Hashkama N.G.N. International Communications 015 Ltd. ("hallo 015") Privacy Policy
1.1. Hashkama N.G.N. International Communications 015 Ltd. ("hallo 015") respects the privacy of the users of its services ("Users"). The purpose of these terms is to generally describe hallo 015's privacy policy and the manner in which it collects and uses personal information related to Users of hallo 015 services (including subscribers to hallo 015 services). "hallo 015 services" for the purpose of this policy include hallo 015's websites (including in application format); including the websites hallo 015.co.il, hallo 015 applications, as well as additional services as hallo 015 may offer from time to time.
1.2. Nothing in these terms shall derogate from what is stated in the engagement agreements between hallo 015 and the Users or from the terms of use of hallo 015's websites or from any other agreement (or other consent) between hallo 015 and the Users. It is possible that the engagement agreements or terms of use or the said agreements will include additional provisions concerning privacy, and in case of contradiction between the provisions of this policy and the provisions in the engagement agreement or the terms of use or another agreement as mentioned, the provisions in the said agreements or terms shall prevail.
1.3. This privacy policy applies to information that identifies or may reasonably identify the User personally ("Personal Information"). It does not apply to data that does not constitute Personal Information, data that does not relate to the private affairs of an identified person (such as aggregated or statistical data), and it does not apply to corporations.
1.4. There is no legal obligation to provide the Personal Information detailed below. However, providing incorrect information or failing to provide all required information may prevent joining or using hallo 015 services (all or part), impair the quality of service, or impair hallo 015's ability to contact the User if necessary.
1.5. Use of hallo 015 services constitutes the User's consent to this privacy policy and to the collection and processing of Personal Information about them according to it. hallo 015 may change the terms of the privacy policy from time to time. If material changes are made to this policy, a notice will be published on the website hallo 015.co.il. Continued use of hallo 015 services after the change in the privacy policy indicates the User's consent to the updated policy.
1.6. This policy is written in the masculine gender for convenience only and refers to both genders equally.
2. Types of Information Collected by hallo 015
hallo 015 provides and markets a variety of services, and for this purpose, it must collect, process, and use information about the Users of these services. The types of information may vary depending on the different services. Below are examples of the types of information that hallo 015 may collect, process, and use:
2.1. Identification details, contact information, and personal data – such as full name, ID number, address, email address, phone number, usernames and passwords for hallo 015 services and end-user equipment provided by hallo 015, voice searches in the various services, information provided or collected during communication with hallo 015 (for service and various inquiries) including call recordings and correspondence, information provided within surveys conducted by hallo 015, etc. Information entered by the User within hallo 015 services may be continuously captured during input, so that if the input is interrupted before the end of the process, hallo 015 can contact the User to complete the process.
2.2. Financial information – such as payment method details, charges and credits, including those of third parties processed through hallo 015, collection actions if performed, credit rating (subject to law), etc.
2.3. Information about the use of hallo 015 services – including the various actions taken by the User while using hallo 015 services, including, among other things:
2.3.1. Information about the use of hallo 015's internet services, including Browse data, such as websites visited by the User, internet services consumed by the User, Browse patterns, duration, and scope.
2.3.3. Information about the use of hallo 015's websites, including Browse times on the sites, duration and frequency of use and stay, types of content viewed on the sites and the extent of viewing and use, products and services purchased by the User on the sites, cookies, queries and searches on the sites, source of arrival to the sites, manner of use of other sites displaying hallo 015 ads and content, etc.
2.3.4. Information about the use of end-user devices, including routers and converters provided by hallo 015 – such as the devices used by the User, the Internet Protocol (IP) address from which the device operates, device identification (Device ID) and its geographical location, the operating system or browser used by the User, operating system version, information about the User's wireless network (including username and password), etc. Regarding end-user devices provided by hallo 015 – also information including technical data about the equipment, such as processor status, battery status, memory status, temperature, disconnections, data about the quantity and type of devices connected to the said end-user devices (including IP address, model, device name, language), etc.
2.2.5. Information about the use of hallo 015's international calling services, including usage data, such as calls to destinations and countries dialed and consumed by the User, dialing patterns, duration, and scope.
3. How Information is Collected and Stored
3.1. The types of information detailed above are collected by hallo 015 in the following ways:
3.1.1. Information provided by the User - during registration for hallo 015 services and during their use, as well as within various inquiries from the User.
3.1.2. Information collected by hallo 015 - during the provision and use of hallo 015 services, information is automatically collected in hallo 015 systems.
3.1.3. Information collected from third parties or hallo 015's outsourcing providers – information from third parties, including credit data service companies and legal databases, public information regarding the User, including from social networks; and information from hallo 015's outsourcing providers, such as marketers and subcontractors, network operators, etc.
3.1.4. Cookies - Some hallo 015 services use information-gathering software, cookies, and similar technologies, such as Conversions API, Enhanced conversion data (these will be generically called "Cookies") for their ongoing and proper operation, for securing the data and information provided, including collecting statistical data about the use of the services, for making decisions regarding the services or the User's activity, for verifying details and identification, preventing fraud and scams, for improving the Browse experience, by adapting content and services to the User's personal preferences, for characterizing products suitable for the User, to tailor relevant advertisements for the User, even in other applications or while Browse other sites, all for statistical, research, marketing, and commercial purposes, as well as for information security needs. Cookies, generally and briefly, are text files that the User's browser or application creates according to commands from the company's computers. Some cookies will expire when you close the relevant application, while others are saved on your device's memory. Cookies contain and collect information such as the content the User viewed, the duration the User spent in the viewing applications or websites, the User's IP address or Device ID, device characteristics, and more. Cookies allow, among other things, the collection of statistical data on the use of hallo 015 services, in order to adapt hallo 015 services to the User's personal preferences and for information security needs. Cookies may also store information about the User's viewing and usage habits on other sites, the pages on websites or viewing applications, and any other action therein. The services may also use third-party cookies – for example (as an example only) cookies from companies like Google (such as those embedded using Google Analytics), Meta Platforms, Taboola, OutBrain, TikTok, ReCaptcha, Firebase. This list is not exhaustive, and hallo 015 may use cookies from additional third parties. Information about the use of cookies by these third parties can be found on the websites of those third parties. For example: - Information about cookies embedded using Google Analytics, which help hallo 015 tailor the Browse or usage experience for the User and derive statistical insights regarding all uses of the services, can be found on Google's site at - www.google.com/policies/privacy/partners. Google allows users to prevent their information from being used by Google Analytics. For more information, see https://tools.google.com/dlpage/gaoptout. - Information about cookies from Meta Platforms Inc. can be found at https://www.facebook.com/privacy/policies/cookies. If the User does not wish to receive cookies, they can change the settings on their device. Additionally, cookies can be deleted from the computer at any time. However, deletion may result in hallo 015 services not being tailored to the User's preferences, and deleting or disabling cookies may cause the User to be unable to use some hallo 015 services and impair the user experience.
3.2. Information about third parties – The User must provide only correct, reliable, and accurate information, only in the name of and for the User, and not in the name of or for third parties, except as detailed below. If the User provides hallo 015 with, or causes hallo 015 to possess, personal information of a third party (whether proactively or by authorizing a third party to use hallo 015 services), the User declares that they have received the explicit consent of the third party for the provision of the information. The reference to the third party's information in this policy is as the User's information, and in any case, the responsibility towards that third party shall lie with the User. It is possible that third parties using a specific hallo 015 service will have access to information about other users of the same service (for example, viewing history in hallo 015 viewing applications which includes information concerning all users under the same subscription, viewing recommendations based on content watched by all users in the subscription, viewing profile of another user in the subscription), and the User and the third parties will have no claims regarding this against hallo 015.
3.3. Storage and handling of information – The Personal Information collected by hallo 015 will be stored and handled in accordance with the provisions of the Privacy Protection Law, 5741-1981 ("Privacy Protection Law"), including its storage in registered databases. The information will be stored on hallo 015's servers or on servers of third parties, including through cloud services, as detailed below. The use of the information will be in accordance with the purposes of the said database and as stated in this policy.
3.4. Withdrawal of consent for providing or collecting information – If a user who already uses hallo 015 services decides to withdraw their consent as stated or part of it, hallo 015 shall be entitled to view this as a request to disconnect from hallo 015 services, subject to the provisions set forth in this regard in the engagement agreements or terms of use.
4. Purposes of Using Information
hallo 015 may use the information for the following purposes:
4.1. Providing hallo 015 services – including managing and operating hallo 015 services, verifying and identifying the User in hallo 015 services, collecting payments, preparing and sending bills, and contacting the User for any reason.
4.2. Adapting hallo 015 services to the User's needs – for example, according to usage patterns of hallo 015 services, displaying links, recommendations, and personalized offers within hallo 015 services.
4.3. Marketing and service activities – including through direct marketing and including through enriching and enhancing information for these purposes, determining a User's eligibility for various benefits that hallo 015 may offer from time to time, sending service messages to the User including debt notices;
4.4. Sending advertising materials (including offering services or products on behalf of hallo 015 or jointly with third parties, including related entities of hallo 015), via electronic message, short message service (SMS or MMS), or automated dialing system, regarding advertising messages (including from third parties and related entities of hallo 015) of a similar type to hallo 015's products and services, and subject to the User's consent also for advertising messages that are not of a similar type. A user who does not wish to receive advertising materials through one of the detailed above or does not wish for their information to be used for direct marketing purposes may contact hallo 015 at any time and notify their refusal as stated or update their preferences through the hallo 015 website or various means offered by hallo 015. hallo 015 may continue to send the User messages whose removal is not required by law or which the law permits or requires sending.
4.5. Improving and developing hallo 015 services – including through research and surveys, monitoring and analysis of information, and for various statistical purposes.
4.6. Security – securing hallo 015 services, preventing fraud, detecting scams or other illegal activity, securing the services including blocking a user misusing hallo 015 services.
4.7. Legal purposes – enforcing hallo 015's rights according to this policy, the engagement agreements, and terms of use; complying with legal requirements, administrative authorities, and courts; protecting hallo 015's rights.
4.8. For any other purpose detailed in this privacy policy or in the engagement agreements or terms of use, and any other purpose permitted by law.
5. Disclosure of Information to Third Parties
hallo 015 may transfer the information to third parties, in Israel or abroad, including entities related to hallo 015, upon the User's request or with their consent. Furthermore, hallo 015 may transfer the information to third parties, in Israel or abroad, including to countries where the level of protection for personal information is lower than the level of protection provided by Israeli law, even without separate consent from the User, in the following cases:
5.1. To third parties providing services to hallo 015 related to the uses of information that hallo 015 itself is permitted to perform, including those providing outsourcing services to hallo 015, such as information processing, storage, cloud computing, marketing activities, repairs, invoice dispatch, collection, replacements, and customer service.
5.2. To third parties providing the User with a supplementary or additional service upon their request (such as streaming services or additional services from external providers), as well as those providing services required for the provision of hallo 015 services (e.g., license holders or other authorized providers for the purpose of providing internet services).
5.3. To third parties such as Google or Facebook for the use of services and tools of those third parties, for advertising and marketing purposes (including targeted advertising and marketing) by hallo 015, to customers and potential customers of hallo 015.
5.4. To comply with a requirement of a competent authority according to law, for defense against a demand, claim, or lawsuit by a competent authority, and for investigating complaints and protecting hallo 015's rights in any dispute, claim, lawsuit, demand, or legal proceedings.
5.5. To prevent harm or damage to body or property, at hallo 015's discretion
5.6. To implement the provisions of this policy or the terms of use or the engagement agreements of hallo 015 and enforce them.
5.7. In the event that hallo 015 transfers or assigns its activity or its rights and obligations, in whole or in part, including hallo 015 services in whole or in part, to third parties, or merges with another entity or undergoes reorganization.
5.8. For transferring information to entities related to hallo 015, for hallo 015 services or the services of the related entities.
6. Non-Personal Information
hallo 015 may use and transfer to third parties anonymous, aggregated, or statistical information that does not personally identify the User, including to advertisers, for any purpose whatsoever, including to improve, enrich, or modify the services and content offered by hallo 015 and by third parties.
7. Information Security
7.1. hallo 015 employs information security measures to protect the confidentiality and integrity of the information, to prevent intrusion into the platforms and sites through which hallo 015 services operate, and to prevent possible harm to the User's privacy, and reviews these measures from time to time. However, hallo 015 cannot guarantee that there will be no disruption to hallo 015 services or that there will be no risk of intrusion into the information whatsoever.
7.2. The User must take their own information security measures, including not providing identification details for accessing hallo 015 services to others, checking that the contact details provided to hallo 015 are correct, using antivirus software and protective measures for the end-user equipment from which access to hallo 015 services is made, and using protective measures for the end-user device such as a password or biometric identification. hallo 015 shall not be liable for damage caused due to intrusion, use of information, or its transfer to third parties resulting from the User's failure to take such measures.
8. Non-Applicability to Third-Party Services
Within the use of hallo 015 services, various advertisements or links to external sites or applications may appear. Clicking on the link is done at the User's discretion and sole responsibility, as clicking will remove the User from hallo 015 services and direct them to an external site or application, to whose terms the User will be subject, including its privacy policy. Use of linked sites or applications, Browse them, or providing details through them, is the sole responsibility of the User and subject to the terms of use, regulations, and privacy policy of those sites or applications.
9. Contact Regarding Privacy
According to the Privacy Protection Law, the User or someone on their behalf may review information about them held in hallo 015's databases and may also request hallo 015 to correct this information if it is incorrect, incomplete, or inaccurate, subject to the provisions of the Privacy Protection Law and the regulations enacted thereunder. This right can be exercised, and any questions or clarifications regarding this policy can be addressed to hallo 015-tlunot@hallo 015.co.il. As detailed in this policy, for the provision of hallo 015 services, hallo 015 shares information with third parties, therefore, the User is aware and hereby confirms that, even if they request hallo 015 to update the information about them, hallo 015 will not be able to update information that has been transferred to third parties for the purpose of providing the service and which is held by those third parties according to their terms.