Privacy Policy

Introduction

This Privacy Policy outlines the commitment of SerVC, Ltd. and its affiliated entities (collectively, "Orca", “SerVC,” “we,” “us,” or “ours”), as the controller, to safeguard the private information of our employees, clients, and business partners (collectively, “you” or “your”). By accessing or using our websites, related applications and services at https://servc.co.il, https://orcainc.com, https://fms.orcainc.com, http://portal.orcainc.com, and other subdomains (collectively, the “Services”), you agree to the terms and practices described in this Policy.

This Policy details the types of information we collect from you, or that you provide, when you visit, access, or use our Services. The information we collect may include details you provide through forms on our websites, correspondence records, survey responses, and materials you upload. Different privacy notices may apply to specific services offered through our websites, and we will provide those notices to you when applicable.

Information Collected from You

This Policy covers information collected:

On our websites. In email, text, and electronic messages between you and our Services, including through third-party services used by our websites for support functions. Offline or through other means, including on other websites operated by SerVC and its affiliates. We might collect a variety of information directly from you, automatically as you navigate our websites, and from third parties to provide and improve our services:

• Identifiers like name and contact details.
• Financial/transaction information, investment deals.
• Internet or other electronic network activity information.
• In addition, we might use automatic data collection technologies, such as cookies and web beacons, to gather information about your equipment, browsing actions, and patterns. This information helps us improve our websites and deliver personalized services.

Please be aware that any information you provide or transmit to third parties is done at your own risk.

Use of Information

The information we collect is used for several purposes:

• Providing and improving our services
• Fulfilling our contractual obligations
• Notifying you about changes to our services
• Customizing your experience

We retain your information only as long as necessary for these purposes and dispose of it securely when no longer needed.

Sensitive Data Handling

SerVC states that it does not seek to collect special categories of personal data, referred to as “sensitive data,” which includes racial or ethnic origin, political opinions, religious beliefs, health data, genetic and biometric data, or trade union memberships. If unsolicited sensitive data is provided to SerVC, the user consents to its use in conformity with the Privacy Policy​​.

Our Pledge About Data Use

SerVC pledges to only collect data that is of legitimate interest and necessary for improving its products and services. SerVC is committed to maintaining fairness and transparency in how we collect and process data. SerVC explicitly states that we will never sell user data and will only share personal data with explicit consent for a specific reason​​. By using our Services, you consent to the collection, use, and disclosure of your personal information as described in this Policy. You have the choice to withhold or withdraw consent for non-essential uses of your data.

‍Disclosure of Your Information

We may disclose aggregated and personal information to employees, affiliates, contractors, service providers, legal advisors, and other third parties as necessary for our services. We may also disclose personal information to law enforcement, regulatory, or other government agencies as required by and in accordance with applicable laws, regulations, legal obligations, enforce agreements, or to protect our rights and safety.

Children Under the Age of 18

We do not knowingly collect personal information from children under 18. If you believe we have collected information from a child under 18, please contact us at support@orcainc.com.

No Legal Duty to Provide Data

You are not under any legal obligation to submit personal information to us. However, if you choose not to do so, certain Services might not be available to you.  

We shall process personal information solely for the purpose for which the data was lawfully established. Should we seek to introduce additional purposes and/or to collect additional personal information, we shall obtain your prior consent. However, if such consent is not granted, we may be unable to provide certain or all Services to you.

Your Israeli Privacy Protection Law Rights

Subject to the Israeli Privacy Protection Law, 1981 and its implementing regulations (the “Israeli Privacy Law”), you have the following rights with respect to your personal information processed by us, we will act in accordance with the Israeli Privacy Law, to comply with your requests to exercise your rights:

1. You may ask whether we hold personal information about you and request copies of such personal information and information about how it is processed;

2. You may request that inaccurate personal information is corrected;

3. You may request the deletion of certain personal information;

4. You may request that we cease or restrict the processing of personal information where the processing is inappropriate;

5. When you consent to processing your personal information for a specified purpose by us, you may withdraw your consent at any time, and we will stop any further processing of your personal information for that purpose.

6. You may request that we export your personal information, or transfer it to a third party, subject to applicable legal requirements.

In certain circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, however, in those circumstances, we will still respond to notify you of such a decision.

You can exercise your rights of access, rectification, erasure, restriction, objection, and data portability by contacting us at the information provided in the "Contact Information" section below.

Your California Privacy Rights

If you are a California resident, you have specific rights regarding your personal information under the CCPA. To exercise these rights, please email us at support@orcainc.com. We will respond to your request within 45 days and provide a basis for any denial.

California’s Shine the Light Law

California residents may request information regarding our disclosure of personal information to third parties for direct marketing purposes. To make such a request, please email us at support@orcainc.com.

General Data Protection Regulation (GDPR)

If you are a resident of the European Union, you have rights under the GDPR, including access, rectification, erasure, data portability, objection, and consent withdrawal. To exercise these rights, please email us at support@orcainc.com.

1. Data Processing Grounds: We process your personal data on several legal bases, including your consent, necessity for the performance of a contract with you, compliance with our legal obligations, and our legitimate interests. For each processing activity, the specific legal basis is clearly identified.
2. Data Subject Rights: Under the GDPR, you have the right to access, rectify, erase, restrict processing, and object to processing of your personal data, as well as the right to data portability. You can exercise these rights by contacting us at support@orcainc.com
3. Data Protection Officer (DPO): Our Data Protection Officer oversees compliance with data protection laws. You can contact the DPO at support@orcainc.com for any questions or concerns regarding your personal data.
4. Data Breach Notification: In the event of a data breach, we will notify the relevant supervisory authority within 72 hours and communicate with affected data subjects without undue delay, in accordance with GDPR requirements.
5. Impact Assessment and Compliance Documentation: We conduct Data Protection Impact Assessments for high-risk processing activities and maintain records of our processing activities, ensuring compliance with GDPR.

Accessing and Correcting Your Information

You can review or change your personal information by logging into your user/investor account profile(s) on the websites. For assistance, email us at support@orcainc.com. We may retain certain information as required by law or for legitimate business purposes.

Data Security

We implement security measures to protect your information from unauthorized access and loss. However, please keep your password confidential and avoid sharing it. We encourage two-factor authentication for an enhanced security.Additionally, you are responsible for providing accurate and updated information. We strive to maintain data quality and integrity.

Generative AI Use

At SerVC, we utilize generative AI tools within ORCA to enhance the functionality of our platform, including automation, analytical tools, summaries, and informational insights. These tools are designed to support operations under strict human oversight and system controls. Please note that AI-generated outputs are provided for informational purposes only and do not constitute professional advice.

For more details on how we use generative AI and our policies around data protection and confidentiality, please refer to our Generative AI Use Policy.

Monitoring and Enforcement

We monitor our data practices to ensure compliance with this Policy and applicable laws, and we have mechanisms for addressing privacy-related complaints and concerns.

Incident Reporting and Requests for Information

We take the security of our systems seriously and encourage you to report any incidents, bugs, failures, vulnerabilities, or any other technical concerns related to our Services. Additionally, if you have any specific requests for information not covered by this Privacy Policy, please reach out to us.

How to Report:

• Complaints, Bugs, and Incidents: If you encounter any issues related to the functionality or security of our Services, please report them to us at support@orcainc.com.
• Vulnerabilities: If you identify any security vulnerabilities, please email support@orcainc.com directly. We will investigate and respond to all reports in a timely manner.
• Requests for Information: For any additional inquiries or requests for more information, you may contact us via support@orcainc.com.

We strive to respond to all reports within 72 hours, and where applicable, we will take appropriate steps to address any reported issues, including notifying relevant parties or regulatory authorities.

Third Parties Authorized to Receive Personal Information

To provide and enhance our services, we work with trusted third-party service providers who may receive personal information (PII). These third-party vendors assist us in hosting, data storage, communication, and operational functions. The following third parties are authorized to receive PII for these purposes: AWS S3, AWS Cognito, MongoDB, Twilio, Box, Zapier, Termly, and Webflow. We ensure that these third parties maintain industry-standard security measures in compliance with SOC II requirements to safeguard your personal information. Your data is shared with these providers solely for the purposes of delivering our services, and we ensure that appropriate data protection agreements are in place.

Right to Object to PII Processing

You have the right to object to the processing of your personally identifiable information (PII) in certain circumstances, as required by applicable data protection laws, including SOC II standards.

How to Object:

• Submit Your Request: Email our Data Protection Officer at support@orcainc.com, clearly stating your objection and the specific processing activity in question.
• Response Time: We will acknowledge your request and respond within 30 days. If more time is needed, we will notify you of an extension.
• Review Process: We will assess your objection. If valid, we will stop processing your PII for the specified purpose. If we need to continue processing for legal or contractual reasons, we will inform you.

Exceptions:
Please note that objections may not apply if the processing is required for legal obligations, contract fulfillment, or the protection of vital interests.

Changes to Our Privacy Policy

We will post any changes to this Policy with a notice on our websites. It is your responsibility to stay updated by periodically checking our websites and this privacy policy. Your continued use of the Services after any changes to this Policy constitutes your acceptance of those changes.

Contact Information

For questions, complaints, or exercising your rights under this Policy, contact us at:

Website: https://www.orcainc.com/privacy-policy

Email: support@orcainc.com

Postal Address: WeWork, 1st floor, Shankar St. 1, Herzliya, 4672501, Israel