Privacy Policy
Faropoint Privacy Policy
Last Updated: May 2023
Faropoint Israel Ltd. (“FAROPOINT”, “we” or “us”) operates a website at www.faropoint.com (the “Site”) as well as various online tools offered via the Site to assist potential investors and others who are interested or involved in the acquisition, leasing, management, and financing of real estate and real estate projects offered by FAROPOINT. This privacy policy (our “Privacy Policy”) describes our data practices regarding the collection of Personal Information (defined below) via the Site.. This Privacy Policy does not apply to any Personal Information collected by third party websites or apps not operated by FAROPOINT. Further, your access to and use of the Site is subject to the FAROPOINT Terms of Service located at https://www.faropoint.com/ Terms of Service.
A. Information FAROPOINT Collects About You.
Personal Information You Provide. We use the term “Personal Information” to mean any information that could be used to identify you, including your name, address, email address, birth date, financial information, cell or land-line phone number, or any combination of information that could be used to identify you. What Personal Information we collect from you depends on what aspects of the Site you choose to use and how you interact with the Site.
Site Visitors. We have structured our Site so that, as a casual site visitor, you may come to our Site and review selected information without registering. However, if you wish to become an Investor, then we require you to provide certain additional Personal Information.
Investors. If you choose to access our Site as an Investor, we require that you complete a registration form that is facilitated by a third party service provider. An Investor is an individual who is over the age of 18 and has completed the applicable registration process. The registration forms will specify the information which you must provide to subscribe, which may include such items as (i) name; (ii) email address; (iii) phone number(s); (iv) mailing address; (v) social security number (for IRS tax reporting purposes); (vi) bank account number; and (vii) birth date. The registration forms may additionally request information that you may, at your option, choose to provide or withhold. To the extent this additional information constitutes Personal Information, the third party service provider which collects this information will treat it in the manner specified in its privacy policy. We may also require each Investor to provide information designed to verify his or her identity and to provide certain financial information.
Automatically-Collected Information. Even if you do not register for an account on the Site, we may collect certain information automatically. For example, we may automatically receive and record in our system the following information: ● your internet protocol (IP) address and location; ● referrer URL; ● the type and version of your web browser; ● device identifiers including mobile advertising identifiers; and ● your operating system. We also record page views and other general statistical and tracking information. We use this data to help us administer and operate our Site, to better understand how our users access and interact with the Site, and for security and monitoring purposes. We may send email messages that use a “click-through URL” linked to content on our Site. When you click one of these URLs, you pass through our web server before arriving at the destination web page. We track this click-through data to help determine interest in particular topics and measure the effectiveness of our customer communications. If you prefer not to be tracked, simply do not click text or graphic links in the email.
B. How We Use Your Personal Information.
We use your Personal Information for the following business purposes: ● to facilitate your activities with respect to our Site; ● to contact you regarding administrative issues, such as questions about your specific request, or otherwise respond to your comments or requests; ● to verify and authenticate your identity, to help us ensure that the individuals who use the Site are who they claim to be; ● to prevent, detect, mitigate, and investigate fraud, security breaches, and potentially prohibited or illegal activities, including, for example, activities prohibited by the Anti-Money Laundering Act; ● to help us operate our Site; ● to deliver notices regarding your account; ● to comply with IRS requirements and for tax reporting purposes; ● to provide you with information, such as notices of investment opportunities via our Site or updates concerning investments that you have participated in; ● to send you information we believe is relevant to you, such as news, bulletins, marketing materials, or other information; ● to enforce this Privacy Policy and our Terms of Use; ● to conduct user surveys and questionnaires; and ● to comply with applicable law.
We use aggregated information to analyze the effectiveness of our Site, to improve our Services, and for other similar purposes. In addition, from time to time, we may undertake or commission statistical and other summary analyses of the general behavior and characteristics of users participating in our Site and the characteristics of visitors at our Site, and may share aggregated information with third parties, including advertisers. We may collect aggregated information through features of the software that support our Site, through cookies, and through other means described in this Privacy Policy. To enable us to better understand the characteristics of our Investors and/or to provide services tailored to your needs, we may combine the Personal Information an Investor provides with certain automatically-collected information that would not otherwise be personally identifiable. If we combine or link any automatically-collected, non-individually identifiable information with your Personal Information, the resulting combination will be treated as Personal Information under this Privacy Policy.
C. How We Share Personal Data. We do not disclose your Personal Information to unaffiliated third parties except as provided in this Privacy Policy, as follows:
Service Providers. To assist us in running our business and to perform certain services and functions, we may share your Personal Information with third-party providers of hosting, transfer agent, email communication and customer support services, analytics, marketing, and advertising service providers, which companies provide integrated services to us as part of our product.
Affiliates. We may share information with our affiliates, meaning an entity that controls, is controlled by, or is under common control with FAROPOINT. Our affiliates may use the Personal Information we share in a manner consistent with this Privacy Policy.
For Legal Reasons. We may share your Personal Information to the extent we reasonably believe we are required to do so by law or to comply with legal or regulatory requirements, or to protect against fraud, illegal activity, or to otherwise protect FAROPOINT against liability.
In Connection with a Corporate Transaction. In the event of a transaction or proposed transaction involving the transfer of substantially all of the assets of FAROPOINT or one or more of its businesses to another entity, whether an affiliate or a third party, or in connection with a bankruptcy, we may share your Personal Information in the diligence process or to otherwise facilitate the transaction, and with individuals assisting in the transaction or in connection with a bankruptcy. Your Personal Information may also be one of the transferred assets as part of the transaction or bankruptcy.
For Safety & Security. We may reveal your Personal Information to third parties, including law enforcement agencies, in order to protect the safety and security of our users or of any third party.
D. Keeping your Information Safe. We limit access to your Personal Information to those employees who have a legitimate business need to access such information. In keeping with industry standards and practices, we maintain commercially reasonable physical, electronic and procedural safeguards and controls to protect your information. The Site is built upon a secure infrastructure with multiple layers of protection and we use industry standard encryption technologies to safeguard your information.
Users will be required to identify and authenticate themselves prior to accessing restricted portions of the Site. Generally, identification and authentication take place through the use of your user name and a password. You are responsible for keeping your password confidential. Both we and our service providers have security standards and procedures in place designed to prevent unauthorized access to your accounts and personal information. A key part of this process helps ensure that all information we have about you is accurate and up-to-date. If you ever discover inaccuracies in our data or if your personal information changes, notify us at office@faropoint.com .
The transmission of information via the Internet is not completely secure, and for this reason we cannot guarantee the security of information sent to us electronically. If we learn of a security systems breach, we may attempt to notify you electronically so that you can take appropriate protective and mitigating steps. We may also post a notice on or through the Site in the event of a security breach. Depending on where you live, you may have a legal right to receive notice of a security breach in writing.
E. Cookies, Pixel Tags, and Similar Technologies. A cookie is a small amount of data, often including a unique identifier, which is sent to your browser from a website and stored on your computer’s hard drive. We use both “session” cookies and “persistent” cookies, as follows: Session cookies: We use session cookies to improve navigation on our Site and to collect aggregate statistical information. A session cookie expires when you close your browser. Because these cookies are strictly necessary to use the Site, you cannot refuse them. “Persistent” cookies: Persistent cookies are bits of information that are placed on the hard drive of your computer and can remain for extended periods of time. Persistent cookies also enable us to provide enhanced, more personal features (such as showing or hiding notifications), and track and target the interests of our users to enhance the experience on our Site. The types of persistent cookies used on the Site are described in more detail below. You may set your browser so that it does not accept cookies, and you may also use the direct opt-out tools provided by the parties described below. If you do not enable or if you disable cookies, however, you may not be able to access certain personalized features of our Site. We may also use so-called “pixel tags” – small graphic images (also known as “web beacons” or “single-pixel images”) – to tell us what parts of our website have been visited or to measure the effectiveness of marketing campaigns on our Site. In contrast to cookies, which are stored on a user’s computer hard drive, pixel tags are embedded invisibly on our Site. Pixel tags inform us whether emails have been opened, to help ensure that our messages are of interest to our users. We may tie the information gathered by pixel tags to our users’ Personal Information, in which case it will be subject to the terms of this Privacy Policy.
In particular, the Site uses Google Analytics, an analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies to help us analyze how users use the Site. The information generated by the cookie about your use of the Site will be transmitted to, and stored by, Google. Google will use this information for the purpose of evaluating your use of the Site, compiling reports on Site activity for Site operators and providing other services relating to Site activity and internet usage, including tracking which pages of our Site you visit so we can optimize your experience with our Site. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. We have implemented the IP anonymization feature in Google Analytics which anonymizes your IP address to protect individual privacy. You can opt-out from the collection of this information by Google by downloading and installing a browser plug-in at https://tools.google.com/dlpage/gaoptout.
Our Site allows site visitors and Investors to participate in surveys and questionnaires, which from time to time we may post on the Site. We also encourage our users to provide feedback to us about our Site and our Services. You are free to choose whether you participate in these activities. We may ask that, in addition to providing your responses, you also provide us with your contact information. In these instances, we use any Personal Information you choose to provide to us in connection with these activities for the purposes for which you submit the information. We aggregate information derived from survey and questionnaire information – with your Personal Information removed – for monitoring or improving the use and appeal of this Site (with no other obligation to you and, specifically, with no obligation to compensate you for these uses). You are not obligated to participate in any of these activities.
F. NOTICE FOR CALIFORNIA RESIDENTS.
The Company does not sell or share any information that it collects from users of the Site. If the Company elects to change this position, it will notify all registered users of the change in accordance with the procedures of this Privacy Policy.
This section applies only to California residents. Pursuant to the California Consumer Privacy Act of 2018 (“CCPA”), below is a summary for the last twelve (12) months of the “Personal Information” categories, as identified and defined by the CCPA (see California Civil Code section 1798.140 (o)), that we collect, the reason we collect the Personal Information, where we obtain the Personal Information, and the third parties that we may share the Personal Information. We generally might collect the following categories of Personal Information when you use the Site:
Identifiers such as a name, address, unique personal identifier, email, phone number, your device’s IP address, software, and identification numbers associated with your devices.
Commercial information.
Internet or other electronic information regarding you browsing history, search history, the webpage visited before you came to our Website, length of visit and number of page views, click-stream data, locale preferences, your mobile carrier, date and time stamps associated with transactions, and system configuration information.
Your geolocation, to the extent you have configured your device to permit us to collect such information.
We generally do not collect protected classifications about our users, biometric information, professional or employment-related information, or education-related information. For more information about the Personal Information we collect and how we collect it, please refer to the applicable sections above.
We collect your Personal Information from the Site for the business purposes described in this Privacy Policy. The CCPA defines a “business purpose” as the use of Personal Information for the business’s operational purposes, or other notified purposes, provided the use of Personal Information is reasonably necessary and proportionate to achieve the operational purpose for which the personal information was collected or another operational purpose that is compatible with the context in which the personal information was collected. The categories of third parties with whom we may share your Personal Information are listed above.
If you are a California resident, you have rights in relation to your Personal Information; however, your rights are subject to certain exceptions. For instance, we cannot disclose specific pieces of Personal Information if the disclosure would create a substantial, articulable, and unreasonable risk to the security of the Personal Information, your account with us or the security of our network systems.
To assert your right to know, your right to access, or your right to delete your Personal Information, please contact us by email at office@faropoint.com . To confirm your identity, we may ask you to verify Personal Information we already have on file for you. If we cannot verify your identity based on the information we have on file, we may request additional information from you, which we will only use to verify your identity, and for security or fraud-prevention purposes.
Right Against Discrimination. You have the right not to be discriminated against for exercising any of the rights described in this section. We will not discriminate against you for exercising your right to know, access, delete or opt-out of sales.
Right to Know. You have the right to request in writing: (i) a list of the categories of Personal Information, such as name, address, email address, that a business has disclosed to third parties during the immediately preceding calendar year for the third parties’ direct marketing purposes, and (ii) the names and addresses of all such third parties. In addition, you have the right to request: (i) the categories of Personal Information we have collected about you, (ii) the categories of sources from which Personal Information is collected, (iii) the business or commercial purpose for the information collection, (iv) the categories of third parties with whom we have shared Personal Information, and (v) the specific pieces of Personal Information we hold about an individual.
Right to Access. You have the right to request a copy of the specific Personal Information we collected about you during the 12 months before your request.
Right to Delete. You have the right to request us delete any Personal Information we have collected from you or maintain about you, subject to certain exceptions (i.e., we may have either a legal requirement or legitimate interest to maintain your Personal Information that supersedes your right to delete)
Right to Opt-Out of Selling. The CCPA broadly defines “Personal Information” and “selling” such that sharing identifiers linked to you for a benefit may be considered a sale. We do not “sell” your Personal Information in the traditional sense; however as described above, we may share information about you with our partners, third parties or affiliates for our marketing purposes. Under the CCPA, such sharing may be considered a “sale” of Personal Information. All California residents have the right to opt-out of such sharing. For more information about how you can opt-out of having your information shared in this way, please click on the “Do Not Sell My Personal Information” link in the footer. Please note that if you opt-out, we may be unable to offer you some of our Services which require sharing of Personal Information.
If you are a California resident you may request a notice from us describing what categories of personal information (if any) we have shared with third parties, including our corporate affiliates during the preceding calendar year. You may request such notice once a year and free of charge. To request a notice, please contact us as provided in the “Inquiries or Concerns” section of this Privacy Policy. In your request, please specify that you are seeking a “California’s Shine the Light Disclosure.”
G. Links to Other Sites. This privacy statement applies only to Personal Information collected by our Site. Our Site contains links to other sites that are not owned or controlled by FAROPOINT. FAROPOINT is not responsible for the privacy practices of such other sites, and we encourage you to be aware when you leave our Site and to read the privacy statements of each and every web site that collects Personal Information.
H. Data Security We have put in place commercially-reasonable security systems intended to prevent unauthorized access to or disclosure of Personal Information, and we take reasonable steps to secure and safeguard this Personal Information against loss, theft, and unauthorized use, disclosure, or modification. With that said, there is no such thing as 100% security of the networks, servers, and databases we operate or that are operated on our behalf. For example, email sent to or from the Site may not be secure. Before submitting any Personal Information via the Site, please be aware of these inherent risks and understand that you do so at your own risk.
I. Data Retention. We keep your Personal Information for as long as reasonably necessary for the purposes described in this Privacy Policy, while we have a legitimate business need to do so in connection with your account, or as required by law (e.g., for tax, legal, accounting or other purposes), whichever is longer.
J. Children’s Privacy. Our Site is not directed to children under the age of 18. We do not knowingly seek to collect or maintain Personal Information or other information from children under the age of 18. We will use commercially reasonable efforts to delete any Personal Information or other information later determined to be provided by a child under the age of 18. Use of the Site by children under the age of 18 is not permitted. If you become aware that a minor has provided Personal Information through our Site, please email us at office@faropoint.com .
K. Changes to This Privacy Policy. We reserve the right to alter, modify, update, add to, subtract from or otherwise change this Privacy Policy at any time, which will become effective as of posting on the Site. We encourage you to periodically review this Privacy Policy to stay informed about how we collect, use, and share Personal Information.
l. Contact Us. If you have any questions about this Privacy Policy, the practices of our Site, or your dealings with our Site, please contact us as follows: Email: office@faropoint.com / Mail: Faropoint Israel Ltd. 7 Menachem Begin Rd., Ramat Gan, Israel
COOKIES POLICY
What is a cookie?
A cookie is a small text file that is stored in your web browser that allows the Company or a third party to recognize you. Cookies might be used for the following purposes: (1) to enable certain functions; (2) to provide analytics; (3) to store your preferences; and (4) to enable ad delivery and behavioral advertising.
Cookies can either be session cookies or persistent cookies. A session cookie expires automatically when you close your browser. A persistent cookie will remain until it expires or you delete your cookies. Expiration dates are set in the cookies themselves; some may expire after a few minutes while others may expire after multiple years. Cookies placed by the website you’re visiting are sometimes called “first party cookies,” while cookies placed by other companies are sometimes called “third party cookies.”
What cookies are used when I use the the Company Site?
When you access and/or use the Site, the Company or a third party may place a number of cookies in your browser. Some of the cookies will only be used if you use certain features or select certain preferences, and some cookies will always be used.
Each cookie serves one of four different purposes:
a.) Strictly Necessary Cookies: These first party cookies allow users to use various features of the Site.
b.) Functional Cookies: These cookies track information about how the Site is being used so that we can make improvements and report on our performance. We may also use analytics cookies to test new ads, pages or features to see how users react to them. Analytics cookies may either be first party or third party cookies.
c.) Performance Cookies: These first party cookies store your Site preferences.
d.) Targeting Cookies: These third party cookies (also known as “behavioral” or “targeted” advertising are placed by advertising platforms or networks in order to: (i) deliver ads and tracks ad performance, and (ii) enable advertising networks to deliver ads that may be relevant based upon your activities. the Company runs our advertisements on many Internet websites as part of our video programming, typically before or during the playback of a video that you chose to watch. Many of these video publishers are accessible to the Company through third-party advertising networks or video ad exchanges. Those networks may also place cookies on your browser upon visiting a the Company customer’s website to facilitate ad serving as described above.
Finally, we may set cookies within emails we send to you (if you have consented to receiving emails from us). These cookies are used to track how often our emails are opened and clicked on by our customers. You can manage email cookies in the same way as website cookies, as explained above.
How do third parties use cookies on the Site?
Third party companies like analytics companies and ad networks generally use cookies to collect user information on an anonymous basis. They may use that information to build a profile of your activities on the Site and other websites that you’ve visited.
What are my cookie options?
If you don’t like the idea of cookies or certain types of cookies, you can change your browser’s settings to delete cookies that have already been set and to not accept new cookies. To learn more about how to do this, visit the help pages of your browser. Please note, however, that if you delete cookies or do not accept them, you might not be able to use all of the features we offer, you may not be able to store your preferences, and some of our pages might not display properly.
If you no longer want to be exposed to the Company retargeted video ads you can opt-out on our Privacy Preference Center. Please note that the opt-out mechanism relies on a cookie that is set on your browser in order to recognize you as a user who opted-out. You must opt-out again if you clear that cookie from your browser or if you use a different internet browser or computer.
You may also opt out of third party cookies by following the instructions provided by each third party in its privacy policy.
You may opt out of Google’s use of cookies by visiting the Google advertising opt-out page.
Do you use any other user tracking technologies?
We use additional technologies to help track user activities and preferences. For example, we use web beacons (also known as clear gifs, pixel tags or web bugs). Web beacons are tiny graphics (about the size of period) with a unique identifier that are embedded invisibly on web pages or emails. They are used to track user activities and communicate with cookies. You cannot opt out of web beacons used in webpages, but you can limit their use by opting out of the cookies they interact with. You can opt out of web beacons used in emails by setting your email client to render emails in text mode only. Finally, we use local storage to facilitate certain functions, but we do not retain the data captured via local storage.
Interest Based Advertising
We and third parties engage in interest-based advertising provided by vendors in order to deliver advertisements and personalized content that we and other advertisers believe will be of interest to you. To the extent third-parties are using cookies or other technologies to perform these services, the Company does not control the use of this technology or the resulting information for online, mobile, or email advertising, and is not responsible for any actions or policies of such third parties. Advertisements, emails, and other messages may be delivered to you by the Company or its service providers based on your online or mobile behavior, your search activity, your geographic location or other information that is collected by us or obtained from third parties. You may also see advertisements for third parties on the Site, other websites or services, or on your mobile device, based on your visits to, and activities on, the Site. Some of our vendors and we may use our own or third-party aggregated or anonymized personal information, demographic data, and other inferred commercial interests to assist in the delivery of our advertisements to you.
In addition, we and our business partners use third parties to establish deterministic or probabilistic connections among devices (such as smartphones, tablets, and computers) to deliver more relevant advertising to you and for advertising analytics and reporting purposes. This means that information about your use of websites or applications on your current device may be combined with information from your other devices. We also may share this information and other inferences with third parties to allow them to target advertising, personalize content, or analyze behavior. This allows, for example, advertisements you see on your tablet to be based on activities you engaged in on your smartphone. These business partners may share and combine information from cookies with identifiers (such as device IDs assigned by Google or Apple) and IP addresses to make connections among related devices. This also allows for a more personalized experience across the Site.
If you have any questions about our Cookie Policy, you may contact us by sending an email to office@faropoint.com
