GENERAL Data Protection Regulation – GDPR Compliance Statement

background

The General Data Protection Regulation (GDPR), which came into force across the European Union from 25 May 2018, brings with it the most significant change in European data protection law in two decades. The GDPR is designed to adapt to changes in the digital age and is based on the implementation of an adapted degree of privacy and ongoing risk management.

Our Commitment

We at Teamnet are committed to ensuring the protection of the personal information processed by us and to provide an appropriate response to the risks associated with the information and therefore we carry out comprehensive processes to secure the information. We are responsible for updating and expanding existing processes in order to comply with the requirements of the GDPR. To strengthen our commitment to maintaining the data privacy of our customers, suppliers we work with and other stakeholders.

Contents:

1. The field of information security policy
2. Collection of information
3. Use of information
4. Transmission of information to third parties
5. Storage of information
6. Duration of the storage of the information
7. Your rights with respect to the personal information concerning you
8. Policy changes
9. Contact us

1. Information Security Policy

For Teamnet, information is an asset, which, like other important business assets, is valuable, and therefore deserves adequate protection. Information security protects information from a wide range of threats, to ensure business continuity, minimize damage to the company and increase, as much as possible, business opportunities and profits on investments.

Teamnet has decided to implement information security through a series of control measures, which can be policies, rules, procedures, organizational structures and software functions.

Teamnet identifies its security requirements based on the following three sources:

First source – risk assessment for the organization. In the risk assessment process, the various threats to the organization’s assets are defined, as well as the organization’s vulnerability to these threats, also assessed are the likelihood of the occurrence of the threats and their possible impact.

Second source – legal requirements: laws, regulations and contractual obligations that the organization, its trading partners, contractors and service providers must comply with.

Third source – a set of data processing policies, objectives, and requirements that the organization has developed to support its activities.

The company’s management is responsible for the strict observance and implementation of all the instructions and procedures appearing in this file, for this purpose the company’s management has appointed the CEO, Mr. Israel Amar, as the management’s supervisor of the information security system.

All employees of the company are responsible for the implementation of the requirements specified in this set of procedures, and for the security of the information specified at all stages of the work relating to their areas of operation or affected by them.

Resources are allocated to information security in accordance with actual needs for implementing the information security policy. This also applies to specialists who receive guidance and instruction to improve their professional knowledge.

Each manager is responsible to the Company for both the security of the information in his or her personal performance and the security of the information in the performance of his or her employees.

As part of this responsibility, each manager must:

• Initiate an information security improvement activity.
• Provide and control appropriate and suitable tools to carry out the work.
• Attend to the training of employees in all aspects of their activities, including an occasional refresher course to renew their certification.
• Encourage and involve all of its employees in information security efforts.
• Ensure that you operate in accordance with applicable procedures, specifications, and processes.
• Ensure in advance that potential malfunctions are prevented.
• In the event of malfunctions and deficiencies, the manager must act according to the nature and severity of the malfunction by informing and personally guiding the employee, cultivating tools and methods, training and recertifying.

Every employee in the company is responsible for information security in the performance of his   duties and in doing so:

• Initiate and contribute to information security improvement efforts to the best of his ability.
• Work in accordance with company procedures.
• Work as directed by supervisor.
• Contact supervisor or professional authority as needed.
• Conduct a self-test for the security of information and the integrity of their work before moving the product to the next phase of execution.

To prevent the violation of civil or criminal laws, regulations, or contractual obligations and security requirements, the Company’s management monitors laws and regulations (through legal counsel) related to its area of operations and ensures that employees a regularly as: Electronic Signature Laws, GDPR and database laws.

The Company’s management works continuously to ensure that the Quality Policy is understood, implemented and maintained at all levels of the Company through competence development, training and information in regular meetings.

To protect the integrity of the software and information, the Company takes precautions to prevent and detect the intrusion of malicious software.

All Company employees are aware of the dangers associated with unauthorized or malicious software, and Company managers implement special controls, as appropriate, to detect or prevent their access.

In order to prevent business disruptions and protect critical business processes from the effects of serious failures or disasters, the Company reserves the right to establish a disciplinary process for employees who have violated the organization’s security policies and procedures In addition, it is a proper and fair means of dealing with employees suspected of serious or persistent security violations.

2.Information Collection

The Company undertakes to use personal information about you only for the purposes specified in the privacy policy below, as and to the extent that it is updated from time to time.

Teamnet collects the detailed information as follows:

1. Information about your geographic location;
2. Information about your visits and usage, including referral source, length of visit, page views, and your paths through the Site;
3. Information you send such as your e-mail address, name, gender, birthday
4. Information related to anything you purchase, services you use, or transfers you make,
5. Information contained in messages you send to us by email or through our website, including the content of the message and its metadata;
6. Any other type of personal information that you send to us.

Before you disclose another person’s personal data to us, you must obtain that person’s consent to disclose and process that personal data in accordance with this policy
3. Use of information

Personal information provided to us will be used for the purposes specified in this Policy. We may use your personal information for the following purposes:

1. Administering our website and business;
2. To enable you to use the services available on our website;
3. Sending services that you have purchased;
4. Sending statements, transaction accounts, and payment reminders to you, and collecting payments from you.
5. Send you non-marketing commercial messages;
6. Send you email notifications that you have specifically requested;
7. Sending you marketing communications relating to our business and the businesses of carefully selected third parties that we believe may be of interest to you by mail or, if you have expressly consented, by email or similar technology ( you can tell us at any time if you are no longer interested in receiving marketing communications);
8. Handling inquiries and complaints submitted by or relating to you;
9. Keep our site secure and prevent fraud;
10. Verification of compliance with the Terms of Service (including monitoring of private messages sent through the Privacy Message Service);

If you provide us with personal information for publication, we will publish the information and use it in other ways in accordance with the license you provide to us.

Your privacy settings can be used to limit the publication of your information, and can be adjusted with controls.

We will not provide your personal information without your consent to any third party for the purpose of directly marketing it or any other third party.

It is hereby clarified that the legal bases set forth above are the legal bases for the personal data processing operations carried out by the Company under European data protection laws. It is hereby clarified that to the extent that the processing of personal information about you is subject to other legal systems, then the legal basis for processing personal information about you under those laws may be different.

In certain laws, and with respect to only some users, when we process personal information for the purpose of fulfilling the legitimate interests of the Company or a third party, the processing of such information is subject to the interests or fundamental rights and freedoms of the persons to whom the personal information relates supersede the legitimate interests of the Company or any third party.

Wherever personal information about you is processed based on this legal basis, you are welcome at any time to contact us in order to obtain details of the examination carried out by us in the matter and which led to our decision that certain personal information processing activities can be carried out based on this legal basis.

4.Transfer of information to a third party

We may disclose your personal information to any of our employees, managers, professional consultants, agents, suppliers, or subcontractors as reasonably necessary for the purposes set out in this policy.

We may disclose your personal information:

1. According to what is required of us by law;
2. In the context of any existing or future legal proceedings;
3. To establish, exercise, or defend our legal rights (including the provision of information to others for the purposes of fraud prevention and credit risk reduction);
4. To the purchaser (or potential purchaser) of any business or property that we acquire (or are considering purchasing);
5. And to any person who we reasonably believe may apply to a court or competent authority for the release of the personal information, if we believe it is reasonable for that court or authority to order the release of such personal information.
   Except as provided in this policy, we will not provide your personal information to a third party.

International data transfers

1. Information we collect may be stored, processed, and transferred between any of the countries in which we operate in order to enable us to use the information in accordance with this Policy.
2. Information we collect may be transferred to the following countries, which do not have data protection laws compatible with those operating in the European Economic Area: the United States of America, Russia, Japan, China, and India.
3. Personal information that you post or submit for publication may be available, via the Internet, around the world. We cannot prevent the use or misuse of this information by others.

You consent to the transfers of personal information described in the International Data Transfers section

4. How information is stored

1. This section describes our data storage procedures and policies to help ensure that we comply with our legal obligations regarding the retention and deletion of personal data.
2. Personal data that we process for one or more purposes will not be kept longer than necessary for that purpose or those purposes.
3. Notwithstanding the other provisions in this section, we will retain documents (including electronic documents) containing personal data:

• In accordance with what is required of us by law;
• If in our opinion the documents may be relevant to any ongoing or potential legal proceedings;
•  To establish, exercise, or defend our legal rights (including the provision of information to others for the purposes of fraud prevention and credit risk reduction).

Security of your personal information

1. We will take reasonable organizational and technical precautions to prevent the loss, misuse, or alteration of your personal information.
2. We will store all the personal information you provide on secure servers (password and firewall protected).
3. All computerized financial transactions made will be protected by encryption technology.
4. You acknowledge that the transmission of information over the Internet is not secure by its very nature, and we cannot guarantee that data sent over the Internet will be secure.

   5. The duration of the storage of the information

The Company will store personal data about you for as long as is necessary for the purposes of using the data specified in this policy, or for such longer period as is required under the provisions of the relevant law.

For the most part, we will store your personal information in accordance with the statute of limitations in the relevant local law or in accordance with the regulatory provisions that apply to the company, to the extent that they require it to retain the information for longer periods.

In order to ensure that personal information about you is not retained by us beyond what is required, the Company conducts periodic examinations.

6.Your rights in relation to personal information about you 

You can instruct us to provide you with every detail of your personal details that we hold relating to you; The provision of this information will be subject to the following conditions: Provision of adequate evidence for your identity.

We may refuse to provide personal information you request to the extent permitted by law.

You can instruct us at any time not to process your personal data for marketing purposes.

In practice, you will generally express your prior consent to our use of your personal information for marketing purposes, or we will provide you with an option to opt out of having your personal information used for marketing purposes.
Third Party Sites

Our site includes external links, and details about third-party sites. We have no control over, and are not responsible for, the privacy policies and practices of any third party.

Right to rectification of personal information about you – To the extent that personal information about you processed by Teamnet is inaccurate, you may request that Teamnet make corrections to such personal information. In addition, to the extent that personal information about you is incomplete, you may request that the Company supplement such personal information and taking into account the purposes of the processing of personal information, the Company will comply with your request.

Requests to correct and / or complete personal information about you should be sent via email

Right to delete personal information about you – You may request that personal information about you held by the company be deleted.

Requests to delete personal information about you should be sent via email

This right of yours does not apply where the Company has an obligation to process the personal information about you under laws applicable to the Company, for the purpose of performing an obligation arising from the public interest or the exercise of official authority of the Company, for the purpose of the public interest in the field of public health, or for the purposes of defending against legal claims.

The Right to restrict the use of personal information about you – You can request that the use of your personal data by the company be restricted (1) to the extent that you believe that personal information about you held by the company is inaccurate – for a sufficient period of time to allow the company to verify the correctness of the personal information about you, (2) if the processing of personal information about you is illegal and you request the restriction of its use instead of deleting it,  (3) If the Company no longer needs to use the personal information about you, but it is necessary for you to commence, administer or defend against legal proceedings, or (4) if you object, for reasons relating to you, to the processing of personal information about you, to the extent that the legal basis for its processing is the performance of a task or tasks in the public interest, to exercise official authority vested in the Company or to fulfill the legitimate interests of the Company and/or a third party, including the creation of a profile about you by virtue of any of the above legal bases – until determining whether the Company has decisive legitimate reasons for processing personal information about you,  that override your interests, rights and freedoms, or for the establishment, application or defense of legal claims.

Requests to impose restrictions on the use of personal information about you should be sent via email

Right to object to the use of personal information about you – You may at any time object, for reasons related to you, to the processing of personal information about you, to the extent that the legal basis for its processing is the performance of a task or tasks in the public interest, the exercise of official authority vested in the company or the fulfillment of the legitimate interests of the company and / or a third party, including the creation of a profile about you by virtue of any of the above legal bases,  Unless Company demonstrates the existence of overriding legitimate grounds for processing personal information about you that override your interests, rights and freedoms, or for the purpose of establishing, implementing or defending against legal claims.

In addition, you may at any time object to personal information about you being processed for direct marketing purposes, including to create a profile about you for this purpose, and in such case the Company will cease processing personal information about you for direct marketing purposes.

Objections to the use of personal information about you as detailed above should be sent via email

Right to portability of personal information about you – You may request to receive the personal data you have provided to the Company in a structured, acceptable and machine-readable format and to transfer this data to another data controller. To the extent technically feasible, you may request that the transfer of your personal data be made directly by the Company to the other data controller.

It should be emphasized that your right to receive personal information about you or to transfer it to another data controller applies only to personal information about you that is processed based on your consent or based on the need to perform a contract to which you are a party or to take steps at your request before entering into a contract.

It should also be emphasized that this does not prejudice the Company’s right to keep a copy of the personal information about you as stipulated in the European legislation in the field of privacy protection.

Requests to receive and/or transfer personal information about you should be sent via email

Right to withdraw the consent – You may withdraw your consent to the use of personal data about you that the Company uses on the basis of your consent at any time from that moment by the Company; And this without affecting the lawfulness of the use of personal data concerning you that took place before the withdrawal of consent.

Revocation requests must be sent by e-mail.

Right to lodge a complaint – To the extent you have a complaint regarding your personal information and/or this policy, you may contact the Company’s Information Security Officer as follows:

Mr. Israel Amar CEO –  email: israel@teamnet.co.il

To the extent that you are dissatisfied with the handling of your complaint, you may lodge a complaint with the data protection authorities in the European Union, in particular the data protection authority located in your place of residence, place of work or where the violation of your rights in relation to personal information about you has occurred under European privacy laws.

The Company will provide you with a response in relation to your request to exercise any of your rights stated in this section vis-à-vis the Company without delay and in any case within one month from the date of receipt of your request. The time period may be extended by an additional two months where required, given the complexity and number of requests; The Company will notify you, within one month of receiving the request, of such an extension together with the reasons for this. The response to your request to exercise any of the rights stated in this section vis-à-vis the Company shall be free of charge. At the same time, if it is clear that your requests are unfounded or exaggerated, then the Company may charge a fee for responding to requests or refusing requests.

7.Changes to the Policy

We may update this policy from time to time by posting a new version on our website. You should check this page periodically to make sure you understand any changes made to this policy. We may notify you of changes to this policy by email or through the private messaging system on our site.

8.Contact

In order to implement the responsibility for data protection and to comply with regulatory requirements, Mr.Israel Amar has been appointed  to serve as the Teament’s Information Security Officer. For any questions on the subject, you can contact us by email: israel@teamnet.co.il

Signed by

Israel Amar– CEO

15/09/2022