How We Use Your Information
 

We process personal information for a variety of business purposes, including:

To provide the Services or Information Requested.

• Fulfill our contract with you or the organization on whose behalf you use the Services;

• Assess the needs of your business to determine suitable products;

• Manage your information;

• Process payment card and/or other financial information to facilitate your use of the Services;

• Respond to questions, comments, and other requests;

• Provide access to certain areas, functionalities, and features of our Services; and

• Answer requests for customer or technical support.

Administrative Purposes.

• Pursue legitimate interests, such as direct marketing, research and development (including marketing research), network and information security, and fraud prevention;

• Measure interest and engagement in the Services;

• Develop of new products and services;

• Improve our products and Services;

• Ensure internal quality control and safety;

• Verify individual identity;

• Carry out audits;

• Communicate with you about activities on the Services and changes to our agreements;

• Prevent and prosecute potentially prohibited or illegal activities;

• Enforce our agreements; and

• Comply with our legal obligations.

Marketing Our Products and Services. We may use personal information to tailor and provide you with content and advertisements. We may provide you with these materials as permitted by applicable law.

If you have any questions about our marketing practices or if you would like to opt out of the use of your personal information for marketing purposes, you may contact us at any time as set forth below.

De-identified and Aggregated Information Use. We may use personal information and other information about you to create de-identified and/or aggregated information, such as de-identified demographic information, de-identified location information, de-identified or aggregated trends, reports, or statistics, or other analyses we create. De-identified and aggregated information is not personal information, and we may use and disclose such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes.

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Technologies. We, as well as third parties that provide content, advertising, or other functionality on the Services, may use cookies, pixel tags, local storage, and other technologies to automatically collect information through the Services. Our uses of such Technologies fall into the following general categories:

• Operationally Necessary. This includes Technologies that allow you access to our Services that are required to identify irregular behavior, prevent fraudulent activity and improve security or that allow you to make use of our functions;

• Performance Related. We may use Technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how our visitors use the Services;

• Functionality Related. We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Services. This may include identifying you when you sign into our Services and keeping track of your specified preferences or past pages viewed;

• Advertising or Targeting Related. We may use first-party or third-party Technologies to develop and deliver content, including ads relevant to your interests, on our Services or on third-party sites.

Consent. E. H. Newton may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information or with your consent.
 

How We Disclose Your Information
 

Your Organization. If you use our Services on behalf of an organization (e.g., your employer), that organization may: (i) access information associated with your use of the Services including usage and other data (e.g., who has accessed, shared, amended, created, edited, or deleted Documents), and the contents of the communications and files associated with your account; and (ii) control and administer your account.

Service Providers. We may share any personal information we collect about you with our third-party service providers. The types of service providers to whom we entrust personal information include service providers for: (i) the provision of the Services; (ii) the provision of information, products, and other services you have requested; (iii) marketing and advertising; (iv) payment processing; (v) customer service activities; and (vi) the provision IT and related services.

Affiliates. We may share personal information with our affiliated entities.

Business Partners. We may provide personal information to business partners to provide you with a product or service you have requested. We may also provide personal information to business partners with whom we jointly offer products or services.

Interest-Based or Personalized Advertising. Through our Services, E. H. Newton may allow third-party advertising partners to set Technologies and other tracking tools to collect information regarding your activities and your device (e.g., your IP address, cookie identifiers, page(s) visited, location, time of day). These advertising partners may use this information (and similar information collected from other services) for purposes of delivering personalized advertisements to you when you visit third party services within their networks. This practice is commonly referred to as “interest-based advertising” or “personalized advertising.” If you prefer not to share your personal information with third party advertising partners, you may follow the instructions below.

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Disclosures to Protect Us or Others. We may access, preserve, and disclose your personal information if we believe doing so is required or appropriate to: (i) comply with law enforcement or national security requests and legal process, such as a court order or subpoena; (ii) protect your, our or others’ rights, property, or safety; (iii) to collect amounts owed to us; (iv) when we believe disclosure is necessary or appropriate to prevent financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (v) if we, in good faith, believe that disclosure is otherwise necessary or advisable.

Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction as permitted by law and/or contract.
 

International Data Transfers
 

All information processed by us may be transferred, processed, and stored anywhere in the world, including but not limited to, Israel and other countries.
 

Your Choices
 

General. You may have the right to object to or opt out of certain uses of your personal information.

Email Communications. If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email. Note that you will continue to receive transaction-related emails regarding products or Services you have requested. We may also send you certain non-promotional communications regarding us and our Services, and you will not be able to opt out of those communications (e.g., communications regarding the Services or updates to this Privacy Policy).

Technologies and Personalized Advertising. If you would like to opt-out of the Technologies we employ on the Services, you may do so by blocking, disabling, or deleting them as your browser or device permits. Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt-out of personalized advertisements on some mobile applications by following the instructions for Android and iOS.

The online advertising industry also provides websites from which you may opt-out of receiving targeted ads from advertisers that participate in self-regulatory programs. 

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Data Retention
 

We retain the personal information we receive as described in this Privacy Policy for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.
 

Security of Your Information
 

We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. Unfortunately, the Internet cannot be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any information you provide to us. To the fullest extent permitted by applicable law, we do not accept liability for unauthorized disclosure.

By using the Services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Services. If we learn of a security system’s breach, we may attempt to notify you electronically by sending a notice through the Services or by sending an e-mail to you.
 

Third Party Websites/Applications
 

The Services may contain links to other websites/applications and other websites/applications may reference or link to our Services. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen or approve, and are not responsible for the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk.
 

Children’s Information
 

The Services are not directed to children under 13 (or other age as required by local law), and we do not knowingly collect personal information from children. If you learn that your child has provided us with personal information without your consent, you may contact us as set forth below. If we learn that we have collected any child’s personal information in violation of applicable law, we will promptly take steps to delete such information.
 

Changes to Our Privacy Policy

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We may revise this Privacy Policy from time to time in our sole discretion. If there are any material changes to this Privacy Policy, we will post a notice of the update on our Site, or as otherwise required by applicable law. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you continue to use the Services after the new Privacy Policy takes effect.

 

Contact Us
 

If you have any questions about our privacy practices or this Privacy Policy, please contact us at:

E. H. Newton
Jabotinsky Street 22
Jerusalem, Israel
esther@ehnewton.com