Revised: November 2020
- Important information and who we are
BidGemmer Ltd. is a company incorporated in Israel, with registration number: 515822799.
Email address: firstname.lastname@example.org
Address: HaAgada 5, Ramat Gan, Israel 5237745
Telephone number: +1-530-436-6377
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Third Party Websites
- Your Data
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
Personal data can refer to data of yours, a customer of BidGemmer, or any of your clients who use the Services. You are responsible for obtaining any requisite consents with respect to the use and/or storage of any personal data or personal information belonging to your clients
We may collect, receive, use, store and transfer different kinds of personal data about you which we have grouped together follows:
- Identity Data includes first name, last name, username or similar identifier, title, date of birth and gender.
- Contact Data includes email address and telephone numbers.
- Know Your Counterpart (KYC) Data includes date of birth, country of birth, nationality, residence, passport number, passport copy and expiry date and information received in connection with any relevant checks. This may also include criminal record checks where appropriate and where permitted by applicable laws. Please see further detail below.
- Transaction Data includes details about payments to and from you and other details of Services you have purchased.
- Profile Data includes username and password, purchases or orders made by you and/or your client.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties, your communication preferences, services you searched for or viewed, download errors, length of visits, page response times, and page interaction data (such as clicks, mouse-overs, and scrolling).
- Cookies– Cookies will collect personal data such as internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our Site.
We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from personal data but is not considered personal data as this data does not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Personal data relating to criminal convictions and offenses will only be processed where authorized by applicable laws. For example, a criminal record check may be carried out as part of the KYC check.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you or your employer and you fail to provide that data when requested, we may not be able to perform the Services. In this case, we may have to cease provision of the Services.
- Personal Data Collection
We use different methods to collect data including through:
Direct interactions. By filling in forms, both online or offline, in person at customer meetings, or by corresponding with us by post, phone, email or otherwise. This includes personal data provides when:
- Applying for and/or using our Services;
- complete any form relating to pre-engagement checks;
- subscribe to our Service or publications;
- request marketing to be sent to you;
- provide us some feedback.
Third parties or publicly available sources. We may receive personal data from various third parties and public sources as set out below:
- KYC Data may be provided to us by a colleague, by a third party or by you directly.
- Identity and Contact Data from publicly available sources.
- Use of Personal Data
We will only use personal data when and where the law permits. Most commonly, we will use personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. Please note:
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
We have your consent to using your personal data for a particular activity.
Note that we may process personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To comply with anti-money laundering regulations and undertake necessary pre-engagement checks||(a) Identity
|(a) Necessary to comply with a legal obligation
(b) Necessary for our legitimate interests (to manage and operate our business)
|To perform the contract we have entered into with you and provide you with Services||(a) Identify
|Performance of a contract with you|
(d) Marketing and Communications
|(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated)
|To make suggestions and recommendations to you about goods or services that may be of interest to you||(a) Identity
(e) Marketing and Communications
(b) Necessary for our legitimate interests (to develop our products/services and grow our business)
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising:
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us or if you provided us with your details when you registered for a promotion and, in each case, you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any company outside BidGemmer Ltd. for other marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.
A cookie is a small text file containing small amounts of information which is downloaded to / stored on your computer (or other internet enabled devices, such as a smartphone or tablet) when you visit a website.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
- Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes set out in the table in Section 4 above.
External Third Parties
- Third parties who carry out anti-money laundering and other pre-engagement checks on our behalf.
- Intuit QuickBooks, Sage, SMBS\Rubinstein Software LTD for external invoicing purposes.
- Mixpanel and Mouseflow for website traffic and webpage interactions and usage.
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
- International transfers
You, a customer, must abide by applicable law with respect to the transfer of persona data and/or personal information. This includes with respect to transferring data outside the European Economic Area (EEA), including Botswana, Canada, China, India, Israel, Hong Kong SAR, Namibia, Singapore, South Africa, UAE and the USA.
Whenever we, Bidgemmer, will transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
- Where we use providers based in the US, we may transfer data to them if they have contractual provisions approved to meet EEA standards.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
- Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
- Data retention
We will only retain personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances you can ask us to delete your data: see Request erasure below for further information.
In some circumstances we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
- Legal rights
Subject to certain exemptions, and in some cases dependent upon the processing activity we are undertaking, you have certain rights in relation to your personal data. These rights pertain to your (personal data) and/or your client’s personal data. You are also obligated to inform your clients accordingly
To access personal data
You have a right to request that we provide you with a copy of your personal data that we hold and you have the right to be informed of; (a) the source of your personal data; (b) the purposes, legal basis and methods of processing; (c) the data controller’s identity; and (d) the entities or categories of entities to whom your personal data may be transferred.
To rectify / erase personal data
You have a right to request that we rectify inaccurate personal data. We may seek to verify the accuracy of the personal data before rectifying it.
You can also request that we erase your personal data in limited circumstances where:
- it is no longer needed for the purposes for which it was collected; or
- you have withdrawn your consent (where the data processing was based on consent); or
- following a successful right to object (see right to object); or
- it has been processed unlawfully; or
- to comply with a legal obligation to which the Company is subject.
We are not required to comply with your request to erase personal data if the processing of your personal data is necessary:
- for compliance with a legal obligation; or
- for the establishment, exercise or defense of legal claims.
Right to restrict the processing of your personal data
- You can ask us to restrict your personal data, but only where:
- its accuracy is contested, to allow us to verify its accuracy; or
- the processing is unlawful, but you do not want it erased; or
- it is no longer needed for the purposes for which it was collected, but we still need it to establish, exercise or defend legal claims; or
- you have exercised the right to object, and verification of overriding grounds is pending.
We can continue to use your personal data following a request for restriction, where:
- we have your consent; or
- to establish, exercise or defend legal claims; or
- to protect the rights of another natural or legal person.
Right to transfer your personal data
You can ask us to provide your personal data to you in a structured, commonly used, machine‑readable format, or you can ask to have it transferred directly to another data controller, but in each case only where:
- the processing is based on your consent or on the performance of a contract with you; and
- the processing is carried out by automated means.
Right to object to the processing of your personal data
You can object to any processing of your personal data which has our legitimate interests as its legal basis, if you believe your fundamental rights and freedoms outweigh our legitimate interests.
If you raise an objection, we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms.
Right to object to how we use your personal data for direct marketing purposes
You can request that we change the manner in which we contact you for marketing purposes.
You can request that we not transfer your personal data to unaffiliated third parties for the purposes of direct marketing or any other purposes.
Right to obtain a copy of personal data safeguards used for transfers outside your jurisdiction
You can ask to obtain a copy of, or reference to, the safeguards under which your personal data is transferred outside of the European Union.
We may redact data transfer agreements to protect commercial terms.
Right to lodge a complaint with your local supervisory authority
You have a right to lodge a complaint with your local supervisory authority if you have concerns about how we are processing your personal data.
We ask that you please attempt to resolve any issues with us first, although you have a right to contact your supervisory authority at any time.
If you wish to access any of the above mentioned rights, we may ask you for additional information to confirm your identity and for security purposes, in particular before disclosing personal data to you. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive.
Exercising your rights
You can exercise your rights by contacting us. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly or inform you if we require further information in order to fulfil your request.
We may not always be able to fully address your request, for example if it would impact the duty of confidentiality we owe to others, or if we are legally entitled to deal with the request in a different way.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.