Privacy Policy

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Our Commitment to You

Raphael Latam Funnel LTD and its affiliated companies are dedicated to providing its users with the highest level of transparency and control over the use of their data. In order for us to provide you with our services we are required to collect and process certain personal information about you and your activity.

By entrusting us with your information, we would like to assure you of our commitment to keep such information private. We have taken measurable steps to protect the confidentiality, security and integrity of this information. We encourage you to review the following information carefully.

Grounds for data collection

Processing of your “Personal Data” (meaning any information which may potentially allow your identification with reasonable means) is necessary for the performance of our contractual obligations towards you and providing you with our services and the operation of our websites (hereinafter the “Websites” and “Service”), to protect our legitimate interests and for compliance with legal and regulatory obligations to which we are subject.

When you use our Service, you consent to the collection, storage, use, disclosure and other uses of your Personal Data as described in this Privacy Policy.

How do we receive data about you?

We receive your Personal Data from various sources:

Registration information – When you voluntarily provide us your personal details in order to create an account or register to our Service.
When you communicate with us – For example when you send us an email, we collect the Personal Data you provided us with.
Technical information – When operating our service, we use various technological tracking tools to collect information regarding your use of the Website. Along with our partners, we may use tracking technologies such as cookies, JavaScript, beacons and Local Storage, which are used to store content information and preferences. You can learn more about the tracking tools we use by reading the “tracking technologies” section below.
Third party information – We may receive your personal data from third party providers who help us with the provision and maintenance of our Services, such as social networks (for example your name and user name, when you register or log-in to our Service), traffic analytics vendors, fraud prevention agencies and others.

What type of data do we collect?

Personal Data

In the course of using the Service, we may ask you to provide us with certain Personal Data to provide and improve the Service, to contact or identify you, to enable you to access certain parts of the Service, and as otherwise indicated in this Policy. We collect the following Personal Data about you:

Registration information – in order to register and enjoy the full functionality of our Service we may collect the following Personal Data:
- When you register to our Service we will collect your email address, name and eventually phone number.
- If you make a purchase on our website, we might also collect your personal address, documents, pictures, and other documents that you will voluntarily provide us by uploading them to our website.
- If you connect your account to a social network (for example: if you log in via Facebook or Google+), we may also receive certain details, such as your profile name and profile photo and other social account details.

Please note that although registration is not mandatory, unregistered users may have limited usage of the Service.

When using our Service – our server will collect your IP-address and unique device identifiers.

Non-Personal Data

We also collect data about the use of our Service and the characteristics and activities of users, in order to operate it and improve it. We may collect the following non-Personal Data:

Technical information – such as aggregated usage information, e.g. your approximate geo location, page visits, clicks, the browser you are using and its display settings, session start/stop time, time zone, network connection type (e.g., Wi-Fi, cellular), and cookie information etc.
Information from third parties – this category includes information we receive from our business partners. This may include pseudonymous advertiser identifiers or aggregated analytical data. This information is also used to enhance data points about a particular unique browser or device.

If we combine Personal Data with non-Personal Data, the combined data will be treated as Personal Data. Further Personal Data will only be stored and processed if you voluntarily provide it to us, e.g. through a contact form.

Tracking Technologies

When you visit or access our Services we use (and authorize 3rd parties to use) pixels, cookies, beacons and other technologies. Those allow us to automatically collect information about you, your device and your online behavior, in order to enhance your navigation in our Services, improve our Website’s performance, perform analytics and customize your experience on it. In addition, we may merge information we have with information collected through these tracking technologies with information we may obtain from other sources and, as a result, such information may become Personal Data.

We also use a tool called “Google Analytics” to collect information about your use of the Service. Google Analytics collects information such as how often Users access the Service, what pages they visit when they do so, etc. We use the information we get from Google Analytics only to improve our Service. Google Analytics collects the IP address assigned to you on the date you visit the Service, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with personally identifiable information. 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 and the Google Privacy Policy.

What are cookies?

Cookies are small text files (composed only of letters and numbers) that a web server places on your computer or mobile device when you visit a webpage. When used, the cookie can help make our Services more user-friendly, for example by remembering your language preferences and settings. You can find more information about cookies at www.allaboutcookies.org.

Cookies are widely used in order to make websites work in an efficient way. Cookies remember your preferences, and make the interaction between you and the Service smoother and more efficient.

How to manage your cookie settings?

There are various ways in which you can manage and control your cookie settings. Please remember that, by deleting or blocking cookies, some of the features of the Services may not work properly or as effectively.

Turning off cookies via your web browser
Most web browsers will provide you with some general information about cookies, enable you to see what cookies are stored on your device, allow you to delete them all or on an individual basis, and enable you to block or allow cookies for all websites or individually selected websites. You can also normally turn off third party cookies separately. Please note that the settings offered by a browser or device often only apply to that particular browser or device.
Information about cookies is usually found in the “Help” section of the web browser. Below are some links to some commonly used web browsers:

For other browsers, please consult the documentation that your browser manufacturer provides.

Turning off third party cookies
You can turn off certain third party targeting/advertising cookies by visiting the following link: Network Advertising Initiative.
Other helpful resources

To learn more about advertisers’ use of cookies the following links may be helpful:

How do we use the data we collect?

Provision of service – for the provision and improvement of our Services, including for support and to respond to your queries.
Service announcements – we will use your Personal Data to communicate with you and to keep you informed of our latest updates to our Services and offer you service offers.
Analytics, surveys and research – from time to time, we may conduct surveys or test features, and analyze the data we have to develop, evaluate and improve these features, all in order to improve our Services and think of new and exciting features for our users.
Marketing and advertising – We may use your Personal Data in the following ways: we or our partners may send you promotional material concerning our Service, or our partners’ services, which we or our partners, believe might interest you; we may also display certain adverts on our Service, which we believe will be relevant for you. We make our best efforts to make sure you see only relevant ads and receive relevant communications from us, including but not limited to, by building an automated profile based on your Personal Data.
- Opt-out of receiving marketing materials – If you do not want us to use or share your Personal Data for marketing purposes, you may opt-out in accordance with this “Opt-out” section. Please note that even if you opt-out, we may still use and share your Personal Data with third parties for non-marketing purposes (for example to fulfill your requests, communicate with you and respond to your inquiries, etc.). In such cases, the companies with whom we share your Personal Data are authorized to use your Personal Data only as necessary to provide these non-marketing services.
- You may choose not to receive our promotional or marketing emails by clicking on the “unsubscribe” link in the emails that you receive from us. Please note that even if you unsubscribe, we may continue to send you service-related updates and notifications, or reply to your queries and feedback you provide us. You may also object to the use of your Personal Data for advertising purposes by disabling your cookies, as described in the Tracking Technologies section above. Please note we have no control over our partners’ communications, in order to unsubscribe from our partners’ communications please contact the relevant partner, or use the “unsubscribe” link in its emails.
Protecting our interests – we may use your Personal Data when we believe it’s necessary in order to take precautions against liabilities, investigate and defend ourselves against any third party claims or allegations, investigate and protect ourselves from fraud, protect the security or integrity of our services and protect the rights and property of Raphael, its users and/or partners.
Enforcing policies – we may use your Personal Data in order to enforce our policies, including but not limited to our Terms.
Compliance with legal and regulatory requirements – we may use your Personal Data to investigate violations, and as required by law, regulation or other governmental authority, or to comply with a subpoena or similar legal process.

With whom do we share your Personal Data?

Internal concerned parties – we share your information with companies in our group, as well as our employees, in order to provide you with our services.
Business partners – we share your information with business partners, such as storage and analytics providers and advertisers, who help us provide you with our service. These third parties may have access to your Personal Data so that they may perform these tasks on our behalf, but they are obligated to comply with this Privacy Policy and may not use your Personal Data for any other purpose. We may also share your personal data with business partners such as marketers whom we believe can offer you relevant or complimentary products and services. You may object to the transfer of your personal data to such business partners at any time, or unsubscribe from their communications, as detailed in the “Marketing and advertising” section above.
Compliance with laws and law enforcement entities – we cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We will disclose any data about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), to protect our or a third party’s property and rights, to protect the safety of the public or any person, or to prevent or stop any activity we may consider to be, or to pose a risk of being, illegal, unethical, inappropriate or legally actionable. We also may be required to disclose an individual’s Personal Data in response to a lawful request by public authorities, including meeting national security or law enforcement requirements.
Merger and acquisitions – we may share your data if we enter into a business transaction such as a merger, acquisition, reorganization, bankruptcy, or sale of some or all of our assets. Any party that acquires our assets as part of such a transaction may continue to use your data in accordance with the terms of this Privacy Policy.

How do we protect your information?

We have implemented administrative, technical, and physical safeguards to help prevent unauthorized access, use, or disclosure of your Personal Data. Your data is stored on secure servers and isn’t publicly available. We limit access of your information only to those employees or partners on a “need to know” basis, in order to enable the carrying out of the agreement between us.

While we seek to protect your information to ensure that it is kept confidential, we cannot absolutely guarantee its security. You need to help us prevent unauthorized access to your account by protecting your password appropriately and limiting access to your account. You will be solely responsible for keeping your password confidential and for all use of your password and your account, including any unauthorized use. You should also be aware that there is always some risk involved in transmitting information over the internet. While we strive to protect your Personal Data, we cannot ensure or warrant the security and privacy of your Personal Data or other content you transmit using the service, and you do so at your own risk.

Retention

We will retain your Personal Data for as long as necessary to provide our services, and as necessary to comply with our legal obligations, resolve disputes, and enforce our policies. Retention periods will be determined taking into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time. Under applicable regulations, we will keep records containing client personal data, trading information, account opening documents, communications and anything else as required by applicable laws and regulations.

Updates to this Policy

This Privacy Policy is subject to changes from time to time, in our sole discretion. The most current version will always be posted on our website (as reflected in the “Last Updated” heading). You are advised to check for updates regularly. By continuing to access or use our Services after any revisions become effective, you agree to be bound by the updated Privacy Policy.

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