PRIVACY POLICY

PRIVACY NOTICE

We, at Lace Model Ltd (the “Company“), are committed to respecting our users’ privacy, protecting their personal information and making sure it is used properly by us. This privacy notice explains the principals of our privacy practices for processing personal information on our website (the “Site”). We collect both personal information (which may identify an individual) and anonymized information (which does not identify an individual) about our users when they use the Site and/or our services.

Purposes for use of personal information may differ, dependent on the reason it is collected: Personal information collected in the Site will be generally used in order to respond to your query in the Site and communicating with you. We maintain technical and administrative security measures to protect our user’s personal information.

Personal information is stored in a server of UPRESS located in Israel, and may be used and/or transferred to other places around the world, whether by ourselves or by third party’s acting on our behalf, who are committed for the security of the personal information).

Our users may have certain rights with respect to their personal information, such as the right to review, ask to rectify, erase, transfer, withdraw consent, and object to processing their personal information, by sending us a request.

We may keep user’s personal information if required for the purposes mentioned above, and unless restricted by applicable law, we may retain anonymized information indefinitely.

For further information, you can access our following full privacy policy, where you can inter alia find specific examples of why and how we use users’ personal information. If you have further questions please contact: Info@LaceModel.com

FULL PRIVACY POLICY

Preamble and Definitions.

We, at the Company, respect our Users’ right for privacy with regards to the use of their Personal Information. The purpose of this full privacy policy (as may be amended from time to time) (“Privacy Policy”) is to ensure you are fully informed and aware as to the scope and nature of Information the Company collects and/or otherwise receives from or about you while you are using the Site, and how is it being processed and/or otherwise used by the Company.

Following your first use of the Site, you will be asked to indicate that you have read this Privacy Policy. Please read carefully the terms of this Privacy Policy. If you have further questions or concerns regarding this Privacy Policy, please contact us at: Info@LaceModel.com

Definitions:

“Anonymized Information” shall mean any information, data or content, in any format or media, which is anonymous and/or does not personally identify you as an individual and/or cannot be attributed to you as an individual (such as browser type, browsing history, device information, time user spent on the Site, etc.), or as otherwise defined in Data Protection Laws.

“Data Protection Laws” shall mean the Israeli Data Protection Laws, and any other data protection laws and/or regulations applicable to Company with respect to processing Personal Information in the Site, according to the terms of the Privacy Policy.

“Information” shall mean Personal Information and Anonymized Information, together.

“Israeli Data Protection Laws” shall mean the Israeli Protection of Privacy Law (1981) and the regulations promulgated pursuant thereto, and as amended, replaced or superseded from time to time.

“Personal Information” shall mean any information, data or content, in any format or media, which identifies or can personally identify you as an individual (such as name, phone, mail, images, and any other information that you provided subject in your note ), or as otherwise defined in Data Protection Laws.

“Process” shall have the meaning ascribed to it under Data Protection Laws.

“Consent” shall have the meaning ascribed to it under applicable Data Protection Laws.

“Use” shall mean: With respect to the Site – any accessing and/or viewing and/or visiting and/or browsing the Site for any purpose.

“User” or “you” or “your” (including any alterations thereof) means the legal entity or individual that is using the Site for any purpose.

“User Information” shall mean Site Information.

Collection of Information – General Provisions

We collect and Process two types of data: Personal Information and Anonymized Information.

The collection and Process Site Information commences on your first Use of the Site for any purpose.

Collection and Use of Personal Information.

Personal Information you provide – When you Use the Site, the Site Information you will be required to provide us is your name, your e-mail, and your message to us (in the “contact us” text box) and images (if applicable);

Personal Information we Collect or Generate – When you Use the Site, we may collect some Site Information about you, such as examples: IP address, location information etc., by using certain technological tools as detailed in section ‎3 below.

How we use Personal Information. Personal Information that you provide and/or that we collect or generate shall be used by Company for the following main purposes (as may be amended from time to time):

If you approach us via the Site – the Company will use your Site Information in order to respond to your request, or review your application (to the extent applicable). For this purpose, we may transfer your Information also to companies in our agency (subsidiaries and etc).

In addition, Company may use User Information for the following purposes: (a) to transfer to its third party vendors, service providers, contractors who are working on our behalf for storage, hosting, clearing companies, process and/or back up purposes; and (b) resolve disputes, comply with any applicable law, regulations or other requests from authorized authority(ies); (c) to enforce this Privacy Policy, and/or (d) as otherwise authorized by you.

Lawful basis for Processing

We only process Personal Information where we have a lawful basis to do so. The lawful basis will depend on the reason(s) we collected and need to use your Personal Information. The legal basis for processing Personal Information may differ according to the applicable laws apply in different jurisdictions:

Where Israeli Data Protection Laws apply, we will obtain your Consent in order to Process your Personal Information. If processing of Personal Information is subject to other applicable laws, other legal basis may apply.

Your rights regarding your Personal Information

In this section, we hereby inform you what rights you may have with respect to the Processing of your User Information. Please note that your rights may differ, dependent on your jurisdiction and the Data Protection Laws:

You may have the right to request a review of your Personal Information that we Process;

You have the right to have your Personal Information rectified to the extent it is incorrect, incomplete or not processed in compliance with Data Protection Laws;

You may be entitled to require that we erase certain part of your Personal Information if its processing is not justified;

In some circumstances, you have the right to withdraw consent (where the lawful basis for Processing is Consent).

If you wish to exercise any of your rights regarding your User Data, please contact us at: Info@LaceModel.com. We will act in accordance with the Data Protection Laws, in order to comply with your request

Anonymized Information

General. In addition to the collection of Personal Information as described above, we may also collect and Process Anonymized Information. The collection of Anonymized Information commences on the first Use of the Site.

Anonymized Information we Collect. The Anonymized Information we collect may differ, dependent on whether you use the Site:

Anonymized Information that we collect from your use of the Site may include operating system version; network identifier, browser type, etc.

How We collect Anonymized Information. We may use certain tools in order to collect Information, such as Analytics, Console, WordPress.

“Google Analytics” is a technological tool which analyzes how Users interact with our Site. For more information about how “Google” uses the information provided to Google Analytics, see: https://analytics.google.com/. You can control the information provided to “Google” and opt out of certain ads provided by “Google” by using any of the methods set forth here or using the Google Analytics opt out browser.

A “cookie” is a small data file that we transfer to the User’s computer/device, which creates a unique identifier, in order to identify the User in its future interaction with the Site.

Depending on your computer settings, you may be allowed to refuse the use of such tools (whether in whole or in part). However, this may affect your ability to use the Site, including the access and use certain features.

How We use Anonymized Information. The Company may use Anonymized Information for the same purposes it uses Personal Information (where applicable), and also for the following purposes: (i) monitor and analyze your Use of the Site for the technical administration and troubleshooting of the Site (ii) for commercial research and further development; (iii) improving the Site by creating system analytics and statistical data; (iv) transfer to third party vendors, service providers, contractors who are working on our behalf for storage, process and/or back up purposes and (v) for any other legitimate purpose.

Share of Information with Third Parties

We respect your privacy and will not disclose, share, rent, or sell your Personal Information to any third party, other than as permitted under this Privacy Policy. that in connection with the purposes set forth in this Privacy Policy, the Company may make the Information available to other third party, as follows:

Service Providers: We may share and/or otherwise transfer the Information to third party’s service providers which assist us in the operation of the Site, including (without limitations) for storage or hosting of the Information and/or the process thereof, for the purposes set forth in this Privacy Policy.

Official Authorities: We may share and/or otherwise transfer the Information to third parties, in order to comply with any applicable law, regulations or legal requests and assist law enforcement agencies, or when we believe in good faith that disclosure of Information is necessary to prevent imminent physical harm, financial loss or to report suspected illegal activity. In all cases, such Information will only be disclosed in accordance with applicable laws and regulations;

Resolve dispute: We may share and/or otherwise transfer the Information to third parties to take any action in any case of dispute involving you with respect to your usage of our Site and/or Service; and

Business transfer: We may sell, transfer or otherwise share some or all of our assets, including the Information in connection with a merger, acquisition, reorganization or sale of assets or in the event of bankruptcy.

International transfer of Information: Please be advised that Information may be hosted, stored, processed, maintained and transferred to various countries around the world, including through cloud-service providers.

Automated Decision Making.

The Site use technological means via algorithms without any human involvement. However, certain decisions with respect to your Personal Information will include human intervention. In any event, you may express your opinion or ask for more information regarding our decisions, and also ask that the decision be reviewed by a person and not by a machine. By using the Site you consent (and, where applicable, undertake to obtain to consent of your users) to such automated decision making.

Choice

At any time, you may choose (opt out) whether your Personal Information is (i) to be disclosed to a third party, other than to third parties who act as our agents or sub-processors to perform tasks on our behalf and under our instructions, or (ii) to be used for a purpose that is materially different from the purposes for which it was originally collected, pursuant to this Privacy Policy, or subsequently authorized by you. You may exercise your choice by contacting us at: Info@LaceModel.com

Retention

We retain different types of Information for different periods, depending on the purposes for processing the Information, our legitimate business purposes as well as pursuant to legal requirements under the applicable law.

We will retain certain Site Information as long as required and needed to address your query in the Site.

Unless otherwise restricted under applicable law, Anonymized Information will be retained indefinitely

Security.

We take the safeguarding of the Information very seriously, and use a variety of methods to try to protect the Information from loss or unauthorized use or access when it is in our possession or control, including reasonable technical and organizational measures that restrict access to the Information. However, we do not promise that any Information will be fully protected from unauthorized disclosure or use.

Please note that the Company does not check the validity of the use of Your Account, and any use of Your Account with your name and password will be considered as your User.

Changes to the Privacy Policy. We reserve the right to change this Privacy Policy at our sole discretion, and/or subject as required due to change in Data Protection Laws. We will inform you of any such change by posting a new updated Privacy Policy and a prior notice prior to such change; the effective date of any change of Privacy Policy will be clearly marked at the end of each new Privacy Policy posted.

Our Policy Regarding Children’s Privacy. The Site is designated for business purposes. As such, the Website is not meant to be used by or for persons under 18, and we do not knowingly collect personal data from minors younger than 18. If these age requirements are not met, you are required to obtain the consent of the parent or guardian to provide and process Personal Information in accordance with this Privacy Policy.

Contact Us. If you have any concerns or questions about this Privacy Policy, please contact us at: Info@LaceModel.com Upon request, we will provide you with the contact information for that regulator. However, we recommend you contact us first – and we will do our best to solve any complaint.

Additional information for Israeli Users:

No Legal Requirement. We hereby inform you, and you hereby acknowledge that you have no legal obligation to provide us with any Personal Information (or any other Information) when you use the Site, and the provision of it is solely based on your free will. However, you are aware that without the provision of Site Information, we will not be able to provide you with the information required by you when you approached us via the Site.

Your Consent. by Using the Site, you hereby represent, acknowledge and provide your informed consent that your Personal Information will be stored in our database(s), and will be Processed by us (including, by third parties acting on our behalf) for the purposes and the terms as specified in this Privacy Policy.

International transfer. Information may be stored, processed, maintained and transferred to various countries outside of Israel, where the privacy laws may not be as protective as those in Israel. By Using the Site, you hereby provide us your informed consent to the use and/or process and/or storage and/or transfer of Information to countries outside of Israel. We undertake to comply with the applicable provision set forth in the Data Protection Laws that relate to the transfer of Personal Information abroad.

Last Updated: July 1, 2023