Privacy Policy

1. Who we are (database owner)

Data is collected and managed by Saar Robert Adi, a licensed dealer (Osek Murshe), dealer no. 301721155, No. 117, Kibbutz HaHotrim, 3087000, Israel ("SENTLOCK", "we"), who is the owner of the database and responsible for processing the data.

2. What data we collect

• Information you provide — e.g. contact details when registering or purchasing a subscription (name, business name, email, phone);
• Transaction information — plan, amount, currency and payment identifiers; the card details themselves are not collected by us (see section 6);
• Information collected automatically — log data, IP address and usage data, and analytics cookies — subject to consent;
• We do not collect specially sensitive data through this marketing website.

3. Why we use it & the basis

We use the data to provide the service and manage the subscription, to communicate with you, to meet legal obligations, and to improve and secure the service. The basis for processing is your consent, performance of our engagement with you, a legal obligation, or a legitimate interest, as applicable.

In line with Amendment 13's enhanced transparency requirement, this document clarifies what data is collected, for what purpose, the risks, and with whom it is shared.

4. With whom we share data

We do not sell personal data. We may share data with service providers acting on our behalf, including:

• PayPlus — the payment processor, to process payments;
• infrastructure, hosting and analytics providers acting as our data processors;
• competent authorities, where required by law.

5. Cookies

We use essential cookies, and — subject to consent — analytics and marketing cookies. You can manage your preferences at any time via "Cookie preferences" in the site footer.

6. Payment data & card security

Card details are entered directly into the secure Hosted Fields of the payment processor PayPlus, hosted in PayPlus's environment. Card details do not pass through SENTLOCK's systems, are not stored by us and are never collected by us at any stage. PayPlus is responsible for securing card data in accordance with the PCI-DSS standard.

7. Data retention

We retain personal data for as long as it is needed for the purposes for which it was collected, to meet legal obligations (including tax and accounting duties) and to protect legal rights, after which we delete it or render it anonymous.

8. Your rights

Subject to applicable law, you have, among others, the following rights:

• to inspect data about you and request its correction or deletion, under the Protection of Privacy Law;
• to withdraw consent at any time;
• to submit an inquiry or complaint to the Privacy Protection Authority;
• for EU users — rights of access, rectification, erasure, restriction, portability and objection under the GDPR.

9. Data security

We apply reasonable technical and organisational measures to protect the data, in accordance with the Protection of Privacy (Data Security) Regulations, 5777-2017, including access control, encryption in transit and security procedures.

10. International transfers

Where data is processed outside Israel (e.g. by infrastructure providers), this is done subject to the provisions of Israeli law on transferring data abroad and with appropriate safeguards.

11. Contact & Data Protection Officer

For any privacy matter: email privacy@sentlock.co, or by post to Saar Robert Adi, No. 117, Kibbutz HaHotrim, 3087000, Israel. If a Data Protection Officer (DPO) is required under Amendment 13, their details will be published here.

12. Changes to this policy

We may update this policy from time to time. An updated version will be published on this page with the date of the update.

13. Governing version

In case of any discrepancy between this version and its translation into any other language, the Hebrew version prevails.