CCPA PRIVACY NOTICE

Last Modified: January 1, 2024

APPLICABILITY: The California Consumer Privacy Act of 2018 (“CCPA”) as amended by the California Privacy Rights Act of 2020 (“CPRA”), any other California privacy laws, and this CCPA Notice apply to visitors, employees, users, applicants for employment, and independent contractors, and others who are California residents (“consumers” or “you”). Any terms defined in the CCPA and CPRA have the same meaning when used in this CCPA Notice. This CCPA Notice applies to California residents’ Personal Information, which we collect directly or indirectly while using our website or in order to provide our Services, or business-to-business Personal Information, where and to the extent applicable.

This CCPA Notice is an integral part of our Privacy Policy, and thus, the information provided herein is in addition and complementing the information provided through the Privacy Policy, and definitions used herein shall have the same meaning as defined in the Privacy Policy.

PART I: A COMPREHENSIVE DESCRIPTION OF THE INFORMATION PRACTICES:

(A) CATEGORIES OF PERSONAL INFORMATION WE COLLECT

We collect Personal Information which is defined under the CCPA as any information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household or device, all as detailed in the table below.

Personal Information further includes Sensitive Personal Information (“SPI”). As detailed in the table below we do not collect nor process SPI.

Personal Information does not include: Publicly available information that is lawfully made available from government records, that a consumer has otherwise made available to the public; De-identified or aggregated consumer information; Information excluded from the CCPA’s or CPRA’s scope, such as: Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPPA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA) and the Driver’s Privacy Protection Act of 1994.

We have collected the following categories of personal information within the last twelve (12) months:

(B) CATEGORIES OF SOURCES OF PERSONAL INFORMATION

  • Directly and indirectly from activity on our website: For example, directly from you when you inquire about our services via the website, or indirectly, we collect your usage data automatically from measurement tools.
  • Directly from you: For example, from forms you contact us, requesting support, etc.
  • From third-parties: For example, from vendors who assist us in performing services for consumers, internet service providers, data analytics providers, and data brokers.

(C) USE OF PERSONAL INFORMATION

We may use the Personal Information collected as identified above, for the following purposes: To fulfill or meet the reason you provided the Personal Information (support, respond to a query, etc.); monitor and improve our services; analyze your interaction with the website and your use; provide the services; respond to law enforcement; or otherwise as detailed in our Privacy Policy.

We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

(D) DISCLOSURES OF PERSONAL INFORMATION FOR A BUSINESS PURPOSE

We may disclose your Personal Information to a contractor or service provider for a business purpose. When we disclose Personal Information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except performing the contract. We further restrict the contractor and service provider from selling or sharing your Personal Information. In the preceding twelve (12) months, we disclosed the following categories of Personal Information for a business purpose:

(E) SALE OR SHARE OF PERSONAL INFORMATION

In the preceding twelve (12) months, we do not “sell” information as most people would commonly understand that term, we do not, and will not, disclose your Personal Information in direct exchange for money or some other form of payment. However, for retargeting and analytic purposes, when we promote our Services, we use third-party tools that are able to market our Services online, measure these marketing efforts, identify individuals that are interested in our Services, etc. This is done by placing cookies, pixel or other tracking technology on our website and sharing with these vendors the online identifiers and online behavior information. The CCPA defines these actions as “sharing” or “selling”.

In the preceding twelve (12) months, we “sell” or “share” the following categories of Personal Information for a business purpose:

(F) CHILDREN UNDER AGE 16

We do not knowingly collect information from children under the age of 16.

(G) DATA RETENTION

The retention periods are determined according to the following criteria:

  1. For as long as it remains necessary in order to achieve the purpose for which the Personal Data was initially processed. For example: if you contacted us, we will retain your contact information at least until we will address your inquiry.
  2. To comply with our regulatory obligations.
  3. To resolve a claim, we might have or a dispute with you, including any legal proceeding between us, until such dispute will be resolved, and following, if we find it necessary, in accordance with applicable statutory limitation periods.

Please note that except as required by applicable law, we will not be obligated to retain your data for any particular period, and we may delete it for any reason and at any time, without providing you with prior notice if our intention to do so.

Online identifiers are usually kept for a short period. Other information usually will not be retained for more than 24-months, unless you have further contact with the Company.

Information pertaining to purchase of our Services and management of User Account may be kept for longer periods and even without limitation as such information is part of our internal record keeping as a business as well, sometimes, contain information we obliged to retain (e.g., transactional data as part of our bookkeeping obligations).

When we destroy your Personal Information, we do so in a way that prevents that information from being restored or reconstructed.

PART II: EXPLANATION OF YOUR RIGHTS UNDER THE CCPA and how to exercise them

(H) YOUR RIGHTS UNDER THE CCPA

If you are a California resident, you may exercise certain privacy rights related to your Personal Information. You may exercise these rights free of charge except as otherwise permitted under applicable law. We may limit our response to your exercise of these privacy rights as permitted under applicable law, all as detailed herein and, through sending us our Subject Request Form.

To learn more about your California privacy rights, please visit https://oag.ca.gov/privacy/privacy-laws.

(I) HOW CAN YOU EXERCISE THE RIGHTS?

You may exercise your rights by using the Data Subject Request Form available in the Data Subject Request Form. The instructions for submitting, the general description of the process, verification requirements, when applicable, including any information the inquirer must provide are all detailed in the Data Subject Request Form.

(J) AUTHORIZED AGENTS

“Authorized agents” may submit opt out requests on a consumer’s behalf. If you have elected to use an authorized agent, or if you are an authorized agent who would like to submit requests on behalf of a consumer, the following procedures will be required prior to acceptance of any requests by an authorized agent on behalf of a California consumer. Usually, we will accept requests from qualified third parties on behalf of other consumers, regardless of either the consumer or the authorized agent’s state of residence, provided that the third party successfully completes the following qualification procedures:

A. When a consumer uses an authorized agent to submit a request to know or a request to delete, a business may require that the consumer do the following:

  1. Provide the authorized agent signed permission to do so or power of attorney.
  2. Verify their own identity directly with the business.
  3. Directly confirm with the business that they provided the authorized agent permission to submit the request.

B. A business may deny a request from an authorized agent that does not submit proof that they have been authorized by the consumer to act on their behalf.

(K) NOTICE OF FINANCIAL INCENTIVE

We do not offer financial incentives to consumers for providing Personal Information.

You may contact us as follows:

  • By email: info@and-ventures.com
  • By Mail:

AnD Ventures

2 Sapir St.

Herzliya, Israel

PART III: OTHER CALIFORNIA OBLIGATIONS

Direct Marketing Requests: California Civil Code Section 1798.83 permits you, if you are a California resident, to request certain information regarding disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please use the Data Subject Request Form.

Do Not Track Settings: Cal. Bus. And Prof. Code Section 22575 also requires us to notify you how we deal with the “Do Not Track” settings in your browser. As of the effective date listed above, there is no commonly accepted response for Do Not Track signals initiated by browsers. Therefore, we so not respond to the Do Not Track settings. Do Not Track is a privacy preference you can set in your web browser to indicate that you do not want certain information about your web page visits tracked and collected across websites. For more details, including how to turn on Do Not Track, visit: www.donottrack.us.

California’s “Shine the Light” law (Civil Code Section § 1798.83): permits employees that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. Currently we do not have employees in California.

UPDATES:

This notice was last updated on January 1, 2024, as required under the CCPA, we will update the CCPA Notice every 12 months. The last revision date will be reflected in the “Last Modified” heading at the top of this CCPA Notice.