PrivacyPolicy

Bank of Jerusalem Ltd. Privacy Policy

Bank of Jerusalem Ltd. (hereinafter: “we,” “the Bank”) considers safeguarding the privacy of its customers, employees, and service users (hereinafter: “you”) to be of the utmost importance and is committed to maintaining that privacy.

The Privacy Policy was created out of this commitment to safeguarding your personal data and information, and its purpose is to provide an explanation regarding which information we collect, the reason for collecting such information, and how we use it. In addition, this policy outlines how you can exercise your rights under the Privacy Protection Law 5741-1981 and its amendments, as well as the steps we take to maintain the confidentiality and security of your information.

The provisions of this policy apply to the services provided by the Bank and to the Bank’s websites available under the Bank’s domain names, as well as to the Bank’s customers, potential customers, end users, employees, subcontractors, visitors to the Bank’s premises, business partners, suppliers, and so forth.

Policy Applicability

1. The Privacy Policy defines the Bank’s relationship to personal data and how it handles such information.
2. “Personal data” is information about a particular person, or information that can be used to identify a particular person, such as: name, ID number, location data, biometric identification details, health status, education, financial status, employment information, and so on (hereinafter: “Personal Data”).
3. “Non-personal data” is information that is unrelated to a particular person or cannot be associated with any particular person.
4. The restrictions and requirements set forth in this policy regarding the manner of collection, use, disclosure, transfer, storage, and retention of said Personal Data do not apply to non-personal data.
5. Non-personal data is subject to our general usage policy, as found at https://www.Bankjerusalem.co.il/others/trial

Information Collection, Type, and Usage

6. Collection of Personal Data: In the course of using the Bank’s websites and/or any other technology provided under the auspices of the Bank, whether in the context of consuming or visiting the Bank’s services; and/or as part of our provision of such services to you and/or as part of the operation of such a service; and/or through your interest in the Bank’s services, when visiting the Bank’s branches and/or using in-person and/or telephone and/or digital services, you may be required to provide personal data about yourself, and/or personal data may be collected and provided to the Bank by third parties and/or shall be collected automatically through the use of the Bank’s technologies and interfaces with other databases, subject to your consent and/or regulations and other applicable laws.
7. The Personal Data that is collected may include: first name, last name, marital status, telephone number, demographic information, details on your personality, financial information, credit data, biometric information, photographs, information about people related to you, information about criminal charges, information about the device you use to access these services (such as: device type, device model, operating system, etc.), location data, actions performed on the website, IP address, mouse movement or screen recording, and so forth.
8. As a general rule, the provision of such Personal Data is dependent on your desire and consent, whether given in advance or in retrospect, and may be subject to active or passive consent. However, there may be certain cases in which the provision of such data will be deemed essential, in accordance with legal requirements or the law applicable to the matter at hand. In these cases, you are permitted to withdraw your consent by notifying the Bank. It will be clarified that such withdrawal of consent may prevent the Bank from providing you with the desired service.
9. To the extent that a given service is intended for a minor user under the age of 18, the user must obtain the consent of a parent or legal guardian prior to using the services and providing Personal Data within the context of such services.
10. The Bank reserves the right to take security measures and utilize automated software to collect user data in order to verify and/or authenticate the identity of users of its various online/digital services and to prevent instances of fraud, deceit, and identity theft.
11. The Bank uses various software programs and technologies based on, among other things, cookies, tags, and pixels (hereinafter, collectively: “Cookies”), to facilitate the ongoing operation of the online services, in order to verify your details and/or identity and to collect and characterize various statistical data about you and your usage of the online services, actions performed, and usage preferences, to adapt services and products to the user’s personal preferences or needs, to adapt and target advertisements and marketing content in accordance with the information and data that has been collected and processed, and to cross-reference all such data with the user’s other online services and other platforms provided by and/or through the Bank, whether via direct in-branch interaction with the Bank in the course of managing the user’s accounts and/or via other online and digital activities of the user through the Bank’s other sites. This may involve the use of third-party Cookies, such as Google Analytics, ReCaptcha, AppsFlyer, Firebase, and other advertising and statistical services offered by companies such as Google and Facebook, in accordance with their terms of use and privacy policies, in order to analyze and monitor events and activities across digital channels and identify patterns of use in an aggregate, deidentified manner.
12. Cookies are actually text files (or lines of code) that are created within your browser and/or mobile device, generally within the device/computer settings, and gather relevant information, such as how long you stay on the site/page/screen, your browsing behavior and the actions you perform, including the IP address of your device, the referring domain name and how you accessed the service, device location, connection dates, and other digital identification codes. The Bank needs to cross-reference such data and activities to, among other reasons, secure your information and protect access to your Personal Data, as well as to prevent fraud, identity theft, and unauthorized use or misuse of the various services the Bank provides for you. In addition, this data will also be used to make financial, business, and other decisions regarding the provision of various services to you and the scope of such services.
13. You may update or change the settings of your device/computer at any time and completely or partially block the use of various Cookies and/or other permissions requested by the online and digital services you use. In such an event, some services, in whole or in part, may not function correctly (for example, automatic user identification, usage preferences, or language preferences may not be saved). Changing the settings of your device, as stated, is at your own risk. You may also opt out of using third party services (such as Google Analytics) under the terms of such services, and they may redefine and alter the advertising directed at you by that third party (such as Facebook) in line with your user settings on their sites.
14. By accepting the terms of this Privacy Policy, you agree to the use of the technologies described and other technologies as may be used for similar purposes from time to time, including the use of information that will be stored through such technologies for the purpose of identifying and/or analyzing your activities. 
15. The Bank uses, receives, collects, processes, and stores solely the information it requires for the purposes of, among others:
    • Providing information and services: Including processing and analyzing data, making decisions related to contacting you, providing services tailored to you, optimizing services, managing an account, and providing customer service. The Bank may require access to Personal Data for the purpose of its work. The Bank (and its employees) is bound by the Privacy Policy and by banking secrecy, and is prohibited from using the information, with the exception of the purposes detailed above.
    • Business management: Improving the service, upgrading the content of the site, collaborating with business entities to provide services, creating statistical reports that contain aggregate, deidentified information; security – the Bank may use personal information to secure the website and the services offered on it, to detect and prevent cyber attacks, fraud, phishing, identify theft, and information leaks, and to verify software licenses and their originality. For complete information about purposes related to information security, please see the following link: https://www.bankjerusalem.co.il/others/security; marketing and advertising – the Bank may use personal information to contact you for marketing and advertising purposes, including, but not limited to, sending a message about a new service or product that might interest you. If you receive an advertisement without your consent or you wish to stop receiving direct marketing emails, you can request to be removed from the mailing list by using the “Remove” link included within the advertising material.
    • Compliance with regulatory provisions and applicable laws:
      • Data storage and archival – The Bank stores and/or archives Personal Data for as long as is required for the purpose of business management and the provision of services and/or the fulfillment of obligations under any law, standard, regulatory provision, or contract, and subject to this Privacy Policy.
      • Law enforcement – The Bank may use Personal Data in response to a court order or directive from the government or law enforcement agency (regulator) (including in response to the requirements of authorities regarding national security or law enforcement needs), or out of a good faith belief that such an action is necessary for: (a) compliance with a legal obligation, (b) protecting the rights of the Bank and its interests or those of third parties, (c) preventing or investigating service failures, (d) taking urgent action to protect the security of users of the website and the services or the public, or (e) supplying a defense against legal claims or legal liability.

16. Insofar as the Bank makes use of Personal Data in a manner not detailed and defined in this Privacy Policy, you will be notified of such an intention, either in advance or at the time of using the Personal Data.
17. If you have a reasonable basis to believe that the Bank has not complied with any instruction of those detailed above, you are asked to notify the Bank as soon as possible by calling the customer service center at *5727 or by contacting the Bank through the website.
18. Deidentified information: As deidentified information cannot be used to identify any particular person, the Bank reserves the right to use such information in any way that is not prohibited by law and in accordance with the Bank’s terms of use and/or agreement.
19. All information is stored in the Bank’s databases and is used in accordance with the defined purpose for which it was collected. This information is stored in accordance with all applicable laws.

Duty of Confidentiality and Information Security

20. All Personal Data provided by you and/or received within the context of the services and/or as a result of your use of the website shall be kept confidential in accordance with the Bank’s duty of confidentiality and/or the Protection of Privacy Law, 5741-1981, and subject to all legal or regulatory obligations and/or requirements that apply to the Bank.
21. The Bank is obliged to secure the Personal Data and information, as stated, in accordance with the law and its procedures. The Bank uses appropriate technological means, as is customary in the industry, in accordance with its regulatory obligation to maintain information security, reduce risks, and protect it from loss, improper use, alteration, theft, damage, information loss, unauthorized access, or unauthorized use.
22. However, information security is also dependent on your actions. Your awareness of information security, preventive actions, and cautious behavior can reduce threats to information security. For this purpose, we have created a page of suitable guidelines for you, which is updated periodically and is available on the Bank’s website, at: https://www.bankjerusalem.co.il/others/security
23. The Bank shall not accept any claim or be held liable for any damage that may be caused to you, the user, or to any third party as a result of loss of Personal Data and/or unauthorized use of Private Data due to circumstances that are not under the Bank’s control and/or resulting from force majeure and/or software or hardware or communication disruptions for which the Bank is not responsible.
24. In the event of any concern regarding a breach of information security and/or the confidentiality of information, please notify the Bank by calling the customer service center at *5727 or via the Bank’s website.

Data Transfer, Third Party Processing, Sharing and Disclosure

25. As a general rule, the Bank does not share Personal Data without the consent of the customer. However, there may be instances, as set forth in this Privacy Policy, in which Personal Data is transferred in accordance with legal or regulatory provisions and/or when deemed essential at the discretion of the Bank in good faith. In any case, the Bank ensures that only the required information is transferred.
26. The Bank may share Personal Data with its partners, contractors, suppliers, and third parties who process Personal Data on its behalf for the purpose of its business activities, offering, provision of services, decision making, and so forth. These parties have been selected, reviewed, and approved by the Bank and have been charged by it to meet the level of privacy protection and information relevant to the Personal Data and the requested processing. The Personal Data shared shall be the minimum necessary and relevant for the purpose of performing their function and/or solely for the purpose for which it is shared.
27. In addition, the Bank shall share Personal Data with regulators, law enforcement agencies, and so forth, in accordance with its obligations under the law and/or applicable regulations. The Bank ensures that only the information required by law and by regulation is transferred and also secures the transfer to the relevant party. Furthermore, Personal Data may be shared with the Bank’s subsidiaries within the context of its business management and/or for the purpose of offering additional services to you that, in its opinion, constitute complementary and/or ancillary products and/or products that may be of interest to you (subject to your consent). The Bank ensures that the subsidiaries meet the standard of privacy detailed in this policy insofar as it applied to them and/or that they comply with all requirements of the Protection of Privacy Law and its regulations and/or any other regulation that applies to them.
28. Your Personal Data may be shared with third parties, in accordance with certain actions performed by you, for the purpose of completing and performing such an action. For example, when transferring funds, the account name and account number shall be shared, or when depositing a check, a copy / details of the check shall be shared, with the receiving party and/or service providers for the purpose of carrying out your requests. In any case, the Bank charges the third party to maintain a level of confidentiality and information security that is no less than and/or equal to the level required by the Protection of Privacy Law and its various regulations, including the Protection of Privacy (Data Security) Regulations, 2017.
29. Cloud Services: The Bank uses cloud technologies, in the context of which the cloud service provider may have access to Personal Data, for example, but not limited to, cases in which the cloud service provider requires access to Personal Data for the purpose of securing the information or securing the Bank’s website. In such cases, the cloud service provider is obliged to comply with the Bank’s Privacy Policy and information security policy and duty of confidentiality at the level at which the Bank has committed itself in regards to you, and may not make any use of the information shared with it, except for the purpose for which it was shared.
30. Sale, Merger, Reorganization, Liquidation, Etc.: Personal Data may be included in the assets shared in the appointed cases. Whosoever steps into the shoes of the Bank or its purchaser shall continue to hold the right to use Personal Data in accordance with and subject to this Privacy Policy.
31. Without derogating from the aforesaid uses detailed above, and to the extent that the settings of your device/computer permit it, the Bank may provide statistical and/or aggregate information, which is depersonalized and cannot personally identify you, to third parties, among other purposes, to improve, enhance, or streamline the service and auxiliary or related services, as well as to provide custom content adapted to your needs and preferences. 

Data Retention

32. The Bank may retain Personal Data for any period permitted or required by law. It may not be possible to delete such data permanently, as it is protected under the legal obligation to retain it in accordance with the laws and regulations applicable to the Bank. In such a case, we shall render the data unavailable (as if it had been deleted) and use it only for the purposes for which it is retained by law or regulation.

Your Rights

33.  You have the right to review Personal Data about you stored in the Bank’s databases. This right of access does not apply to any database established in accordance with Section 28 of the Prohibition on Money Laundering Law. In addition, you may request to change, update, correct, or delete information that is incorrect or inaccurate, and so forth.
34. u Insofar as you wish to exercise these rights, you must contact us in writing via the contact page on the Bank’s website (at: https://www.bankjerusalem.co.il/support/) and/or by telephoning the customer service center at *5727. Upon receipt of the request, the Bank shall evaluate whether the right can be exercised and to what extent. The right may not be exercised, or may not be exercised to its fullest extent, if you do not own the information, the information provided does not match the information in the databases of official national authorities upon which the Bank relies (e.g., the Population and Immigration Authority), and/or the request is unclear and non-specific, violates the privacy of others, and/or is not made in good faith.
35. Insofar as the information is not in the direct possession of the Bank, the Bank should be contacted for evaluation and exercise of the aforesaid rights in addition to contacting a third party. The Bank handles cases starting from the submission of a formal application to the Bank, as stated in this section (in writing or by telephone), and the total time elapsed under the Protection of Privacy Law shall begin from the moment the application is submitted to the Bank, either directly by you or by a third party and/or any other entity.
36. The customer has the right to be removed from direct email marketing services. If you do not wish to receive email newsletters and/or advertising, you can use the removal button included in the newsletters/advertisements, or contact the Bank at Privacy@bankjerusalem.co.il.

Miscellaneous

37. This Privacy Policy does not apply to any Personal Data transferred by you to third parties.
38. This Privacy Policy does not apply to websites or applications of third parties that are linked to by the Bank’s website and/or third parties whose services or products are distributed by the Bank. Links and references found on the Bank’s websites do not constitute the Bank’s endorsement of these websites or services or any indication that the Bank has reviewed them. The Bank recommends that you contact the third party for clarification regarding its own privacy policy.
39. In the event that you choose to use and/or download and/or install external websites/pages/applications which interface with the use of the services, the Bank has no control over the terms of the privacy policy of such external websites/pages/applications and/or how they operate and/or the consequences of using such external websites/pages/applications and/or the risks related to the use of such external websites/pages/applications, and the full responsibility for the use of such external websites/pages/applications rests solely on you.
40. It is hereby clarified that, in addition to this Privacy Policy, the legal aspects and any additional terms of use, if any, shall also apply to the services and/or products, as well as all the documents you have signed in connection with the bank account held in your name, insofar as it is held. All that is stated in these terms is in addition to any other agreement between you and the Bank.

Changes to the Privacy Policy

41. The Bank’s services may change from time to time, as a result of which this Privacy Policy shall also be updated. The Bank reserves the right to update, change, or make adjustments to the Privacy Policy at its sole discretion at any time (hereinafter: “Updates”). Updates to the Privacy Policy shall be published on the Bank’s websites, indicated by the “Last Updated” date as seen at the head of this Privacy Policy.
42. You are encouraged to review the Privacy Policy from time to time, and especially prior to providing any Personal Data.
43. This Privacy Policy was last updated on the date indicated above and the continued use of the services after the implementation of changes to the policy indicates the acceptance of such changes. If you do not accept any such change, you are obliged to cease visiting the Bank’s websites and receiving any Bank services, to the greatest extent possible.

Inquiries and Complaints

44. The Bank believes in providing effective solutions to issues in a way that will be satisfactory to all parties, and we undertake to take reasonable measures in an effort to address inquiries and complaints. You are welcome to contact us with any inquiry, complaint, or privacy application at Privacy@bankjerusalem.co.il.

Last Updated: 19.01.2021