer’s suitability for the Service, Shalem, through third party service providers, obtains an initial background check (and subsequent periodic follow-up checks where and if required) on the Buyer. Each Soft Credit Check may, without limitation, include a review of the following information: (i) credit history, including a hard or soft pull of a personal or business credit bureau data and score; (ii) criminal records; (iii) information that is publicly available about the Buyer; and (vi) whether the Buyer has ever been declared bankrupt (“Soft Credit Check Information“). Shalem may keep Soft Credit Check Information and use it for the purpose of authorizing any future transactions with the Retailer. | Provide The Services: We use your Soft 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 Data 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.
HOW WE COLLECT YOUR DATA
Depending on the nature of your interaction with us, we may collect Personal Data as follows:
- Automatically – we will collect your Online Identifiers and Behavior Data including analytics data (or use third-party measurement and marketing tools). For more information on the cookies we use and how to opt out of third-party collection of this information, please see our Section 5 below “Cookies and Similar Tracking Technologies”.
- Provided by the Retailer – if you are a Buyer, we will collect information as provided to us by the Retailer in order to provide the Services.
- From third parties who assist us in the performance of our Services – for example, from third party service providers who perform the Soft Credit Check or from data enrichment partners.
- 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.
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. The cookies and similar tracking technologies we use are detailed under the cookie list page appears on our Website footer.
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 Data 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.
SHARING PERSONAL DATA WITH THIRD PARTIES
We may share your Personal Data 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 Data 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 Data 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 Data 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 Data 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 Data 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 Data 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 Data 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.
INFORMATION SECURITY
Securing your Personal Data is of high priority. We design our systems with your security and privacy in mind. We have implemented physical, technical, and administrative security measures that comply with applicable laws and industry standards, such as encryption, access restrictions and permissions, etc.
Note that we cannot be held responsible for unauthorized or unintended access to your account or to our Services and Website beyond our control, and we make no warranty, express, implied, or otherwise, that we will always be able to prevent such access.
Please contact us at: privacy@shalemplatform.com, if you feel that your privacy was not dealt with properly, in a way that was in breach of our Privacy Policy, or if you become aware of a third party’s attempt to gain unauthorized access to any of your Personal Data. We will make a reasonable effort to notify you and the appropriate authorities (if required by applicable law) in the event that we discover a security incident related to your Personal Data.
DATA RETENTION
We retain Personal Data we collect as long as it remains necessary for the purposes set forth above, all in accordance with applicable laws, or until an individual expresses a preference to opt-out.
In certain circumstances, we will retain your Personal Data for longer periods of time and mainly:
- Where we are required to retain Personal Data in accordance with legal, regulatory, tax, or accounting requirements;
- Where we deem retention is necessary to obtain an accurate record of your dealings with us in the event of any complaints or challenges (e.g., adverse event); or
- If we reasonably believe there is a prospect of litigation relating to your Personal Data.
WHERE DO WE STORE YOUR DATA?
We maintain Personal Data that we collect from you in secured cloud storage environments provisioned by third party cloud providers in the United States. Nevertheless, any such information will be maintained and processed by us and our authorized service providers which are located in various locations around the world, including, without limitation, the United States and in our facilities in Israel.
It is our policy, irrespective of your jurisdictions, to maintain all Personal Data in secure environments provisioned by third parties that: (i) have assured us of the safeguards which they implement to protect your rights to privacy; (ii) where applicable, hold and process such information on our behalf in jurisdictions which have been determined to ensure an adequate level protection, or (iii) perform such processing pursuant to your consent and acceptance of such third-parties privacy policy as further detailed in this Privacy Policy. By providing your information, you expressly consent to the place of storage and transfer described above, including transfers outside of the jurisdiction in which the information was provided.
YOUR RIGHTS
We acknowledge that different people have different privacy concerns and preferences. Our goal is to be clear about what information we collect so that you can make meaningful choices about how it is used. We allow you to exercise certain choices, rights, and controls in connection with your Personal Data. Depending on your relationship with us, your jurisdiction and the applicable data protection laws that apply to you, you have the right to control and request certain limitations or rights to be executed.
For any question you have regarding your right, or if you wish to exercise them, please contact us at: privacy@shalemplatform.com
Certain rights can be easily executed independently by you without contacting us, for example:
- If you are our Retailer or authorized user, you can correct certain information provided under the account (such as contact information) through the account settings;
- You can opt-out from receiving our marketing emails by clicking “unsubscribe” link.
In the event you are a Retailer – note that termination of the engagement or closing your account does not automatically resolved in deletion of data. If you wish to delete the information, please ensure to contact us with such request.
In the table below you can review your rights depending on your interaction with us, how you can exercise them, and appeal a decision we take in this regard, any specification per geo-location or territory are available below the table:
| RIGHT TO KNOW (ACCESS) | You further have the right to know which Personal Data we specifically hold about you, and receive a copy of such or access it, if you wish to receive a copy of the Personal Data, please submit a Data Subject Request form (“DSR”) as available here. You do not need to create an account with us to submit a request to know or delete. |
| RIGHT TO CORRECTION | You have the right to correct inaccuracies in your Personal Data, taking into account the nature and purposes of each processing activity. At any time, you may correct any of the account information through your account, or otherwise you may submit a DSR as available here. |
| RIGHT TO DELETION | In certain circumstances, you have the right to delete the Personal Data we hold about you. Please submit a DSR as available here. |
| RIGHT TO PORTABILITY | You have the right to obtain your Personal Data in a portable, and to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance. We will select the format in which we provide your copy. If you wish to exercise this right, please submit our DSR as available here. |
| RIGHT TO OPT OUT FROM: (I) SELLING PERSONAL DATA; (II) RIGHT TO OPT OUT FROM TARGETED ADVERTISING; AND (III) RIGHT TO OPT OUT FROM PROFILING | Marketing: You have the right to opt-out from Marketing communications by unsubscribing through the email received. Newsletter: You have the right to withdraw consent when you no longer wish to be in our newsletter list. Cookies: You have the right to opt-out from cookies tracking your behavior for analytic and marketing purposes. Sale of Personal Data for targeted advertising, monetary gain or profiling, or Share or Sale of Personal Information for analytic or marketing: If and to the extent applicable, you have the right to opt out of the sale of your Personal Data, for the purposes of targeted advertising, sale to a third party for monetary gain, analytic, etc. through the cooking setting on our Website footer. Last, you are able to install privacy-controls in the browser’s settings to automatically signal the opt-out preference to all websites you visit (like the “Global Privacy Control”). We honor the Global Privacy Control, where applicable, subject to your jurisdiction, as a valid request to opt-out of the sharing of information linked to your browser. |
| RIGHT TO APPEAL | If we decline to take action on your request, we shall so inform you without undue delay as required under applicable laws. The notification will include a justification for declining to take action and instructions on how you may appeal, if applicable. |
| NON-DISCRIMINATION | Such discrimination may include denying a good or service, providing a different level or quality of service, or charging different prices. We do not discriminate our users. |
PROTECTING CHILDREN
Our Website and Services are intended for those who are over the age of 16, or equivalent minimum age for either providing consent to processing of Personal Data or using the Services in the relevant jurisdiction. If you are under such age, you are not permitted to use the Services or the Website. In certain jurisdictions using the Services may be restricted for Users under the age of 21.
JURISDICTION-SPECIFIC NOTICES
ADDITIONAL NOTICE TO CALIFORNIA RESIDENTS
This section applies to California residents only pursuant to the California Consumer Privacy Act of 2018 as amended by the CPRA (“CCPA”).
Please see the CCPA Privacy Notice which discloses the categories of Personal Information collected, purpose of processing, source, categories of recipients with whom the Personal Information is shared with for a business purpose, whether the Personal Information is sold or shared, the retention period, and how to exercise your rights as a California resident.
ADDITIONAL NOTICE TO COLORADO RESIDENTS
Under the Colorado Privacy Act (“CPA”) if you are a resident of Colorado, acting as an individual or in the household context only (and not in a commercial or employment context, as a job applicant or as a beneficiary of someone acting in an employment context), your rights with respect to your Personal Data are described below.
Under the Colorado Privacy Act (“CPA”), we are required to provide a privacy notice that identifies the following: in Section 3 to the Privacy Policy, we describe our collection and processing of Personal Data, the categories of Personal Data that are collected or processed, and the purposes for which Personal Data is processed, stored or used. We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated, or incompatible purposes without obtaining your consent. Additionally, Section 6 to this Privacy Policy details and discloses the categories of third-parties we share for business purposes. Section 10 to this Privacy Policy details and discloses your rights and Personal Data shared or sold for targeted advertising, if and to the extent applicable.
We will respond to your request within 45 days after receipt of a verifiable Consumer Request and for no more than twice in a twelve-month period. We reserve the right to extend the response time by an additional 45 days when reasonably necessary and provided consumer notification of the extension is made within the first 45 days. If we refuse to take action on a request, you may appeal our decision within a reasonable period time by contacting us at privacy@shalemplatform.com and specifying you wish to appeal. Within 60 days of our receipt of your appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied, you may submit a complaint as follows: Colorado AG at https://coag.gov/file-complaint/
Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable.
ADDITIONAL NOTICE TO CONNECTICUT RESIDENTS
This section applies to Connecticut residents acting only as an individual or household context (and not in a commercial or employment context or as a representative of business, non-profit or governmental entity).
Under the Connecticut Data Privacy Act (“CDPA”), we are required to provide you with a clear and accessible privacy notice that includes the following: in Section 3 to the Privacy Policy, we describe our collection and processing of Personal Data, the categories of Personal Data that are collected or processed, and the purposes for which Personal Data is processed, stored or used. We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated, or incompatible purposes without obtaining your consent. Additionally, Section 6 to this Privacy Policy details and discloses the categories of third-parties we share for business purposes. Section 10 to this Privacy Policy details and discloses your rights and Personal Data shared or sold for targeted advertising, if and to the extent applicable.
We shall respond to your request within 45 days of receipt. The response period may be extended once by 45 additional days when reasonably necessary, taking into account the complexity and number of requests and we inform you of such extension within the initial 45 days response period, together with the reason for the extension. If we decline to take action on your request, we shall so inform you without undue delay, within 45 days of receipt of your request. If we refuse to take action on a request, you may appeal our decision within a reasonable period time by contacting us at privacy@shalemplatform.com and specifying you wish to appeal. Within 60 days of our receipt of your appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied, you may submit a complaint to the Connecticut Attorney General at link: https://www.dir.ct.gov/ag/complaint/ or (860) 808-5318.
We shall provide information in response to your request free of charge, up to twice annually, unless requests are manifestly unfounded, excessive or repetitive. If we are unable to authenticate your request using commercially reasonable efforts, we may request additional information reasonably necessary to authenticate you and your request. If we cannot authenticate you and your request, we will not be able to grant your request.
ADDITIONAL NOTICE TO VIRGINIA RESIDENTS
This section applies to Virginia residents acting only as an individual or household context (and not in an employment or commercial context).
The Virginia Consumer Data Protection Act (“VCDPA”) requires us to disclose the following: in Section 3 to the Privacy Policy, we describe our collection and processing of Personal Data, the categories of Personal Data that are collected or processed, and the purposes for which Personal Data is processed, stored or used. We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated, or incompatible purposes without obtaining your consent. Additionally, Section 6 to this Privacy Policy details and discloses the categories of third-parties we share for business purposes. Section 10 to this Privacy Policy details and discloses your rights and Personal Data shared or sold for targeted advertising, if and to the extent applicable.
We will respond to your request within 45 days after receipt of a verifiable Consumer Request (no more than twice in a twelve-month period). We reserve the right to extend the response time by an additional 45 days when reasonably necessary and provided consumer notification of the extension is made within the first 45 days. If we refuse to take action on a request, you may appeal our decision within a reasonable period time by contacting us at privacy@shalemplatform.co and specifying you wish to appeal. Within 60 days of our receipt of your appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied, you may submit a complaint to the Virginia Attorney General at https://www.oag.state.va.us/consumercomplaintform.
Any disclosures we provide will only cover the 12-months period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable.
We shall provide information in response to your request free of charge, up to twice annually, unless requests are manifestly unfounded, excessive or repetitive. If we are unable to authenticate your request using commercially reasonable efforts, we may request additional information reasonably necessary to authenticate you and your request. If we cannot authenticate you and your request we will not be able to grant your request.
ADDITIONAL NOTICE TO UTAH RESIDENTS
