Privacy Policy

Welcome to the privacy policy of FRÉ Skincare Ltd., company registration number 515311470 ("the Company" or "we"), which operates the online shopping website https://freskincare.co.il ("the Website" or "the Site"). We respect the privacy of customers and users of the Website and the Company's services ("the Users" or "the User").

The following privacy policy describes how we collect information provided by you and/or information collected during your use of the site, the type of information collected, the way the information is used, and the manner in which you, as the data subject, may remove or change it. This privacy policy is an integral part of the website's terms and conditions of use, and they should be read together.

The contents of this document are written in the masculine gender for convenience purposes only and are intended for both women and men.

The section headings in this privacy policy are for convenience of use and shall not be used for interpretation or any other purpose.

General

By using the Website and/or as part of your engagement with the Company, you agree to the collection, use, processing, and retention of information that comes from you and/or is collected regarding you, in the manner described in this privacy policy. If you do not agree to the terms of this privacy policy, you must cease using the site and the services.

In this policy, the term "Information" means any data relating to a person through which that person can reasonably be identified, and in accordance with the definition of "personal information" in the Privacy Protection Law, 1981 ("the Law"), including your first and last name, ID number, residential address, telephone number, email address, etc.

The information provided and/or collected about the User will be stored in the Company's databases, of which it is the controller. It is clarified that the provision of information is subject to the User's consent and willingness, and the User is under no legal obligation to provide the information. However, without providing the information, the Company may not be able to provide some or all of the information and/or services to the Users. If you have chosen to provide information, please provide accurate and complete data relating only to you (providing personal details of a third party is prohibited unless you have obtained their express consent to do so). Providing incorrect details, or failing to provide all required details, may, among other things, prevent you from completing registration, using the site's services (in whole or in part), harm the quality of the service provided to you, and even prevent us from contacting you if necessary.

What information do we collect?

As part of your use of the Website and the Company's services, for the purpose of making purchases on the site, communicating with customer service, participating in sales promotions, and other actions, the User may be required to provide personal information and/or personal information may be collected about them, as detailed below:

• Information you provide to us and/or that is collected by us - When registering for the Website and services and during their use, in order to create an account and/or to place an order, you will be asked to provide us with, and/or information will be collected about you, such as first and last name, address, telephone number, email address, payment method details, monitoring of purchasing processes, products you have shown interest in or requested to purchase, shopping cart content, advertisements you have clicked on, times you have used the site, reviews of products and services, and any other information provided or received in connection with the User and the services. In addition, it may be possible for the User to connect to the site using an existing account on social networks or other platforms (Facebook, Google, etc.), without opening a dedicated account on the site. You are aware that by connecting to the site using such platforms, you authorize the automatic collection of information stored in your accounts on those platforms.
• Communication with customer service - As part of communication (telephone or digital) with customer service, or via a dedicated form on the site, information may be collected by the Company that can personally identify the User, including first and last name, contact details, content of the inquiry, purchase history, and any other information provided.
• Use of the site - As part of the use of the site, information will accumulate regarding your shopping habits and preferences, products and services you have purchased, information about articles, products, and services that interested you, pages on the site you viewed, offers and services, advertisements and topics of interest to you, information pages you visited, registration for special services requiring registration, offers and services that interested you, your IP address, browser type, operating system, and additional statistical information, among other things, through Google Analytics (and as detailed in the Cookies policy below)
• Mailing list and customer club - For the purpose of signing up for a mailing list or customer club, the User will be asked to provide information including personal details, contact details, and additional details.

The information collected will be stored by the Company for the period necessary to ensure the objectives detailed in this privacy policy unless a longer retention period is required or permitted by law.

The Database

Use of the site and/or the services offered by the Company constitutes your agreement to this privacy policy and that the information provided and/or collected about you will be stored and managed in the Company's database, which is stored with hosting and data backup providers that may also be located outside the borders of Israel, which are held and operated by third parties that are not the Company.

Purposes of using the information

The use of the information provided by you and/or collected about you will be done in accordance with the provisions of this privacy policy and the purposes of the database, and subject to the provisions of any law - for the purposes detailed below:

• To improve and operate the site, services, products, and content offered therein, including through statistical analysis of actions and user behavior, for the purpose of developing services, products, and content tailored to your needs, and for segmentation and media analysis.
• To tailor the advertisements, content, and services displayed to you during your visit to the site, for the purpose of creating customer profiles and monitoring user actions on the site, and for marketing contact to you for the purpose of sending marketing offers, including personalized advertisements.
• To identify you and save you from having to enter your details every time you return to areas where registration is required, to enable you to use the site, the content included in it, and the services it offers, and to manage, support, and resolve technical and other problems on the site.
• In order to contact you for the purpose of providing service and support, including in connection with placing an order, coordinating delivery times, sending satisfaction surveys, following up on updates regarding missing products, and collections.
• In order to comply with the requirements of any law, regulation, or other legislation and to assist competent authorities and any third party, when we believe in good faith that we must do so.
• For the purpose of enforcing our terms of use and/or any agreement with the Company and/or anyone on its behalf, including fraud prevention.
• To send you from time to time, via email, SMS, WhatsApp, or any other means including social networks and similar technologies (whether current or future), information regarding the Company's services and products, whether by the Company itself or in cooperation with others, advertising information, promotions and sales, newsletters, direct mail and/or other, and any other correspondence and content, as well as providing mailing and information services in connection with products and services of others. Such information will be sent to you in accordance with your consent at the time of creating your account on the site or at the time of purchase or otherwise. If you do not wish to receive these messages, you may choose not to join the site's distribution list, or remove your details at any time from the site's distribution list by any means provided to you in any email message you receive from the Company. If you are not the only user of the email address to which the marketing content is sent, you confirm by your consent to receive marketing messages from the site via email that you have obtained the consent of all other users of the aforementioned email address and that your consent constitutes their consent as well to receive marketing messages via email from the site. It is clarified that consent to this privacy policy constitutes consent for the purposes of Section 30A of the Communications Law (Telecommunications and Broadcasting), 1982. The Company will also be entitled to transfer the information from time to time to third parties, as detailed below.
• In order to contact the User and/or send them operational messages, alerts, and updates in various ways, including via email, messages, and SMS.
• To verify the information you provided to us at the time of registration to the site and/or during your use of it (including by referring it to external service providers, in order to protect against fraud).
• For the purpose of conducting surveys, including satisfaction surveys, including in connection with promotions and/or services offered by the Company, anyone on its behalf, and/or third parties with whom the Company has cooperation.
• For the purpose of managing customer clubs, as well as for the purpose of managing and providing service to customers.
• For the purpose of analysis, control, measurement, statistics, and research by the Company.
• For any other purpose detailed in this privacy policy or in the terms of use.
• To comply with the provisions of the law.

Without derogating from the above, we shall be entitled to make use of information that does not personally identify you for various legitimate purposes. Thus, for example, for the purpose of improving the services and applications offered on the site; for the purpose of tailoring content, services, and advertisements displayed on the site; and for the purpose of statistical research regarding the use of the site, services, and content offered through it.

Transfer of information to third parties

The Company will not transfer your personal details and the information you provided and/or was collected about you in connection with the use of the site and the services to third parties, except in the cases detailed below:

• To the extent necessary for the proper supply, management, and/or control of the services and content offered through the site and/or by the Company, such as transferring details to employees or related companies, subcontractors, or other entities involved in the site and its operation and/or providing the Company with services in connection with it, such as storage, courier, and logistics companies, clearing companies, companies providing support services for the Company's security and technology systems, lawyers and professional consultants, companies operating advertising and marketing services and platforms, etc.
• If a claim is raised or a suspicion arises at the Company that you have committed an act and/or omission that harms and/or is likely to harm the Company and/or anyone on its behalf and/or any third parties and/or on the background of a breach or suspected breach by the User of the terms of use of the site and/or the terms of the privacy policy and/or the provisions of the law and/or any agreement with the Company and/or anyone on its behalf.
• To the extent that the transferred information does not include details that would allow you to be identified personally.
• According to a legal requirement and/or if a judicial order is received instructing the Company to provide your details or the information about you to a third party.
• If we receive notice of legal proceedings against us regarding actions taken by you, as well as in any case of claim, demand, lawsuit, and any legal dispute, as far as they exist, between you and the Company and/or anyone on its behalf.
• If the Company organizes its activity or the activity of the site within another framework (including in the event that it merges with another entity or merges the activity of the site with the activity of any third party), and also in the event that it changes its legal structure, including in the event that the Company transfers the activity of the site and/or any part thereof to a third party - the Company will be entitled to transfer to the new entity a copy of the information collected about you, provided that this entity accepts towards you the provisions of this privacy policy.
• In the event that the Company believes that the provision of the information is necessary in order to prevent damage to the Company and/or anyone on its behalf, and/or to any third party, and/or in order to prevent other damage at its discretion.
• To companies and organizations related to the Company and/or with which the Company has cooperation, including a parent company, subsidiary, and sister company (including in connection with promotions, marketing activities, etc.), provided that they use the information about you according to the provisions of this privacy policy.

The transfer of information to third parties as described may also occur outside the borders of the State of Israel, including to third parties located in countries where the level of data privacy protection differs from the provisions of Israeli law.

It is clarified that the content you provide for publication on the site will be exposed to all users of the site. Therefore, act wisely and cautiously regarding providing content for publication. Remember also that you must exercise in providing content and inquiries at least the same degree of caution you exercise when making contact that is not done via the Internet.

You will have no claim or demand against the Company and/or anyone on its behalf regarding the provision of your details as described.

"Cookies" and other tools

We (and third-party entities that may provide service on our behalf), use automated tools that collect information such as Cookies and other tools (such as online analysis tools) and measurement pixels (including these - pixel tags, tags, web beacons) and the like, which are technologies sent to the device and/or browser from which the User is surfing and store various data files on it (hereinafter collectively "the Cookies").

The Cookies contain and collect various information such as the pages the User visited, the duration the User spent on the site, information the User viewed on the site, where the User came from to the site, the User's IP address including the estimated geographic location derived from it, the number of entries to the site, the characteristics of the User's device or computer including screen resolution, type of operating system and version, web browser type, version and language preference, domain names, and more. The Company as well as third parties operating the Cookies can access from time to time the information accumulated in the Cookies, and such information may be stored on the servers of the Company and/or of the third parties.

The Company uses Cookies for the following purposes, all or some: (1) ongoing operation of the site; (2) collection of data regarding the use of the site; (3) improvement of the browsing experience and tailoring it to the User; (4) statistical, research, marketing, and commercial purposes; (5) data security; and (6) tailoring content including marketing content that may interest the User, even when they surf other sites.

Where the Company allows the use of third-party Cookies, the use and information collected through them is subject to the privacy policies of those third parties. The Company has no control over the data stored in them and over access to the information, or over its cross-referencing with other information details, and these uses and others are subject to the privacy policies of those third parties. The Company has no control over the privacy policy documents of those third parties or the way they implement them, including in cases of requests to be removed from the ability to use Cookies.

Examples of using third-party Cookies - The Company uses Google Cookies such as those embedded using Google Analytics, which helps to tailor the browsing or usage experience for users and to derive statistical insights regarding the use of the site. The use of Google Analytics is subject to the relevant privacy policy of Google.

In addition, the Company uses various analysis and advertising systems of Google, Facebook, etc., as tools for measuring site usage characteristics, measuring the effectiveness of advertising campaigns, and selecting audiences for campaigns, and more. More information about these tools can be found, among other things, in the cookie policy of the aforementioned advertising systems.

Modern browsers and other technological tools allow limiting the receipt of certain cookies, so if you wish to avoid receiving them as described, you can do so by changing the browser settings. If you do not know how to do this, check the help file of the browser you are using. You should be aware that disabling the ability to receive cookies may result in you not being able to use our services, in whole or in part. Likewise, you can delete the cookie files from your computer at any time. It is suggested that you do so only if you do not want our services to be tailored to your preferences.
You can also use automated tools for managing Cookies according to your choice. Possible tools accessible for free use: http://www.aboutads.info/choices or https://youradchoices.com/control . For mobile devices see also: https://www.networkadvertising.org/mobile-choice.

It is clarified that deleting existing cookies does not affect information already stored in cookies, at the Company, and at third parties. In addition, and notwithstanding the above, cookies that are essential and necessary for the operation and management of the site cannot be disabled.

Advertisements on the Company's site and external links

In accordance with the provisions of the Communications Law (Telecommunications and Broadcasting), 1982, an advertiser shall not send a commercial advertisement via email or other telecommunications means without receiving the recipient's consent. If such consent has been given, you may retract this consent at any time by clicking the "Remove" button from the mailing list, which is attached to every promotional mailing, or by sending a removal request to the email address designated for this purpose: support@freskincare.com, or to any other email address designated for this purpose, as will be published from time to time.

In addition, within the site, advertisements and links to external sites and applications that are beyond the control of the Company and that are not covered by this privacy policy may appear. Clicking on such an advertisement or link will be done on the User's own judgment and responsibility. The User will be subject to the terms of the external site and/or application, including its privacy policy. The Company disclaims all responsibility for the privacy practices of other sites to which the Company may refer via such an advertisement and/or link, and the Company recommends that you examine the aforementioned privacy policy yourself.

Use of the site by minors

The Company's services are not directed at users under the age of 18. By browsing the site, you declare and undertake that you are not a minor. In the event that it becomes clear to the Company that it holds information collected from a minor without the consent of a parent or legal guardian, where such consent was required, the Company will act to delete this information as soon as possible.

Data Security

The Company attaches great importance to data security in its systems. In order to keep the information, the Company operates accepted systems, applications, and procedures for data security, designed to minimize risks of theft, damage, loss, or unauthorized access. However, despite the efforts and measures the Company takes, and while these systems and measures reduce the risks of unauthorized intrusion, they cannot grant absolute immunity. Therefore, the Company cannot guarantee that the site and/or its use will operate without any interruption and/or that the information collected within it will be absolutely immune from unauthorized access or misuse of stored information, and you are aware that the Company and/or anyone on its behalf will not bear any responsibility for any damage and/or loss and/or information leakage of any kind (including due to violation of privacy), caused by the use of the site and/or the services accompanying it and/or the content stored in the databases, including anything related to the collection of information, its use, its transfer to third parties, its storage, and its security.

The User is aware that the Company uses external clearing services. The Company does not store the User's credit card details. When placing an order, the User enters the credit card details within an online clearing page that is stored or linked directly to the site of a third-party service provider of an external credit clearing company, and the Company is not a party to this. The information transferred to the credit clearing company is stored in its databases and in accordance with the credit clearing company's privacy policy. The Company has and will have no control over the data processing performed by the credit clearing company. The User is responsible for checking the policy of the credit clearing company before making payments.

Without derogating from the provisions of the privacy policy, the User acknowledges and agrees that the Company will not be liable for any damage of any kind, indirect or direct, that will be caused to the User and/or anyone on their behalf in anything related to the credit clearing company, including in anything related to the use of information, its processing, etc.

Providing content for publication

User content is published in areas intended for this purpose, such as communities, discussion groups (forums), chats, comments on articles (talkbacks), blogs, and other services that allow you to enter your own content into the site - whether separately, in an area intended for user content only, or together with the Company's content. When you upload, create, publish, or make available such user content through the site or services, this means that you declare and confirm that you are the owner of the rights in such content, that you are permitted to provide them for publication, and that the Company as well as the public of users, including people outside the site, may access this content, associate it with you, and make any use of it. In doing so, you authorize the Company to publish this content also in other media and/or to use the information for streamlining service and handling complaints, all according to the Company's discretion. It is clarified that by providing such content for publication, you declare and confirm that you do not infringe on the privacy of any other person. Of course, you are not legally required to provide such content to the Company, and its provision is dependent on your desire and consent.

User consents, right to review information, update and removal

Any information provided by the User through the site, both as part of registration and/or purchase of services and/or products through the Company's site, will be provided of the User's own volition and full consent and will constitute clear and express consent in accordance with the provisions of Sections 11 and 17 of the Law and Section 30A of the Communications Law (Telecommunications and Broadcasting), 1982.

In accordance with the provisions of the Law, the User or their representative has the right to review the information collected about them, and to request its correction if it turns out that the information is incorrect, incomplete, or outdated. In addition, where information is used for the purpose of personal contact with you, you may demand the deletion of the information relating to you from the Company's databases. You are also entitled to demand to receive the information you provided to the Company in an accessible and structured format, and even request its transfer to another entity.

In this case, the Company will delete information it needs in order to contact you with commercial offers as described above. Information required by the Company for the purpose of managing its business - including documentation of commercial and other actions you performed on the site and management of records according to law - will continue to be stored by the Company according to law, but will no longer be used for the purpose of contacting you. To exercise this right, you are invited to contact us via the email address below: support@freskincare.com

Changes to the privacy policy

The Company may update and/or change the privacy policy from time to time at its sole discretion. In any case where material changes are made to this policy regarding the use of personal information and/or information of special sensitivity that you provided or that was collected about you, a notice will be published in the appropriate place on the website. We recommend that you check the privacy policy from time to time because the updated policy will apply to you. It is clarified that your continued use of the website following the publication of a notice regarding an updated privacy policy constitutes your agreement to all the terms of the updated privacy policy.

Applicable Law and Jurisdiction

The terms of this privacy policy, as well as any changes or amendments thereto, as well as the use of the Company's website, shall be governed by the laws of the State of Israel without regard to its conflict of law provisions. Exclusive jurisdiction in connection with any dispute and/or claim arising in connection with the use of the website and this privacy policy is granted exclusively to the courts in Tel Aviv-Yafo.

Contact Us

If you have any questions or concerns regarding this privacy policy or any other matter regarding the website services, please contact us via email at support@freskincare.com.

August 2025