[Last Updated: September 6, 2023]
MBD Financial Ltd., a company organized under the laws of the United Kingdom (“Cedar”, “our”, “we” or “us”), is the owner, developer and operator of an online platform enabling the collecting, storing, processing and communicating of Client Instructions and other information to, from and among Client, Members and Cedar (collectively "Services").
MBD Financial Ltd., incorporated under the laws of the State of the United Kingdom, is the ”Data Controller” (as such term is defined privacy legislation) of the Personal Data collected from Visitors Clients and Members.
Depending on your interaction with us, meaning if you browse our website, we collect two types of data:
"Non-Personal Data" meaning, information which does not identify a specific natural person and cannot reasonably be used for such identification. We collect Non-Personal Data regarding use of the website, such as the scope, frequency, latency, pages accessed and viewed, time and date stamp, interactions with content and materials displayed through our website, language preference, and other technical information regarding the device used to access the website, for example type of device, type of browser, operating system, etc. This data is considered as Non-Personal Data when collected on an aggregate basis, or otherwise not combined with online identifiers.
Also, we may sometimes process and anonymize or aggregate Personal Data and identifiable information in a manner that shall create a new set of data that will be Non-Personal Data. Such a new data set can no longer be associated with any identified natural person.
Non-Personal Data may be used by us without limitation and for any purpose, including for commercial, research, or statistical purposes, in order to maintain and develop our website, including among others, for ensuring the technical functioning of our website, to help prevent fraudulent use of the website, etc.
"Personal Data" meaning, individually identifiable information, namely information that identifies an individual or may with reasonable effort be used to identify an individual. This may include online identifiers, first and last name, email address, etc.
If we combine Personal Data with Non-Personal Data, we will treat the combined data as Personal Data.
We have included in the table below information about the types of Personal Data processed, how we process and use Personal Data, the lawful basis for which we do so subject to the GDPR and processing operations.
Depending on the nature of your interaction with us through the website, we may collect information as follows:
There are several types of cookies, and among others:
You may find more information about the cookies we use as well as opt-out of cookies or change your preferences and any time by using the cookies setting tool available on our website.
Also note that, 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 set your browser to block all cookies, including cookies associated with our website, or to indicate when a cookie is being used by us, by adjusting the privacy and security settings of your web browser. Please refer to the support page of your browser to learn more about how you can adjust your privacy and security settings. Please note that once you choose to opt out or disable cookies, some features of the website may not operate properly, and your online experience may be limited.
Where we use third-party advertising cookies, such third-party may independently collect, through the use of such tracking technologies, some or all types of Personal Data detailed above, as well as additional data sets, including to combine such information with other information they have independently collected relating to your online activities across their network of websites, for the purpose of enhanced targeting functionality and delivering personalized ads, as well as providing aggregated analytics related to the performance of our advertising campaign you interacted with. These third parties collect and use this information under their own privacy policies and we are not responsible for their privacy practices.
We share your Personal Data with third parties, including with trusted partners or service providers that help us to manage our business operation, website, etc. You can find here information about the categories of such third-party recipients.
Where we share Personal Data with services providers and partners, we ensure they only have access to such information that is strictly necessary in order for us to provide the services of fulfil the purpose for which data was shared. These parties are required to secure the Personal Data they receive and to use the data for pre-agreed purposes only, while ensuring compliance with applicable data protection regulations (note that, such service providers may use other Non-Personal Data for their own benefit).
Due to our global business operation, we may store or process your Personal Data in several territories, including, for example in Israel, the UK, EU, US or in other countries. Thus, your Personal Data may be transferred to and processed in countries other than the country from which you accessed our websites or otherwise the country of your jurisdiction. We will take appropriate measures to ensure that your Personal Data receives an adequate level of data protection upon its transfer. Where Personal Data collected from within the EU or UK, is being transferred outside such territories to countries which didn’t receive an adequacy decision on behalf of an authorized authority (such as the EU Commission), we will take necessary steps in order to ensure that sufficient safeguards are provided during the transferring of such Personal Data, in accordance with the provision of the standard contractual clauses approved by the European Union or the UK Information Commissioner’s Office . Thus, we will obtain contractual commitments or assurances from the data importer to protect your Personal Data, using contractual protections that EEA and UK regulators have pre-approved to ensure your data is protected (known as standard contract clauses), or rely on adequacy decisions issued by the European Commission. Some of these assurances are well-recognized certification schemes.
In addition, some of the third parties used for cookies management in our website, may store and process data globally, including in the US (e.g., Google Analytics servers). When granting consent for such cookies through the cookies tool in the website, you hereby acknowledge and approve such cross border transfer, in accordance with such third party’s privacy practices.
We retain the Personal Data we collect as long as it remains necessary for the purposes set forth above, all in accordance with applicable laws, or until an individual expresses a preference to opt-out.
In certain circumstances, we will retain your Personal Data for longer periods of time and mainly:
We may at our sole discretion, delete or amend information from our systems, without notice to you, once we deem it is no longer necessary for such purposes.
We acknowledge that different people have different privacy concerns and preferences. Our goal is to be clear about what information we collect, so that you can make meaningful choices about how it is used. We provide you with the ability to exercise certain choices, rights and controls in connection with your Personal Data. Depending on your relationship with us (e.g., if you are a visitor of our website or a Visitor), your jurisdiction and the applicable data protection laws that apply to you, you have the right to control and request certain limitations or rights to be executed.
Certain rights can be easily executed independently by you without the need to contact us, and for example:
Where we are not able to provide you with the information for which you have asked, we will endeavour 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 in accordance with applicable law.
We take great care in implementing and maintaining the security of our website Visitors’ Personal Data. We employ industry standard procedures and policies to ensure the safety of individuals’ information and prevent unauthorized use of any such.
We have implemented technical, physical and administrative security measures to protect the Personal Data we process. In addition, we limit access to Personal Data stored by us.
Although we take reasonable steps to safeguard information, we cannot be responsible for the acts of those who gain unauthorized access or abuse our website, and we make no warranty, express, implied or otherwise, that we will always be able to prevent such access.
The website is not intended for individuals under the age of eighteen (18). Accordingly, we do not knowingly solicit Personal Data from or market to children as defined under applicable law. We request that such individuals do not provide Personal Data. If you become aware or have any reason to believe that a child has shared any Personal Data with us, please contact us through the means of contact detailed herein.