Privacy Notice

Recently Updated: February, 2021

This Privacy Notice (“Privacy Notice”), is an integral part of our Terms and Conditions [Insert link], and governs the processing and transfer of personal data collected or processed by Hydroponics Network Ltd. ("Hydroponics Network Ltd." or "Company") in connection with its sites, Services and the Platform.

Any capitalized terms not defined herein shall have the meaning ascribed to them in the Terms.

If you choose to use the Site, App, Services, and interact with the Platform, or otherwise provide data to us, you acknowledge and agree to the use of such data in accordance with this Privacy Notice, and undertake that you will comply with the provisions herein. You may not use the Site or Services or submit any data through them if you do not agree to any of the terms below. This Privacy Notice shall not be construed in any manner to derogate from the Terms or any other agreement or understanding between Hydroponics Network Ltd. and you.

Please note, that the Site and the Services may contain links to other websites, products or services offered by third parties, which are not governed by this Privacy Notice. This Privacy Notice does not apply to the practices of entities which are not controlled by Hydroponics Network Ltd .. 

THE HIGHLIGHTS:

  • You are not required by law to provide us with any Personal Data. Sharing Personal Data with us is entirely voluntary. Some of our Services however, may depend on providing us with certain Personal Data, as specified below.

  • You may not share Personal Data about other people with us which you are not authorized to share or use.

  • In general we use Personal Data (1) in order to provide our Services to our Users and clients, based on our contractual relationship with them; (2) where we have a legitimate interest to do so (for example for website's security purposes and fraud detection); (3) where there is a legal obligation imposed on us or to protect our legal rights; and (4) otherwise with your consent to do so.

  • Children under the age of 16 are not permitted to use the Site and Services or provide us with any Personal Data without the consent of a parent or guardian.

  • You may be entitled under applicable law to request to review, amend, erase or restrict the processing of your Personal Data. Please note that in case you request to erase or restrict the processing of your Personal Data, your use of the Site and Services may be restricted or disabled.

  • We do not sell, trade, or rent Users' Personal Data to third parties. We only share Personal Data with third parties in connection with the provision of the Services to our Users, or other limited circumstances as specified herein. If you have any questions or requests regarding the processing of your Personal Data, or would otherwise like to contact us in connection with this Privacy Notice, please send us an email to: [Insert address].

 

[We recommend creating a “layered” structure for the privacy notice, meaning that the below headlines highlighted in green are used as links leading to the information included in each section, for the reader's convenience]

  1. What data is collected by Hydroponics Network Ltd. and for what purposes?

Hydroponics Network Ltd. collects both personal and non-personal data.

“Personal Data”, means information which identifies or may identify an individual, including first and last name, phone number, email address, pictures, billing information, unique online identifiers etc.

Personal Data does not mean information about a company or organization (such as contact information), but does include information about such corporate entity's employees and consumers.

“Non-Personal Data”, means non-identifiable aggregated data, such as technical data transmitted by the user's device and aggregated use of the website by the general public. This data is not used to identify individual Users.

Non-Personal Data Processed by Hydroponics Network Ltd.

We collect non-personal data regarding use of the Site and the Services, such as the scope, frequency, latency, pages accessed and viewed, interactions with content and materials displayed through our Services, and other technical information regarding the device used to access the Services. This information is not used in order to identify any specific User.

Non-Personal Data is used mainly for click stream analysis in order to maintain and develop our Site and Services, including among others, in order to measure and understand the level of engagement with the Services, for general business analytics for ensuring the technical functioning of our network, to help prevent fraudulent use of the Services and for developing new services and features.

Personal Data Processed by Hydroponics Network Ltd.

We collect the following Personal Data, and process it in accordance with the purposes and legal basis specified below.

Type of Personal Data

Purposes of Processing

For EU persons - Legal Basis under the GDPR

Personal Data provided during registration and creation of User's Account

Name, email address, phone number photo.

[Please confirm / add]

To provide the Services to the User.

To resolve any disputes, communicate with you regarding customer service and support issues, and to respond to questions or comments and help resolve any problems.

Performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.          

Necessity of processing for the purposes of our legitimate interests.

Data regarding use of the  Site or Platform

Profiles and pages you interact with, people, groups and content you search on the  Site, or Platform, content you upload to your Profile or otherwise share through the Site, or Platform, interactions made with other Users on the public interfaces of the Site, or Platform.

To provide the Services to the User.

To operate, provide, maintain, protect, manage and improve the Site or Platform.

To prevent and address potentially prohibited or illegal activities, fraud, misappropriation, infringements, identity thefts and any other misuse of the Site or Platform or the Services and to enforce the Terms, as well as to protect the security or integrity of our databases and the Services, and to take precautions against legal liability.

Performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.

Necessity of processing for the purposes of our legitimate interests.

Newsletters and Marketing Materials

In the event you sign up to receive our newsletter or other marketing materials, you will be requested to provide your email address.

[Although not currently an option in the website, this is customary in case you wish to add the option in the future]

To send you our newsletter and other marketing materials.

 

Your consent. 

You may easily unsubscribe at any time by contacting us at [Insert address], or by other means we will make available (eg “unsubscribe” link within the applicable email).

Online Identifiers

Online identifiers such as your IP address. This data might be collected by us or by our service providers.

To operate, provide, maintain, protect, manage and improve the Platform and our Services, their content and the way in which we offer them; for auditing and tracking usage statistics and traffic flow.

Necessity of processing for the purposes of our legitimate interests.

User's Content

If you choose to share any User Content on the Platform, such content will be collected by us as well as shared with other users of the Platform and our affiliates and will be considered as non-confidential.

To provide you with the feature of a social network of growers, and for the provision and development of our Services.

Performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.

Your active consent when choosing to share your content voluntarily.

Special Categories of Personal Data

“Special Categories of Personal Data”, means any Personal Data constituting or revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data, data concerning a person's health or data concerning a person's sex life or sexual orientation.

While we do not intentionally collect Special Categories of Personal Data, the Platform may contain such data uploaded and shared by Users, and constituting User Content. As further specified in our Terms, you may not upload or share any Personal Data you are not permitted or authorized to share, and you are responsible for ensuring that data shared by you on the Platform does not infringe the rights, including privacy rights, of others.  

 

How Personal Data is collected:

Certain data is collected automatically by using cookies and other similar tracking technologies, while other data is provided by you voluntarily and actively, such as when you upload content to your profile.

Do Not Track Disclosure:

The Platform does not respond to Do Not Track signals. For more information about Do Not Track signals, please see: http://www.allaboutdnt.com/ .

  1. Does Hydroponics Network Ltd. Use Cookies?

Yes, we use cookies and similar technologies. The way in which we, and third parties placing cookies in connection with the Services, use cookies and collect data, is explained in our COOKIE POLICY [Insert Link].

  1. Will Hydroponics Network Ltd. Share Personal Data with Others?

We do not sell any personal data to non-affiliated third parties for their marketing or business purposes.

Non-Personal Data

Non-Personal Data, aggregate and statistical or otherwise anonymized data may be shared without limitation with third parties at our discretion.

Personal Data 

We may share Personal Data only under the following limited circumstances:

  • With trusted partners and service providers who assist us in operating the Services and conducting our business, such as fraud prevention, bill collection, marketing, account maintenance and technology services.

  • With our affiliates and connected companies, such as subsidiaries, sister-companies and parent companies.

  • With third parties if necessary to comply with applicable law, a legal or regulatory requirement, for the administration of justice, to protect your vital interests or the vital interests of others, to protect the security or integrity of our databases or the Services, to take precautions against legal liability, to enforce our agreements and policies, or in the event of a corporate sale, merger, reorganization, dissolution or similar event.

  • Other third parties with your consent to do so. However, if we do share your information based on your consent, following such disclosure, the information shared will be subject to such third party's privacy practices which might differ from our practices detailed herein.

In addition, please note that when you share content on the Site or Platform, such content and your interaction with it will be publicly shared on the Site or Platform and outside the Site or Platform.

  1. Retention and Security of Data

We retain the data we collect solely for as long as required to fulfill the purposes for which it was initially collected as specified above, or for longer periods in the event we are required to do so in order to comply with legal, tax and accounting requirements . In addition, we will retain information we believe is needed in order to protect our rights and interests in accordance with applicable laws.

Non-Personal Data and statistical anonymized data may be retained by us without limitation of time.

 

We employ security measures to protect your Personal Data from unauthorized access, use, disclose or accidental loss and destruction. Note that, 100% security can never be provided, thus we will not be responsible for unauthorized acts that are beyond our control. In the event of a data incident relating to your Personal Data, we will take reasonable efforts to provide notification (in the event required under applicable laws).

  1. Will Hydroponics Network Ltd. transfer Personal Data internationally?

Our databases are currently located in ____.

If you are residing in a country outside the EU, while accessing or engaging with the Services, the international transfer of Personal Data is likely to occur.

Additional information for EU Residents

In the event that you are a resident of the EU, please note that where possible, we implement appropriate safeguards to protect data transferred as well as your rights in connection with such data.

Please be informed that the international transfer of Personal Data is associated with certain inherent risks, such as accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to Personal Data transmitted, stored or otherwise processed.

Some of our processing activities take place in Israel. The European Commission has decided that the State of Israel ensures an adequate level of privacy and data protection, therefore, in accordance with the GDPR, the transfer of Personal Data from the EU to Israel is lawful and does not require any specific authorization.

Any other transfer of Personal Data originating from the EU to a third country (other than Israel) shall be made in accordance with applicable law, including by providing adequate protections, or otherwise implementing appropriate safeguards to ensure the protection of our Users' rights.

  1. Persons under 16

If you are a User, please be aware that you may not use or interact with the Site, App or Platform if you are a person under the age of 16, without the appropriate consent of a parent or guardian.

  1. How Can I Review and Control My Personal Data?

You may review your Personal Data by accessing your Account on the Site or App. You may also review additional data not available on your Account by contacting us at [Insert address].

In the event any Personal Data is incorrect or outdated, you may update and correct such data by providing us with appropriate notification or correcting the data directly on the Site or App, as applicable to you.

If we are not able to provide you with the information that you have asked for, we will attempt to explain the reasoning behind such inability and inform you of your rights in such a case. We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any such information in accordance with applicable laws. In addition, the process of locating or deleting the data, as applicable, may take up to thirty (30) days (following our receipt of the validation proof that we requested) in accordance with applicable laws. Please note that, data, privacy and other related laws in your jurisdiction may provide you with different or additional rights related to the data we collect from you, which may also apply.

Additional Information for EU Residents

In addition to the rights specified in the general Privacy Notice, if you are an EU resident, please note that you are also entitled to the following:

  • Right of erasure and restriction. You may also be entitled to request the erasure or the restriction of your Personal Data, and we will comply with such requests, to the extent required under applicable law. 

  • Portability of Personal Data. To the extent relevant to you and to the Services, you may be entitled to request the portability of your Personal Data, and we will comply with such requests, to the extent required under applicable law. 

  • Filing a complaint to a Supervisory Authority. You are also entitled to file a complaint with the appropriate supervisory authority in connection with concerns you may have with regards to your privacy and Personal Data.

  1. Changes and Updates

We may update this Privacy Notice from time to time. Modifications to this Privacy Notice will be posted on the Site, and shall be effective as of the date in which they are posted on the Site. We encourage you to periodically review this Privacy Notice to stay informed about our practices related to the collection and processing of Personal Data.

  1. Contact us

If you have any questions or concerns regarding privacy issues, or if you wish to be provided with any other information related to our privacy practices, please contact us at:

Hydroponics Network Ltd [Insert email address]

  • Insert physical address]

For EU residents - [Insert physical address in the EU]

 

 

 

Hydroponics Network Ltd. Cookie Policy

 

Avner - please note, this cookie policy can be part of the general privacy notice, but also separate links should be available on the website (ie there should be 3 links on the website: (1) Terms; (2) Privacy Notice; and (3) Cookie Policy

In addition the website should include the following banner for people accessing it from the EU:

“This site uses cookies for functional, operational, analytical and advertising purposes. Please refer to the Cookie Policy [Add link] for more information. ”

 

We recommend creating a "layered" structure for the cookies policy, similar to the privacy notice.

About this Cookie Policy

This Cookie Policy explains what cookies are and how we and third parties use them. For further information on how we use, store and process Personal Data, see our Privacy Notice: [Insert Link]

  1. Cookies and Similar Technologies

    1. A cookie is a small text file that is placed on the browser of your computer or mobile device (or other end device), by websites you visit and applications you use. Other automated means often used on websites and applications are Pixel tags (also known as web beacons or clear GIFs). Pixel tags are typically transparent graphic images placed on a website. These pixels are used in combination with cookies to measure the actions of visitors on the website.

Most websites and applications use cookies and other automated means to collect certain data and facilitate services. Cookies are typically used in order to make websites function, or function more efficiently, make your experience when browsing the website or application more enjoyable and smooth, to remember your preferences, to autocomplete details so you do not have to insert your full details every time you log in (such as user name and password), to tailor content and information that is displayed to you and otherwise work to personalize your experience of the website or application. Cookies are also commonly used as tools enabling websites and applications owners to better understand the use of their products and services, to conduct business analytics and to engage in advertising activities for their business purposes or on behalf of third parties. 

  1. There are different types of cookies. Some cookies come directly from the website or application you are browsing and others come from third parties which place cookies on such site. Such types of cookies are commonly categorized as "First Party Cookies" and "Third Party Cookies", respectively.

  2. Cookies can be stored for varying lengths of time on your browser or device.
    "Session Cookies" are limited to the duration of your visit to the relevant website or application, and are terminated when you exit the website or application. "Persistent Cookies" will remain stored on your computer or device until deleted or until they reach their expiry date.

  1. Categories of Cookies

    1. Strictly Necessary Cookies - These cookies are necessary to enable the communication between the user's device and the website or application, or to provide the user with services requested by him / her, such cookies are used for the sole purpose of carrying out a transmission of a communication over an electronic communications network, or to allow the provider of an online service to provide its services as explicitly requested by users.

    2. Functionality Cookies - These cookies allow the website or application to remember choices the user made (such as username, password, language preferences, or region) and provide enhanced, more personal features, to improve the user's experience on the website or application.

    3. Performance (Analytic) Cookies - These cookies collect information about how visitors use the website or application, such as which pages visitors go to most often and if they are likely to get error messages from certain pages. These cookies collect aggregate information that does not identify a specific user personally. These cookies are used to improve how a website or application works, analyze use patterns of the website or application, and assist the provider to maintain and improve its services.

    4. Advertising (Targeting) Cookies - These cookies are used to deliver personalized advertisements to the user. Such cookies may be used to analyze a user's preferences in accordance with the contextual information about the user's activities on the website or application (for example, if a user is surfing a webpage displaying an article about a sporting event, cookies may be used to display to the user an advertisement associated with sports fans), or to correlate between a user and information about such user collected from other websites or applications (for example, to display to the user an advertisement associated with sports fans based on the user's profile in other websites or applications). These cookies are used to promote advertising campaigns of website and application owners or those of third parties, as well as help measure the effectiveness of an advertising campaign.

Advertising cookies are usually placed by advertising networks, which connect between the relevant advertiser and the location of publication of the advertisement.

  1. What Cookies do we use and what Information is collected using Cookies? [Please review and confirm]

    1. Cookies used on the Platform– the Platform contains both First Party Cookies and Third Party Cookies, Strictly Necessary Cookies, Functionality Cookies, Performance (Analytic) Cookies, and Advertising (Targeting) Cookies.    

    2. information collected through on our Site through the use of cookies includes:

  • Information about your operating system and device;

  • Webpages accessed within the Platform, the link that led you to the Platform, dates and times you accessed the Platform, event information (eg system crashes) and general location information (ie city or region). 

  • Information provided on the Platform  by Users in order to streamline the User's experience and prevent user from having to re-enter information during the next visit to the Platform;

  • Number of visitors on the Platform and which webpages have been viewed;

  • Advertising user ID and information associated with targeted advertising. 

  1. How To Manage Cookies

If you do not want cookies to be placed on your device when browsing the Platform, you can adjust your browser settings to manage or reject such cookies, or to notify you when a cookie is being placed on your browser. These settings are usually found in the 'Options' or 'Preferences' menu of your Internet browser. For more information on how to change your browser settings, click on the Help section of your Internet browser. Most Internet browsers also allow you to see what cookies are currently stored on your device and selectively delete them as you wish.

See below links to common browsers enabling the control of cookies:

Browser Type

 

Chrome

https://support.google.com/chrome/answer/95647?hl=en;

Firefox

https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences;

Opera

https://help.opera.com/en/latest/security-and-privacy/;

Internet Explorer

https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies;

Safari

https://support.apple.com/en-il/guide/safari/manage-cookies-and-website-data-sfri11471/mac;

Edge

https://support.microsoft.com/en-us/help/4027947/windows-delete-cookies

 

Please note however, that if you choose to disable certain cookies, some features of the Platform  may not operate properly and your online experience may be limited.

  1. Changes and Updates

    1. We may update this Cookie Policy from time to time. We encourage you to periodically review this Cookie Policy to stay informed about our use of cookies, the information we collect via cookies, and any updates in relation thereto.

    2. We will post any changes to this Cookie Policy on the Platform.

  2. Cookies used on the Platform:

The following cookies are used on the Platform: [Please complete]

First Party Cookies

Cookie category

Cookie name

Purpose

Strictly Necessary cookies  

 

 

 

 

 

 

Functionality cookies

 

 

 

 

 

 

Performance (analytic) cookies

 

 

 

 

 

 

Advertising (targeting) Cookies

 

 

Other

 

 

 

 

 

 

 

 

 

THIRD-PARTY COOKIES

Cookie category

Name of third party

Cookie name

Purpose

Strictly Necessary Cookies

 

 

 

 

 

 

 

 

 

Functionality Cookies

 

 

 

 

 

 

 

 

 

Performance (analytic) cookies

 

 

 

 

 

 

 

 

 

Advertising (targeting) Cookies