The HedgeWiz Privacy Policy was last updated on November 22, 2016.

We, HedgeWiz Pure Risk Management Solutions Ltd. and our corporate affiliates (“we” or “us”), are committed to protecting and respecting your privacy. This Privacy Policy (“Policy“) (together with our terms of use http://66p.153.myftpupload.com/terms/ and any other documents referred to on it) outlines which information we collect from you, when you (“you” or “your”, the user of the website) access and use our website and the products and services provided by us (which, together, are referred to as the “Services“), how such information will be processed by us, and how we protect it. The Policy also wishes to make sure that you are aware of the options available to you when you access and use our Services.

From time to time, we will review and may make updates to this Policy. We encourage you to check this page for any changes to the HedgeWiz Privacy Policy; your continued use of this site after any change to this Policy will constitute your acceptance of such changes.

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

You are entering into a legal agreement.      

            By accessing or using our Services, you agree to this Policy and to our Terms of Use http://66p.153.myftpupload.com/terms/. If you do not agree to this Policy or Terms of Use, please do not access or otherwise use our Services or any information contained herein.

Scope

This Privacy Policy covers only data collected through the Website and not any other data collection or processing, including, without limitation, data collection practices of other websites to which we link or data that we or our subsidiaries or affiliates collect offline or through websites, products, or services that do not display a direct link to this Privacy Policy.

1. The information we may collect from you and how we obtain it
2. Information you provide us or give us permission to obtain

You may be asked to provide us with certain personal information (“Personal Information“) and other information that does not identify you when you register to any of our Services or use any of them, and when you report a problem with our site. The information you give us may include your name, address, e-mail address and phone number, financial and credit card information, as well as certain business information, such as the name of the company, in whose name you access the Services, budget, balance sheet, account identifications and account history, financial statements, other details.

Any information you provide us is provided by you voluntarily. However, certain information is required in order for you to register and enjoy the full benefits of our Services.

You may also give us permission to access your personal and non-personal information contained in services provided by other sources.

1. Information we collect from your use of the Services

Website Log and Device Information – When you use our Services, we may automatically collect certain information, including information that your browser sends whenever you visit a website. This information may include, for example, (a) technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform and the geographic location of the computer system that you are using to log-in; as well as (b) information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); products you viewed or searched for, the frequency and scope of your use of the Services, page interaction information (such as scrolling, clicks, and mouse-overs), the content you viewed (including advertisements you clicked on) and pages you visited, the address of the web pages you visited that had HedgeWiz features, your communications with third parties, and cookie data.

In addition, we may collect information about the device you are using our Services on, such as the type of the device, the hardware model, operating system version, your device and hardware settings, unique device identifiers, and crash data.

As such, the information we collect may be “personally identifiable” (meaning it can be used to specifically identify you as a unique person) or “non-personally identifiable information” (meaning it can’t be used to specifically identify you). We use both types of information, and combinations of both types, as described above. If we combine non-personally identifiable information with Personal Information, we will treat the combined information as Personal Information.

Mobile Device – When you use a mobile device like a tablet or phone to access our Services, we may automatically collect and store certain technical information, such as your operating system, version, device manufacturer and model, and other information about your mobile device, as well as the frequency and scope of your use of the website. We may also generate a unique device identifier for use by HedgeWiz to operate the Service. Device identifiers are small data files or similar data structures stored on or associated with your mobile device, which uniquely identify your mobile device. We may also collect different types of information about your location, including general information (e.g., IP address, zip code) and more specific information (e.g., GPS-based functionality on mobile devices used to access the Services), including Personal Information, and may use that information to customize the Services. You hereby authorize us and our website to access such components of your mobile device. You can grant or revoke your consent at any time and prevent us from continuing to access your GPS information by disabling the GPS or other location-tracking functions on your device, provided your device allows you to do this.

Information collected by Cookies and similar technologies – A cookie is a small text file that is stored on a user’s device for record keeping purposes. Cookies can only be read by the server that sent them, and they cannot read data from the hard drive. We or our service providers may use cookies, web beacons and similar technologies to collect and store certain information, such as your registration information, language preferences and other account settings, so you don‘t have to set them up every time you use our Services.

We may also use these technologies to recognize your browser type as you navigate on the Internet and to collect aggregate and statistic information about your online activity on our site, such as the web pages you visit, the links you click, and the searches you conduct on our site. This allows us to better serve you with more tailored information and facilitate your ongoing access to and use of the Services.

We may allow our authorized service providers to access the information collected by cookies from our website to allow them to assist us in various activities, such as doing analysis and research on the effectiveness of our site, content and advertising.

To learn more about cookies, please visit http://www.allaboutcookies.org/. You may delete or decline cookies by changing your browser settings. The “Help” function in the toolbar of most browsers should indicate how you can set your browser to notify you before accepting cookies or to disable cookies entirely. However, if you refuse to accept cookies, you won’t be able to access and take advantage of many features of our Services properly.

Collaboration with Google. We may collaborate with Google as a business partner. “DoubleClick” cookie is used by Google in the ads served on the websites of its partners, such as websites displaying AdSense ads or participating in Google certified ad networks. When users visit such partner’s website and either view or click on an ad, a cookie may be dropped on that end user’s browser.

• Third party vendors, including Google, use cookies to serve ads based on a user’s prior visits to websites.
• Google’s use of the DoubleClick cookie enables it and its partners to serve ads to users based on users’ visits to our site and/or other sites on the Internet.
• Users may opt out of the use of the DoubleClick cookie for interest-based advertising by visiting Ads Settings.

Information collected by third parties. We may allow third parties, including our authorized service providers, advertising companies, and ad networks, to display advertisements on our site. These companies may use tracking technologies, such as cookies, to collect information about users who view or interact with their advertisements. Unless expressly stated otherwise, our website does not provide Personal Information to these third parties. This information allows them to deliver targeted advertisements and gauge their effectiveness. Some of these third party advertising companies may be advertising networks that are members of the Network Advertising Initiative, which offers end users a single location to opt out of ad targeting from member companies (www.networkadvertising.org).

2. How we use the information we collect and store

We use information held about you in the following ways:

1. Information you give to us.
   • When we store your registration information and account settings, we are able to save you the trouble of having to fill and set them up every time you access and use our Services.
   • We use the information to help us to better customize and display the content and website experience and any advertisements provided to you with our Services tailored to your interests and to ensure that content from our site is presented in the most effective manner for you and for your device.
   • Depending on your notification settings, we may send you newsletters, updates, marketing materials and other information by e-mail and/or via mobile devices in order to notify you about changes to our service or because we think the specific information is interesting for you.
2. Information we collect about you.
   • We use the information to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes and as part of our efforts to keep our site safe and secure.
   • The information helps us measure and research the effectiveness of the Services’ features and offerings, advertisements, and e-mail communications, and to improve them when necessary.
   • We may also use it to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.
   • Automatically collected information is analyzed to improve our web sites, and includes without limitation details such as the IP address assigned to you when you accessed our web sites, what pages you visited, how long you spent on each page, and how you found our web site. This information can be used to answer such questions as “How do people find out about our products and services?” and “What are the most popular pages on our web site?”
3. Third Party Analytics Services
   • We use Google Analytics to analyze the activities of visitors to our site. Google’s use of cookies and other tracking technologies enable it to have access to information about visitors to our site. We use the information from Google Analytics only to improve this site and the use of our Services by our customers. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Although Google Analytics plants a permanent cookie on your web browser to identify you as a unique user the next time you visit this site, the cookie cannot be used by anyone but Google. Google’s ability to use and share information collected by Google Analytics about your visits to this site is restricted by the Google Analytics Terms of Use[insert link: https://www.google.com/analytics/terms/us.html] and the Google Privacy Policy [include link: https://www.google.com/intl/en/policies/privacy/]. If you do not want to participate in Google Analytics, you may also download the Google Analytics Opt-out Browser Add-on [insert link: https://tools.google.com/dlpage/gaoptout?hl=en]
   • We use Inspectlet to analyze the activities of visitors to this website, and Inspectlet’s authorized use of cookies and other tracking technologies enable it to have access to Personal Information of visitors to this website. Such access to and use of Personal Information by Inspectlet is governed by Inspectlet’s privacy policy (https://www.inspectlet.com/legal#privacy).
   • We use the Lucky Orange analytics to analyze the activities of visitors to this website. Lucky Orange may record mouse clicks, mouse movements and scrolling activity. Lucky Orange may record keystroke information that you voluntarily enter on this website. You can choose to disable the Lucky Orange Service athttp://www.luckyorange.com/disable.php. Note that doing so will disable other features of the Lucky Orange system that this site employs.
4. Information we receive from other sources.We may combine this information with information you give to us and information we collect about you. We may us this information and the combined information for the purposes set out above (depending on the types of information we receive).
5. Storage of Information. In addition, please be aware that we may host or store your data and information (including Personal Information), in the United States and other countries through certain third parties that we use to operate and manage the Website and Services, including Amazon Web Services (“AWS”), ObjectLabs Corporation (“mLab“) and DigitalOcean. AWS, mLab and DigitalOcean all state that they participate in the EU-US Privacy Shield framework. By using the Services, you acknowledge and expressly consent to the transfer and processing of your Personal Information in this way. We may store your information also after any customer relationship has been terminated or ceased. Such information may be used for any internal purpose, such as quality control efforts or customer analysis.
6. Questions and requests. If you have any questions or concerns about HedgeWiz’ Privacy Policy or data processing or if you would like to make a complaint about a possible breach of local privacy laws, please contact us at: info@hedgewiz.com.

4 Harav Bar Shaul St., Rehovot,

Israel.

E-mail: info@hegdewiz.com

Please include the full name and contact information in your request.

3. Disclosure of your information

We value your privacy and will not share your Personal Information with third parties except in the following instances:

1. When we employ third parties to process personal information on our behalf. In the course of operating our business, it may be necessary or appropriate for us to provide access to your Personal Information to others such as our service providers or contractors. These third parties do not retain, share or store this Personal Information or part of it other than for providing these services and such third parties’ use will be bound by strict agreements limiting their use of such information and in compliance with this Privacy Policy. For instance, we may engage a security consultant to help us better identify spam. Where practical, we seek to obtain confidentiality agreements that are consistent with this Privacy Policy and that limit others’ use or disclosure of this Personal Information.
2. With our affiliates. This relates to companies that are legally part of the same group of companies that we are part of, or that become part of that group.
3. With brokers. We may share certain details about your company with specific brokers in order to assist you to open a new account with the brokers and facilitate deals and payments between you and certain brokers and/or their clients. We may also share information about the trades you have executed using our platform with your brokers.

1. Non-Personally Identifiable Information. We may also share aggregated or non-personally identifiable information that we collect under any of the above circumstances with our business partners, affiliates or other third parties to develop and deliver targeted advertising on our websites and on websites of third parties. We may combine non-personally identifiable information we collect with additional non-personal information collected from other sources. We also may share aggregated information with third parties, including advisors, advertisers and investors, for the purpose of conducting general business analysis. For example, we may tell our advertisers the number of visitors to our website and the most popular features or services accessed. This information does not contain any personal information and may be used to develop website content and services that we hope you and other users will find interesting and to customize content and advertising.

We may disclose your personal information to third parties:

1. In the event that we sell or buy any business or assets, in which case disclose your Personal Information to the prospective seller or buyer of such business or assets.
2. If HedgeWiz or substantially all of its assets are acquired by a third party, in which case Personal Information held by it about its customers will be one of the transferred assets.
3. We may disclose Personal Information (i) as a response to a legal request (such as a court order, search warrant, or subpoena) if we believe that we are required to do so by applicable law; or (ii) when we believe that such disclosure or use is necessary in order to: reveal, prevent and address fraud and other illegal activities; enforce this Policy or our Terms of Use, including in order to investigate potential breaches; protect our rights, property or safety, or those of our users or from members of the public from harm, as required or permitted by law; and prevent death or imminent bodily harm.
4. Your rights to access your information

You can change your information at any time by editing your profile and/or deleting content that you have posted, by sending an email to support@hedgewiz.com.

In addition, if you find that the information on your account is not accurate, complete or updated, then you are responsible to make all necessary changes to correct it. Please keep in mind that false, incorrect, or outdated information may prevent you from registering to our Services and impair our ability to provide you with Services.

You can close or deactivate your account at any time. Following termination or deactivation of your account, we may (a) retain information (including your profile information) and User Content for various purposes including statistics, analytics, backup, archival Terms of Use enforcement, (b) take actions we deem necessary to protect the integrity of our website or our users, or take other actions otherwise permitted by law.

This does not apply to information or content you have shared previously with other users and which they have not deleted, or which was copied or stored by other users.

Please also note that after you close or deactivate your account, you will not be able to sign in or access any of your personal information. However, you can open a new account at any time, subject to the Terms of Use.

5. Your choices with respect to your information

Our goal is to enable you to decide over your information and with whom such information is shared. If you have a HedgeWiz account, many of the choices that you have are built directly into your account settings.

Here are some examples to how you can manage your information and the access of others to it:

1. You can add or update information and close your account as described above.
2. As mentioned above, the “Help” function on most browsers indicates how you can set your browser to notify you before accepting cookies or to disable cookies entirely. However, if you refuse to accept cookies, you won’t be able to access and take advantage of many features of our Services.
3. How do we secure your information?

We consider data security a top priority and we do our best to secure the Personal and business related Information that you choose to provide. For that purpose, we:

1. Encrypt many of our services using SSL.
2. Employ firewalls and intrusion detection systems.
3. Practice administrative, technical, and physical security procedures to help protect the information you provide us. For example, only authorized employees, contractors and agents are permitted to access personal information, and they may do so for permitted business functions only. These authorized personnel are subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations.
4. We may store any information collected through third party service providers in a number of jurisdictions, including the United States of America and various member states of the European Union.

Please keep in mind – although we take reasonable organizational, technical and administrative measures to protect your Personal Information, no method of transmitting or storing electronic data is ever completely secure. Therefore we cannot promise or guarantee that such information will be immune from any wrongdoings, malfunctions, unlawful interceptions or access, or other kinds of abuse and misuse. Please also be aware that we may use third-party cloud service providers that provide hosting, data storage and other services pursuant to their standard terms and conditions that are generally non-negotiable; and accordingly, although we seek to conduct reasonable due diligence on such service providers, we may be unable to impose contractual obligations on them with respect to the measures they use to protect Personal Information.

If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us at support@hedgewiz.com.

7. Protection of children’s privacy

Our Services are not directed to children under 18.

If it comes to our attention through reliable means that a registered user is under 18 years of age, we will cancel that user’s account and/or access to the Services.

8. Changes to our Privacy Policy

Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy. Your continued use of our Services following the posting of changes to this Policy or providing notice to you, whichever occurs first, means that you accept those changes.

9. General

We reserve the right to discontinue or modify any aspect of the Services at any time. This Policy, together with our Terms of Use and any other legal notices published by us on our website, shall constitute the entire agreement between us concerning the Services. If any provision of this Policy is deemed invalid by a court of competent jurisdiction, the invalidity of such provision shall not affect the validity of the remaining provisions of this Policy, which shall remain in full force and effect, provided, however, that in such event this Policy shall be interpreted so as to give effect, to the greatest extent consistent with, and permitted by, applicable law, to the meaning and intention of the excluded provision as determined by such court of competent jurisdiction.

10. California Privacy Rights

When California customers provide personal information to a business, they have the right to request certain disclosures if that business shares personal information with third parties for the third parties’ direct marketing purposes. Once per calendar year the customer may request that the business provide a list of companies with which it shares personal information for those companies’ direct marketing purposes, and a list of the categories of personal information that the business shares. HedgeWiz generally does not sell products or services directly to individual California consumers. However, if we engage in such contact, you may request information about our compliance with this law by contacting us at:

4 Harav Bar Shaul St., Rehovot

Israel.

E-mail: support@hedgewiz.com

Any such inquiry must include “California Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code. Please note that we are only required to respond to one request per customer each year, and we are not required to respond to requests made by means other than through this email address or mail address.

11. Governing Law and Jurisdiction

Unless otherwise required by a mandatory law of a member state of the European Union or any other jurisdiction, this Policy shall be governed by the laws of the State of Israel, without respect to its conflict of laws principles. We each agree to submit to the personal and exclusive jurisdiction of the courts located in Tel Aviv, Israel, and waive any jurisdictional, venue, or inconvenient forum objections to such courts.

Our Services are controlled and operated from Israel, and we make no representations that they are appropriate or available for use in other locations.

NOTE TO INTERNATIONAL USERS

We are an Israeli private company headquartered in Rehovot, Israel. If you are located outside of Israel, the personal information you provide to us will be transferred to Israel and governed by applicable Israeli laws and regulations and this Privacy Policy. Some of this information may be transferred to, processed and stored temporarily by our service providers in other countries, as further detailed above. By submitting your personal information, you consent to its transfer to and storage in Israel and other countries designated by us, its governance by Israeli laws and regulations, and its use in accordance with this Privacy Policy.