SARINE GROUP PRIVACY POLICY

Our Commitment to You

The Sarine Group of Companies (“Sarine”) 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 want 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 carefully.

Grounds for data collection

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

When you use our Services, 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 may receive your Personal Data from various sources:

1. Contact information — When you voluntarily provide us your personal details in order to contact us or you register to our Service (for example, your name and email address);
2. When you communicate with us — For example, when you send us an email we collect the Personal Information you provided to us.
3. When you use our services — for example when you purchase a machine or bring stones to be scanned at one of our laboratories, we collect the Personal Information you provided to us.
4. Third party information:
   1. Authorized third party service centers — When we receive your Personal Data from authorized third party service centers to whom you provide your Personal Information in order to receive our services.
5. Technical information — When operating our Services, we use various technological tracking tools to collect information regarding your use of the Website. Along with our partners, we 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 visiting our Cookie Policy.

What type of data we collect?

Personal Data

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

• Registration and reservation information — when you create an account on our Service, or when you make a reservation with us, we may collect the following information: your name, identification or passport number, your mailing address, your email address, your telephone number, your transport information (such as departure, destination and time of your transport) and your billing details (such as your credit card number).
• Information from third parties — the information we receive from our business partners (such as an authorized third party service center) may include the details pertaining to services you received, but may also include other information such as your contact details.
• When using our Website — our webserver will collectyour IP-address, and information about your general location.

If you contact us through the contact form on our Website, we will also collect your name, phone number and email address, and any other information you chose to include in your request.

Non-Personal Data

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

• Technical information — this may include data such as website visits, the browser you are using and its display settings, device type, session start/stop time, referral URL, time zone, network connection type (e.g., Wi-Fi, cellular), and other cookie information.

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 third parties to use) pixels, cookies, events 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 Services’ performance, perform analytics, and customize your experience. In addition, we may merge data we have with data collected through these tracking technologies and data we may obtain from other sources, and as a result, such data may become Personal Data.

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 service offerings.
• Analytics, surveys, and research — from time to time we may conduct surveys or test features, and analyze the data we have in order to develop, evaluate and improve our Service and to think of new and exciting features for our users.
• Protecting our interests — we may use your Personal Data when we believe it is necessary 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 to protect the rights and property of Sarine, its users and/or partners.
• Compliance with legal and regulatory requirements — we may use your Personal Data to investigate violations and as otherwise 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 authorized third party service centers who help us provide you with our Services. These third parties may have access to your Personal Data so that they may perform these tasks on our behalf, however, they are obligated to comply with this Privacy Policy and may not use your Personal Data for any other purpose.
• Compliance with laws and law enforcement entities — we cooperate with government and law enforcement officials in relation to the enforcement and compliance with the law. We will disclose any data about you to government or law enforcement officials or other authorized parties to the extent that we believe, in our sole discretion, is necessary or appropriate to respond to claims and legal processes (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 poses 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 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 is not 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.

Transfer of data outside the EEA (for EU residents)

If you are an EU resident, please note that some data recipients may be located outside the EEA. In such cases we will transfer your data only to such countries as approved by the European Commission as providing an adequate level of data protection, or enter into legal agreements ensuring an adequate level of data protection.

User Rights (for EU residents)

As an EU resident, you may request to:

1. Receive confirmation as to whether or not Personal Data concerning you is being processed, and access your stored Personal Data, together with supplementary information.
2. Receive a copy of Personal Data you directly volunteer to us in a structured, commonly used, and machine-readable format.
3. Request rectification of your Personal Data that is in our control.
4. Request erasure of your Personal Data.
5. Object to the processing of Personal Data by us.
6. Request to restrict processing of your Personal Data by us.
7. Lodge a complaint with a supervisory authority.

However, please note that these rights are not absolute, and may be subject to our own legitimate interests and regulatory requirements.

Non-EU residents, are welcome to contact us in case of any question using the contact details below.

How to contact us?

If you wish to exercise any of the aforementioned rights, or receive more information, please contact our Data Protection Officer using the details provided below:

Yaron.Simon@sarine.com

Our Policy toward Children

We understand the importance of protecting children’s privacy, especially in an online environment. The Website and Services are not designed for or directed at children under the age of 16 years old (“Minors”). We do not knowingly collect Personal Data from Minors. If a parent or guardian becomes aware that his or her child has provided us with Personal Data, he or she should contact us using the details provided above.

Updates to this Policy

This Privacy Policy is subject to changes from time to time, at 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.