Privacy Policy

The following document constitutes the privacy policy of the KEDEM SPA HOUSE spa areas owned by Spa and Wellness Ltd. and the line of cosmetics, body, and additional complementary products (hereinafter: "the Network"), including the Network's customer clubs and e-commerce sites.

Entry or initial use of any of the digital assets (without derogating – the Network's website, the Network's spa area websites, the Network's customer club) (hereinafter: "the Digital Assets") of the Network constitutes agreement to the terms of use. If the user does not agree to these terms, they must immediately cease further entry and use of the Digital Assets.

Privacy Policy

  1. General
    1. The Network respects the privacy of its users and customers and all users of the services offered and provided by it (hereinafter: "the User" and/or "the Users") within the framework of the Network's digital assets and related services. The Network places great importance on protecting users' privacy and is committed to protecting the personal information they share with the Network, and to that end, operates according to the provisions of the following privacy policy and applicable law.
    2. The Network has several branches in Tel Aviv and Herzliya, and should additional branches open, the terms of use and policy will apply to all of them accordingly.
    3. The Network respects the privacy of its users and is committed to adhering to accepted privacy protection rules in Israel. Use of personal information provided by users or collected about them will be made solely in accordance with this privacy policy or as required by law.
    4. 'Personal Information' in this privacy policy means any identifiable information about the user that will be provided or collected about them during their use of the Digital Assets, for registration for the offered services, as well as any identifiable information about them that will be collected about their use of the Digital Assets.
    5. The purpose of this privacy policy is, among other things, to explain the Network's practices regarding users' privacy and how the Network uses personal information provided to it by users or collected by it as part of their visits and uses of the Digital Assets.
    6. This privacy policy applies to all of the Network's digital assets, as applicable, but in cases of specific activities and services (for example, a special sale held on one of the digital assets), additional and different rules may apply, and a specific dedicated policy regarding the provision, collection, and use of personal information may be published alongside them.
    7. For the avoidance of doubt, the provisions of this policy document shall apply only to personal information, as defined in the Privacy Protection Law, 5741-1981 ("Privacy Protection Law"). If any information is collected about users in a way that does not directly identify them and constitutes unidentified or aggregated information, the Network shall be entitled to make any possible use of such information.
    8. This policy is intended for all genders and is written in the masculine form for convenience only.

 

  1. Information Collected
    1. The Network collects, receives, and stores the following types of information relating to users of the Digital Assets:
      • Technical information visible to the Network and/or provided by users during their use of the Digital Assets and the services offered therein, including before user identification, and including: 1. Information about user behavior – such as activity patterns on the Digital Assets, browsing hours, browsing path, visits to pages and products, usage habits. 2. Information about user devices – such as IP address (depending on the network, computer, or mobile device used for browsing the Digital Assets), device ID, browser type, and information about geographic location, all whether the device or any of its components are operating or off, depending on the device settings.
    1. Some of the services provided within the Digital Assets require registration, provision, and collection of personal information, whether during entry to the Digital Assets and any use thereof, or at the beginning and during the engagement period. The Network and any third party acting on its behalf and collecting information for it, collect, manage, and store personal information provided by users consciously and voluntarily during their use of the Digital Assets and the services offered therein. Personal information will be collected from the details provided by users as part of order placement processes, contact creation, registration process and personal account creation, service reception, participation in activities and joining customer clubs and/or any other process initiated by users or other services they chose to receive during their use of the Digital Assets, whether they finished entering the information in the relevant fields and submitted it or not. Such information may include:
      • Personal information such as full name, contact details (mobile phone and email), residential address, ID number, date of birth, gender, marital status, and in some cases, also wedding date and estimated birth dates.
      • When making an online purchase, we collect information necessary for the transaction. This information includes details of the products purchased (type, price, quantity), purchase date, and payment method details (without storing full credit card data). Benefits. 
      • Information within the framework of performing various actions and receiving services such as order details, purchased products, prices, discounts utilized, product returns and exchanges, credits, communication with customer service representatives, calls, recordings, surveys, queries, product returns and exchanges, execution instruction details, information about uncompleted actions (e.g., partial completion of an order form or any uncompleted purchase process), information about completed actions, as well as information about the use of payment methods issued by us (including information about adding payment methods to digital wallets or mobile devices), and any other information related to the use of the Digital Assets and the services offered therein.
      • Information within the framework of membership in the Network's customer club such as membership details, points accumulation, benefit redemption, purchase dates, spa areas where purchases were made, and shopping preferences.
      • Information received as part of using services of external third parties to the Network and/or campaigns, which have business relationships with the Network, such as shared customer clubs, credit cards with which the Network has an arrangement, and other commercial collaborations, including any information received from such third parties.
      • Social media information – if a user chose to provide information by granting access to a Google, LinkedIn, Facebook, or another platform account ("Social Networks"), they grant the Network permission to receive information details from those social networks subject to the user's settings on those social networks and/or their privacy policy.
      • Third-party information – if a user shared personal information with the Network about any third parties (for example, family members or friends for gifts or recommendations), the user must inform those parties before such information is provided to the Network, and obtain their consent to the provision of the information and the uses that will be made of such information in accordance with the provisions of this privacy policy. For the avoidance of doubt, users declare and confirm that they have and will have at all times all necessary consents for carrying out the above.
    1.  Users are aware that most of the information they provide and/or that will be collected about them is not required by law and is provided to the Network with their consent and free will, inter alia, so that the Network can provide them with certain services, and that they agree that the Network will store such information in its databases, as detailed in this privacy policy. Notwithstanding the foregoing, it is clarified that without providing some of the information, users will not be able to join the Digital Assets and/or enjoy some of the services offered therein. Thus, failure to provide required personal information (such as contact details, address, payment method details, etc.) will prevent the ability to register for services, place orders, receive invoices, join customer clubs, or enjoy personalized benefits; blocking cookies may impair the proper functioning of the Digital Assets and the personalized experience; refusal to consent to the use of technologies involved in self-checkouts may prevent the use of these checkouts.

 

  1. Use of Information 
    1. The Network and service providers to the Network use non-personal information (which does not personally identify users) for statistical, analytical, and research purposes, for customization, development, data refinement, drawing conclusions, and improving the Digital Assets and the services offered therein, as well as for the Network's advertising and commercial needs.
    2. The Network and entities engaged in data processing on behalf of and for the Network, or in providing other services to the Network, use personal information in accordance with the provisions of this privacy policy, and including for:
    3. Managing and operating the Digital Assets and the services offered therein;
    4. Providing the various services offered by us or by anyone on our behalf, including service providers and providers who assist in operating the services offered within the Digital Assets;
    5. Customizing, developing, and improving the Digital Assets and the services offered therein, including the possibility of creating services tailored to user requirements and expectations, as well as changing or canceling existing services, including the development, training, or retraining of machine learning models and the use of additional technologies for research and development purposes;
    6. Responding to users' questions regarding the use of the Digital Assets, as well as providing service and technical support, conducting surveys, responding to their inquiries, and maintaining contact with them;
    7. Decision-making, by a human factor or automatically, regarding users or other parties, including for examining a request to engage with the Network and/or its business partners and even before joining certain services within the Digital Assets, assessment and risk management checks, conducting surveys, and the like;
    8. Sending operational messages and notifications to users through various digital means, including by email, SMS messages, push notifications, etc., including regarding services provided within the Digital Assets, identification means and password recovery, surveys, delivery actions, reminders for incomplete transactions and items in the cart, execution confirmations, and the like;
    9. Transmitting various content, including marketing offers and promotional materials on behalf of the Network or its business partners, by any means of communication, including email, SMS messages, instant messages, calls, push notifications, etc., subject to user consent and the ability to unsubscribe from the mailing list at any time and thus not receive such promotional messages;
    10. Tailoring advertisements to be displayed to users when using the Digital Assets and other digital platforms across the Network;
    11. Issuing and sending digital documents to the Network's customers such as, but not limited to: order confirmations, digital receipts and invoices via SMS, and satisfaction surveys.
    12. Complying with legal requirements, including for legal proceedings, orders, including discovery orders or government, regulatory, and/or any other competent authority requests, as required or permitted by law;
    13. Detecting, preventing, or otherwise addressing any illegal and/or unauthorized use of the Digital Assets and/or in connection with the services offered therein, including in cases of fraud, deception, misuse, security and safety issues, and technical problems;
    14. Using artificial intelligence (AI) technologies for analytical, marketing, and automation purposes, including analyzing large quantities of information, identifying trends, personalizing content and products, and optimizing operational processes;
    15. For any other purpose required or permitted by law or as detailed in this privacy policy.
    16. For the avoidance of doubt, it is clarified that these entities involved in data processing as mentioned above act on behalf of and for the Network, and may include various service providers, cloud services, and other business partners who assist in operating the Digital Assets and the services offered therein, inter alia, to ensure their proper functioning, timely completion of user-requested actions, security, service improvement, and the like.
    17. Within the Digital Assets and as part of the services offered therein, and in order to register and use the personal account, users may be required to enter information such as ID card, username, membership number, and personal password. It is clarified that users must keep their username and password strictly confidential, and they undertake not to disclose them or allow them to be used by other parties. Users will be solely and entirely responsible for any use made of the Digital Assets and the services offered therein by them, on their behalf, or in their name, including through the use of their username and password.
    18. Users declare and confirm that all information provided by them or collected about them within the Digital Assets and the services offered therein is correct, reliable, and accurate, and that they use the Digital Assets and the services offered therein solely on their behalf and for themselves, except in cases where they have been explicitly and in writing authorized to do so by the Network.
    19. Users acknowledge and agree that personal information about them may also be transferred outside the borders of the State of Israel, including to corporations that own the Network, including for storage and processing in countries that do not provide the same standard of protection as that provided by applicable law in Israel regarding the privacy and security of users' personal information. Users explicitly approve and agree to the transfer of information provided by them and/or collected about them to these countries.
    20. The data and information collected or provided by users will be lawfully stored for the period required at the Network's discretion in its databases and for the purposes for which they were collected. The Network may record telephone calls with customer service representatives and retain correspondence conducted with them (such as chat, email, or messages), for quality control, training, service improvement, and documentation of inquiries. At the beginning of each call, a recording notification will be provided.
  2. Disclosure of Information to Third Parties
    1. Users' personal information will not be disclosed to third parties without their consent, unless otherwise permitted by this privacy policy. Notwithstanding the foregoing, the Network may share and transfer personal information about users to third parties from time to time, in the following cases:
    2. Upon receiving consent from users for such transfer;
      • As part of or in connection with the provision of services offered within the Digital Assets, including to service providers and vendors who assist in operating the various services offered on the Digital Assets (it is clarified that unless stated otherwise, these entities have no right to use the information beyond the purpose for which it was provided);
      • As part of the Network's collaborations with its business partners, including Network companies;
      • To respond to user support or service requests;
      • To enforce this privacy policy and/or the terms of use, including as part of an investigation of possible violations of the privacy policy or terms of use;
      • To detect, prevent, or otherwise address fraud, deception, misuse, security and safety issues, and technical problems;
      • To comply with legal requirements, including for legal proceedings, orders, including discovery orders or government, regulatory, and/or any other competent authority requests;
      • In any case where the Network believes that disclosure of information is necessary to prevent serious harm to the Network, other users, or third parties;
      • In the event that the Network transferred and/or assigned its activity, rights, or obligations to users to a third party, including within the framework of business negotiations, and in cases of transfer of shares in the Network or its main assets, if the transfer of information is necessary for performing such actions;
      • In any case where the information is transferred to corporations that own the Network, including for supervision, management, and ongoing operation purposes;
      • If it is statistical/aggregated information that does not directly identify users.
  1. Information Collection Technologies
    1. When using the Digital Assets, including through the Network's marketing campaigns on social networks, the Network may use automated tools and technologies such as tags, beacons, SDKs, pixels, and the like, as well as cookies, through which information about users' activity on the Digital Assets or other sites may be collected and accumulated.
    2. Cookies and pixels, in general, are tiny text files and graphic images, as well as code snippets that users' browser or platform create according to a command, and which are placed on the Digital Assets pages and allow to identify whether a certain action has been performed. When the user accesses the Digital Assets and/or any of the services offered therein, cookies and pixels generate a message about this action. Cookies and pixels are used to collect information and allow the Network to measure responses to activities offered on the Digital Assets pages, to improve, secure, prevent fraud, etc. Some cookies and pixels will expire when the browser or relevant application is closed, and others are stored on the user's platform memory or sent to the Network, including to service providers acting on behalf of and for the Network and even users' suppliers, for the purpose of providing the services offered within the Digital Assets. The Network or third parties operating the cookies and pixels may access their accumulated content from time to time and it may be stored on their servers.
    3. The Digital Assets use cookies and pixels to characterize their use and improve the user experience, by collecting data. These tools collect information about the use of the Digital Assets. This information includes, among other things, the users' internet service provider details, IP address, the location of the device used to access the Digital Assets, the times and methods of use of the Digital Assets, browser type, and additional anonymous details indicating how the Digital Assets are used. If personal information is collected through cookies and pixels, it will be subject to the provisions of this privacy policy and the Network will be entitled to use it accordingly.
    4. Some cookies and pixels are stored on the device and allow the Network to automatically activate certain features, as well as to facilitate and simplify the user experience of the Digital Assets and the services offered therein.
    5. Cookies and pixels help track visitor preferences and improve the user experience on the Digital Assets. For example, cookies and pixels allow saving the details entered by users into various forms, thereby saving time from re-entering details on the next visit, or identifying preferred products for users to display offers and recommendations.
    6. Within the Digital Assets, users' information is collected and used by various advertising tools from third-party advertising companies, which are embedded in the Digital Assets. The Network may share such user information with these third-party advertising companies and also receive such information about users from them, for the purposes detailed in this privacy policy above. 
    7. The Network uses digital analytics and measurement tools, including Business Intelligence systems, for data analysis and deriving business insights. These tools help to better understand customer needs, improve products and services, and adjust the business strategy.
    8. Most cookies can be disabled. For example, most internet browsers allow users to delete cookies from their device, block the reception of cookies, or receive alerts before cookies are stored, but it should be clarified that deleting cookies from the browser or the user's platform memory will not delete information and content that has already been transferred to the Network or to third parties through them. However, it should be noted that if the user deletes the cookies or does not allow their storage, the user's online experience on the Digital Assets may be impaired, including with regard to the possibility of providing the services offered therein. Users are advised to refer to the instructions in their browser or the "Help" screen to learn more about these functions.
    9. By agreeing to the terms of this privacy policy, you agree to the use of the described technologies and other technologies, as they may be from time to time, for similar purposes, including the use of information collected through them for your identification and/or characterization based on them. If you do not agree, please update your device or browser settings according to your preferences as stated above.

 

  1. Marketing Mailings
    1. If users have shown interest in and/or purchased products and/or services from the Network, including within the Digital Assets, or if they have agreed to receive marketing mailings from the Network on one of its Digital Assets, as applicable, the Network and/or anyone on its behalf will send marketing and promotional information to those users, including updates, offers, benefits, and promotions, etc., through various digital means, including via email, various instant messaging software (such as chat and WhatsApp) and SMS messages. If users do not wish to receive such mailings, they can withdraw their consent at any time within the mailing itself and in accordance with the provisions detailed in the website's terms and conditions, and therefore should refer to the provisions detailed in the received mailing or the website's terms and conditions.
    2. The Network may carry out direct mail solicitations (as the term is defined in the Privacy Protection Law) by electronic and other means, based on its databases. As part of direct mail activities, users agree that the Network may approach them with personalized solicitations, based on their affiliation with a network possessing certain characteristics and based on segmentation and profiling activities carried out by the Network on the basis of the information stored with it as mentioned above. Direct mail content may include advertisements, value propositions, news content, and other content from the Network and its business partners, as chosen by the Network.
    3. The user is entitled, at any time, to request to stop receiving direct mail solicitations from the Network, and to request that information about them not be used for such activities in relation to specific entities or for specific purposes.
  1. Access Permission
    1. To perform certain activities and operations, including as part of certain services offered on some platforms within the Network's digital assets, access to specific services on users' devices may be requested. These permissions include, among others:
    2. Camera and gallery, location services, account access (Google, etc.), calendar: for example – to create reminders for events/meetings; push notifications; device identification/identity data.
    3. Users are not obligated to grant access to the aforementioned services, and they can cancel or prevent access to them through device settings. However, restricting access to these services may limit users' ability to fully enjoy the features and services offered within the digital assets.

 

  1. Links 
    1. The digital assets, including the services offered within them, may include links to various platforms (such as pages, websites, applications, and the like) on the internet that are not operated or managed by the Network, including activities and services offered by them. The Network does not control or supervise the activities of these platforms, and linking to them through the digital assets does not indicate the Network's consent to their content and does not guarantee their reliability, timeliness, or legality. Any use made of them is the sole responsibility of the users. The use of such platforms is subject only to the terms of use and privacy policy appearing therein, if any, and therefore users are advised to review these documents before making any use of such platforms.
  1. User Rights
    1. Subject to the provisions of the law, users have the right to review identifiable personal information held and stored about them through the digital assets in the Network's databases, and also to request its correction or deletion, if they find that the information is inaccurate, incomplete, or outdated. Users who wish to exercise these rights can contact the Network in writing using the methods stipulated by law or by emailing: dafni@kedemspahouse.com.  The Network will make reasonable efforts to comply with these requests, in accordance with the provisions of the law.
  1. Information Security
    1. Reasonable efforts have been invested in the digital assets to maintain information security, including through technological mechanisms and systems aimed at helping protect against information leakage, unauthorized access and use, and against the transfer, disclosure, copying, and deletion of information. However, while these efforts can reduce existing risks, it cannot be guaranteed that the digital assets will be absolutely immune to these actions, and there will be no liability for any damage caused to users or anyone on their behalf as a result.
    2. Users are aware that there is always a certain risk in services based on information processing, especially when transmitted over the internet, and they agree to the submission and collection of information in accordance with the provisions of the privacy policy and the law and assume the risk of information security incidents occurring that may affect the confidentiality, integrity, or availability of the information as stated.
  1. Changes to the Privacy Policy
    1. The provisions of this privacy policy may change from time to time, partly to reflect technological, business, legal, or regulatory changes. It is clarified that if material changes are made to the provisions concerning the use of personal information provided and/or collected about users within the digital assets, a notice will be published on the appropriate platform within the digital assets and/or in this privacy policy. Use of the digital assets after such changes indicates users' consent to these changes, and therefore it is recommended to review this privacy policy from time to time.
  1. Responsibility for Content and Availability
    1. The digital assets, including any content and/or service available through them, are provided to users by the Network as they are and subject to their availability ('As Is' and 'As Available'). Although the Network makes efforts to present accurate and reliable information in the digital assets as much as possible, the Network is not and will not be responsible, directly or indirectly, for the availability, truthfulness, reliability, and/or accuracy of the content appearing therein, and reliance on any content displayed in or through the digital assets is the sole responsibility of the users.
    2. Users may use the digital assets and the content available through them for private and personal purposes only. The content of the site does not grant any rights other than those detailed in the terms of use, which constitute a full and binding agreement between the users and the Network. The content displayed in the digital assets is provided for the convenience of users and for their personal use only. Although the Network makes efforts to present accurate and up-to-date information, the content does not constitute professional advice, and should not be relied upon as the sole basis for making financial, legal, personal, or other decisions. When ordering services and/or products or performing other actions based on the information displayed in the digital assets, it is recommended to exercise discretion and check the suitability of the products or services for each user's personal needs. The Network is not responsible for the results of decisions made based on the information displayed in the digital assets, and the use of this information is the responsibility of the users. Products, descriptions, design, colors, or appearance of products and services described or displayed in the digital assets are for illustration purposes only, and there may be discrepancies and differences between what is displayed and the actual product. If you identify a significant discrepancy between the actual appearance of the requested product and the product displayed in the digital assets, please contact us so that we can take action to correct it, at the Network's sole discretion. In any case, the Network shall not be responsible in connection with any product and/or recommendations and/or offers displayed in the digital assets.
    3. Job Postings. The Network may publish job postings and career opportunities in the digital assets, on the dedicated pages. These postings or their content do not constitute a commitment or guarantee the acceptance of any applicant for employment or anyone interested in a position with the Network, or detract from or change any other screening processes that may be conducted by the Network. Job postings and job offers are always addressed to both genders, even if not explicitly stated in the body of the posting.
    4. Intellectual Property. The digital assets and the content appearing therein, including, without derogating from the generality of the foregoing: trademarks, website design, graphics, logos, drawings, data, models, designs, illustrations, music, photographs, images, maps, audio clips, video clips, text, graphics, and the like are protected by the copyright laws of the State of Israel, international conventions, and copyright laws of other countries. All intellectual property rights, including copyrights, trademarks, patents, designs, methods, and trade secrets related to the digital assets and the content appearing therein, are the exclusive property of the Network or of third parties who have granted the Network permission to use them. No commercial use may be made of the information appearing in the digital assets, including texts, images, illustrations, designs, trademarks, logo, and brand names of the Network, without obtaining explicit, prior, and written consent from the Network. Use of information without such consent is strictly prohibited and will constitute an infringement of the Network's intellectual property rights. It is strictly forbidden to copy, reproduce, distribute, publish, transmit, display, perform, recreate, process, sublicense, reverse engineer, translate, sell, or rent any part of the information by any means or method, without obtaining explicit, prior, and written consent from the Network. The Network's names, with all their derivatives and brands, as well as the names of the websites and applications linked to the digital assets, and the domain names of the website/s, are protected trademarks of the Network and its full and exclusive property. The mere use of or entry into the digital assets does not grant any license and/or rights therein.
    5. Restrictions on Use of Digital Assets. Users undertake to use the digital assets lawfully and in accordance with the terms of use. It is strictly forbidden to make or attempt to make any changes to the digital assets, to copy or download material stored therein using various automated tools such as "Robot", "PageScrape", "Spider", Crawlers or any other similar method, algorithm or process. It is forbidden to download, copy or transfer to others material not intended for download or transfer, to attempt to gain access to transactions performed by other users, and to display content from the digital assets in any way that changes their original design. Likewise, it is forbidden to perform any action that may harm the intellectual property of the Network, the privacy of other users, their dignity or their rights, or cause damage to the digital assets or their users. Violation of these provisions may lead to the termination of access to the digital assets and the taking of legal action.
    6. Applicable Law: The use of the digital assets and/or any claim, demand and/or request arising from this use shall be governed solely by the laws of the State of Israel, and the jurisdiction shall be the Tel Aviv court, and the substantive and procedural law shall be Israeli law, subject to the Network's right to take legal proceedings in the courts where the user's address and/or place of business and/or assets or part thereof are located, at the Network's discretion. If any term of use is found to be illegal, void or unenforceable for any reason, that term will be deleted from the terms of use and its deletion will not affect the legality and validity of the remaining terms of use.
    7. For any question and/or request and/or request to delete an account and/or comment regarding this policy, please contact the Network's customer service at dafni@kedemspahouse.com. 
    8. The Network reserves the right to update, delete and/or add to any of the terms of use at any time and without obligation to give prior or subsequent notice, therefore it is recommended to keep updated on the prevailing policy from time to time. If you do not agree to all or part of the terms of use, please refrain from using the digital assets.
    9. Links that may be present in the digital assets, to external or other sites, are provided for convenience only. Any reliance on these sites or their content, use of them, or providing details through them, is the sole responsibility of the user and in accordance with the terms of use and privacy policy of those sites, separately and independently of the terms of use below.
    10. It is clarified that the Network reserves the right to remove any content from the digital assets at any time, including the links appearing therein, or to refrain from adding new links, all at its sole discretion.