BRICKWlls ltd (“we”, “us”) a company registered under the Israeli company registration law, with company registration number 511767610, having its address at Israel, is the owner of Brickwalls (“App”).

For more information about us and how to contact us, please see section 6 of this notice.

This notice is to inform our clients/users or prospective clients, how we use the personal information we collect about them in the course of providing services and their rights in relation to the processing of their personal information.

By using the App and App features and services you agree with collection and usage of personal and non-personal data. Should you not agree do not access and do not use the App and the services within. 

Changes to this Privacy Policy may be made by posting the new version of the policy here and updating the “Last Updated” date above. Each time you use the Platform, however, the current version of this Privacy Policy will apply. Please check the date of this Privacy Policy and review any changes since the last time you used the Platform.

Please note, if you are younger than 18, you are prohibited from registering for our app or open a user account.

How Do We Collect Information About You?

We collect your personal information from various sources, including:

• Directly from you, when you use the App, when you request any of our services, or request to receive marketing, or when you communicate with us; We also collect information generated by you when you use our services, such as your transaction information.
• Using automated technologies. When you use or access our App and services, we may collect technical data about your equipment, browsing actions and patterns and information about the way you use our services. We collect this data by using cookies; For those cookies that are not strictly necessary for the provision of our services, we will seek your consent at the time of your initial visit to our website. For more information and options regarding our use of cookies:

Cookie notice and similar/alternative Technology

When you visit our app, a cookie or other Tracking Technologies will be sent to your computer or mobile device, software development kits that enables tracking may be used as well in order to store and sometimes track information. Cookies we use may differ in duration, some last only for the duration of your application session and expire when you close your browser or exit it. While other cookies are used to remember you when you return to the app and will last for longer. The cookies we use collects information, browser and mobile device type, your IP address and/or the operating system. We use cookies, such as tracking GIFs, web beacons, pixel codes and in-app IDs, to create a unique device ID so we will be able to remember that you have visited us before, where permitted, track whether you have opened an email that we have sent to you and your related actions customize promotional layout and/or content, collect statistical information and Features (visit duration) and user origin.

Some of the in our app are set by us, and some are set by third parties. You can set your cookie preferences, and obtain specific information on cookies by accessing our cookie management tool. 

By blocking or deleting cookies our app, you may not be able to take full advantage of the full services we offer. 

• We may also use cookies from third party service providers, such as credit reference agencies, fraud prevention agencies, identity verification vendors, banks, and payment services providers, authentication service providers, marketing and analytics providers and from publicly available sources such as public registers. Third parties may use their own cookies and each of them will do it under their own Privacy policy (or similar document) that you should read and understand before engaging with any of them.

What information we collect from you and why 

We may collect, store, and use the following information about our clients and perspective clients:

• Identity information - your full name, proof of identity, including document copies and proof of address, date and place of birth, your age, photo, occupation and country of residence. This information may be necessary in order for you to use our App as a client, to provide you with our services and to carry out our obligations arising from any contracts between us. It is also necessary in order to verify you are eligible to receive our services and to comply with any applicable legal obligation.

• Contact details – your name, email address, phone number. This information is necessary to provide you with our services, to perform our contract or to manage our relationship, including to respond to any enquires and resolve any complaints and to comply with our policy and obligations. We may also use your contact details to provide you with marketing information about our products where you have provided your consent.

• Professional qualifications – level of education, profession etc., We process this information in order to ensure that you qualify to receive services from us based on applicable policy and terms and conditions.

• Profiling information – before we can provide you with our services and periodically thereafter, we may do this through the use of whether it is suitable for us to provide you with our services and products. you are evaluated by automated means in respect of your eligibility (such as age) to receive our services. We will then inform you accordingly. The reason for assessing your appropriateness is to enable us to offer to you services suitable to you. 

• We may collect information as part of our Know Your Client (KYC) obligations in order to determine whether to onboard and maintain you as a client and in order to fulfil our obligations. 

• Financial information – bank account details and statements, payment card details, e-wallet information, financial transactions performed through our services etc. We process this information in order to register you as a client, to provide you with our services and to carry out our obligations arising from any contracts between us. Also, to fulfil legal requirements (including in relation to anti-money laundering) and other regulatory obligations -such us appropriate client due diligence-, and to manage payments, fees and charges, to pay, collect and recover any money. 

• Transaction data – details about usage and services you, details of your transactions, including financial transactions through our services. We process this information in order to perform our contract and administer our relationship and to comply with legal and regulatory obligations we get from financial institutions. We may analyze this data based on our legitimate interests, in order to provide you with relevant information about our services and products, and other information or marketing materials.

• Profile and usage data – your username and password, purchases, your interests, preferences and feedback. This information is necessary in order to perform our contract with you and to comply with our legal obligations. We may analyze those data based on our legitimate interests or in case you are a perspective client, on your consent, in order to provide you with marketing materials.

• Communication data – we process the contents of your communications with us, such as contents of e-mail correspondence, chats or the “contact us” form on our App. We also may record our telephone communications. We do this also in order to perform our contract and to administer our relationship.

     Should you choose to participate in surveys, we (or third party such as research companies) may present the provided information on our app. 

• Technical information – we collect certain technical information when you use our services, such as your IP address, MAC address, device approximate location, your login data, plugins your login credentials, UDID, Google advertising ID, IDFA, cookie identifiers, and other identifiers such your operating system version, browser type, language preferences, time zone, referring domains and the duration of your visits. This information is necessary in order to perform our contract, to comply with obligations/restrictions and we may also analyze this data based on our legitimate interests or on your consent, in order to provide you with marketing materials.

• Marketing Data, Analytics and Data from Tracking Technologies – When you visit or access our services, we use and authorize third parties who provide services to us to use pixels, cookies, events and other technologies ("Tracking Technologies"). These allow us to automatically collect information about you, your device and your online behavior, in order to enhance your navigation in our services, improve our App’s performance, perform analytics and customize your experience on it. In addition, we may merge information we have with information collected through these tracking technologies and with information we may obtain from other sources in order to profile your interests in our products/services for marketing purposes. We base this processing on your consent.

     Information may include your Personal and non-Personal Data. For non-personal Data, we will not be limited in our use and disclosure within applicable law restrictions.         Should you choose not to provide any such information’ you may not be able to use some or all services available on our app (the “Services”). We may, invite you to get in touch with some of your contacts who might be interested in our services. These contacts will identify you as their referrer. 

After providing us with your consent to access your location data You may withdraw it at any time by adjusting settings on your mobile device Stopping all location data collection is possible by un-installing our mobile app. due to the fact that the collection of location data is necessary to comply with our legal and other obligations and provide our services. Services that are dependent on knowing where you are may be provided after we will collect information and Features through the app regarding your real time location were requested or agreed to by you in order to deliver content. Where you have requested or agreed to location-aware services, the information collected, combined with a device identifier, will enable us to recognize your mobile browser. If requested, we may share your location information with third-party partners, in order to provide you with services and for other research, analytics and marketing uses.

We also process all of the above categories of information based on our legitimate interests, in order to prevent fraud or protect your, our, or others’ rights or when we believe it’s necessary in order to take precautions against liabilities, investigate and defend ourselves against any third-party claims or allegations, investigate and protect ourselves from fraud, protect the security or integrity of our services and protect our rights and property, that of our clients and/or partners.

You may initiate interaction that will require personal data transfer between us and third parties website or service, such as Meta and X. You will enable to “like” or “share” content from the app with another website or service; to log-in to the app and Features using your username and password for a such websites and to otherwise connect the App and Features to a third-party website or service.

While using third party website information might be shared between the app and such website (or app) the parties may have access to certain information about you and your use of the app and Features and the third-party website.

We from time to time will review the Personal Data we hold and delete it or anonymize it. We will treat such Personal data According to our policy and/or legally mandated retention periods. 

With whom do we share your personal information?

• Internal concerned parties - we share your information with companies in our group, as well as our employees. We limit access to those employees or partners who need to know the information in order to provide you with our services.
• Financial providers and payment processors - we share financial information about you only, if necessary, in order to provide you with our services. 
• Business partners - we may share your information with business partners, such as storage providers and analytics providers who help us provide you with our service.
• Supervisors and our legal and other consultants - we may disclose any information in case we believe, in good faith, that such disclosure is necessary in order to enforce our Terms or Client Agreement as may apply, take precautions against liabilities, investigate and defend ourselves against any third party claims or allegations, protect the security or integrity of the site and our servers and protect the rights and property of Brickwalls its users and/or partners. We may also disclose your personal information where requested by any authority having control or jurisdiction over us, you or our associates or in the territories we have clients or providers. 
• Mergers and acquisitions – we may share your information in case we enter into a business transaction such as a merger, acquisition, reorganization, bankruptcy, or sale of some or all of our assets. 
• Non personally identifiable information (aggregated statistics) may be used in order to describe our business and Services third parties. Affiliates and/or our agents may be disclosed with your Personal Data through the app and Features, processing transactions, viewing order references and/or for IT support and security services, data analyzing, Communications and other uses
• In order to prevent fraud (or if we believe that such action is necessary) or for our app protection, we may disclose your Personal Data to other authorized parties and/or in case we are obliged to do so by law. Your non-Personal Data may be shared without limitation according applicable law. Your Personal Data may be shared with trusted third parties at your request or with your consent.

Transfer of data outside the EEA - Some data recipients may be located outside the EEA. 

For non-EU users, and more specifically for EEA, SUI & UK based users, your personal data may be transferred to recipients located outside of the EEA, SUI & UK to countries where we have facilities or engage service providers. The processing of your data may take place world wide and some of these countries may not offer the same level of privacy protection as the laws in your country of residence.

 Some of these countries are providing an adequate level of data protection according to EEA/UK/Swiss standards, such as Canada (commercial organizations). For transfers to countries not recognized as offering an adequate level of data protection, should such data transfer be needed we will have in place adequate measures as required by applicable laws.

You may get a copy of our implemented safeguards and/or information about the entities residing in third countries to which your personal data may be transferred (where possible) and you can contact us as directed in the Notice under the Contact Us section.

For residents of China, your Personal Data will be processed and stored outside of Mainland China, in jurisdictions including the United States of America (USA) and the European Union, and other jurisdictions as well where we, our survey service providers, or other Company affiliates, agents, data processors, or contractors, may be located. You also understand that our third-party survey-research partners, receive and process your Personal Data outside of Mainland China, including in the following countries: USA, Canada, France, Romania, Israel, Pakistan, and India. You may also contact us at any time for additional information regarding these processing activities using the contact us function and our address or email address as above.

We may receive Personal Data or transfer it to and from trusted third parties. Personal data might be transferred internationally and such transfers may be restricted by applicable law, we may transfer Personal Data subject to contractual protections and other mechanisms under applicable law for the transfer of Personal Data.

For residents of India, by using the app you confirm that your age is over 18 as well as confirm that Features or Services, you consent (as “Data Principal’) to the Company’s processing and use of your Personal Data (as “Data Fiduciary”) in accordance with this International Notice and our Terms and Conditions.

You understand that your Personal Data may be transferred, and will be processed and stored, outside of India, in jurisdictions not subject to restriction by the Indian government, possibly including the United States of America (USA) and the European Union (EU), where we, our survey service providers, or other Company affiliates, agents, data processors, or contractors, may be located.

The Personal Data types that the Company may process, and its purpose in doing so, is set forth above. Your Rights as Data Principal with respect to your processed Personal Data, you have the right to Request a summary of Personal Data processed, and/or the processing activities involved, know the identities of all other data fiduciaries and data processors with whom your Personal Data has been shared, along with a description of the data shared Correct, complete inaccuracies in, or update your data; Request erasure of your data, unless its retention is required in compliance with law; Withdraw your consent at any time; Complain and obtain redress for your grievances.

To exercise these rights or seek additional information regarding the Company’s use of Personal Data, please use the “Contact Us”, or similar contact link in the footer of the app: support@brickwalls.link

How we protect your information and for how long we keep it

We have implemented administrative, technical, and physical safeguards to help prevent unauthorized access, use, or disclosure of your personal information. Your information is stored on secure servers and isn’t publicly available. We limit access of your information only to those employees or partners that need to know the information in order to enable the carrying out of the agreement between us.

We will retain your personal information for as long as necessary to provide our services, to comply with our legal obligations and resolve disputes. Retention periods will be determined by legal requirements, by the type of information that is collected and the purpose for which it is collected, bearing in mind the applicable requirements to the situation and the need to destroy outdated and unused information at the earliest reasonable time. Under applicable regulations, we are obliged to keep records containing client personal data, trading information, account opening documents, communications and anything else as required by applicable laws and regulations.

While we seek to protect your information to ensure that it is kept confidential, we cannot absolutely guarantee its security. You should be aware that there is always some risk involved in transmitting information over the internet. While we strive to protect your Personal Information, we cannot ensure or warrant the security and privacy of your personal Information or other content you transmit using the App, and you do so at your own risk. 

Your Rights

For EU users, you have the right to:

• Request a copy of your information, together with information about how this is processed. 
• Request correction of the information that we hold about you. Please inform us if your personal data changes during your relationship with us.
• Request erasure of your information where there is no good reason for us continuing to process it or where you have exercised your right to object to processing.
• Object to processing of your information where we are relying on our legitimate interest for example where we are processing your personal information for direct marketing purposes.
• Request the restriction of processing of your information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy.
• Request the transfer of your information to another party in a structured, commonly used and machine-readable format where we process this information on the basis of your consent or to perform our contract and we carry out the processing by automated means.
• Marketing and opting out - We will occasionally send you marketing information where you have provided your consent for us to do so and we may build a profile of your interests for marketing purposes. You are free to withdraw your consent at any time by opting out by using the “unsubscribe” link at the bottom of each marketing e-mail, by contacting our Data Protection Officer (“DPO”) or by changing your marketing preferences in your account settings. Please note that even if you unsubscribe from marketing material, we may continue to send you service-related updates and notifications, or reply to your queries.

For non-EU users, you have the right to:

know if your data is being processed and you may request a copy of the related personal data at where this is possible. Additionally, you have the following rights:

• Rectification - You have the right to request the rectification about changes that you would like reflected in our records.
• Restriction - provided that the legal requirements for restriction are met, you have the right to request a restriction of processing from us. You may object to the processing and we will verify whether our legitimate grounds prevail.
• Data Portability - If certain terms are met and technologically possible, you may ask to get your personal data delivered to you or to a third party in a machine-readable format.
• Withdraw consent - Where your consent is needed, you have the right to withdraw your consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.
• Automated Decision-Making - You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you as far as further legal requirements are fulfilled.
• Erasure - You have the right to request the erasure of your information where there is no good reason for us continuing to process it or where you have exercised your right to object to processing.

Please keep in mind that we may need to verify your identity before fulfilling any personal data and/or other requests.

Unsolicited advertising

The company shall not initiate contact with any individual that has not explicitly accepted the company’s Terms and Conditions. This includes, but is not limited to, unsolicited advertising through communications via email, phone, text message, social media, or other digital or physical channels. The company recognizes and respects the right of individuals to privacy and strictly adheres to all applicable anti-spam laws and regulations, including the prohibition of unsolicited commercial messages. 

All communications must clearly disclose the Company’s identity. The Company shall apply a strict anti-spam policy and shall never use spam email techniques in marketing material.

How to contact us and how to make a Request and how to submit complaints: 

For EU users, you have the right to file a complaint with the relevant Data Protection Authority. For EEA residents, you have the right to make a complaint at any time to the regulator in your jurisdiction. To find out how to contact your local regulator, please visit the official website of the European Union.

UK residents have the right to make a complaint at any time to the Information Commissioner’s Office (“ICO”), the UK regulator for data protection issues on the official website.

Switzerland residents have the right to make a complaint at any time to the Federal Data Protection and Information Commissioner (FDPIC) using the website. 

If you wish to exercise any of the above rights, file a request or receive more information, please do it so through our App by using CONTACT US or by contacting our DPO directly, using the details provided below:

Email: support@brickwalls.link

Attn. DPO

Brickwalls LTD company, registration number 51560601043

 Tel Aviv, Israel