Privacy Policy

(Last Updated:  November, 2021)

This Privacy Policy (“Privacy Policy”) describes APM & Co. (“APM”, “we”, ”our”, or “us”) practices of collecting and processing Personal Data (as such term is defined below) from users who access, browse, or otherwise interact with our website (“user(s)”, “you” or “your”), available at: (“Website”).

This Privacy Policy explains what data we may collect from you, how such data may be used or shared with others, how we safeguard it, and how you may exercise your rights related to your Personal Data.

We want to enable you to freely decide whether you wish to provide us with any information which may be required or obtained and therefore, we encourage you to read this Privacy Policy carefully and use it to make informed decisions.

If you have any questions about this Privacy Policy, please contact us at: apm@apm.law or as described below.

1. Information We Collect

We may collect the following types of data:

• “Non-Personal Data” – non-personal and anonymized information which may be gathered or made available through your access to our Website and interaction with us, including: type of browsers; type of operating system; type of device; time and date you access the website; language preference; country-level location, etc. We use this data solely to enable the operation of the Website and to enhance our Website and the content offered therein. For the avoidance of doubt, we are not aware of the identity of the user from who we collect such data from.
• “Personal Data” – individually identifiable information, namely information that identifies an individual or may, with reasonable effort, identify an individual.

For the avoidance of doubt, any Non-Personal Data connected or linked to any Personal Data shall be considered as Personal Data for as long as such connection or linkage exists.

Please note that you are not required by law to provide us with any Personal Data and you can avoid from doing so and object to the processing of certain of your Personal Data.

The table below details the types of Personal Data we collect:

2. How We Collect Data

The above detailed data is collected as follows:

1. Automatically – we may use cookies (as elaborated below) to gather some information automatically.
2. Provided by you voluntarily – we will collect information if and when you choose to provide us with the information, e.g., when you communicate with us, when you apply for a job or when you request to join our mailing list.

3. Sharing Data with Third Parties

We will not share your Personal Data with third parties, except as specifically mentioned herein:

• Compelled Disclosures – to satisfy any applicable law, regulation, legal process, subpoena, or governmental request, solely to the extent required;
• Enforcement of our Rights and Security – to enforce this Privacy Policy, including the investigation of potential violations thereof, solely to the extent required, and to detect, prevent, or otherwise address fraud, security, or technical issues, solely to the extent required;
• Business Transfers and Affiliated Companies – we may share your information with any joint ventures (“Affiliated Companies”) solely if and when applicable or necessary for the purposes described in this Privacy Policy, or in the event of a corporate transaction (e.g. sale of a substantial part of our business, merger, consolidation or asset sale). In the event of the above, our Affiliated Companies or acquiring company will assume the rights and obligations as described in this Privacy Policy;
• Third Party Service Providers – where applicable, to collect, hold or manage your Personal Data through our authorized third party service providers, as reasonable for our business purposes (e.g., hosting service, email marketing, etc.).
• Explicit Consent – if you specifically request us to provide a third party with your Personal Data.

4. Cookies Policy

We and our third-party service providers may use cookies to gather, store, and track certain information related to your access of, activity, and interaction with our Website and content therein, as applicable.

A “cookie” is a small piece of information that a website assigns to your device while you access such a website. Cookies are very helpful and may be used for a variety of different purposes. These purposes include, among other things, allowing you to navigate between pages efficiently, enabling automatic activation of certain features, remembering your preferences, and making the interaction between you and the website quicker, easier and smoother. Cookies are also used to help customize your experience and for advertising purposes (including personalized advertising). You can find out more information about cookies at www.allaboutcookies.org.

In general, several types of cookies may be used on our Website including the following:

• Essential, Functionality, Operation & Security Cookies. These cookies are essential for enabling user movement around the Website, and certain features of the platform, as applicable, to function properly, and for security purposes. This category of cookies either cannot be disabled or if disabled, certain features of the Website may not work.
• Analytical, Measurement & Performance Cookies. These cookies are used to collect information about how our Website is being used, for example, to assess the number of users who have viewed a certain page as well as their country of origin.
• Performance, Targeting & Advertising Cookies. These cookies may be used to build a profile of your interests and show you personalized content and advertisements.

Our service providers may use the following cookies for the purpose of tracking and analyzing your use, all as detailed below:

In addition, most browsers will allow you to erase cookies from your computer’s hard drive, block acceptance of cookies, or receive a warning before a cookie is stored. You may remove cookies by following the instructions in your device preferences. More information about your ability to disable cookies can be found here (as applicable to your browser): Google Chrome; Firefox; Internet Explorer; Safari; Edge; Opera.

5. Data retention

We retain the Personal Data we collect for as long as it remains necessary for the purposes set forth above, all under the applicable regulation, or until you will express your preference to opt-out, where applicable. We may at our sole discretion, rectify or erase information from our systems, without prior notice to you, once we deem it is no longer necessary for such purposes.

6. User Rights

Individuals have certain rights under applicable privacy laws with regards to their Personal Data. Subject to your jurisdiction (and additional conditions), these rights may include might include:

• The right to be informed –you have the right to be provided with information regarding our data collection and privacy practices, as detailed in this Privacy Policy;
• The right to access your Personal Data – you have the right to request a confirmation from us that we process your Personal Data, and in some cases, be provided with a copy of the Personal Data we process.
• The right of rectification – you have the right to require to update Personal Data which is not correct;
• The right to the erasure of your Personal Data – you have the right to require the erasure of certain Personal Data if specific conditions are satisfied. This right is not absolute. We may reject your request under certain circumstances, including where we must retain the data in order to comply with legal obligations or defend against legal claims, etc.;
• The right to restrict the processing of your Personal Data – you may be entitled to limit the purposes for which we process your Personal Data if specific conditions are satisfied;
• The right to object to the processing of your Personal Data – you have the right to object to the processing of certain Personal Data, in the event the basis for processing is our legitimate interests, however, we will be permitted to continue the processing if our legitimate interests override your rights, or when processing is necessary to establish, exercise or defend a legal claim or right, etc.;
• Data portability – you have the right to have your Personal Data “port” to a third-party;
• The right to file a complaint to a supervisory authority; and
• The right to withdraw your consent – when the lawful basis for the processing of your Personal Data is your consent.

If you wish to exercise any or all of the above rights, please contact us at apm@apm.law, or as described below.

Subject to the applicable regulation, where we are not able to provide you with the information for which you have required, or to the extent you have required, whatever that reason might be, we will endeavor to explain the reasoning for this and inform you of your rights. We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any such information. Please note that in the event you have asked us to exercise your data rights herein, we will respond to your request within the timeframes set forth under applicable regulation.

7. Security & Data Transfer

We take great care in implementing physical, technical, and administrative security measures that we believe comply with applicable regulation and industry standards to prevent your information from being accessed without the proper authorization, improperly used or disclosed, unlawfully destructed, or accidentally lost. You need to remember, however, that unfortunately, the transmission of information via the internet cannot be 100% secure. As such, although we will do our best to protect your Personal Data, we cannot guarantee the full security of data transmitted via our website, and any transmission of your data shall be done at your own risk.

Note that, as we may use third party service providers and our Website uses third party cookies as described above, your Personal Data might be processed in other territories outside your country. We will take appropriate measures to ensure that your Personal Data receives an adequate level of data protection upon its transfer, in accordance with applicable laws. You may exercise your rights, where applicable, to receive information on such a transfer mechanism.

8. Amendments

We reserve the right to periodically amend or revise this Privacy Policy which will be effective immediately upon the implementation of the revised Privacy Policy on our Website. The last revision date will be reflected in the “Last Updated” heading located at the top of the Privacy Policy. We will make a reasonable effort to post notification in the event that we implement any changes that substantially change our privacy practices. We recommend that you review this Privacy Policy periodically to ensure that you understand our privacy practices and to check for any amendments.

9. Protecting Children

Our Website is not directed nor is it intended for use by children under the age of sixteen (16) and we do not knowingly process a child’s information. We will immediately discard any information that we receive from a user that is considered a “child” upon our discovery that such a user shared Personal Data with us. If you are under the age of eighteen (18), please be sure to read the terms of this Privacy Policy carefully with your parents or other legal guardians. Please contact us at: apm@apm.law, or as described below if you have reason to believe that a child has shared any information with us.

10. Contact us

If you have any questions about this Policy, please contact us at:

APM House, 18 Raoul Wallenberg St.,
Building D, 6th floor, Ramat Hachayal,
Tel Aviv, 6971915, Israel

Or: 110 Derech Hevron St.,
Beit Hanatziv, 3rd Floor,
Jerusalem

You can also contact us via email at: apm&co@apm.law