Last Updated: 09/05/ 2022
We at Gyni S.G Ltd. (hereinafter: “Sweet Victory” or “Our” or “We” or “Us”), are committed to protect your Personal Data. This Data Protection Policy explains how Sweet Victory collects, processes and stores the information from you or other data subjects through our website (hereinafter: “Website“).
As used in this policy, “Personal Data” or “Personal Data” means information that refers to, is related to, or is associated with an identified or identifiable individual or as otherwise may be defined by applicable law, such as a name, address, telephone number, e-mail address, information about activities directly linked to a person, such as that person’s location or IP information.
This data protection policy (hereinafter: “Policy“) may be revised or updated from time to time, and such changes shall come into effect from the moment Sweet Victory publish the new policy notifies you of such changes and/or updates, either by email, notification on our website or any other reasonable manner.
For any questions regarding the collection, processing or use of Personal Data relating to you and exercising your data subject rights (all as explained below) please contact us, at our dedicated data protection and privacy e-mail address: email@example.com.
General Principles of Our Data Protection
Sweet Victory is committed to ensuring that your Personal Data and the privacy of your data is protected according to the appropriate industry standards and practices in relation to the data we collect, and all in correspondence to Sweet Victory’s relevant legal obligations.
This policy explains your rights regarding the Personal Data Sweet Victory collects, processes and uses through the Sweet Victory Website, as well as Sweet Victory’s use of safeguards to protect these rights.
We collect and process your Personal Data in good faith, in a proportionate manner according to the declared purpose, and with the appropriate technical and organizational measures in line with the state-of-the-art measures, while taking into account the risks represented by our collection and processing and the nature of the Personal Data and data protected by us.
If any collection and processing of Personal Data will be carried out, in the course of Sweet Victory’s business and provision of services, by external data processors on Our behalf, Sweet Victory will require, within the framework of its contracts with such external processors, for them to comply with relevant legal data protection rules and legislation applicable to the services they provide to Sweet Victory, prior to the transferring your Personal Data and data.
Important note: please refrain from browsing our Website, sending us e-mail messages with queries or requests, or otherwise providing Us with your Personal Data, if you do not consent to the collection, use, processing or disclosure of this data as set forth herein.
Your Rights to Limit our Collection and Processing
You have certain rights in relation to the Personal Data that we hold about you, as detailed below:
- Consent – We will only process your Personal Data if you have consented to such processing, unless We are otherwise legally authorized or obliged to collect and further process Personal Data relating to you any of your rights below.
If we process data solely based on your informed consent, We will only use the data for the purposes stated in the consent procedure and within the scope outlined below.
- Withdrawal of consent – You may revoke or withdraw your consent at any time by contacting and requesting so by contacting us at: firstname.lastname@example.org, and We will stop processing your Personal Data unless We are legally obliged or authorized to continue processing your information, including for ongoing legitimate business interests, which we will notify you in our response to your request, where applicable.
- The Right of Deletion (“To be Forgotten”) and Right of Rectification – You may also request the erasure or correction of all or part of your Personal Data that is held by Sweet Victory
Upon your request, Sweet Victory will accommodate your request and delete (or alternatively equivalently irreversibly anonymize) or correct your Personal Data or remove from part or all of our records, as per your request, as soon as reasonably possible and when technically feasible, and unless there is an overriding legal interest or other authorized basis for the continuation of the processing of your Personal Data, which we shall notify you in response to your request.
Please be aware that in the event of deletion or correction of Personal Data upon your request, Sweet Victory may not be able to further provide you the services you applied for through the Website, in whole or in part and by requesting such deletion/correction, you irrevocably agree and waive any claim against Sweet Victory’s inability to provide the services through the Website.
- Personal Data of children and minors – We do not knowingly collect or process Personal Data relating to children and minors under the age of 16 years unless We are legally obliged to do so by an authorized court or governmental authority order or writ or parental consent.
If we become aware that Personal Data was transferred to us or collected by us relating to children and minors under the age of 18 years without the informed consent of a parent or legal guardian or according to a legal obligation from a court or governmental authority, We will delete such Personal Data without undue delay.
If the request for erasure of data relates to the Personal Data of a child or minor, please attach to the request adequate proof of your status as parent or guardian of the child or minor.
- Transparency and Data Portability. You are entitled to ask us for information about what type of Personal Data about you has been collected by Sweet Victory
You are also entitled to obtain (in a commonly used and machine-readable form) and reuse your Personal Data as you have provided to us (following your consent or to allow us to perform services under a contract) and which We process, for your own purposes across different services and free of charge, subject to technical feasibility and lawfulness considerations.
- Automated decision-making. Sweet Victory shall not intentionally take any potentially damaging decision concerning you because of using automated processing and decision-making operations without human intervention; and commits that where such will be implemented, we will give you the opportunity to obtain human intervention in such a decision, express your point of view, and obtain an explanation of the decision.
- In the implementation of these data protection rights, Sweet Victory is committed to providing a timely and transparent response to your requests and upholding your right to contact us on data protection and privacy protection manners at the dedicated e-mail address: email@example.com.
- Any data subject right you wish to uphold by Us, may not be fulfilled if you do not provide Us with relevant and/or sufficient information required for us to identify you as the data subject of said Personal Data, and we shall inform you accordingly in such an event.
- If you believe Sweet Victory has violated any of your data subject rights, you are entitled to:
- For EU countries – file a complaint to the Data Protection Authority in your jurisdiction of residence about the alleged data protection breach;
- file a lawsuit to the courts of the state of your residence.
Information We Collect:
The Personal Data collected and used by Sweet Victory is limited strictly to any data which is necessary for us to provide you with services you request in the course of our ongoing business while operating under our relevant legal and data protection legislation and regulations obligations, as detailed herein below:
- Collection of Personal Data Occurs when You:
- 1. Contact us via our designated support e-mail address or electronic form through our “Contact Us” page of our Website
- What is the Personal Data We collect and when do we collect it:
- 1. When you contact us through our contact details on the Website, we may collect the following fields of Personal Data:
- 1.1. Your full name
- 1.2. your email address;
- 1.3. the Content of your inquiry and/or request, and any Personal Data you elect to input therein;
- 2. When you browse through our websites and/or specific pages/portions thereof:
Automated Browsing Data which includes information about your computer, your web browser, mobile device, operating system, IP address, your location, website visit history including keywords and searches;
Why Sweet Victory Uses your Personal Data:
Sweet Victory uses data and Personal Data for the following reasons:
- to ensure that content in the website is presented in the most effective manner for you, including personalization;
- to process your contact request when you contact us through e-mail and/or to revert back to you accordingly;
- For performance of analytics such as trend analysis, site administration, statistical analysis of usage of the site, enhance and review integrity and stability of the website and to study trends in order to improve our website;
How you can assist Protecting your Information
If you receive an email that looks suspicious, e.g. refers to an order you do not recall making or requesting information already provided, or you have doubts as to whether an email was actually sent by Us, please contact us and report this.
Please note that we will never ask for payment method details via email and/or any personal information.
Similarly, when We promote our offers, we do so by using the same email account through which we send you all our marketing communications, and we will not ask for your personal information in these emails.
How We Protect Information:
We implement generally accepted industry standards to maintain the safety of your Personal Data against loss, alteration, theft or access by unauthorized third parties when you enter, submit, or access your Personal Data and once we receive it. However, no method of transmission over the Internet, or method of electronic storage is flawless or entirely secure.
Therefore, while we strive to protect your Personal Data via the aforementioned technical and organizational means, we cannot guarantee its absolute security. What we can guarantee is that we will not sell, share, transfer or use the data We collect from you for purposes other than those purposes stated expressly herein above.
The above notwithstanding, Sweet Victory will not be liable or responsible for any damage or loss resulting from the improper use or any breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data.
Third Party Sites:
Our website may contain links to third party websites, payment portals or social media platforms. We have no control over third-party sites or services, and all use of third-party sites or services is at your own risk. Sweet Victory cannot accept responsibility for the privacy policies of any such third party sites and such third-party websites are governed solely by such third parties’ privacy policies and you are advised to be careful and check any such third party’s privacy policies and compliance with laws, prior to supplying them with any of your personal data to them.
Sweet Victory is not responsible for content available by means of such third party sites. Sweet Victory does not endorse any information or products offered by third parties and we urge our users to exercise caution in using third-party services.
Data retention and deletion
Sweet Victory deletes (or equivalently irreversibly anonymizes) personal data where the purpose for which the data was being collected or processed ceases to apply, except the extent it is prohibited to do so under local, Israeli law (and in such cases only to the extent required) and/or or if applicable data protection rules require us to delete such personal data
However, we shall keep your personal data as long as necessary to follow-up on your inquiries and/or requests via our Website, and/or for legitimate and essential business interests, such as following up on any business opportunities you propose or raise in your inquiries, making data-driven business decisions about new features and offerings, and always when required for complying with our legal obligations, and resolving disputes, such as the following circumstances:
- If there is an unresolved issue relating to your account, such as an outstanding credit on your account or an unresolved claim or dispute we will retain the necessary personal data until the issue is resolved;
- Where we are required to retain the personal data for our legal, tax, audit, and accounting obligations and/or regulatory requirements, we will retain the necessary personal data for the period required by applicable law; and/or,
- Where necessary for our legitimate business interests such as fraud prevention or to maintain the security of our users.
- Where necessary to cooperate with a criminal investigation by law enforcement agencies and/or any regulatory authority’s inquiry and/or audit, in each such case solely subject to extent request and as per the applicable law.
The above notwithstanding, there are types of Personal Data we process will only be kept for as long as the original purpose of processing persists, such as your e-mail address and other information sent as part of a request or when browsing as long as your consent to usage of Cookies and Tracking Tools is intact. Where such a request has been withdrawn or sufficiently fulfilled and no longer relevant we shall delete such as part of our commitment to data minimization.
Note: We will also delete your Personal Data upon your expressed request to fulfill your data subject right, provided you forward such a request by e-mailing us, as mentioned above.
Transfer of Your Information:
We do not sell, trade, or otherwise transfer to outside parties your Personal Data, except as specifically stated in this Policy.
The above statement does not include trusted third parties who assist us in operating our services, conducting our business, or servicing you, and prior to such transfers those parties are contractually obliged to keep your Personal Data confidential and to not use it for any purpose other than to fulfill their obligations to us in relation to the provision of our services to you.
Be advised that notwithstanding, We may share you information with subcontractors and other partners that are located in countries abroad which do not necessarily have the level of data protection in your jurisdiction.
We transfer our customers’ Personal Data outside of the EEA or a Country subject to a decision by the European Commission that the country to which our customers’ data is transferred provides an adequate level of data protection, only if it is strictly necessary, and in any such case we will execute EU approved model clauses in relation to the protection of our customers’ data prior to such transfers.
Notwithstanding the above, all our subcontractors and other third parties will be subject to contractual obligations limiting their use of your Personal Data and subjecting their activities to the applicable data protection and privacy legislations applicable to your personal data and further to the foregoing all our subcontractors will be subject to non-disclosure and non-use obligations.
Be advised that We will fully cooperate with any law enforcement authorities or court order requesting or directing us to disclose the identity or behavior of any user suspected to have engaged in illegal behavior and thereby we may also release your information when we believe release is appropriate to comply with the law, enforce our site policies, or protect ours or others rights, property, or safety.
However, non-personally identifiable user information may be provided to other parties for analytics, trends study, or other uses, as previously established is one of the purpose of use herein above.
We may revise this Policy from time to time, and such changes shall come into effect from the moment Sweet Victory notifies you of such changes and/or updates, either by email, on the websites or in some other reasonable manner.
When we make material changes to this Policy, we’ll provide you with prominent notice as appropriate under the circumstances, e.g., by displaying a prominent notice within the Sweet Victory website or by sending you an email message to that effect.