This Privacy Policy ("Privacy Policy") governs the manner in which Shu.L.A Holdings Ltd., Company No. 516530045 (hereinafter: "Shu.L.A", "the Company", "we", "our" or "us") uses personal information (as defined below) that we collect, receive and store about individuals in connection with use of: (i) the website https://www.book-chat.co.il and any other website we operate (collectively, including subdomains, content and services: "the Website"), and (ii) the software system at https://app.book-chat.co.il/ ("the Software"). The Website and Software are referred to herein, jointly and severally, as "the Services".
Introduction
We respect your privacy and the privacy of other users. The purpose of this Privacy Policy is, among other things, to explain our online information practices and the choices you can make regarding how your personal information is collected and used in connection with the Services.
"Personal Information" means any information that can be used, alone or in combination with other information, to personally identify an individual, including without limitation: first and last name, personal profile, email address, residential or other physical address, and/or other contact details.
End User License Agreement (EULA). This Privacy Policy forms part of the End User License Agreement for the Software, which can be viewed from within the Software that you received before installing and/or using the Software for the first time ("EULA"). Any defined term not defined in this Privacy Policy shall have the meaning given to it in the EULA.
Consent. You are not legally required to provide us with personal information, and you hereby confirm that the provision of your personal information is made of your own free will. By using the Services, you agree to the terms of our Privacy Policy and to all collection, processing and sharing of personal information for the purposes set out herein. If you do not agree to this Privacy Policy, please do not access or otherwise use the Services.
Choice. You may choose whether to provide or disclose personal information. If you choose not to provide personal information necessary for the provision of the Service, we will be unable to provide you with the Service.
What Personal Information We Collect, How We Collect It, and the Purposes of Collection
We do not currently require you to provide personal information in order to access the general information available on the Website and Software. However, we receive and/or collect personal information from you in the following ways and for the following purposes:
Registration. In order to use certain Services we offer, you may be required to register. During registration you will be required to provide certain information such as name and password in order to access the Services ("Registration Information"). We may send you a text message (SMS) to your mobile phone or other electronic device with a SIM card in your possession, in order to confirm registration for the Services. If you choose not to register, you may be unable to access and/or use certain features of the Services.
User Verification. For the purpose of verifying the device in your possession as part of the login process to the Software, we will transmit your mobile phone number (or alternatively the device phone number) to a third-party server, which will send a text message back to your device. This text message will contain a one-time temporary password (OTP) for logging in to the Service.
Use of Services. During your use of the Services, we may collect personal information relating to your use of the Services.
Remote Support Service. As part of our customer service, you may use our remote support service for your device via phone or any other platform, including but not limited to: Zoom, Google Meet, AnyDesk, or any other applicable tool. In this context, with your consent to allow a Company representative access to begin the service as part of operating the Service through the Software, once the support session is complete, the Company is unable to remotely operate your device.
Contact Us Requests. If you send us a "Contact Us" request, whether by submitting an online form or by emailing our email address, you are required to provide certain personal information such as full name, phone number, and email address.
Processing and Analysis. In order to provide the Services and operate the Company's business, we may use personal data for processing and analysis purposes.
Specific Purpose. If you provide personal data for a specific purpose, we will use it in connection with that purpose. For example, if you contact us by email, we will use the personal information you provide to answer your question or resolve your issue, and will respond to the email address you used to contact us.
Business Purposes. We may use your personal information for business purposes, for example to help us improve the content and functionality of the Website, to better understand our clients and users, to improve the Services, to identify or address misuse, to enforce legal agreements and this Privacy Policy, to provide customer service, and to manage our business (e.g., processing invoices).
Statistical Purposes. We may use any personal information you provide to produce statistical reports containing aggregate information.
Marketing Purposes. Subject to your explicit consent, we may use the personal details you have provided, including your email address and/or phone number, to send updates, commercial offers, promotional materials and/or other marketing content — all in accordance with the Services in which you expressed interest and/or purchased, or in accordance with your stated preferences. You may withdraw your consent at any time by sending a message or following the unsubscribe instructions included in any marketing message sent to you.
Security and Dispute Resolution. We may use personal information to protect the security of the Website and Services, to identify and prevent cyberattacks, fraud, phishing, identity theft and data leaks, to verify original software licenses, to resolve disputes, and to enforce agreements.
Cloud Services. We may need to share personal information with our cloud service providers. For example, to help protect and secure the Website or Services, a cloud services administrator may need access to personal information. In such cases, the cloud service provider is bound by our privacy and security requirements and may not use the personal information it receives from us for any other purpose.
Development and Customer Service. In order to provide customer service and support, or to assist in protecting and securing our systems and Services, our development and customer service teams may access personal information. Our employees are bound by our privacy and security requirements and policies, and are prohibited from using personal information for any other purpose.
Sale, Merger, Dissolution, etc. Personal information may form part of the assets transferred in such a scenario. You acknowledge that any successor or acquirer of the Company and its assets will continue to have the right to use your personal information and other information in accordance with the terms of this Privacy Policy.
Law Enforcement. We may use personal information about you to respond to a subpoena or request from law enforcement authorities, a court, or a government agency, or in good faith belief that such action is necessary to: (a) comply with a legal obligation; (b) protect the rights, interests or property of us or third parties; (c) prevent or investigate misuse of our Services; (d) act in urgent circumstances to protect the personal safety of users of the Website and Services or the public; or (e) protect the Company from legal liability.
Other Purposes. If we need to use any personal information in any way inconsistent with this Privacy Policy, you will receive notice of such use before or at the time of use.
How We Use Personal Information
We may use the personal information you have provided to us and/or information collected by us in the following ways:
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Personal information you provide to the Company will be stored in our database(s), and the Company will use it in accordance with applicable law and various regulatory requirements, and for the purposes set out in this Privacy Policy, by itself and/or through third parties acting on its behalf (including the right to transfer it to third parties acting on its behalf outside Israel), for the purposes described in this Privacy Policy.
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We will use your personal information to provide and improve our Services, to identify and authenticate your access to parts of the Services you are authorized to access, to send you updates and information about the Services, and to notify you of updates we may make to the Services or Software.
Disclosure of Information to Third Parties
We may transfer your personal information to our local and/or foreign subsidiaries and/or affiliated companies for the purpose of storing and/or processing such information on our behalf. This information may be transferred to other countries. We require such parties to agree to process the information in accordance with our Privacy Policy.
We may share your personal information with third-party vendors and partners to assist us in our business operations and to provide our Services to you and other users. Such information may be transferred to other countries. We make commercially reasonable efforts to engage with third-party service providers and parties that publish privacy policies governing how they process personal information.
We may also share personal information with our partners for the purpose of reporting on and operating the Services.
We may disclose your personal information and/or any information collected through the Services if we determine, in our good-faith discretion, that such disclosure is reasonably helpful or necessary in order to: (i) comply with any law, regulation, legal process or request of any competent court or governmental authority; (ii) enforce our EULA, including investigating potential violations thereof; (iii) detect, prevent or otherwise address fraud or security issues; or (iv) protect against harm to the rights, property or safety of the Company, our users, you, or the public.
Personal information you provide to the Company will be stored in our database(s) and used in accordance with applicable law and regulatory requirements, and for the purposes set out in this Privacy Policy, by itself and/or through third parties acting on its behalf (including the right to transfer it to third parties outside Israel), all in accordance with this Privacy Policy.
WhatsApp Business Cloud API
Our platform integrates with the WhatsApp Business Cloud API, operated by Meta Platforms, Inc. ("Meta").
When you use our Services to communicate via WhatsApp:
- Meta as Data Processor: Meta acts as a data processor on our behalf when processing WhatsApp messages. Meta does not use WhatsApp Business conversation data for ad targeting or AI model training.
- Encryption: Message content is encrypted in transit using the Signal protocol, ensuring secure communication between businesses and their customers.
- Message Retention: Message data may be retained on Meta's servers in accordance with Meta's own retention policy (typically up to 30 days). We retain message data in our own systems in accordance with the data retention settings configured for your account.
- No Data Selling: We do not sell, share, or distribute WhatsApp conversation data to unauthorized third parties.
- No Profiling: We do not use WhatsApp Business data to build or enhance user profiles beyond what is necessary to provide the Services.
- Opt-In: Messages are only sent to individuals who have provided their consent to receive WhatsApp communications from the relevant business. Each business using our platform is solely responsible for obtaining valid opt-in consent from their contacts in accordance with applicable law and WhatsApp's Business Policy.
For more information about how Meta handles data, please see Meta's Privacy Policy at: https://www.whatsapp.com/legal/privacy-policy-eea
For WhatsApp's Business Policy, see: https://business.whatsapp.com/policy
Cookies
A cookie is a small information file that we transfer to your computer or mobile device for the purpose of keeping a record of how you use the Service through the Website. When you visit the Website, we may place these files on your computer or device. The Company uses "cookies" for proper ongoing operation and employs various technologies to collect statistical data about Website use for information security purposes. Technology service providers may collect information about you and use it according to their own privacy policies and for their own purposes.
Technologies currently exist that offer the ability to prevent collection of cookies and/or prevent tracking technologies. You can set whether cookies will be used and/or use anti-tracking solutions. Some cookies may be essential for Website operation, and blocking them may impair or prevent the provision of the Service and/or degrade the user experience.
By using the Website, you consent to the collection of such information and its use by us and/or by the operators of the aforementioned technologies.
To the extent that you provide personal information of/for any third party, you have obtained all required consents from that third party under applicable law, and the use of such personal information by the Company in accordance with this Privacy Policy will not infringe the privacy or other rights of that third party.
Use of Anonymous Information
We may use anonymous information (as defined below) or disclose it to third-party service providers in order to improve our Services and enhance your service experience. We may also disclose anonymous information (with or without payment) to third parties, including advertisers and partners. "Anonymous Information" means information that does not include identification of an individual user, such as aggregate information about use of the Services.
Data Subject Rights
Under the Israeli Data Protection Law, 5741-1981, you have rights with respect to the personal information we hold about you as the data subject, including, among others, the right to review the information.
Any individual may review information collected about them in the Company's databases, and may request its correction and/or deletion in cases where the information is incorrect, incomplete, unclear or outdated. Requests for review, correction or deletion of information may be sent to: a@book-chat.co.il
Please note that deletion of certain information may prevent continued receipt of the Services and may result in cancellation of registration for the Services, to the extent the information is required for service provision. Notwithstanding the foregoing, the Company may continue to retain information necessary for proper management of the Services, compliance with legal requirements, and documentation of actions you took in the context of using the Service.
Direct Marketing
From time to time the Company may wish to send you details about our Services, where you have given your consent to such contact. If you have not given consent or have withdrawn your consent, and you have inadvertently received a direct marketing message, please notify us immediately at a@book-chat.co.il and we will act immediately to prevent recurrence.
Accuracy
To the extent you provide us with personal information, we aim to maintain accurate personal information. If you wish to delete or correct any of your personal information that we may store, you may submit a request via email to a@book-chat.co.il. Your email should include detailed information regarding your request.
Data Retention
The Company may retain personal information for any period permitted or required by law and/or pursuant to your consent. Personal information that has been deleted may continue to be stored in backup files or archives for an additional period of time due to technical issues or for legal, regulatory, tax and/or other legitimate business reasons.
We retain and store personal information for as long as necessary for the proper operation of the Company's business and maintenance of its Services, to fulfill contractual obligations, and to comply with applicable laws and regulations. Data retention is carried out subject to our data retention policy and this Privacy Policy, within databases that are maintained and secured in accordance with applicable law.
Children's Privacy
Our Services are not designed to attract minors. Accordingly, we do not intend to collect personal information from anyone we know to be under the legal age. If we discover that we have collected personal information from a minor, we will delete it as quickly as possible. If you believe we may have such information, please contact us at: a@book-chat.co.il
Information Security
The Company is committed to protecting personal information and data, and employs appropriate and industry-standard technological measures to protect information security and guard against loss, misuse or alteration of information. However, these measures do not provide absolute security, as no server, network, database, internet network or email inbox is fully immune from failures or security breaches. You should therefore carefully consider what details you share and with whom.
The Company implements information security measures in its information systems based on three aspects: legal, organizational and technological. The Company implements systems, security measures and procedures to secure personal information, with the aim of reducing risks of theft, damage, loss of information, unauthorized access or unauthorized use. For example, the Company conducts audits of data collection, storage and processing practices, including physical security measures, to prevent unauthorized access to systems. In addition, the Company restricts access to personal information to its employees and suppliers only to the extent they need the information to process it. All parties with access to information are subject to contractual confidentiality obligations, and violations may result in disciplinary action or termination of engagement.
You are responsible for taking basic protective measures on your computer or end device from which you use the Website (including installing antivirus software, locking the computer, changing passwords, etc.) in order to protect your personal information.
The Company shall not be liable for any damage caused to the User or a third party resulting from loss of private information and/or unauthorized use of private information due to an event beyond the Company's control and/or resulting from force majeure, and/or from software, hardware or communications failures.
The Company operates in accordance with the Israeli Data Protection Law, 5741-1981 and its regulations, in particular the Privacy Protection Regulations (Information Security), 5777-2017, and the directives of the Israeli Privacy Protection Authority. If you have any questions regarding security in the Service or confidentiality, you may contact us at: a@book-chat.co.il
Merger, Sale or Bankruptcy
In the event we are acquired by and/or merge with a third party, and/or in the event of bankruptcy and/or a similar event, we reserve the right to transfer or assign personal information in the circumstances described above.
Commitment
We are committed to protecting your privacy. Protecting your privacy online is an evolving field, and we continually develop our Service to meet these requirements.
Changes
We reserve the right, at our sole discretion, to change this Privacy Policy at any time. Such changes will take effect ten (10) days after publication of the updated Privacy Policy on the Website, and your continued use of the Services after such a change means you accept those changes.
To the extent you provide personal information of/for any third party, you have obtained all required consents from that third party under applicable law, and the use of such personal information by the Company in accordance with this Privacy Policy will not infringe the privacy or any other rights of that third party.
Governing Law
The law applicable to any dispute concerning this Privacy Policy is Israeli law only. The exclusive jurisdiction to hear any dispute and/or conflict in connection with the Website, Services, Company and/or this Privacy Policy and data security, shall be vested solely in the competent court in the Haifa and Krayot District.
Contact Us
If you have any comments or questions regarding our Privacy Policy or the personal information we may store and use, please contact us at: a@book-chat.co.il