Privacy Policy

We at Seperforma Ltd. (the “Company”, “Seperforma“, Business “We”, “Us” or “Our”), are committed to securing your (“You“, “Your” or “User”) Personal Data (as defined below) and Your privacy. This privacy policy (the “Policy”) provides You information regarding the types of information that We collect about the users of Our website (“Website”) when We collect it, how We use it, store it, process it and share it with other third parties.

This Policy is part of and should be read in conjunction with our Terms of Use.

In this Policy, any reference to “Personal Data” is to any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or in combination with additional information that We have or that We have access to.

When do we collect personal data about you?

• We may collect Personal Data about You in the following circumstances:
• When You access or use the Website;
• When You are using the Website an employee or a representative of a Company how is interested in partnering with us;
• When Users use the Website;
• When You interact with Us in any manner, including by sending Us messages at the “Contact us” or “Partner with us” or in any other manner.

No obligation to provide personal data to the company and its implications

You are not obligated to provide Us with any Personal Data about You. However, in some instances, not providing such Personal Data will prevent Us from providing You with the Services You requested Us to provide You, will prevent Your use of the Services or a part thereof.

What types of personal data do we collect?

We (or others on Our behalf) may collect the following types of Personal Data about You:

1. Website usage information – this information includes online activity log, traffic information (including, without limitation, IP address, time of access, date of access, web and mobile page(s) visited, language used, crash reports and type of browser used, information regarding the device You used. Some of this information may not identify You personally, and therefore not constitute Personal Data;
2. Website activity information – whenever You use the Website, We monitor Your use of the Website and record Your activity. The information that We gather about You in this context includes any activity that You perform in the Website, such as the business checking accounts or other banking products you have reviewed, dates and times on which You will use the Website, the length of time You will be watching content on the Website, Your interaction with content in the Website, etc.
3. Service activity information – whenever You use the Website, we monitor Your use of the Website and record Your activity. The information that We gather about You in this context includes any activity that You perform through the Website, including any Code transcript, text, images or videos that You upload or provide to us in the context of the Website.
4. Communication information – When You contact Us, though any channel whatsoever, including social media networks, you may provide Us with Your full name, business name and e-mail address, job description, telephone number and the content of your communication with Us.
5. Aggregate Information – We will also create statistical, aggregated, and anonymized data relating to our Users and the Service for analytical purposes, including business development and Website improvements. Aggregated data is derived from Personal Information and User Data but in its aggregated form it does not relate to or identify any particular client or individual or any specific user’s data. This data is used to understand our customer base and to develop, improve and market our Website.

The purposes of the processing of personal data

The Company processes Your Personal Data for one or more of the purposes outlined in this section and according to the appropriate legal basis.
The Company will not process Personal Data about You unless there is a legal basis for such processing.
The legal bases according to which the Company may process Personal Data about You are as follows:

1. Processing is necessary for the purposes of the legitimate interests pursued by the Company or by a third party. By way of example, for the purpose of improving Our Website will we use the data collected during the conversation and the content thereof to improve our Website; or for the exercise or defence of legal claims.
2. Your consent that the Company will process Personal Data about You for one or more specific purposes. By way of example, providing the Services.

How do we use personal data?

We may use Personal Data about You for the following purposes:

 To operate the Website and provide the Services.

• To contact You for the purpose of operational requirements.
• To personalize content and/or offers to You.
• To respond to Your queries, requests and/or complaints.
• To send You materials regarding the Services, events and other information we think will be of interest to You, subject to Your consent.
• To analyze and improve the Services, as well as to develop and offer new ones.
• To analyze and track usage to determine the usefulness or popularity of certain content and to better understand the online activity of the Website users.
• Monitor and analyze trends, usage and activities in connection with the Website and the Services.
• To perform and maintain various activities supporting the offering and provision of the Website, including, but not limited to, the Website (such activities include back office functions, business development activities, strategic decision making, financing management, etc.).
• To protect Our and third parties’ interests, rights and assets, including detecting, investigating and preventing fraudulent transactions or unauthorized or illegal activities and initiation or exercise or defense of legal claims and preventing.
• To fulfil Our legal or regulatory requirements.

Sharing of personal data to third parties

1. We will not disclose Personal Data about You to third parties except as detailed in this Policy.
2. We may transfer Personal Data to entities that control Us, entities that are under Our control and/or to entities under common control or ownership with Us, as shall be from time to time (collectively the “Group”). Such entities may use the Personal Data to support the needs of the Group.
3. The Company may also share Personal Data about You with third parties that provide Us with the following services:
   • Storage and hosting providers, including cloud computing services and data security services;
   • IP address information;
   • Analysis of user experience;
   • Support;
   • Marketing;
   • CRM data management;
   • Accounting and legal services; and
   • Research, analytical, technical, and diagnostic services.
4. Upon Your consent or instruction;
5. In the event that we will be subject to an audit or a Due diligence process;
6. In the event that We sell, assign or transfer some or all of Our business or assets to a successor or acquirer, or if We are acquired by or merge with a third party, or if We file for bankruptcy or become insolvent, or any other situation where Personal Data may be sold, assigned or transferred to a successor or acquirer;
7. To protect Our rights, property and interest or those of third parties;
8. To fulfil Our legal or regulatory requirements or to comply with a national authority request or a court order.
9. In the preceding twelve (12) months, We have not sold any Personal Data.

Retention

We will retain Personal Data about You only for as long as necessary for the fulfilment of the purposes for which such Personal Data is collected. We may retain Personal Data about You for longer periods, if We find it necessary to comply with legal requirements applicable to Us.

Cookies and trackers

1. We may use certain third party services, such as analytics companies or companies delivering advertisements, which may also use cookies or other technologies, and those practices and providers are subject to their own policies.
2. Cookie (which is a small text file) is installed on the device via which You visit or access the Website. The cookies allow Us to collect information about You and Your behaviour, in order to improve Your user experience, to remember Your preferences and settings, and to customize and offer You products and services that may interest You. Cookies are also used to collect statistics and perform analytics.
3. Some of the cookies We use are session cookies, which are downloaded temporarily to Your device and last until You close Your web browser, while others are persistent cookies, which last on Your device after You cease browsing the Service and are used to help the Service remember You as a returning visitor when You return to the Service.

Types of cookies:

The cookies We may use have been classified according to their functionality, as follows:

Type of Cookie	Purpose	Additional Information
Strictly Necessary Cookies	These cookies are strictly necessary to enable You to navigate the Website and use features You have requested. They are used to provide You with Our content, products, and Website that You have requested. Such cookies are essential to help Your device download or stream information so that You can navigate around the Website, use its features, and return to pages You have previously visited.	These cookies collect Personal Data about You, such as user name and last login date, and identify You as being logged in to the Website. These cookies are deleted when You close Your web browser (session cookies).
Functionality Cookies	These cookies are used to recognize You when You return to the Website and allow Us to remember Your choices and preferences and measure how You use our website.	These cookies survive the closing of Your web browser, and last until their applicable expiry time.
Performance Cookies	These cookies are used to provide aggregated statistics in respect of the performance of the Website and to test and improve such performance, in order to provide better user experience. In addition, they allow Us to carry out analytical functions on the Website.	These cookies collect anonymized data that is not related to an identified or identifiable natural person. These cookies are valid for varying periods; some are deleted once You close Your browser, while others have an indefinite validity period.
Third Party Marketing/Targeting Cookies	These cookies are used to deliver ads and marketing communications, and to display the Website in a manner that is more relevant to You. They are also used to measure the effectiveness of an advertising campaign. These cookies record Your visit to the Website and the pages You have visited.	Some of these cookies are provided and used by third parties. These cookies are valid for varying periods; some are deleted once You close Your browser, while others have an indefinite validity period.

The Cookies incorporated in our Website are as follows:

Third Party	Name	Retention	Type	Function
Yes	Google.com	30 Days	Performance & Advertising	Marketing & Optimization
Yes	Bing.com	30 Days	Advertising	Marketing & Optimization
Yes	Facebook.com	30 Days	Advertising	Marketing & Optimization
No	Linkedin.com	30 Days	Advertising	Marketing & Optimization
No	https://top10businessbanks.com/	Up to 6 Months	Strictly necessary cookies	Essential for Using The site
Yes	Doubleclick.net	30 Days	Advertising	Marketing & Optimization

Blocking and removal of cookies

You can change Your browser settings to block and delete some or all cookies. Please see below links to instructions on how to do this in respect of some of the most popular web browsers:

• Firefox
• Edge
• Internet Explorer
• Google Chrome
• Safari

ONLINE TRACKING NOTICE:AT THIS TIME, THIS SERVICE DOES NOT SUPPORT DO-NOT-TRACK SIGNALS.

Security

We have implemented suitable security policies, rules and technical measures to protect and safeguard the Personal Data under Our control from unauthorized access, improper use or disclosure, unauthorized modification, or unlawful destruction.

Links to other websites

1. The Website may contain links to websites and/or applications of third parties. Other websites and applications may also reference or link to Our Website. We do not control such websites and applications, nor the collection and/or processing of Personal Data about You by such websites and applications, and thus We are not responsible for the privacy practices. This Policy does not apply to any actions taken via such websites and/or applications.
2. Whenever You access such third parties’ websites and/or applications, We recommend that You carefully review their privacy policies prior to using such websites and/or applications and prior to disclosing any Personal Data about You.

Your rights in respect of the personal data

• Generally, You have the right to request that We provide You with confirmation as to whether Personal Data about You is being collected by Us, to ask to review such data, to rectify the content if applicable and to erase the Personal Data no longer required by Us. You may also restrict Your consent to certain processing of Your Personal Data.
• Where the legal basis for the processing of the Personal Data about You is consent, You may at any time withdraw Your consent for the purposes for which You provided Your consent by sending a notice free of charge to the following email address: info@top10businessbanks.com.
• Where You withdraw Your consent for the processing of Personal Data about You, We might not be able to provide You with some or all of the Services You requested or in the form intended to be provided to You, and You will have no claim in respect of that.
• At any time, You may approach Us by sending a notice to the email address info@top10businessbanks.com, in order to receive information concerning the review performed by Us. This is so You can conclude that We may process the Personal Data about You on account of such processing being necessary for the purposes of the legitimate interests pursued by the Company or by a third party.
• The Company may provide You with offers that are tailored for You specifically, in order to connect You to brands, products and services in ways that are important to You. This may include ads, offers and other sponsored content related to products and services of Our’s or of third parties. This is done following the processing of Personal Data about You, in order to adjust the materials presented to You, on the basis of Your preferences, behaviour, characteristics and interests.

If You reside in the U.S.A, please read below with respect to the California Consumer Privacy Act (CCPA), California Privacy Rights Act (CPRA), the Virginia Consumer Data Protection Act (VCDPA), and the Colorado Privacy Act (CPA)) rights You might have:

	Right	Scope
1	Right to know	You have the right to receive the following information: ·         The specific pieces of Personal Data We have collected about You. ·         What types of Personal Data collected; ·         categories of personal data collected; ·         What are the types of sources of the Personal Data collected; ·         the purpose of collecting the Personal Data; and ·         Types of third parties with whom We share Personal Data, if any.
2	Right of Erasure	You may ask Us to delete Your Personal Data and direct Our service providers to do so. Please note that We may not delete Your Personal Data if it is necessary to complete Our legal obligation to You to provide the Website or Services otherwise protect Our legal rights, comply with an existing legal obligation; or use Your Personal Data, internally, in a lawful manner that is compatible with the context in which You provided the information.
3	Right to non selling or sharing	You may ask us to not sell or share Your Personal Data.
4	Right to Non-Discrimination for the exercise of Your privacy rights	You have the right to not be discriminated by Us because You exercised any of Your rights under the CCPA.
5	Right to designate an authorized agent to submit CCPA requests on Your behalf	You may designate an authorized agent to make a request under the CCPA on Your behalf. To do so, You need to provide the authorized agent written permission to do so and the agent will need to submit to Us proof that such agent has been authorized by You. We will also require that You verify Your own identity, as explained below.

Transfer of personal data

• Personal Data about You may be transferred to a third country (i.e. jurisdictions other than the one You reside in) or to international organizations. In such circumstances, the Company shall take appropriate safeguards to ensure the protection of Personal Data about You and to provide that enforceable data subject rights and effective legal remedies for data subjects are available.

You may request that the Company provide You with details concerning the safeguards employed by it to protect the Personal Data about You that are transferred to a third country or an international organization, by sending an email to the following address: info@Top10businessbanks.com.

Changes to the policy

We may amend, from time to time, the terms of this Policy. Whenever We amend this Policy, we will notify You of such amendments by publishing the updated Policy on the Website. In addition, when We make significant amendments to this Policy, we will strive to inform You about such amendments via means of communication We believe are reasonably appropriate to inform You of such amendments and by publishing a notice about such amendments on the Website. Unless stated otherwise, all amendments will enter into force upon publication of the updated Policy on our website or the designated page in the Website.

Contact us

For any queries relating to this Policy and data protection, please contact Us at info@Top10businessbanks.com.

Last updated: May, 2023.