Privacy Policy
Faropoint Privacy Policy
Last Updated: June 2021
Point-Faro Investments 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://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. 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.
G. 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.
H. 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.
I. 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 support@faropoint.com.
J. 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.
k. Your California Privacy Rights (“Shine the Light” Law). California law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their Personal Information (if any) for such third parties’ direct marketing purposes in the prior calendar year, as well as the type of Personal Information disclosed to those parties. However, FAROPOINT does not share your Personal Information with third parties for their direct marketing purposes. How We Respond to “Do Not Track” Signals Our Site currently does not respond to “Do Not Track” (DNT) signals and operates as described in this Privacy Policy whether or not a DNT signal is received. If we do so in the future, we will describe how we do so in this Privacy Policy.
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: Point-Faro Investments Ltd, 2 Hashlosha St. Tel Aviv, Israel.
