PRIVACY POLICY – " EMPRO"

Effective From: December 2022

This This privacy policy (the "Privacy Policy") is an integral part of the terms of use and both documents should be read together.

EMPRO respects the privacy of its users. To improve the protection of the Users, EMPRO publishes this Privacy Policy regarding how EMPRO collects Your information from Your use of the Service.

The processing and collection of personal data is governed by the General Data Protection Regulation (the “GDPR”) and the California Consumer Privacy Act ("CCPA"), and whenever you’ll provide EMPRO such information, EMPRO will only use your information in line with all applicable data protection laws, including the GDPR and the CCPA. At all times You are in control of Your information, and You can withdraw Your consent to provide Your information to EMPRO.

The data controller of the Service is HAUSER'S STUDIO LTD, Israeli C.N. 515850063, which is the entity which decides how Your personal information is processed and for what purposes as detailed in the Privacy Policy.

General

During Your use of the Service, EMPRO will collect Your following information with accordance to Your consent which may be withdrew at any time:

1. Contact Details you may provide us such as email address, name and phone number;
2. non-personal information including location data, IP address, device data such as mobile identifiers, carrier network information, the mobile website or mobile app used and cookie or pixel tag data;
3. any other data which will be detailed by EMPRO, if applicable.

Your Rights Regarding Your Personal Information

1. Under the GDPR and subject to different exemptions, You have the following rights:
   • To access Your personal data and receive a copy of Your personal data upon Your request;
   • To rectify, erase or restrict Your information upon Your request (right to be forgotten);
   • To object to the processing of Your information;
   • To request that EMPRO will provide the You with Your personal information and, if possible, to transmit Your data directly to another data controller (right to data portability).
   • To withdraw Your consent to processing and the processing at any time;
2. No fees are required for exercising any of the above rights. However and subject to the GDPR, EMPRO may charge You a reasonable fee including administration fees if Your request is repetitive or excessive or demands EMPRO to bear excessive and/or expensive efforts.
3. To exercise your rights, please contact EMPRO’s Data Protection Officer at the following contact details:
   HAUSER'S STUDIO LTD
   216 Gilboa St.
   Nirit
   Israel
   Email: gdpr@empro-con.com

Database and Use of Information

1. All collected information as stated above is stored in EMPRO’s database. With accordance to Your consent, EMPRO warrants to use such information for the following purposes:
   • Enabling convenient and efficient use;
   • Improve and enrich existing services and content;
   • Modify and/or remove existing services and content;Perform research and provide statistic information to third parties, including advertisers (in such case, the provided information will not identify You);
   • Enforce EMPRO's terms and conditions;
   • Contacting Users who provided their details via the Website;
   • Any other purpose detailed in the terms of use and this Privacy Policy.
2. Information You decide to provide EMPRO is collected and used because EMPRO has a legitimate business interest for Your personal data to be used for the above purposes. This enables EMPRO to send You relevant and personalized content designed to improve Your use of the Service. You have the right to object to this by contacting EMPRO via email: gdpr@empro-con.com. Please note that if you object, this may affect EMPRO’s ability to send personalized content to You.
3. Please note that some of the information You will be requested to provide is necessary for providing You the Services. Therefore Your refusal to provide some information may result in You not receiving the Services since EMPRO will not be practically able to provide you the Services.
4. EMPRO may receive Your information from third parties which EMPRO cooperates with (e.g. business partners, professional advisors, service providers, etc.) and EMPRO may receive Your information from them.

Transferring Information to Third Parties

1. Subject to Your consent, EMPRO will transfer and/or share Your information in the following events and circumstances and, when applicable, will give you reasonable notice upon doing so:
   • When You have permitted EMPRO to transfer and/or share Your information;
   • When You violate the terms of use of the Website or act illegally;
   • To enforce the Terms or other agreements or policies;
   • In response to a subpoena or similar investigative demand, a court order, or a request for cooperation from law enforcement or other government agency;
   • To establish or exercise EMPRO's legal rights;
   • To defend against legal claims; or as otherwise required by law. In such cases, EMPRO may raise or waive any legal objection or right available to EMPRO, in EMPRO's sole discretion;
   • When EMPRO believes disclosure is appropriate in connection with efforts to investigate, prevent, report or take other action regarding illegal activity, suspected fraud or other wrongdoing;
   • To protect and defend the rights, property or safety of EMPRO, its Users, employees or others;
   • In connection with a substantial corporate transaction, such as the sale of EMPRO's business, a divestiture, merger, consolidation, or asset sale, or in the event of insolvency.
   • With accordance to the CCPA, We do not share, sell, disclose or commercialize your information unless explicitly mentioned otherwise.

Third-Parties

1. There are a number of places in the Service where You may click on a link to access other websites that do not operate under this Privacy Policy and are not related to EMPRO including, but not only, links leading to third party websites. These links may independently solicit and collect information, including personal information, from You and, in some instances, provide EMPRO with information about Your activities on those links.
2. Every third party such as detailed above may have its own privacy policy describing its use of personal information, and such policy will regulate the use, handling and disclosure of such personal information of the User. Should You require additional information regarding any privacy policy of third parties, EMPRO recommends that You visit these third-party Services and read their privacy policies.
3. Your information will be handled and used by EMPRO’s trusted third parties including the following recipients in order to provide services provided by EMPRO:
   • Providers, partners and sub-contractors on behalf of EMPRO;
   • Analytics and search engine providers that may assist EMPRO in improving the optimization and performance of the Service

Retaining Your Information

EMPRO will only retain Your personal information for as long as necessary to fulfil the purposes it was collected for including, but not only, for the purposes of complying with legal, accounting, or reporting requirements. The retention period is determined based on the amount, nature, and sensitivity of Your personal information, the potential risk of harm from unauthorized use or disclosure of Your information, the purposes for which EMPRO processes Your information and whether such purposes can be achieved through other means with accordance to any applicable law.

Use of Various Collection Technologies

1. Upon Your consent, We use various technologies to collect information from Your device and about Your activities while using the Service in order to improve and personalize Your online experience of the Service including by means of storing cookies to Your device. Please note that some of the technologies We use are necessary for using the Service and some are used to provide features of third parties.
2. Please note that We cannot guarantee the proper performance and use of the Service, and therefore without permitting Us to gather information via such technologies, We will not be able to provide You Our Services and You will be requested to refrain from any use of the Service.
3. During your use of the Service, third-party Services may store cookies to Your device, e.g. when some content of the Service is embedded from the Third Party Services. Please note that We have no control over these cookies and You should check such third party’s cookie policy.

Data Security

1. EMPRO takes appropriate security measures for data security purposes to help prevent unauthorized persons from gaining access to Your personal information. However, no system can be completely secure. Therefore EMPRO does not warrant that its services will be totally immune to any breaches of security and/or unauthorized access, including access to the data stored in the Service, although EMPRO will contact You upon a breach of Your data security with accordance to any applicable law.
2. EMPRO inspects, from time to time, the data security of the Service and performs modifications and upgrades accordingly in order to keep the Service’s security. Nonetheless, EMPRO will not be liable for any direct or indirect damage caused to You due to exposure of Your information by an unauthorized access to EMPRO’s database and/or due to any negligence or act not controlled by EMPRO.

Minors

We do not knowingly collect or solicit information from anyone under the age of eighteen (18) or knowingly allow minors to use the Service or any of Our Services. If we become aware that we have collected information from a minor without the consent of his/her parent or guardian, we will immediately remove such collected information and block his/her access to the Service and/or any of Our Services.

Email Updates

1. EMPRO may offer to all its users to receive email messages and/or newsletters about updates, improvements and other user notifications regarding EMPRO’s activity, including via emails and SMS (the “Mailings”)
2. It is clarified that at any stage You will have the ability to opt out of receiving the Mailings by contacting EMPRO and/or by clicking on a link available on the Mailings sent to You by EMPRO.

Changes to This Privacy Policy

EMPRO may occasionally update this Privacy Policy. EMPRO will notify You by sending an email to the email address You most recently provided EMPRO and/or by prominently posting notice of the changes and will state at the heading of the Privacy Policy the date of change.