The date of the last effective update is Dec 1, 2021.
SIRABCP Inc is referred to as SiRA or our or us or we.
www.sirafly.com and www.sirabcp.com are referred to as Site.
An end-user of our Site is referred to as you or your(s) or yourself.
Personal identifiable information is referred to as PI
The words “process”, “collect”, “gather”, “utilize”, “share”, “use”, “treat”, “disclose”, “divulge” and analogous shall be related to your PI and alternative data collected from our visitors and /or users, such as cookies.
The SiRA team does every possible effort to keep your trust; and thus we adhere to these principles as follows, in order to defend your privacy:
- SiRA does not rent or sell your PI.
- SiRA does not divulge your contact information to third parties or other users without your consent.
- Any PI that you give to SiRA will be protected by industry-standard technology and codes of behavior.
For purposes of this Policy, the Site shall be the initial point of contact between you and SiRA and will serve as the initial point of collection of any personal data you may provide us.
To use the Site, you may need to disclose some of your PI to us, which may include information such as your forename, surname, mobile phone number, IP address, and email. Moreover, our third-party payment processing agents may also require the collection of sensitive financial information of our users (e.g. credit card and payment information). If you would prefer not to reveal part or all of your PI to us, we do not guarantee that you will continue to enjoy our services fully.
Purpose of collection
For us to provide our services, and to use and/or offer the products and services of our affiliates, clients, and third-party contractors, there is a necessity for us to store, use, combine, integrate, disclose, process and confirm the transference of your PI, either to other legitimate third parties or amongst our affiliates.
The purpose of gathering, utilizing, and disclosing your PI includes, but is not limited to: (i) verify your e-mail address; send password retrieval links and other account notices; (ii) provide updates related to our services, Site, and our affiliates’ products and services; (iii) contact and interact with other members of our Site; (iv) improve your user experience, offer newsletters, offer promotions, surveys, send service-related announcements and contact you about inquiries for our services.
The Site might provide an option of using your social media and other third-party credentials (e.g. Facebook and Google) to execute single-sign-on and interact with other users in the Site. Thus, by this, we will collect your PI as given by such third-party platforms, but never more than the PI these platforms disclose. For more information, please read the terms and policies of such platforms.
Management of your PI
As our user, you will normally be able to manage and select the quantity and type of PI you may reveal to us when using our Site, usually in your account settings. We constantly try to develop our user experience, and continuously work to: (i) notify you concerning the ways in which your personal information may be utilized and shared (overseas included); (ii) preserve the security and protection of your personal details; and/or (iii) enforce the accessibility of your personal information in order for you to exercise your right of correction of said information.
In order to execute your privacy rights, kindly get in touch with us as instructed in the contact section of the Site. Your privacy request must include, at the least, the following information: (i) your complete name, address and/or e-mail address for us to inform you of the response to your request; (ii) attached documents testifying your identity; and (iii) a lucid and brief description of the PI with regard to which you seek to enforce any of your privacy rights.
Industry-standard technology and codes of behavior are utilized by us to guard your registered user information and PI. We employ and maintain rational security procedures to protect our databases and PI records from unlawful access, attainment, destruction, employment, alteration or revelation. However, please keep in mind that the Internet and related information distribution channels are not inherently safe or mistake-free means.
SiRA does not knowingly collect any kind of information from persons under the age of thirteen (13). You must at least be eighteen (18) years of age, or older—to purchase our products and/or to use our services.
We, or our affiliates, clients, contractors, licensors, officers, agents, and/or representatives, reserve the right to allow access to any of your PI when we think it is reasonably important or when you violate the terms mentioned in this policy. Hereafter, we will have the right to disclose any or all gathered PI and/or data when the following circumstances arise: (i) if necessary under applicable law; (ii) in reply to a legal demand or subpoena from an agency of the law ; (iii) to protect ourselves and our affiliates from any legal third party claims and procedures that may be brought to us (inclusive of takedown notices); and/or (iv) to prevent or cause cessation of any undertakings that may be construed by us as having the ability to be or cause a predicament or hazard to us.
Occasionally, we will ask you for express permission and approval to receive electronic messages in electronic format which are then sent to an electronic address and that contains a message asking recipients to participate in commercial activities such as newsletters, purchase of products, services, and invitations to participate in surveys.
Our Site may present our commercial partner’s hyperlinks as well as those of other third parties. It is important that you consider that we are not responsible for data practices that are conducted by third parties or the privacy thereof and that the way in which such third parties may assemble, process, handle or utilize your PI is not in our control. When such a link is used to go from our Site to an outside website, our Policy and Terms are redundant and your further browsing is at your personal and ultimate risk.
Periodically, Google Analytics may be employed by us, alongside AdWords and AdSense tracking codes, in conjunction with remarketing codes and software tools of other third parties. This is for the purpose of collecting marketing analysis of the method in which you browse our Site. This gathered information is anonymized, that is, it is impossible for it to be used to track back individual persons.
We employ third-party payment processors in order to provide and manage transactions undertaken through the Site. The payment processors we use are PayPal and Stripe. The management of your payments to us is subject to the fees, terms, and circumstances, and privacy policies of such third-party payment processors and SiRA shall not be held responsible for any and all outside fees, errors, and delays by such payment processors.
SiRA has its head offices in Delaware, with our people working from USA, Israel, and Ukraine. The servers that may process your PI are situated in the USA. If you are accessing our Site, you must know that you are maybe conveying your PI to Israel and, thus, you hereby permit such transfer, if any. Please be advised that its authorities may have personal data and privacy laws that differ from those of yours, with different levels of security and rights enforcement.
Upon the case where SiRA particularly undertakes the process of personal data that has been duly disclosed by you to us, and that is subject to national legislation that implements the EU Data Protection Directive (95/46/EC), by clicking the “I Accept” button or otherwise accepting the terms and conditions of our services through a clickable action or similar action, you hereby acknowledge, agree and accept to such transfer.
Notice to Israel Residents
SiRA’s business operations are located in Israel. In compliance with Israel’s Privacy Protection Law, (5741-1981), we are responsible for any and all factual or suspected security data breaches into our PI databases and are also required to notify our Israel customers of any such factual or suspected breach (by email and/or post). For purposes of this Policy, a breach of security shall be defined as non-authorized access — or authorized access — of PI for a non-legitimate purpose, which thereby creates a contingency regarding the safety, confidentiality, or access of such PI.
Periodically, and at the final discretion of ourselves, we may update, change, suspend and/modify or our Site, our services, this Policy, and/or our Terms, in whole or in part. We hereby reserve such right in order to operate our business and protect ourselves. Your use after any changes indicates your acceptance thereof and we will post a notice regarding such changes on our Site, and may also write an email to you or otherwise notify you.
PI access, update and delete
You can manage and update most of your personal information via the Account/Profile Settings area on the website. You have a right to ask us to erase or receive your PI stored on our servers. Please contact us via email and we will be happy to assist.
If you have any questions or queries about us, our Site, our Services, or these Terms, please contact us as indicated on our contact page: www.sirabcp.com/contact.