Bidflyer Labs Ltd. (“Fareplace”, “we”) is committed to maintaining the privacy of its users (“user”, “you”). The following information describes how Fareplace collects and processes information about you when you use our website (the “Website”) (as defined below).

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Our privacy policy (“Privacy Policy”) explains:

• What information do we collect, and why do we collect it

• How we use that information

• How we disclose information and transfer data

• Data Subjects rights 

• Cookies collection 

• Opt-In or Opt-Out from receiving information

• Links to other websites

• Data Security 

• Data Retention rights

• Children’s privacy rights

• Questions regarding Our Privacy Policy 

• Revisions and Modifications to Our Privacy Policy 

• Governing Law and Jurisdiction

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By using our Website, you agree to this Privacy Policy. 

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1.      General

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Fareplace is a marketplace platform for airline companies (the “Platform”) that allows them to unlock new revenue streams by offering additional products and pricing combinations to their customers during the booking process (the “Services”). This Website provides information on the Platform and the Service and enables Fareplace’s users to get a demo of the Platform or contact Fareplace for support.

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2.     Collecting Information

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Please note that the scope of this Privacy Policy is limited only to information collected by Fareplace through your use of its Website. Some information may be automatically collected, and some are collected when you interact with our Website. The type of information that may be automatically collected is non-personal information, which includes your session durations, the content you accessed on the Website, the frequency and scope of your use of the Website and information about your computer and internet connection including the operating system you use and browser type. 

Information from which you can be personally identified may also be collected, including but not limited to your full name, job title, email address, company, and Website (hereinafter: “Personal Information”). Personal Information shall be collected only if received voluntarily from you, including without limitation, via the following ways:

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a. Book a Demo

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If you wish to book a demo via the Website, we will collect your Full name, job title, email address, company, and website address you submitted to provide you with a relevant demo to use our Services.

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b. Contacting Us

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If you wish to contact us for support regarding our Platform, Services, Website, this Privacy Policy, or any other matter, we will collect your full name, job title, email address, company, and website address and any content you submit to the optional open message tab so we can facilitate your inquiry. 

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3.     Use of Information 

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We use Personal Information we collect from you for various business purposes according to different legal bases of the processing. We may use or process your Personal Information for the following purposes. One or more purposes may apply simultaneously.

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a.    Providing the Requested Services

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• We collect the Personal Information listed in Section 2 above to provide you with the Services you contracted to receive. 

• The information collected will enable us to provide you with technical and professional assistance regarding the provision of the Website to you.

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We process the Personal Information where it is necessary for the adequate performance of the contract regarding the provision of the Website to you.

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b.     Improvement and Development of the Services

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• We collect Personal Information to improve and develop our Website, understand feedback on Fareplace’s Services and Website, and help provide more information on using the Services quickly and easily. 

• We collect Personal Information for ongoing review and improvement of the information provided on our Website to ensure it is user-friendly.

• We collect Personal Information to improve the management and administration of our business and maintain compliance with our internal policies and procedures.

• We conduct surveys and research, test features in development, analyze the information we have to evaluate and improve our Services, develop new features, and conduct audits and troubleshooting activities.

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We process this information in light of our legitimate interest in improving the Website and Services to give our users the best experience.

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c.    Maintain a Safe and Secure Environment

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We may use your information to detect and prevent fraud, abuse, and security incidents in the following ways:

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• Verify and authenticate your identity and prevent unauthorized or illegal activity;

• Enhance the safety and security of our Website;

• Conduct security investigations and risk assessments; 

• Prevent or take action against activities that may breach our terms of service or applicable law.

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We process this information in light of our legitimate interest in improving our Services and enabling our users to browse in a secure environment.

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4.     Disclosure of Information and Transfer of Data

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We reasonably attempt to ensure that we never intentionally disclose any of your Personal Information to any third party without having received your permission, except as provided herein and in this Privacy Policy or otherwise as permitted or required under the law. 

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In order to perform our contractual and other legal responsibilities or purposes, we may, from time to time, need to share your Personal Information with third parties. We may also share your Personal Information with our affiliates, subsidiaries, or any third-party service providers and individuals to facilitate our Website or any portion thereof, such as marketing, data management, or maintenance services. 

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The above-mentioned third parties may be located in countries other than yours, and we may send them the information we receive. When third-party service providers process your Personal Information on our behalf, we will ensure that they comply with obligations similar to those outlined in this Privacy Policy. We will also ensure that they will abide by our data privacy and security requirements and will be allowed to use the Personal Information solely for the purposes we set. We will transfer your Personal Information using appropriate and suitable safeguards while using a variety of legal mechanisms, including contracts, to ensure your rights and protections travel with your data. 

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We may also transfer your information, including Personal Information, in connection with a corporate merger, consolidation, the sale of related assets, corporate division, or other fundamental corporate changes. Furthermore, information about you may also be released to comply with any valid legal obligation, inquiry, or process, such as a search warrant, subpoena, statute, or court order. We will also release specific information in special cases, such as if you use the Website to perform an unlawful act or omission or take any act or omission that may damage Fareplace, its property, and goodwill or if there is an attempted breach of the security of the Website or a physical or property threat to you or others. The authority supervising such activities is the Israeli Privacy Protection Authority, and you have the right to file a complaint to it or any other relevant supervisory authority.

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5.     Your Rights

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You have the right to request access or modify your information at any time. To exercise these options, please contact us at [email protected].

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In some jurisdictions, in particular those located within the European Union (the “EU”) or within the European Economic Area (the “EEA”), you may be afforded specific rights regarding your Personal Information. Subject to such eligibility, you may have the following rights to:

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1. Request a rectification of your Personal Information where the information we hold about you is incorrect or incomplete. 

2. Object to the processing of your Personal Information for direct marketing purposes. 

3. Object to the processing of your Personal Information where our legal basis for that processing is that such processing is necessary for our legitimate interests. 

4. Object to an automated decision-making (including profiling) in certain circumstances. 

5. Request the erasure of your Personal Information in certain circumstances, such as where processing is no longer necessary for the purpose it was originally collected for, and there is no compelling reason for us to continue to process or store it;

6. Receive your Personal Information, or ask us to transfer it to another organization that you have provided to us, which we process by automated means, where our processing is either based on your consent or is necessary for the performance of a contract with you.

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Generally, with regard to information collected on our Website, Fareplace is a “Data Controller”. Therefore, if you wish to exercise the above-mentioned rights, please contact us, and we will make our best efforts to fulfill your request.

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If you wish to file a request regarding any of the above, you may contact us at: [email protected]

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6.     Notice to California Residents

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This section is designated for California residents and is provided under the California Consumer Privacy Act, as amended by the California Privacy Rights Act of 2020 (“California Privacy Laws”). It explains your privacy rights, provides “notice at collection”, and provides certain mandated disclosures about how we handle your Personal Information. This section uses certain terms that have the meanings given to them by the California Privacy Laws, unless otherwise specified. Please note that some of the disclosure obligations required under the California Privacy Laws are satisfied within other sections of this Privacy Policy. 

The California Privacy Laws permit some users to request to exercise certain rights. If these rights are applicable to you, you are afforded with the following rights:

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a.     Right of access

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You can request Fareplace for certain information about our practices with respect to your Personal Information. In particular, you can request to receive information on the following:

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• The categories and specific pieces of your Personal Information that we have collected. 

• The categories of sources from which we collected your Personal Information.

• The business or commercial purposes for which we collected or share your Personal Information. 

• The categories of third parties with which we shared your Personal Information.

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b.     Right to Limit Use and Disclosure of Sensitive Personal Information

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We do not share sensitive Personal Information for cross-context behavioral advertising, and we do not sell sensitive Personal Information.

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c.     Exercising your California Law Rights

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Please note that we will be required to verify your identity and request before an action is taken to exercise your rights. As a part of this process, government identification may be required. Moreover, you may designate an authorized agent to make a request on your behalf. We make our best efforts to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. Any disclosures we provide, will only cover the 12 months period preceding your verifiable request’s receipt. If, for some reason, we cannot reply within such time frame, our response will include an explanation for our inability to comply. If you wish to exercise your California Privacy Laws rights, please contact us at: [email protected].

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d.     Right of No Retaliation Following Opt-Out or Exercise of your Rights

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If you choose to exercise your rights, we will not charge you different prices or provide different quality of our Services, unless those differences are related to your provision of your Personal Information. We will not discriminate against you for exercising any of your rights and unless permitted by the California Privacy Laws, we will not:

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1. Deny you goods or services.

2. Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.

3. Provide you with a different level or quality of goods or services.

4. Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

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7.     CAN SPAM Act

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The CAN-SPAM Act is a Federal US law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out strict penalties for violations.

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To be in accordance with CAN-SPAM, Fareplace agrees to the following:

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• Not use false or misleading subjects or email addresses.

• Identify the commercial message sent to you as an advertisement when required.

• Include the physical address of our business or site headquarters. 

• Monitor third-party email marketing services for compliance, if one is used.

• Honor opt-out/unsubscribe requests quickly.

• Allow users to unsubscribe by using the link at the bottom of each email.

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If at any time you would like to unsubscribe from receiving future emails, you can email us at [email protected]  and we will promptly remove you from ALL correspondence.

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8.     Cookies

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We may use “cookies” or other technologies or files (collectively, “cookies”) to identify how visitors make use of this Website. This aggregated tracking information may help us improve and enhance the Website experience for all our visitors. In addition, cookies adjust the Website to your personal preferences. Cookies contain information such as the pages you visited, the length of time you stayed on the Website, the location from which you accessed the Website, and more. If you prefer not to store cookies on your computer, you may modify your browser settings to reject most cookies or manually remove cookies placed on your computer. However, you may not fully access the offerings on this Website by rejecting the cookies.

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9.     Opt In or Opt Out

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You are always in control of your data, and if you choose to receive information from us, or others, you can change your mind later. If at any time, you would like to stop receiving such information or opt out of a feature, you may notify us by writing to [email protected]. You should be aware, however, that it is not always possible to completely remove or modify information in our databases and servers, although we will always make reasonable efforts to do so upon your request.

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10.    Links to Other Websites

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This Website may provide links to other websites. Please be aware that our Privacy Policy does not cover these other websites. This Privacy Policy does not cover the information practices exercised by other providers of products or services, advertisers or other websites, companies, or individuals, which are not owned or controlled by Fareplace. When linking to another website, we suggest you always read that website’s privacy policy before volunteering any personally identifiable information.

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11.    Data Security

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We deploy industry-standard measures to ensure the security, confidentiality, integrity, and availability of the Personal Information we process. We maintain physical, technical, and administrative safeguards and test and update these periodically. We endeavor to restrict access to Personal Information on a ’need to know’ basis for the provision of our Website, and Services to you. No such measures are perfect or impenetrable. We will take all reasonable actions to minimize harm in a security breach. Although we will do our best to protect Personal Information, we cannot guarantee the security of data transmitted to us, and transmission is at the user's own risk.

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12.    Data Retention

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Generally, Fareplace does not retain information longer than necessary to provide its Website and for its reasonable business and lawful needs. Suppose you withdraw your consent to us processing your Personal Information. In that case, we will erase your Personal Information from our systems unless the Personal Information is required for Fareplace to establish, exercise or defend against legal claims or it is necessary for the performance of the Website.

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13.    Children’s Privacy

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The Website is not intended for children under the age of 18. We do not knowingly or intentionally collect information about children under 18 years of age.

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IF YOU ARE UNDER THE AGE OF 18, YOU MAY NOT USE THE WEBSITE UNLESS PARENTAL CONSENT IS PROVIDED ACCORDINGLY.

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14.    Data Retention

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If you have any questions regarding this Privacy Policy or the practices described above, you are always welcome to contact us at [email protected].

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15.    Revisions and Modifications to our Privacy Policy

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We reserve the right to revise, amend, or modify this Privacy Policy at any time. When changing the policy, we will update this posting accordingly. Please review this Privacy Policy often so that you will remain updated regarding our current policies.

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16.    Governing Law and Jurisdiction

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This Privacy Policy will be governed and interpreted under the laws of the State of Israel without affecting its choice of law rules. You expressly agree that the exclusive jurisdiction for any claim or action arising out of or relating to this Privacy Policy shall be submitted to the competent courts in Tel Aviv, Israel, excluding any other jurisdiction.

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This page was updated on March 15, 2023.

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