Privacy Policy

Last revised: 26 August 2023

This privacy policy (hereafter "privacy policy") is in effect from 26 August 2023. Updating the current privacy policy won’t impact any customers rights. All updates will be in vigor from the date indicated at the top of this very page of the website (hereafter “website”).

This website, https://atgyre.com/, is operated by Assets Tracing Gyre Ltd (hereafter “company”, or “we”). The company is committed to protect, in an open and transparent way, the privacy and integrity of the personal data collected from our clients. The personal data we collect and process, stored as database items, will vary depending on the services needed by our clients.
Personal information in this privacy policy refers to “information”, as defined in the Protection of Privacy Law, 5741-1981 (the “Protection of Privacy Law”), and to any data allowing the identification of a person, either directly or indirectly.

The primary purpose for which we collect personal information is to provide our clients with a custom-tailored service to guarantee them the best management of the company-client relationship. Collected personal data are then used within the norms regulated by the law.

Personal information about visitors (hereafter “visitors”) navigating on the company’s website, and about the company’s other clients (together with the visitors, "company’s users”) is also collected.

Any use of, and/or any attempt to use this website and this company’s services constitute consent to this privacy policy, including consent to the collection and processing of personal information as detailed below. The foregoing does not derogate from other consents that clients have given us, either explicitly or implicitly.

You hereby declare that you are over 18 years of age. If you are not over 18 years of age, or if you do not agree to the present policy, you must leave the website and refrain from using the company’s services.


1. Personal Data collection
The following personal data may be collected and processed:

  • Biographical and Identification Data, including name, email, identity number, gender;
  • Contact Data, including address, phone number and email;
  • Financial and Payment Data, including bank account number and every other element necessary to process payments;
  • Information pertinent to the fulfilment of our services, including all information needed to guarantee the fulfilment of the requested services, including what is provided in the course of the contract, between our client or their organization and the company, or in any case voluntarily provided by you or your organization.

The website automatically also collects and records, in case your browser allows for this type of information to be recorded, navigation data, such as the IP address from which our website is reached, the web pages visited from that IP, and eventually the search engine / website that addressed the visitor to our website. This information is used to evaluate the interest in our website and to perform other market-research related activities, such as surveying browsing habits on our website. This information is never used to track the identity of the user who is accessing the website.

Company’s users can be asked to supply additional details, such as name, location and information about their business, occupation and/or an e-mail address. These data will be processed according to what stated above in this privacy policy. Users may also be asked to submit questions or comments, or to provide additional information by means of surveys or contests. The provision of such information is entirely voluntary. Information provided this way can be used by the company to contact the client and to inform them of changes to our services or our website, when necessary, in the optic of the above-mentioned purposes. Finally, this information can also be used to enhance the usability of the website and to ensure its relevance and it meets our client needs.

We may also ask our clients to give consent to specific uses of the stored data, when needed for purposes not covered by this privacy policy. In these cases, the client is not obliged to provide such consent, but the refusal might result in a participation restriction to some activities in the case such activities require a wider consent to be given.
Finally, collected Personal Information can be used, if deemed necessary, to protect the company from security risks, and can be shared with law enforcement authorities when appropriate.


2. Goals and basis of collecting and processing personal data
The personal information is collected for the company’s activities, which allow us, among others:

  • to conduct the company’s activities and provide our clients with services, either directly by us or with the assistance of third parties; this includes the management and supervision of the website and various services, and responding to your queries;
  • to make content available to our clients, and to send them information and notices about the company, via direct mailing and/or direct mailing services, as defined in the Protection of Privacy Law, and to maintain contact with our clients during and after the provision of our services;
  • for business purposes, such as the improvement of existing services and the development of new services and products;
  • to assess, enforce and/or protect the rights of the company and/or third parties;
  • to comply with the provisions of law and/or rules of ethics (including provision of information to authorities and/or according to directives from authorities);
  • for security purposes, such as, but not limited to, the performing of various analyses for security purposes and as protection against infringement of the rights, property or security of the company and/or the company’s users, as necessary or permitted pursuant to the applicable law.

We may collect aggregate data, statistical data and other data deriving from both the personal information and the additional data in our possession.

Contact form
Processing: If the contact form is filled out and submitted, we will process the personal data therein included, to respond to the received queries, comments, or requests for information. We may also use the data collected in this way to establish a business relationship with the client or the organization they represent. We may retain received queries for a certain amount time for internal administrative purposes, or in order to improve our services or products.
Legal basis for processing: The company relies on legitimate interest when processing personal information collected through the contact form. Consent is given to the company for processing your personal information for marketing purposes, and for receiving from the company communications such as press releases, stock exchange filings, updates about company’s services and information about company events. The company relies on your consent to send you the above-mentioned communications.

Your correspondence with the company
Processing: If you correspond with us by email, through the postal service, or via any other form, we may retain such correspondence and the information contained in it, and use it to respond to your inquiry, to notify you of our events or products or to keep a record of your complaint.
Legal basis for processing: The company relies on legitimate interest when processing your personal information for correspondence purposes.

Business relationships with our contractors
Processing: In the course of our business activities, we collect data necessary for the performance of contracts with our clients, suppliers and other involved parties. In case you establish a business relationship with us, your data will be processed in order to conclude and perform the contract.
Legal basis for processing: The company relies on necessity for the performance of a contract with you when personal information is to be processed.

Website users
Processing: We use cookies to help us enhance your experience when using our website. In some cases, cookies can be considered as personal data. We may collect cookies that are essential for the website user experience, as well as cookies used for functional, statistical or marketing purposes.
Legal basis for processing: When processing cookies, the company relies on your consent on necessity for performance of a contract with them, or on legitimate interest, depending on the type of processing and cookies.



3. How is personal information collected?
Personal information is collected through different platforms and by different means, including:

  • Data provided by the users on the website. Data are collected when you provide the company with data or personal information, such as entering your contact details in the relevant fields on our website, or additional details given during your communication with us. Such data may include elements like “first name”, “last name”, “telephone number”, “email”, “company”, “position”, “message content” and any additional data provided by the users in the framework of their interaction with the company.
  • Data delivered by the company’s clients and suppliers in the framework of their engagement with the company. Some data are collected in the course of the engagement between company and client, such as bank account details, medical documents, commercial documents, details about the client’s economic situation, confidential information, personal information, and any other data required in connection with our Company’s services.
  • Automatic data collection. Some data may be collected automatically while using our website and/or during the process of receiving/providing the services.
  • Data collection from third parties. As necessary, we may receive personal information or data about you from third parties, and by agreeing to the present Privacy Policy, you approve that we receive and collect such data.
  • Information on others. It is possible that you will provide to our company information about other individuals / organizations / institutions. You must ensure that you are providing such information lawfully (you may consult us for this purpose).


4. Personal data about other people
On certain occasions, during the fulfilment of our service, you may provide to us personal data of individuals (such as family members, customers, counterparties, employees, directors, shareholders or beneficial owners) who are not aware of our involvement or our processing of their personal data. In such cases, we are likely to not have direct contact with individuals whose personal data are being processed, or, it may happen, for other reasons, such as maintaining confidentiality, to not be appropriate for us to provide to them a privacy notice detailing how their personal data are processed. For these reasons, before you disclose any such personal data with us, you must verify that the relevant individuals have received this privacy policy and agreed to it, or they have otherwise been informed of our client services.


5. If you fail to provide personal data
In case we need to collect personal data by law, in order to process per your instructions (for instance in relation to anti-money laundering or other KYC checks) or to perform a contract we have with you, and you fail to provide those data upon request, we may not be able to process per your instructions or perform the contract we have, or are trying to have, with you. In this case, our engagement with you may be cancelled after sending you a notification.


6. Whom we share your personal data with
We may share your personal data:

  • with certain service providers we have retained, in connection with the consulting services we provide;
  • if we have collected your personal data in the course of providing consulting services to any of our clients, we may disclose it to that client, and, where permitted by law, to others, for the purpose of providing those services;
  • with any competent law enforcement body, regulator, government agency, court, or other third party, where we believe disclosure is necessary as a matter of applicable law or regulation or in order to exercise, establish or defend our legal rights;
  • with suppliers and service providers who support our business, including IT and communication suppliers, file storage, archiving and/or records management companies and security solutions companies;
  • if we sell or buy any business or assets, in which case we may disclose your personal data with the prospective seller or buyer of such business or assets, to whom we assign or novate any of our rights and obligations;
  • with a person you have given us your consent to disclose to.


7. Transfer of personal information to third parties
The company may transfer personal information to third parties (also as a way of granting access):

  • when the transfer is needed in order to guarantee the fulfilment of our services. In this way, personal information about our clients can be stored on different platforms and on different storage service providers;
  • for the purposes detailed in this privacy policy and/or by law and to realize our legitimate interest;
  • for the ongoing management of the needs of the company, of the company’s users, and of the duty imposed on the company by the law;
  • for the purpose of engaging with the company’s users with regard to the website and/or the services, through different means;
  • in the framework of proceedings between the company’s users and the company and/or any person on their behalf;
  • in order to protect the rights of the company, of the company’s users and/or of any third party;
  • when required by law, and/or under a judicial order, and/or to report to the competent authority, and/or in the framework of legal proceedings;
  • when the activity is transferred to another corporation or firm in any way, in case of a merger, or in case our company merges the website’s activity with a third-party activity.


8. How long your personal data are stored
Your personal data will be stored by our company as long as our business relationship with you lasts. At that point, the company may keep your personal data for the longest of the following periods: (i) any retention period which is in line with the current regulatory requirements; or (ii) the end of the period in which any legal action or investigation might arise, in respect of the services provided.

To determine the appropriate storing period for your personal data, we consider the amount and nature of the personal data collected, and the potential risk of harm coming from authorized use of them, the achievability of those purposes through other means, and the applicable legal requirements.

Personal data can be stored for a longer time in case they cannot be deleted for any legal, regulatory, or technical reasons. In this case, we will make sure that your privacy is protected and that your personal data are only used for those purposes.


9. Security
We are committed to ensure that your personal information is secure with us and with third parties acting on our behalf.
We have put in act appropriate security measures to prevent personal data from being accidentally lost, processed or accessed to in an unauthorized way, or altered or disclosed. In addition, access to personal data is limited to only those employees, agents, contractors and other third parties having a business-related reason to do so. In this case, these figures will process your personal data based on our instructions, and they are subject to a duty of confidentiality.


10. Governing law and jurisdiction
This privacy policy shall be interpreted in light of the laws of the State of Israel, which shall alone control it. In giving consent to the use of our website, and/or in giving/receiving our services, you are also giving consent that the exclusive jurisdiction regarding any demand, dispute or claiming arising from or in connection with this privacy policy is to be given to the competent courts of the State of Israel.


11. Data protection rights
As we process your personal data, we want you to be aware of your rights on the matter. Those rights, and the circumstances in which they are applied, are here listed:

  • maintain access to your personal data. You have the right to access to your personal data, or to receive a copy of them, and to verify that we are processing them according to the current law;
  • request correction of your personal data. You have the right, if you believe that any of your personal information stored by our company is inaccurate or incomplete, to request that we correct such inaccuracies;
  • request erasure of your personal data. You have the right to request the deletion of your personal information, if you believe that at least one of the following is true:
a) we no longer need to process your information for the purposes for which it was provided;
b) we have requested your permission to process your personal information and you wish to withdraw your consent;
c) we are not using your information according to the current law.
Please note that if you request us to delete your information, we may have to suspend the services provided to you;
  • object to the processing of your personal data. You have the right to object to the processing of your personal data if you believe there is something about your particular situation that requires your data to not be processed. If this right is exercised, the company will no longer process your personal data, unless we can demonstrate compelling legitimate grounds overriding your interests, rights, and freedom, or for the establishment, exercise or defense of legal claims.
Depending on the circumstances, we may need to restrict or cease processing your personal data altogether or, when requested, delete your personal information. Please note that if you object to our processing of your personal data, we may have to suspend the services provided;
  • request the restriction of processing of your personal data. You have the right to ask us to use your personal data only for certain things, if you believe that at least one of the following is true:
a) personal data collected are not accurate;
b) personal data collected have been used outside of the scope of the law, but you do not want us to delete them;
c) personal data collected are not relevant any more, but you want us to keep them in case of possible legal claims;
d) you have already asked us to stop using your personal data, but you are waiting for us to confirm whether we have legitimate grounds to still store / use them.
Please note that if you request us to restrict processing your personal data, we may have to suspend the services provided;
  • request the transfer of your personal data. You have the right to receive the personal data you provided to us in an exportable format. You may also request us to provide the data directly to a third party, if technically feasible. We are not responsible for any such third party’s use of your account information, which will be governed by their agreement with you and any privacy statement they provide to you.

To exercise any of your rights, or if you have any other questions about our use of your personal data, please contact us at NE@atgyre.com.

We will address all of your requests promptly.


12. Right to complain
If you have exercised any or all of your data protection rights, or otherwise still feel that your concerns about the use of your personal data have not been adequately addressed by us, you have the right to complain by contacting us at NE@atgyre.com.


13. Changes to this privacy policy
We reserve the right to update and change this privacy policy upon need, in order to reflect any changes to the way in which we process your personal data or due to the changing legal requirements.
We will notify you (by email, or otherwise) when changes to this privacy policy are made; contextually, the privacy policy revision date will be indicated at the top of this page. We do encourage you to review this statement periodically so as to be always informed about how your personal data are processed and protected.
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