Privacy policy The Malca-Amit Group Companies (for the purpose of this Privacy Policy "Group Companies" means our subsidiaries, our ultimate holding company and any subsidiaries of that holding company), in the following referred to as "Malca-Amit", "MA", "us", "we", "our", understands the importance of protecting your privacy. We will only hold, process and transfer the personal information that we collect about you and which personally identifies you in accordance with applicable laws, this Privacy Policy and any terms set out at the point(s) at which personal information is collected (“Collection Terms”). If there is any inconsistency between the Collection Terms and this Privacy Policy, the Collection Terms will prevail. Our Terms & Conditions set out, amongst other provisions, disclaimers, and limitations of liability governing the use of the MA Web-Site. Who are we and what do we do? Malca-Amit provides the luxury goods industry, high-net worth individuals and international banks with a global team of experts, including logistics, security, customs house and special operations professionals. Malca-Amit provides a smooth, expedient and professional service tailored to precise specifications and needs. Malca-Amit stands at the forefront of industry innovation. Our expert knowledge and ground-breaking capabilities enable our clients to achieve maximum efficiency when dealing with the movement of their valuable assets. Which Malca-Amit entity is the controller for the processing of your personal (or the equivalent capacity as defined in other jurisdictions) depends on the circumstances: The Controller in the meaning of data protection law for this Web-Site isMalca-Amit USA, LLC, 580 Fifth Ave, Lobby 1, New York, NY 1003, USA,email address: privacy@malca-amit.com However, if you have been directed to this Privacy Policy by Collection Terms, the legal entity named in the Collection Terms will usually be the controller of your data. In case you have any questions regarding this Privacy Policy or the processing of your data in general, please contact us at privacy@malca-amit.com or contact the party to your agreement. What information do we collect? We collect and process the following personal data about you: information that you provide when you fill out and submit to us our Account Application form (and/or other MA onboarding forms), our KYC forms, when you instruct us under our Global/Domestic Shipping Instructions (GSI/DSS) or register, place an order or fill out a form on the MA Web-Site; a copy of any communication which you may send to us via the MA Web-Site; details of transactions that you instruct (or have instructed) us or any of our Group Companies to carry out on your behalf and the fulfilment by us or our Group Companies of those transactions ; details of your visits to our MA Web-Site (like most websites, we use cookies and/or web beacons to enhance your experience, gather general visitor information, and track visits to our website - please refer to the sections on "Log Files", "Cookies", "Website Analysis" and "Advertising by means of tracking technologies (including Facebook Pixel)" for further information; and data we collected from third parties about Customers and their key persons (authorized representatives, shareholders and principal officers) - please see section "Sources of data" for further information. Do we process personal data? All information which is related to an identified or identifiable natural person (e.g., name, address, phone number, date of birth or email address) is personal data. The processing of your personal data entails for example the data's collection, recording, usage, transmission to third parties or deletion. In some cases, MA asks for your personal data. These cases include situations, in which you wish to access certain areas of the MA Web-Site which require registration or a password and situations in which MA needs your personal data in the context of providing services to its customers. What are the purposes and legal bases for the processing of your data? We process your personal data for the following purposes, based on the legal bases listed: No. Purpose for processing Legal basis for processing Description of legitimate interest for processing if applicable 1 To provide a website for the general public according to our Terms & Conditions. Performance of a contract as well as legitimate interest We have a legitimate interest in providing a website also for non-registered users, in order to generally inform about our business and our services. 2 To provide a protected website area for registered users only according to our Terms & Conditions. Performance of a contract n/a 3 To process transactions. Note: Except as set out in this Privacy Policy, your data, whether public or private, will not be sold, exchanged, transferred, or given to any other company for any reason whatsoever, without your consent, other than for the express purpose of delivering the purchased product or service requested. Performance of a contract n/a 4 To provide goods or services you requested to fulfil our contract. Performance of a contract n/a 5 To set-up and maintain customer accounts. Performance of a contract n/a 6 To send periodic emails to the email address you provide in connection with the sale of a good or service. Legitimate interest We have a legitimate interest in the direct marketing of our offers as long as this is permitted by applicable data protection law and unfair competition law. See the section "Information on your rights to object" in order to learn how you can object to this use at any time. 7 To help us further develop our services. Legitimate interest We have a legitimate interest in developing and improving our services in order to preserve and grow our business./a 8 To provide you access to valuable MA internet-based information and services, and to bill you for those services if you elect to use them. Performance of a contract n/a 9 To record and evaluate usage data for interest based advertising. (website only). Legitimate interest We and our partners have a legitimate interest in interest-based advertising to be able to show our users advertisements based on their personal interests. 10 To collect statistical information about the use of the website (so-called web analytics). Legitimate interest We have a legitimate interest in analysing the usage of our website in order to continuously improve it and to customise it to our users’ needs. 11 To determine disruptions and to ensure the security of our systems, including the detection and tracing of (the attempt of) unauthorised access to our web servers. Compliance with the legal obligations regarding data security as well as legitimate interest We have a legitimate interest in resolving disruptions, ensuring the security of our systems and the detection and tracing of (the attempt of) unauthorised access. 12 To safeguard and defend our rights. Legitimate interest We have a legitimate interest in exercising and defending our rights. 13 To comply with relevant legal obligations, such as keeping accounting records, applicable anti-money laundering and counterterrorism financing laws, customs, transportation safety and security laws and regulations Compliance with legal obligations. n/a How do we protect your personal data? We implement a variety of security measures to maintain the safety of your personal data when you place an order or access your personal data. We offer the use of a secure server. All supplied sensitive/credit information is transmitted via Secure Socket Layer (SSL) technology and then encrypted into our database to be only accessed by those authorized with special access rights to our systems, and are required to keep the information confidential. Log files (website only) We may collect information about your computer, including where available, your IP address, operating system and browser type, the internet address of the website from which you access the MA Web-Site and the date, time and duration of the access. We save log files for the purposes of determining disruptions and for security reasons (e.g., to investigate attack attempts) for a period of 7 to 10 days and delete them thereafter. Log files which need to remain stored for evidence purposes are excluded from deletion until the respective incident has been finally resolved and may be forwarded to investigating authorities on a case-by-case basis. Do we use cookies? (website only) Yes (cookies are small files that a site or its service provider transfers to your computer's hard drive through your Web browser (if you allow) that enables the sites or service providers systems to recognize your browser and capture and remember certain information). We use cookies to record the existence of a browsing session and to compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future. We may contract with third-party service providers to assist us in better understanding our site visitors. Typically cookies do not collect personal data but may be used to create a user profile. In this case, you will be informed about this in this Privacy Policy. If you prefer, you can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all or some cookies via your browser settings. Also, depending on what type of web browser and what browser version you are using, you may be able to change the properties on your cookie file so that cookies are not used or saved. Cookies can also be removed from your hard drive. Please check with your browser provider for more information on removing cookies. Like most websites, if you decline to accept cookies, some of our services may not function properly (for example, you will not be able to log on to any part of the MA Web-Site which is accessible only to registered users). Where you are unable to log on to the MA-Web-Site due to your declining cookies, you can still place orders by contacting customer service. ‍ We use the following types of cookies: Cookies strictly necessary for a service. Some cookies are strictly necessary so we can offer our Web-Site safely. This category includes, e.g., Cookies which serve the purpose of identifying or authenticating our users; Cookies that temporarily store certain user entries (e.g., shopping basket content or content of an online form) Cookies that remember certain user preferences (e.g., search query and language settings); Cookies that store data to ensure the uninterrupted playback of video and audio content. Analytics Cookies We use analytics cookies to record and statistically evaluate our users’ usage behaviour (e.g., clicked ad banners, visited subpages, search queries asked). Advertising Cookies We also use advertising cookies. The usage behaviour profiles created by using these cookies (e.g., clicked ad banners, visited subpages, search queries asked) are used by us to show you advertisements or offers which are tailored to your interests (“interest based advertisement”). Third Party Advertising Cookies We also allow other companies to gather data from our users using advertising cookies. This allows us and third parties to show interest-based advertisements to the users of our Web-Site, which are based on an analysis of their usage behaviour e.g., clicked ad banners, visited subpages, search queries) in general and not restricted to our Web-Site. Website Analytics (website only) We require statistical information about the usage of this Web-Site to design it to be user-friendlier and to perform reach measurements and market research. For this purpose, we use the web analytics tools described in this section below. The usage profiles created by these tools using analysis cookies or by evaluating log files are not combined with personal data. The service providers providing these tools are not permitted to use the information collected on our behalf except to help us conduct and improve our business and subject to our instructions. The tools either do not collect IP addresses or anonymize these upon collection. You will find information on each tool's provider and how you are able to object to the collection and processing of data by the tool. Please note that tools may use so-called opt out cookies in order to remember your objection. This opt out function relates to a device or browser and is thus valid for the terminal device or browser used at this time. In case you use several terminal devices or browsers you must opt out on every device and in every browser used. Note that in case you remove all cookies from your hard drive, the opt out function will not work any longer. Additionally, you can generally avoid the creation of usage profiles by tracking technologies by generally deactivating cookie usage. For more information on how to do so, please refer to the section on cookies[ above. Google Analytics: Google Analytics is provided by Google Inc., 1600 Amphitheatre Parkway, Mountain View, California, 94043 USA (“Google”). You may object to the collection or processing of your data by clicking on this link: https://tools.google.com/dlpage/gaoptout?hl=en Google Conversion Tracking: Google Conversion Tracking is provided by Google Inc., 1600 Amphitheatre Parkway, Mountain View, California, 94043 USA (“Google”). Snowplow: Quantcast Measurement: Facebook Signal: Facebook Signal is provided by Facebook Inc., 1601 Willow Road, Menlo Park, CA 94025, USA ("Facebook"). You may object to the collection or processing of your data by this tool by contacting us at privacy@malca-amit.com Advertising by means of tracking technologies (including Facebook Pixel MV2) (website only) We use so-called tracking tools on this website to better understand your preferences by analysing your behaviour on our website and offer you products or services more in line with your interests. You will find information on each tool's provider and how you are able to object to the collection and processing of data by the tool below. Please note that tools may use so-called opt out cookies in order to remember your objection. This opt out function relates to a device or browser and is thus valid for the terminal device or browser used at this time. In case you use several terminal devices or browsers you must opt out on every device and in every browser used. Note that in case you remove all cookies from your hard drive, the opt out function will not work any longer. Additionally, you can generally avoid the creation of usage profiles by tracking technologies by generally deactivating cookie usage. For more information on how to do so, please refer to the section on cookies above. Google Remarketing: Google Remarketing is offered by Google Inc., 1600 Amphitheatre Parkway, Mountain View, California, 94043 USA (“Google”). Doubleclick: Doubleclick is provided by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA („Google“).Doubleclick Bid Manager: Doubleclick Bid Manager is provided by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA („Google“). You may object to the collection or processing of your data by these tools by contacting us at privacy@malca-amit.com. ‍ Do we disclose any information to other parties (who are the recipients of your data)? Except as set out in this Privacy Policy, we do not sell, trade, or otherwise transfer your personal data to outside parties. Your personal data may be transferred to the following categories of recipients: Service providers (data processors) The service providers we engage are not permitted to use the information collected and/or processed on our behalf except to help us conduct our business and subject to our instructions on the basis of a data processor agreement. We disclose your data to the following categories of service providers: IT service provider (hosting service) Provider of Software as a Service (SaaS) Provider of website analytics tools (website analytics), please see also the section on website analytics, Our service providers are located in the European Economic Area (EEA) respectively the European Union (EU), Israel and the USA. Third parties We also may disclose your personal data to our affiliates and other trusted third parties who assist us in conducting our business, or servicing you and the fulfilment of your order, so long as those parties agree to keep this information confidential. In the event that we sell or buy any business or assets, in which case, we may disclose your personal data to the prospective seller or buyer of such business or assets if legitimate under applicable laws; if we, or substantially all of our assets, are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets, if legitimate under applicable laws. We may also release your data when we believe release is appropriate to comply with the law, enforce any MA Web-Site policies, or protect our or others' rights, property, or safety. Transfers of your data to countries outside the EEA (only for data subjects in the EEA) This section applies to data subjects in the EEA. If the controller of your personal data is located in the European Economic Area ("EEA"), we might forward your personal data to data processors or third parties located outside the EEA. In such cases we ensure prior to the transfer that the transfer is subject to appropriate safeguards, for example by self-certification of the recipient for the EU US Privacy Shield (Art. 45 GDPR) or by having agreed upon so-called standard data protection clauses of the European Union with the recipient (Art. 46 GDPR) or you have given your explicit consent. If the controller of your personal data is located outside the EEA, It will still comply with GDPR requirements; therefore, If your personal data is forwarded to data processors or third parties located outside the EEA, we ensure prior to the transfer that the transfer is subject to appropriate safeguards as described above to the extent necessary. You may also receive an overview of third country recipients and a copy of the appropriate or suitable safeguards in place. Please use the details provided in the "Contacting Us" section. For how long do we keep your personal data? We store your data as long as it is necessary to provide our services or as long as we have a legitimate interest in continued storage. In all other cases, we delete your personal data with the exception of such data that we are required to retain for the purpose of contractual or statutory (e.g., taxation or commercial law) retention periods (e.g., invoices).We will keep your personal data only for so long as is necessary and for the purpose for which it was originally collected. In addition, the following criteria apply: After each transaction, your personal and private information (tax identification number, social security numbers, financial information, etc.) will be kept on file for more than 60 days (longer data keeping terms can be envisaged by applicable laws) in order to process future shipments and comply with applicable import/export regulations. Data you provide when registering via the MA Web-Site Data regarding communication you sent to us via the MA Web-Site Please also refer to the respective Collection Terms for further information regarding the criteria for storage periods. What are your rights and how can you exercise them? You have the following rights: Right of access and rectification: You have the right to obtain confirmation from us as to whether or not your personal data is being processed and a right to access your personal data that is being processed by us. You also have the right to obtain without undue delay the rectification of any inaccurate personal data relating to you and to have any of your personal data that is incomplete completed. In case we have transferred your personal data to third parties, we will inform them about this rectification and completion if required by law. Right to erasure ('right to be forgotten')You have the right to obtain the erasure of your personal data from us without undue delay and we have the obligation to erase your personal data without undue delay if one of the following grounds applies: your personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; the processing of your personal data is based solely on your consent and you have withdrawn your consent; you have objected to direct marketing; you have objected to the processing that is based on our legitimate interest on grounds that relate to your particular situation and there are no overriding legitimate grounds for the processing; your personal data have been unlawfully processed; your personal data have to be erased for compliance with a legal obligation In case we have transferred your personal data to third parties, we will inform them about this erasure if required by law. Please keep in mind that there are limitations to your right to erasure. We are for example not allowed to erase data that we are legally obliged to store. Also, your right to erasure does not apply if we need to store the data for the establishment, exercise or defence of legal claims. Right to restriction of processing: You have the right to restrict our processing of your personal data where you contest the accuracy of the personal data until we have taken sufficient steps to correct or verify its accuracy; the processing is unlawful but you do not want us to erase the data; we no longer need your personal data for the purposes of the processing, but you require them for the establishment, exercise or defence of legal claims; or you have objected to processing based on our legitimate interest (see below) pending verification as to whether we have compelling legitimate grounds to continue processing. Where personal data is subjected to restriction in this way, we will only process it with your consent or to a very limited extent, e.g. for the establishment, exercise or defence of legal claims. Rights to object: You have the right to object to the processing of your personal data that is based on our legitimate interest, on grounds relating to your particular situation, at any time. You also have the right to object to the processing of your personal data for marketing purposes at any time. Please also refer to the "Information on your rights to object" section. Right to Data portability:Where we are relying upon your consent or the fact that the processing is necessary for the performance of a contract to which you are party as the legal basis for processing, and that personal data is processed by automatic means, you have the right to receive all such personal data which you have provided to us in a structured, commonly used and machine readable format, and also to require us to transmit it to another controller where this is technically feasible Right to withdraw consent:Where we have relied on your consent to process particular information and you have provided us with your consent to process data, you have the right to withdraw such consent at any time. The withdrawal of your consent does not affect the lawfulness of processing based on consent before its withdrawal. Right to lodge a complaint with the Supervisory Authority:You have the right to lodge a complaint with a Supervisory Authority. You can appeal in particular to the Supervisory authority, which is competent for your place of residence. You may exercise your rights by contacting us via the contact details supplied in the "Contacting Us". Section. Please ensure for this purpose that a clear identification of your person is possible for us. Sources of Data We collect most information we process directly from you. However, additionally we may collect personal data from third parties, namely anti-fraud databases, sanctions lists, court judgments and similar databases, identity checking providers, as well as publicly available information from the internet, if we are required do to so under applicable anti-money laundering and counterterrorism financing laws to which we are subject. Are you required to provide us with your data? You can visit the MA Web-Site without disclosing your personal data to us. For registration purposes you are, however, obliged to provide us with the personal data needed for contract establishment and performance (for example email address, mailing address, phone number, billing information, business profile or credit card information). When filling out one of our forms in order to establish a contractual relationship with us, you may also be asked to provide certain personal details in order for us to be able to perform the contract. If you decide not to provide us with this information, you will unfortunately not be able to register or use any of our services which require such information. Online security (website only)Unfortunately, the transmission of information via the internet is not completely secure. Whilst we will all reasonable endeavours to protect your personal data, we cannot guarantee the security of your data transmitted to the MA Web-Site: any such transmission is at your own risk. Third party links (website only)Occasionally, at our discretion, we may include or offer third party products or services on our website. We may also include links to and from the websites of third parties. These third party websites have separate and independent privacy policies. We therefore have no responsibility or liability for the content and activities of these third-party linked websites or for their independent privacy policies. You should consult the privacy policies at those sites to determine how your personal data may be used. Nonetheless, we seek to protect the integrity of our site and welcome any feedback about these sites. Changes to our Privacy PolicyIf we decide to change this Privacy Policy, we will post those changes on this page, and update the Privacy Policy modification date below. We will give notice to you prior to amending this Privacy Policy in a way that materially affects you or has an impact on you and if we have your contact details. Contacting UsIf there are any questions regarding this Privacy Policy, you may contact us using the information below. Our postal address is: 580 Fifth Ave, Lobby 1, New York, NY 1003, USA. We can be reached by telephone at +1 (212) 840-8330. We can be reached by email at privacy@malca-amit.com This policy was last modified on 09 July 2018. You may also use the contact information provided to you in the respective Collection Terms. B. Malca-AmitInformation on your rights to object Right to object to direct marketing You may at all times object to the processing of your personal data for direct marketing purposes. Please take into account that, due to logistical reasons, there might be an overlap between your objection and the usage of your data within the scope of a campaign which is already running. Right to object to processing based on legitimate interest Furthermore, you may have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on the legal basis legitimate interests. You may address your objections to: 580 Fifth Ave, Lobby 1, New York, NY 1003, USA Tel +1 (212) 840-8330 Email: privacy@malca-amit.com You may also use the contact information provided to you in the respective Collection Terms. Please check providers and add new ones which are being used but not listed here Please check whether we use the providers outlined here Please add providers here appropriate Malca-Amit Mobile Application Media Blog App Network Videos Legal Terms of Use Privacy Policy This Entire Site and all Contents Copyright 2018 by Malca-Amit | TERMS AND CONDITIONS Disclaimer Please be aware of companies and individuals fraudulently claiming to operate or represent Malca-Amit offices. These companies and individuals are not affiliated with Malca-Amit and may not be operating legally. Only those Malca-Amit companies and offices listed in this website are part of the Malca-Amit International Network™. If you doubt the legitimacy of any company or individual claiming to be part of the Malca-Amit International Network™, please email us immediately at lms@malca-amit.com.