Data Protection and Privacy Policy

Last Updated: 09 February 2022

Preamble

The Israel Coins And Medals Corporation Ltd. (hereinafter: “ICMC” or “Our” or “We” or “Us”), are committed to protect your Personal Data. This Data Protection Policy explains how ICMC collects, processes and stores the information from you or other data subjects through our website (hereinafter: "Website").

As used in this policy, “Personal Data” or "Personal Data" means information that refers to, is related to, or is associated with an identified or identifiable individual or as otherwise may be defined by applicable law, such as a name, address, telephone number, e-mail address, information about activities directly linked to a person, such as that person’s location or IP information.

This data protection policy (hereinafter: "Policy") may be revised or updated from time to time, and such changes shall come into effect from the moment ICMC publishes the new policy and/or notifies you of such changes and/or updates, either by email, notification on our website or any other reasonable manner.

For any questions regarding the collection, processing or use of Personal Data relating to you and exercising your data subject rights (all as explained below) please contact us at: [email protected]

General Principles of Our Data Protection

ICMC is committed to ensuring that your Personal Data and the privacy of your data is protected according to the appropriate industry standards and practices in relation to the data we collect, and all in correspondence to ICMC's relevant legal obligations.

This policy explains your rights regarding the Personal Data ICMC collects, processes and uses through the ICMC Website, as well as ICMC’s use of safeguards to protect these rights.

This Policy further applies also to ICMC’s use of cookies and tracking tools, as specified in detail in our Cookies and Tracking Technologies Policy as we use cookies and tracking tools on our Website to distinguish you from other and to improve your use of our Website, and in some cases, certain features may not function if you remove the cookies from your browser.

We collect and process your Personal Data in good faith, in a proportionate manner according to the declared purpose, and with the appropriate technical and organizational measures in line with the state of the art measures, while taking into account the risks represented by our collection and processing and the nature of the Personal Data and data protected by us.

If any collection and processing of Personal Data will be carried out, in the course of ICMC’s business and provision of services, by external data processors on Our behalf, ICMC will require, within the framework of its contracts with such external processors, for them to comply with relevant legal data protection rules and legislation applicable to the services they provide to ICMC, prior to the transferring your Personal Data and data.

Important note: please refrain from browsing our Website, sending us e-mail messages with queries or requests, or otherwise providing Us with your Personal Data, if you do not consent to the collection, use, processing or disclosure of this data as set forth herein.

Your Rights to Limit our Collection and Processing

You have certain rights in relation to the Personal Data that we hold about you, as detailed below:

• Consent - We will only process your Personal Data if you have consented to such processing, unless We are otherwise legally authorized or obliged to collect and further process Personal Data relating to you any of your rights below.

If we process data solely based on your informed consent, We will only use the data for the purposes stated in the consent procedure and within the scope outlined below.

• Withdrawal of consent - You may revoke or withdraw your consent at any time by contacting and requesting so from Us, and We will stop processing your Personal Data unless We are legally obliged or authorized to continue processing your information, including for ongoing legitimate business interests, which we will notify you in our response to your request, where applicable.
  
  
• The Right of Deletion (“To be Forgotten”) and Right of Rectification - You may also request the erasure or correction of all or part of your Personal Data that is held by ICMC.
  Upon your request, ICMC will accommodate your request and delete (or alternatively equivalently irreversibly anonymize) or correct your Personal Data or remove from part or all of our records, as per your request, as soon as reasonably possible and when technically feasible, and unless there is an overriding legal interest or other authorized basis for the continuation of the processing of your Personal Data, which we shall notify you in response to your request.

Please be aware that in the event of deletion or correction of Personal Data upon your request, ICMC may not be able to further provide you the services you applied for through the Website, in whole or in part and by requesting such deletion/correction, you irrevocably agree and waive any claim against ICMC's inability to provide the services through the Website.

• Personal Data of children and minors - We do not knowingly collect or process Personal Data relating to children and minors under the age of 16 years, unless We are legally obliged to do so by an authorized court or governmental authority order or writ or parental consent.

If we become aware that Personal Data was transferred to us or collected by us relating to children and minors under the age of 18 years without the informed consent of a parent or legal guardian or according to a legal obligation from a court or governmental authority, We will delete such Personal Data without undue delay.

If the request for erasure of data relates to the Personal Data of a child or minor, please attach to the request adequate proof of your status as parent or guardian of the child or minor.

• Transparency and Data Portability. You are entitled to ask us for information about what type of Personal Data about you has been collected by ICMC.

You are also entitled to obtain (in a commonly used and machine-readable form) and reuse your Personal Data as you have provided to us (following your consent or to allow us to perform services under a contract) and which We process, for your own purposes across different services and free of charge, subject to technical feasibility and lawfulness considerations.

• Automated decision-making. ICMC shall not intentionally take any potentially damaging decision concerning you because of using automated processing and decision-making operations without human intervention; and commits that where such will be implemented we will give you the opportunity to obtain human intervention in such a decision, express your point of view, and obtain an explanation of the decision.

Important Notes:

• In the implementation of these data protection rights, ICMC is committed to providing a timely and transparent response to your requests, and upholding your right to contact ICMC
  
  
• Any data subject right you wish to uphold by Us, may not be fulfilled if you do not provide Us with relevant and/or sufficient information required for us to identify you as the data subject of said Personal Data, and we shall inform you accordingly in such an event.
  
  
• If you believe ICMC has violated any of your data subject rights, you are entitled to:

• For EU countries - file a complaint to the Data Protection Authority in your jurisdiction of residence about the alleged data protection breach;
• file a lawsuit to the courts of the state of your residence.

Information We Collect:

The Personal Data collected and used by ICMC is limited strictly to any data which is necessary for us to provide you with services you request in the course of our ongoing business while operating under our relevant legal and data protection legislation and regulations obligations, as detailed herein below:

Collection of Personal Data Occurs when You:

1.1 Contact us via our designated "Help" electronic form at the bottom right of the screen on our Website or through the "Contact Us" online form on our Website.
1.2 When you make online purchase through our online store.
1.3 When you register to open an account on our Website.
1.4 When you browse through the website, through the use cookies and tracking technologies as further elaborated in our "Cookies and Tracking Technologies Policy" 

2. What is the Personal Data We collect and when do we collect it:

2.1 When you register to open an ICMC Account we may collect the following fields of Personal Data:

2.1.1 Your Full Name;

2.1.2 Your billing address

2.1.3 Contact details for the Courier Company to provide your order in your jurisdiction;

2.1.4 Your E-mail address

2.1.5 The last four digits of your credit card, which is used as a token from identification for transactions vis-à-vis our credit card / payment processing service providers to reference the successful payment for your order (as we do not directly process or collect payment method details from our customers);

2.1.6 Your selected Password

 

2.2 When you register to join our newsletter and/or to receive commercial communications from ICMC:

2.2.1 Your Full Name;

2.2.2 Your E-mail address

2.2.3 Categories of products you are interested in receiving information on;

 

2.3 When you contact us through our "Help" message window, "Contact Us" online form or through one of the contact details (E-mail, WhatsApp, phone call) we may collect the following fields of Personal Data:

2.3.1 Your Full name

2.3.2 your email address;

2.3.3 Your cellphone number

2.3.4 Any Attachments you add to the message

2.3.5 the Content of your inquiry and/or request, and any Personal Data you elect to input therein;

 

2.4 When you make online purchases through our online store, we will collected the following Personal Data:

2.4.1 The last four digits of your credit card, which is used as a token from identification for transactions vis-à-vis our credit card / payment processing service providers to reference the successful payment for your order (as we do not directly process or collect payment method details from our customers);

2.4.2 Shipping Address for delivery of purchased goods;

2.4.3 Contact details for the Courier Company to provide your order in your jurisdiction;

2.4.4 If selected, we shall also process the content of your personalized message (up to 100 characters) to be hand written on a purchased gift card to be added to your order.

 

2.5 When you browse through our websites and/or specific pages/portions thereof:

Automated Browsing Data which includes information about your computer, your web browser, mobile device, operating system, IP address, your location, website visit history including keywords and searches;

Note: Once your contact details are received by us, you hereby consent that our representative will be entitled to contact you for further communication according to your inquiry or request based on the contact information so provided. Our representatives may collect additional Personal data from you during such contact and we shall retain and process any such Personal Data to the extent it is relevant in respect to fulfilling your inquiry or request.

Why ICMC Uses your Personal Data:

ICMC uses data and Personal Data for the following reasons:

• to ensure that content in the website is presented in the most effective manner for you, including personalization;
• to process your request to open an account to our Website;
• to manage and process your purchases and orders through our online shop;
• to process your contact request when you contact us through e-mail, Whatsapp, electronic message and/or phone number and/or to revert back to you accordingly;
• For performance of analytics such as trend analysis, site administration, statistical analysis of usage of the site, enhance and review integrity and stability of the website and to study trends in order to improve our website;
• To use data tracking technologies (i.e: browsing and history data) for the purpose of providing you with personalized advertisements;
• To ensure the integrity, security and fulfillment of the Terms of Use and this Privacy Policy by your users, including but not limited to detecting, monitoring, and preventing fraud and/or monitoring account activity.
  
  

How you can assist Protecting your Information

You can follow some simple steps to keep your information secure. When you create your ICMC account, choose a strong password that is unique to this account and do not share your password any other personal. If you suspect that someone else has got access to your password, make sure that you change it immediately. 

If you receive an email that looks suspicious, e.g. refers to an order you do not recall making or requesting information already provided, or you have doubts as to whether an email was actually sent by Us, please contact us and report this.

Please note that we will never ask for your payment method details via email and if required, we shall try to coordinate to converse with your directly. Similarly, when We promote our offers, we do so by using the same email account through which we send you all our marketing communications, and we will not ask for your personal information in these emails.

How We Protect Information:

We implement generally accepted industry standards to maintain the safety of your Personal Data against loss, alteration, theft or access by unauthorized third parties when you enter, submit, or access your Personal Data and once we receive it. However, no method of transmission over the Internet, or method of electronic storage is flawless or entirely secure.

Therefore, while we strive to protect your Personal Data via the aforementioned technical and organizational means, we cannot guarantee its absolute security. What we can guarantee is that we will not sell, share, transfer or use the data We collect from you for purposes other than those purposes stated expressly herein above.

The above notwithstanding, ICMC will not be liable or responsible for any damage or loss resulting from the improper use or any breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data.

 Third Party Sites: 

Our website may contain links to third party websites, payment portals or social media platforms through dedicated buttons, icons or advertising banners, etc.

We have no control over third-party sites or services, and all use of third-party sites or services is at your own risk. ICMC cannot accept responsibility for the privacy policies of any such third party sites and such third-party websites are governed solely by such third parties' privacy policies and you are advised to be careful and check any such third party's privacy policies and compliance with laws, prior to supplying them with any of your personal data to them.

ICMC is not responsible for content available by means of such third party sites. ICMC does not endorse any information or products offered by third parties and we urge our users to exercise caution in using third-party services.

Data retention and deletion

ICMC deletes (or equivalently irreversibly anonymizes) personal data where the purpose for which the data was being collected or processed ceases to apply, except the extent it is prohibited to do so under local, Israeli law (and in such cases only to the extent required) and/or or if applicable data protection rules require us to delete such personal data

However, we shall keep your personal data as long as necessary to provide you with the ICMC Service and for legitimate and essential business interests, such as maintaining the performance of the ICMC Services, making data-driven business decisions about new features and offerings, and always when required for complying with our legal obligations, and resolving disputes, such as the following circumstances:

• If there is an unresolved issue relating to your account, such as an outstanding credit on your account or an unresolved claim or dispute we will retain the necessary personal data until the issue is resolved;
• Where we are required to retain the personal data for our legal, tax, audit, and accounting obligations and/or regulatory requirements, we will retain the necessary personal data for the period required by applicable law; and/or,
• Where necessary for our legitimate business interests such as fraud prevention or to maintain the security of our users.
• Where necessary to cooperate with a criminal investigation by law enforcement agencies and/or any regulatory authority's inquiry and/or audit, in each such case solely subject to extent request and as per the applicable law.

The above notwithstanding, there are types of Personal Data we process will only be kept for as long as you use ICMC Services, such as your e-mail address and other information sent as part of a request or when browsing as long as your consent to usage of Cookies and Tracking Tools is intact. Where such a request has been withdrawn or sufficiently fulfilled and no longer relevant we shall delete such as part of our commitment to data minimization.

Note: We will also delete your Personal Data upon your expressed request to fulfill your data subject right, provided you forward such a request to us, as mentioned above.

Transfer of Your Information:

We do not sell, trade, or otherwise transfer to outside parties your Personal Data, except as specifically stated in this Policy.

The above statement does not include trusted third parties who assist us in operating our services, conducting our business, or servicing you, and prior to such transfers those parties are contractually obliged to keep your Personal Data confidential and to not use it for any purpose other than to fulfill their obligations to us in relation to the provision of our services to you.

Be advised that notwithstanding, We may share you information with subcontractors and other partners that are located in countries abroad which do not necessarily have the level of data protection in your jurisdiction.

We transfer our customers' Personal Data outside of the EEA or a Country subject to a decision by the European Commission that the country to which our customers’ data is transferred provides an adequate level of data protection, only if it is strictly necessary, and in any such case we will vet and check such third parties data protection practices beforehand and verify that the requisite contractual obligations according to the applicable data protection law are executed in  in  order to make all possible efforts to ensure the protection of our customers’ data prior to such transfers.

Notwithstanding the above, all our subcontractors and other third parties will be subject to contractual obligations limiting their use of your Personal Data and subjecting their activities to the applicable data protection and privacy legislations applicable to your personal data and further to the foregoing all our subcontractors will be subject to non-disclosure and non-use obligations.

Be advised that We will fully cooperate with any law enforcement authorities or court order requesting or directing us to disclose the identity or behavior of any user suspected to have engaged in illegal behavior and thereby we may also release your information when we believe release is appropriate to comply with the law, enforce our site policies, or protect ours or others rights, property, or safety.

However, non-personally identifiable user information may be provided to other parties for analytics, trends study, or other uses, as previously established is one of the purpose of use herein above.

Updates and Changes to this Data Protection and Privacy Policy

We may revise this Policy from time to time, and such changes shall come into effect from the moment ICMC notifies you of such changes and/or updates, either by email, on the websites or in some other reasonable manner.

When we make material changes to this Policy, we’ll provide you with prominent notice as appropriate under the circumstances, e.g., by displaying a prominent notice within the ICMC website or by sending you an email message to that effect.

Additional Privacy Protection Terms for California Residents

Beginning January 1, 2020, the California Consumer Privacy Act ("CCPA") gives California residents certain rights with respect to the processing of personal data (known as "personal information" under the CCPA).

This supplement provides additional privacy disclosures and privacy protection provisions in light of the CCPA for California residents accessing our website.

Personal Information Collected and Processed

The section titled "Information We Collect" (add link) sets forth the categories of personal information that ICMC collects and processes about you, a description of each category, and the sources from which we obtain each category.

Requests to Exercise Your Rights under the CCPA

You are afforded and entitled to forward us requests to exercise your rights as a California resident. We will not discriminate against you for exercising any of your rights under the CCPA

You may make a verifiable consumer request related to your personal information twice per 12-month period.

Please note, if you do not have a ICMC member account we may not have enough information about you to verify your identity to exercise your rights under the CCPA and may ask you to provide personal identification information in order to verify your identity.

You may designate, in writing or through a power of attorney, an authorized agent to make requests on your behalf to exercise your rights. Before accepting such a request from an agent, we will require the agent to provide proof you have authorized it to act on your behalf, and we may need you to verify your identity directly with us.

Right To Know - Under the CCPA, you have a right to request information about our collection, use, and disclosure of your personal information over the prior 12 months prior to the date of your request, and ask that we provide you with the following information:

1. The Categories of and specific details of the personal information we have collected about you.
2. The Categories of sources from which we collect personal information about you.
3. The Purposes for collecting personal information as per 1 and 2 above.
4. The Categories of third parties with which we shared your personal information.
5. Categories of personal information disclosed about you for a business purposes.
6. If applicable, categories of personal information sold about you and the categories of third parties to which the personal information was sold, by category or categories of personal information for each third party to which the personal information was sold.

To make a verifiable request for information about the personal information we have collected about you, please forward a request through your personal account area "I want to see the Data Collected on Me" or email or send us a request through the "Contact Us" online form or at: [email protected]

Right To Delete - You also have a right to request that we delete personal information, subject to certain exceptions.

To make a verifiable request for information about the personal information we have collected about you, please forward a request through your personal account area I want to permanently delete my data  or email or send us a request through the "Contact Us" online form or at: [email protected]

Household Requests - We do not collect household data and only process information about individual users making orders and/or operating an account on our website. If all the members of a specific household makes a Right to Know or Right to Delete request, we will respond to each such request individually and not process all the data as a "Household".

Disclosures of Personal Information for a Business Purpose

In the preceding 12 months, ICMC has disclosed certain data from the following categories of personal information to the categories of recipients listed in Section 5 of our Privacy Policy titled "Transfer of Your Information" for one or more business purposes:

• User Data
• Analytics
• Payment and Purchase Data

Sale of Personal Information

We do not sell personal information. We have taken substantial steps to identify and remediate any data sharing arrangements that could constitute a "sale" under the CCPA.

While we do not sell any personal information directly, but we do provide Usage Data to analytics and advertising partners to enable us to provide you with interest-based advertising.

If you prefer not to receive interest-based advertising, please opt out by going to your account privacy settings and using the tailored ads opt out toggle or sending us an E-mail at: [email protected]

For more information on interest-based advertising, please see our Privacy Policy and Cookies and Tracking Technologies Policy

We will continue to update our business practices as regulatory guidance becomes available and provides clarity on what constitutes a sale transaction, particularly in the advertising ecosystem.