Privacy Policy

The purpose of this privacy policy (the “Privacy Policy”) is to detail the manner in which Via Sabra/Israel4All/Israel4All (“us” or “we”) operates in regard to Information (as defined below) which is being collected from you while using the Services.

If a User is an individual in the European Economic Zone (EEA) then the Annex to the Privacy Policy for EU data subjects (the “EU Annex”) shall apply to the processing of such User’s Information (as defined below) and such User will have the additional data subject rights described in that Annex.

We may, from time to time, update our Privacy Policy and therefore it is recommended to check the Privacy Policy frequently for any changes made.

1. General
   1. When using the Services, you must provide us with certain details concerning yourself. These may include, among other things: your full name, your phone number, your e-mail address, your date of birth, your place of residence, your passport number, your credit card information, your health declaration, and any additional personal information you may disclose to us when using the Services (collectively, the “Information”).
   2. We see great importance in safeguarding your privacy, and therefore we put in efforts to ensure a level of security appropriate to the risk involved.
   3. This Privacy Policy applies to the personally identifiable information provided by you, as well as Information collected about you while using the Service
   4. We assume no responsibility for the use of Information by other Users or any other third parties, including external sites, which appear on the Services and are not under our control. In case of doubt, you should review the privacy policy and terms of use of such third party or external site.
   5. You understand that while you are not obligated to provide any information and that any information you provide is provided of your own free will and consent, certain minimum information is required for the proper function of the Services.
   6. The Information shall be kept by us and its use shall be made in accordance with this Privacy Policy, any other agreement between us and you and any applicable law. All credit card information shall not be saved directly by us but shall be saved by a payment gateway in accordance with applicable law.
   7. If you object to the use of your Information, or you wish to remove yourself from our database or you wish to not receive notifications or updates, you must notify us by writing through the Services or the removal mechanism found in any mailing or by emailing info@viasabra.com, in which case we will, subject to applicable law and other internal requirements, remove such information from our database.
2. Purpose of Data Collection

   The disclosure of Information by you constitutes a consent that such Information and any data generated on the basis of the analysis of such Information, which has reached or shall reach us, will be kept by us or any person or entity on our behalf, as required by law, and that such Information may be used for the following purposes:

   1. For the provision of the Services;
   2. For marketing purposes (including via SMS or email);
   3. For statistical analysis, provided that the part of the Information used for such purpose is aggregated and anonymized.
   4. We may use information in the following ways:
      1. For the purposes for which you specifically provided the information;
      2. To send you e-mail notifications about our new or existing products and services, special offers, or to otherwise contact you;
      3. To enhance existing features or develop new features, products and services;
      4. To allow us to personalize the content and advertising that you and others see based on personal characteristics or preferences;
   5. We may combine the information that we collect from you on Via Sabra and Israel4All with information that you provide to us in connection with your use of our other products, services and web site.
   6. We may disclose and use personally identifiable information in special circumstances where it is necessary to enforce our Terms of Use (for example, when necessary to protect our intellectual property rights). We may also disclose or use your personal information when we, in good faith, believe that the law requires us to do so.
3. Transfer to Third Parties
   1. The Information concerning you shall not be sold, leased or delivered by us to any third party, except in accordance with the provisions of Section 3.2 below.
   2. We may disclose any Information, in whole or in part, to third parties, if any one of the following conditions are met:
      1. If the disclosure of the Information, or any part of it, is made to third parties who are parties to or are involved in the provision of the Services, provided that such disclosure is necessary for the performance of the Services. These third parties shall have no right to use this Information except for the purpose of providing the Services;
      2. In accordance with Section 2;
      3. If we are required to do so by judicial order or by law or according to any legal proceedings;
      4. If we organize our activity under a different entity, including by way of a merger with another entity, whether such mergers are at the corporate level or with regard to its activities. In such a case, we shall ensure that the third party to whom we merged accepts the provisions of this Privacy Policy.

      You shall have no claim or demand towards us with regard to the transfer of Information to third parties as specified in this Section 3.2 and waive any such claim or demand.

4. Identifiers

   When you use the Services, we try to make that experience simple and useful. We use industry standard identifiers, such as cookies or other similar technologies. Cookies are small pieces of information which are issued to your computer and/or your mobile or when you visit or access a website and which store and sometimes track information about your use of such website. A number of cookies we use last only for the duration of your session using the Services and expire when you cease using the Services. Other cookies are used to remember you when you return to use the Services and will last for longer. We refer to cookies and equivalents technologies as "Identifiers".

   1. We may use Identifiers to:
   1. Remember that you have visited us before. This means we can identify the number of unique Users we have;
   2. Customize elements of the promotional layout and/or content of the pages included in the Services;
   3. Collect statistical information about the manner in which you use the Services (including the time you spend using the Services) so that we can improve the Services and learn which parts of the Services are mostly used by you;
   4. Assist us in providing Services to your Account, for example analyzing data for the purposes of trouble shooting.
5. Review of information

   You are entitled to review your Information which is being kept by us. If you find any Information to be mistaken, incomplete, or unclear, you may approach and request us to correct or delete such Information, by e-mailing info@viasabra.com.

1. What is the purpose of this Annex?

This Annex applies to the processing by us of the Information of Users in the European Union. It is supplemental to the Privacy Policy above and does not override it; however, in the event of any conflict or inconsistency between this Annex and the Privacy Policy, this Annex shall prevail.

We do not have any establishment in the European Union. Accordingly, this Annex is only intended to apply to Users that are located in the European Union.

All capitalized terms used in this Annex and not separately defined in this Annex are as defined in the Privacy Policy.

2. What information do we collect, how, and for what purpose?

We collect and process Information only if we have a legal basis to do so, in the following situations:

• We may process Information for purposes necessary for using our Website, for the performance of the Services, or for steps preparatory to provide the Services, and to comply with our legal obligations.
• We may process Information for the purposes of our own legitimate interests provided that those interests do not override any of your own interests rights and freedoms which require the protection of the Information.
• We may process Information for certain additional purposes with a User’s consent, and in these limited circumstances where a User’s consent is required for the processing of Information then (i) we will request such consent from a User separately, and (ii) we have the right to withdraw a User’s consent to processing for such specific purposes.


3. Data Retention

We will only retain Information for as long as is necessary to fulfill the purposes for which it is collected. When assessing what retention period is appropriate for the Information, we take into consideration:

• The requirements of our business and the Services;
• The purposes for which we originally collected the Information;
• The lawful grounds on which we based our processing;
• The types of Information we have collected;
• The amount of Information; and
• Whether the purpose of the processing could reasonably be fulfilled by other means.


4. Data Sharing

We will share Information with any third party where we are required by law, where it is necessary to administer the relationship between us and any third party or where we have another legitimate interest in doing so.

"Third Party Service Providers are: IT and data storage services, professional advisory services, clearance and payment services, administration services, marketing services and banking services.

All our Third-Party Service Providers are required to take commercially reasonable and appropriate security measures to protect Information. We only authorize Third-Parties Service Providers to process Information for specified purposes and in accordance with our instructions.

We may share Information with other third-parties, for example in the context of a possible sale or restructuring of its business, where an external organization conducts an audit or undertakes quality checks for us, or where sharing with third parties is appropriate in order to provide the Services. We may also need to share a User’s Information with a regulator or to otherwise comply with the law. We may disclose Information to protect our rights or property or those of its customers or others.

5. Transferring Information outside the EEA

   We are based outside the EEA and accordingly it will process Information outside of the EEA. If any third party by whom Information is to be processed are also based outside the EEA so that their processing of the Information will involve a transfer of data outside the EEA, we will ensure that a similar degree of protection is afforded to it by ensuring that at least one of the following safeguards is implemented:

• We will only transfer Information to countries that have been recognized to provide an adequate level of protection for Information by the European Commission.
• We may use specific contracts approved by the European Commission which give Information the same protection it has in Europe.


6. Data Security

Taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of individuals we maintain, and shall maintain, appropriate technical and organizational measures to ensure a level of security appropriate to the risk of processing Information.

We have put in place commercially reasonable and appropriate security measures to prevent the Information from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed. In addition, we limit access to Information to those employees, agents, contractors and other third parties who have a business need to know (the “Representatives”). The Representatives will only process Information on our instructions, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected data security breach and will notify Users and any applicable regulator of a suspected breach where we are legally required to do so.

7. Users' Rights

Under certain circumstances, Users, by law, have the right to:

• Request access to their Information. This enables Users to receive details of the Information we hold about Users and to check that we are processing it lawfully.
• Request correction of the Information that we hold about a User. This enables a User to have any incomplete or inaccurate information we hold about such User corrected. It is important that the Information we hold about Users is accurate and current. A User shall keep us informed if there is any change to the Information of which we need to be made aware.
• Object to processing of the Information where we are relying on a legitimate interest (or those of a third party) and there is something about a User’s situation which makes such User want to object to processing on this ground.
• Request the restriction of processing of the Information. This enables a User to request that we suspend the processing of Information, for example if such User wishes for us to establish its accuracy or the reason for processing it.
• In the limited circumstances where a User may have provided its consent to the collection, processing and transfer of their Information for a specific purpose, a User has the right to withdraw such consent to the use of Information for that purpose at any time.
• Request the transfer of Information to another party.



If a User wishes to exercise any of the above rights, such User should email info@viasabra.com.

A User will not have to pay a fee to access its Information (or to exercise any of the other rights set forth above). However, we may charge a reasonable fee if a User’s request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances. We may need to request specific information from a User to help us confirm such User’s identity and ensure the right to access the Information (or to exercise any other rights). This is another appropriate security measure to ensure that Information is not disclosed to any person who has no right to receive it.

8. Questions regarding this policy

Should a User have any questions regarding this Privacy Policy and/or the Annex, such User may contact us by email at info@viasabra.com.