privacy policy

Effective Date: March 1, 2026

This Privacy Policy (the “Privacy Policy”) constitutes an integral part of the Terms of Use and should be read together with the Terms of Use. Capitalized terms used herein shall have the meanings ascribed to them in the Terms of Use, unless otherwise defined in this Privacy Policy.

The Operator is committed to respecting the privacy of users of the Website. In order to enhance the protection of user privacy, the Operator publishes this Privacy Policy and provides information regarding the options available to users when using the Website and the Operator’s practices concerning the collection of information from the Website.

1. General

1.1. As part of using the Website, the user may be required to provide personal information to the Operator, including contact details, company information, business role, and other relevant data.

1.2. During use of the Website, data may be accumulated regarding the user’s usage patterns on the Website, including pages visited, tools accessed, and content viewed. This is statistical information and does not personally identify the user.

2. Data Controller

2.1. The data controller responsible for the processing of personal data collected through the Website is:

SmartRetry
Email: contact@smartretry.com
Phone: +972-54-8020708

2.2. The data collected about the user as described above may be stored in the Operator’s registered information database in accordance with applicable law. The Operator undertakes to use such information in accordance with this Privacy Policy and/or in accordance with applicable law, for the following purposes:

To enable efficient and convenient use of the Website for the user;
To improve and enhance the services and content offered on the Website;
To modify or discontinue existing services and content;
To analyze and provide statistical information to third parties, including advertisers (in the event such information is transferred to third parties, it will not personally identify the user);
To enforce the Operator’s Terms of Use;
To transfer user details to business partners, service providers, and/or their representatives where necessary;
For billing and collection purposes;
For any other purpose set forth in the Terms of Use and this Privacy Policy.

3. Marketing Communications

3.1. User details provided by the user shall be subject to the Operator’s Privacy Policy, and the user acknowledges that the information provided by the user and/or collected about the user shall be stored in the Operator’s information database for the following purposes:

Marketing, advertising, sales promotion, and for contacting the user by any means, including by way of direct marketing through any communication medium deemed appropriate (including in writing, print, telephone, facsimile, electronic means, or any other method);
Loyalty programs, statistical analysis and research, conducting surveys, and any other use in connection with the user’s registration on the Website;
Internal purposes, such as investigation of complaints and/or audits;
Operational, marketing, and statistical purposes, including data processing and direct marketing for the realization of these purposes;
Provision of services to the user and ensuring fair commercial activity in accordance with applicable law;
Billing and collection;
Transfer of user details to business partners and service providers where necessary.

3.2. The Operator may, for the purposes set forth above, transfer the information from time to time to other entities with which the Operator maintains cooperative relationships, and to any additional party that will provide services and benefits to users at its discretion. Such entities and parties shall be entitled to use the information transferred to them (for the same purposes) as set forth above, all subject to applicable law.

3.3. The user acknowledges that there is no legal obligation to provide the information, and that providing such information is voluntary and with the user’s consent. The Operator shall also be entitled, for the purposes set forth above, to transfer from time to time non-identifiable, anonymous, or aggregated information regarding user activity on the Website to entities that are partners in the Operator’s activities and to any party that will provide services and benefits to users at the Operator’s discretion.

3.4. Subject to the user’s lawful consent, the Operator shall be entitled to contact the user from time to time through direct marketing for the purpose of receiving offers for various services and benefits of the Operator provided as part of the user’s use of the Operator’s services, by email, text messages (SMS), facsimile, social networks, automatic dialing systems, and/or by telephone, unless and until the user provides notice to the contrary at any time.

4. Disclosure of Information to Third Parties

Circumstances under which the Operator may share the user’s information with third parties:

When the user has authorized the Operator to transfer their personal details to third parties, including for the purpose of business engagement or service provision;
In the event that the user breaches the Terms of Use of the Website or attempts to perform actions contrary to law;
In order to enforce the Terms of Use or other agreements or policies;
In the event that the Operator decides to collect an unpaid debt through a third party specializing in debt collection, including law firms;
In response to a subpoena or other investigative demand, court order, or request for cooperation from a law enforcement or other governmental authority;
In order to establish or exercise the Operator’s legal rights;
In order to defend against legal claims as required by law. In such cases, the Operator may raise or waive any objection or right available to it, at its sole discretion;
When the Operator believes that disclosure is appropriate in connection with efforts to investigate, prevent, report, or take other action regarding illegal activity, suspected fraud, or other wrongdoing;
In order to protect the rights, property, or safety of the Operator, its employees, users of the Website, or others;
In connection with a substantial corporate transaction, such as the sale of the Operator’s business, divestiture, merger, consolidation, or sale of assets, or in the event of liquidation.

5. Aggregated and Non-Personal Information

The Operator may use aggregated and non-personal information that it has collected in any of the circumstances set forth above. The Operator may combine non-personal information that it has collected with additional non-personal information collected from other sources. For example, without limitation, The Operator may also share aggregated information with third parties, including advisors, advertisers, and investors, for the purpose of conducting general business analysis. For example, the Operator may report to its advertisers regarding the number of visitors to the Website and the most popular content or tools. Such information does not include any personal information and may be used to develop content and services that will assist users and to customize content and advertising.

6. Third Parties

6.1. The Website may contain links that allow the user to access other websites that are not subject to this Privacy Policy. These websites may independently request and collect information, including personal information from the user, and in certain cases, may provide the Operator with information regarding user activity on such websites.

6.2. Any third party to whom the Operator may disclose personal information may have its own privacy policy describing how it uses and discloses personal information. Such policy shall govern the use, handling, and disclosure of the user’s personal information after the Operator has shared it with such third parties as described in this Privacy Policy. If you wish to obtain additional information regarding the privacy policies of such third parties, the Operator encourages you to visit the websites of such third parties.

6.3. The Operator may permit third parties, including its authorized service providers, advertising companies, and advertising networks, to display advertisements on the Website. These companies may use tracking technologies, such as “Cookies” to collect information about users who view or interact with their advertisements. The use that these companies make of “Cookies” is subject to their own privacy policies and not to the Privacy Policy of the Operator.

7. Cookies and Tracking Technologies

7.1. The Operator may use various technologies to collect information from the user’s mobile device and/or computer and regarding the user’s activity on the Website.

7.2. The Website uses the following types of cookies:

Essential Cookies: These cookies are necessary for the Website to function properly and cannot be disabled. They enable basic functions such as page navigation and access to secure areas of the Website.
Analytics Cookies: These cookies allow us to analyze Website usage in order to measure and improve performance. They help us understand how visitors interact with the Website by collecting and reporting information anonymously.
Marketing Cookies: These cookies may be used to track visitors across websites. They are used to display advertisements that are relevant and engaging for the individual user.

7.3. The Operator may use standard internet technology, such as web beacons, analytics, and similar technologies, to track the user’s use of the Website. The Operator may also include such technologies in email messages or newsletters for sales promotion purposes, in order to determine whether messages have been opened and whether action has been taken as a result. The information that the Operator obtains in this manner will enable it to customize the services it offers to the user, to display personalized advertisements, and to measure the overall effectiveness of online advertising, content, programming, or other activities.

7.4. Managing Cookies: Most web browsers allow you to manage your cookie preferences. You can set your browser to refuse cookies or to alert you when cookies are being sent. Please note that disabling cookies may affect the functionality of the Website.

8. User Choices Regarding Collection and Use of Information

8.1. The user may choose not to provide the Operator with certain information; however, this may result in the user being unable to use certain features of the Website, as such information may be required for registration for the Operator’s services or for accessing certain functionality.

8.2. When the user registers for the service and has agreed to receive direct marketing as set forth in the Terms of Use, the Operator may, subject to applicable law, send the user direct marketing communications, including but not limited to email messages and/or newsletters regarding service updates, improvements, special offers, or special content. The Operator may send the user other types of email messages, such as service notices, advertising messages, and surveys. If the Operator has already transferred information about the user to a third party before the user changed their preferences or updated their information, the user may need to change their preferences directly with such third party.

9. Information Security

9.1. The Operator implements up-to-date systems and procedures for information security on the Website. These systems and procedures reduce the risks of unauthorized intrusion but do not provide absolute security. The Operator does not warrant that its services will be completely immune from unauthorized access to information stored on the Website.

9.2. The Operator periodically reviews the information security of the Website and makes changes and upgrades as necessary in order to maintain the level of information security of the Website. However, the Operator shall not be liable for any damage, direct or indirect, caused to the user in the event of disclosure of information due to unauthorized intrusion by third parties or as a result of any act or omission beyond the Operator’s control.

10. Data Retention

10.1. The Operator retains personal data only for as long as necessary to fulfill the purposes for which it was collected, to comply with legal obligations, to resolve disputes, and to enforce agreements.

10.2. When personal data is no longer required for the purposes set forth in this Privacy Policy, or upon expiration of the applicable retention period required by law, such data shall be securely deleted, anonymized, or archived in accordance with applicable law.

10.3. Aggregated or anonymized data that does not identify the user may be retained indefinitely for analytical, statistical, or research purposes.

11. International Data Transfers

11.1. The Operator may transfer personal data to countries outside of the user’s country of residence, including to service providers, business partners, and affiliated entities located in other jurisdictions.

11.2. Such transfers shall be made in accordance with applicable data protection laws. Where required, the Operator shall implement appropriate safeguards, such as standard contractual clauses or other lawful transfer mechanisms, to ensure the protection of personal data.

11.3. By using the Website, the user acknowledges and consents to the transfer of their personal data to countries that may have different data protection laws than the user’s country of residence.

12. Right to Access and Update Information

12.1. In accordance with applicable data protection and privacy laws, individuals may have the right to access, review, correct, update, and/or request deletion of personal data held about them. A user who has reviewed their personal data and found that it is inaccurate, incomplete, unclear, or outdated may contact the Operator to request that such information be corrected, updated, or deleted, subject to applicable law.

Such requests should be directed to the Operator by email at: contact@smartretry.com. The Operator may update its contact details from time to time, provided that updated contact information will be made available on the Website.

13. Your Privacy Rights

13.1. Depending on your location, you may have certain rights regarding your personal data under applicable data protection laws, including the General Data Protection Regulation (GDPR) for users in the European Economic Area, the California Consumer Privacy Act (CCPA) for California residents, and similar laws in other jurisdictions.

13.2. Subject to applicable law, you may have the following rights:

Right of Access: Request confirmation of whether we process your personal data and obtain a copy of such data.
Right to Rectification: Request correction of inaccurate or incomplete personal data.
Right to Erasure (Deletion): Request deletion of your personal data in certain circumstances.
Right to Restriction of Processing: Request that we limit the processing of your personal data in certain circumstances.
Right to Data Portability: Receive your personal data in a structured, commonly used, machine-readable format and transmit it to another controller (where technically feasible).
Right to Object: Object to the processing of your personal data for direct marketing purposes or based on legitimate interests.
Right to Withdraw Consent: Where processing is based on consent, withdraw your consent at any time without affecting the lawfulness of prior processing.
Right to Opt-Out of Sale: Request that we do not “sell” your personal information (as defined under applicable law). Note: The Operator does not sell personal information in the traditional sense.
Right to Non-Discrimination: Not receive discriminatory treatment for exercising your privacy rights.

13.3. To exercise any of these rights, please contact us at: contact@smartretry.com. We will respond to your request within the timeframes required by applicable law.

13.4. You may also have the right to lodge a complaint with a supervisory authority in your jurisdiction.

Children’s Privacy

The Website is not intended for use by children under the age of 18. The Operator does not knowingly collect personal information from children under 18. If the Operator becomes aware that it has collected personal information from a child under 18, it will take steps to delete such information promptly.

16. Changes to the Privacy Policy

The Operator may change the provisions of this Privacy Policy from time to time. If material changes are made to the provisions concerning the use of personal information provided by the user, a notice thereof shall be published on the Operator’s Website. The updated Privacy Policy shall be effective as of the date of publication unless otherwise stated.

17. Contact Us

For any questions, requests, or concerns regarding this Privacy Policy or the processing of your personal data, please contact us at:

SmartRetry
Email: contact@smartretry.com
Phone: +972-54-8020708