This privacy statement describes the privacy practices of the Citadel Holdings, LTD investment portal ("us," "we" or "Citadel Holdings, LTD") for Services and other matter offered through the Citadel Holdings, LTD website at www.citadelholdings.co.il (the “Site”). This policy is incorporated in the Citadel Holdings, LTD.com terms of use (the “Terms”). Capitalized terms used and not otherwise defined in this document shall have the meanings set forth in the Terms. All references regarding opting-in or obtaining consent are only relevant to UK and EU investors under the General Data Protection Regulation ("GDPR").
To better protect your privacy, we provide this notice explaining our online information practices, including the choices you can make about the way your information is collected and used at this Site.
By registering to our Site and opting in to the terms of this policy, or by using this Site or Services made available through the Site ("Services"), you thereby agree to this privacy policy (the “Policy”). If you do not agree to be bound by this Policy, you should exit and cease all use of the Site and Services.
In connection with Services, you will be signing additional agreements with Citadel Holdings, LTD or its affiliates or other third parties. In the event of conflicts between the terms of such agreements and the terms of this Policy, the terms of such agreements will govern solely with respect to matters specifically referenced therein, but the terms of this Policy will control all matters related to Citadel Holdings, LTD’s commitments related to privacy of your data collected and used at this Site.
Who we are
Citadel Holdings, LTD is an Israel registered company and performs all the management functions of Citadel Holdings, LTD’s operations and manages all the associated entities. The company’s registered address is Hakfir 15/2, Givat Zev, Israel.
Any questions regarding this policy and our privacy practices should be sent to support@citadelholdings.co.il. Alternatively, you can call +972-54-844-1578.
Information Collection and Use
We respect your privacy. Citadel Holdings, LTD is the sole data controller of the information collected through the Site. We will use and disclose such information in the manner described in this Policy. The terms of this Policy are subject to all applicable laws.
User-Supplied Information
Upon performing the registration process, you will be asked to provide certain information, such as your first and last name, and other identification details, such as your email address, gender and birthday.
In addition, we receive and store any information you enter on our website or give us in any other way (for example, in the course of subscribing for particular newsletter or course, otherwise using the Site or other communications with us, or as contained in written documents you provide). This includes information that can be used to directly or indirectly identify you as well as anonymous information that is linked to information that can be used to directly or indirectly identify you (“Personal information”). Personal information does not include information that has been irreversibly anonymized or aggregated so that it can no longer enable us, whether in combination with other information or otherwise, to identify you. The amount of personally identifying information you provide is up to you, and you are not legally obligated to provide such information. However, your use of the Site or the Services may be curtailed if such information is not provided.
You may provide information on behalf of another person or entity. If you completed the registration on behalf of another entity or if you otherwise provide information regarding another person or entity, you represent to us that you were authorized by that person or entity to give us consent to use the submitted information. We may use third party contractors to collect and aggregate this information. For more information, please see Information Collected by Means of Technology below.
The Site and Services are intended to be used by individuals over the age of 18. If we become aware that we have collected the personal information of a child under 16, we will take steps to delete the information as soon as possible. Please immediately contact us by sending an email to support@citadelholdings.co,il if you become aware that a child under 16 has provided us with personal information.
Information Collected by Means of Technology
We may collect some information automatically from your computer, without notice such as your Internet Protocol (IP) address, computer and connection information, browser type and version, operating system, Internet Service Provider (ISP), time stamps, banner ads you click, the URLs you come from and go to next, and a cookie number.
Citadel Holdings, LTD, our service providers, and other members of our corporate family who provide joint Services to you with us, will sometimes place anonymous cookies or web beacons on your computer when you visit the site. Your browser must be set to accept cookies in order to access Citadel Holdings, LTD as a registered user. We use these cookies and web beacons to recognize returning users, provide relevant content, measure traffic and activity on the site, monitor and improve our Services and protect against fraud. You can block cookies by changing the settings on your browser (consult your browser help menu to find out how) but doing so may prevent us from delivering certain Services to you. We do not link the information we store in cookies to any personal information you submit while on our site.
We also may allow advertisers to occasionally use our Site and they may also use cookies on the Site. Advertisers’ use of cookies is subject to their own privacy policies, and we have no access to or control over these cookies.
Use of Information
Personal information will be used by Citadel Holdings, LTD’s and its affiliates' employees, consultants and third party service providers in connection with Citadel Holdings, LTD’s business (including, without limitation, as described elsewhere in this Policy), in connection with the operation and management of the Site and Services, to enhance performance of the Site, to tailor the Site to Users’ preferences, to analyze trends, to offer you targeted advertisements and to protect us and our users including, without limitation, as follows:
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To enable us to verify your credentials, in order to maintain reasonable security, provide developers with the information that is useful in developing new features and Services for our users, enable us to develop and improve the features, contents, and Services available, fulfill your requests for our products and Services, in connection with your use of the Site or Services, to respond to your inquiries about our Services, to offer you our products or Services that we believe may be of interest to you only if consent has been explicitly provided, to carry out transactions which you have requested, to enforce our rights and resolve disputes.
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We will retain information transmitted to us in the context of use of Services for further internal use in connection with our efforts to improve our Services and products.
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Newsletters: You can opt-in to subscribe to our newsletter(s).If you subscribe we will use your name and e-mail address to send the newsletter to you. We provide you a way to unsubscribe by following the unsubscribe link located at the bottom of each newsletter communication or by emailing us at support@citadelholdings.co.il.
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We may use non-personally identifying information that we collect to provide statistical information about users of the Site or Services, to improve the quality, design and content of our Site, to analyze the use of our Site and to cooperate with law enforcement.
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Our website may also use products that have been developed to record your mouse clicks and activity on the website. The information collected does not include bank details or any sensitive personal data. Data collected by such third parties is for internal use only. The information collected is used to improve our website usability and is stored and used for aggregated and statistical reporting. The information is also used for targeted marketing email campaigns based on user activity. Marketing emails are only sent to users that have opted-in to receive marketing emails.
We review our retention periods for personal information on a regular basis. We are legally required to hold some types of information to fulfil our statutory and regulatory obligations. We will hold your personal information on our systems for as long as is necessary to fulfil the purposes outlined in this Privacy Policy, or as long as is set out in any relevant contract you hold with us, unless a longer retention period is required or permitted by law.
Where any of the uses of your data described above requires your prior express consent, note that you may withdraw your consent through contacting us by sending an email to support@citadelholdings.co.il.
Disclosure of Information
In certain cases, we may provide personal information to other third parties, such as advertisers, partners or for online advertising auctions. Where we provide personal information to third parties, other than for use on our behalf, it will be provided either in aggregated form that does not identify your identity, or in a form that does not link the information to you. In certain cases, such as information provided to our advertisers, we may provide non-personally identifiable identification (for example, gender) in connection with an IP address.
We will not sell, share, rent or trade your personal information with third parties other than as disclosed within this Privacy Policy unless we have your consent.
We may disclose your personal information to:
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Third-party vendors who provide Services to us or facilitate or evaluate the Sites or Services, such as e-mail service providers sending e-mails on our behalf.
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Companies within our corporate family that are involved in operating or providing the Services. We may share your personal information with our affiliates. Our affiliates will follow practices that are at least as restrictive as the practices described in this Privacy Policy, including requests that personal information not be used to provide you with Services.
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Third Party Analytics. Google Analytics is our tracking tool of choice. All collected data is anonymous by default. Personal info is only collected if explicitely asked for. We use a Facebook Pixel. For further information about how Google Analytics uses cookies and IP address data see: http://www.google.com/intl/en/analytics/privacyoverview.html.
We also may share your information:
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In response to subpoenas, court orders, or other legal process or in response to a law enforcement agency’s request; to establish or exercise our legal rights; to defend against legal claims; or as we reasonably believe appropriate to comply with applicable laws, regulations, orders, legal processes or government or regulatory requests, including tax authorities in Israel, the United States and elsewhere, as well as in order to comply with anti-money laundering laws and regulations. In such cases we reserve the exclusive right to raise or waive any legal objection or right available to us.
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When we believe it is appropriate to investigate, prevent, or take action regarding illegal or suspected illegal activities; to protect and defend the rights, property, or safety of our company or this Site, our customers, or others; and in connection with our Terms and other agreements, including where we believe you may have breached the Terms or other agreements with Citadel Holdings, LTD or its affiliates, to detect, prevent or otherwise address fraud or illegal behavior, security or technical issues, or protect against imminent harm to the rights, property or safety of Citadel Holdings, LTD, its affiliates or users or the public as required or permitted by law.
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In the event that Citadel Holdings, LTD goes through a business transition, such as a merger, acquisition by another company, or sale of all or a portion of its assets, your personal information will likely be among the assets transferred. You will be notified via email or prominent notice on our Site for 30 days before any such change in ownership or control of your personal information.
Other than as set out above, you will be notified when personal information about you will be shared with third parties, and you will have an opportunity to choose not to have us share such information.
Cross-border Transfer
We may share personal information with our affiliates' employees, consultants and third party service providers outside your country but only for purposes of performing the Services for which you provided your personal information, even to countries that might not offer a level of protection for your personal information that is equivalent to the one offered in your country of residence. We will obtain your express consent, however, before using your personal information for any purposes other than performing the Services for which you provided the personal information.
For EU users only - Transferring your information outside the European Economic Area.
As part of the services offered to you through this website, the information which you provide to us may be transferred to countries outside the European Economic Area (“EEA”). By way of example, this may happen if any of our servers are from time to time located in a country outside of the EEA. These countries may not have similar data protection laws to the EEA.
In such circumstances, we will enter into model contractual clauses as adopted by the European Commission, or rely on alternative legal bases such as the Privacy Shield, where applicable, or binding corporate rules where our affiliates, consultants or service providers have adopted such internal policies approved by European data protection authorities.
If you use our services while you are outside the EEA, your information may be transferred outside the EEA in order to provide you with those services.
Legal Basis For The Processing of Personal Information from EEA Residents
If you reside within the European Economic Area (EEA), our processing of your personal information will be legitimized as follows: Whenever we require your consent for the processing of your personal information such processing will be justified pursuant to Article 6(1) lit. (a) of the General Data Protection Regulation (EU) 2016/679 (“GDPR”). If the processing of your personal information is necessary for the performance of a contract between you and us or for taking any pre-contractual steps upon your request, such processing will be based on GDPR Article 6(1) lit. (b). Where the processing is necessary for us to comply with a legal obligation, we will process your information on basis of GDPR Article 6(1) lit. (c), and where the processing is necessary for the purposes of our legitimate interests, such processing will be made in accordance with GDPR Article 6(1) lit. (f).
Links
The Site contains links to other sites. Citadel Holdings, LTD is not responsible for and has no liability for privacy policies and/or practices on other sites. We advise you to read the privacy policy stated on other sites you link to through the Site. Our privacy policy only governs information that we collect on the Site.
Security
We take appropriate precautions to protect your personal information by using physical as well as technological security devices. Additionally, we have implemented physical, electronic and procedural safeguards that are designed to protect the security of your information in compliance with the GDPR as well as any other applicable laws in other parts of the world . These include advanced firewall and password protection for our databases, physical access controls to our buildings and files, and restricted access to your personal information to employees that need to know that information to operate, develop or improve our Services. We have invested in leading-edge security software, systems and procedures to offer you a safe and secure investing platform and protect your personal, financial and investment information. While no security system is absolutely impenetrable, we will continually monitor the effectiveness of our security system and refine and upgrade our security technology as new tools become available. Citadel Holdings, LTD’s employees are kept up-to-date on security and privacy practices.
Notifications and Updates
The Site sends new registered Users a welcoming email. After you register with the Site and have provided consent to receiving marketing emails, we may send you on a regular basis via emails information on other Services that we believe may be of interest to you. We give you the option at all times to unsubscribe from receiving these types of communications.
The Site may also send you notifications regarding updates to the Site and our Services only if you have provided consent to receiving updates about our opportunities, services and products. We may also communicate with you to provide requested Services and with respect to issues relating to your account via email or phone.
Profiling
We may analyse your personal information to create a profile of your interests and preferences so that we can contact you with information relevant to you. We may make use of additional information about you when it is available from external sources to help us do this effectively. We may also use your personal information to detect and reduce fraud and any other criminal activity.
Your Rights
Citadel Holdings, LTD encourages you to review your information regularly to ensure that it is correct and complete. As a registered user, you can review and change your personal information by contacting us at the e-mail address, postal address or telephone number listed on the Citadel Holdings, LTD Site.
You also have the right to access, rectification or erasure of the personal information held on our systems, the right to object or restrict the processing of your personal information, and the right to data portability. You may lodge a complaint with the competent data protection authority regarding the processing of your personal information.
To protect the privacy and the security of your personal information, we may request information from you to enable us to confirm your identity and right to access such information, as well as to search for and provide you with the personal information we maintain. There are instances where applicable laws or regulatory requirements allow or require us to refuse to provide or delete some or all of the personal information that we maintain.
You may contact us by sending an email to support@citadelholdings.co.il to exercise your rights. We will respond to your request in a reasonable timeframe, and in any event in less than 30 days.
Choice/Opt-out
You will be required to ‘opt-in’ to having your personal information used for any purpose not directly related to the Site upon registration to the Site. If you no longer wish to receive additional information or promotional materials from Citadel Holdings, LTD, you may opt-out of receiving these communications by using the opt-out mechanism described in the relevant email.
Notification of Changes
This policy may change from time to time and we will post the amended terms on the Citadel Holdings, LTD Site and notify you by email of major changes. Amended terms will take effect immediately for new users, and 30 days after they are posted for existing users. You should review the Privacy Policy periodically to remain informed of any changes. You agree to accept posting of a revised Privacy Policy as actual notice to you.
Your continued use of the Site after any changes to this Policy have been posted (or, if applicable, notified) signifies your acceptance of those changes. If you do not agree to the revised Privacy Statement, please refrain from using our products or services and contact us by sending an email to support@citadelholdings.co.il.
You can also request that we close your Citadel Holdings, LTD account, or request that we no longer use your information to provide you Services, by emailing Customer Service at support@citadelholdings.co.il. After we close your account, we may retain some information if we believe it may be necessary to prevent fraud, assist with investigations, resolve disputes, analyze or troubleshoot programs, if required by law, enforce our Terms of Use and take actions otherwise permitted by law.
Questions and Feedback
Citadel Holdings, LTD is strongly committed to our relationship with you and want to be sure you understand the steps we have taken to protect your personal information. If you have questions or feedback regarding our privacy policy, you may direct them to support@citadelholdingsg.co.il and we will make every effort to answer your questions.
If you are not satisfied with our response, you have the right to make a formal complaint to the relevant data protection authority.
Policy updated March 2019