This Privacy Policy describes how personal data of visitors to the website of TOP GROUP SOFTWARE LTD and its subsidiaries (the “Company”), and/or users of any of the software or cloud services provided by the Company (the “Services”), is collected, stored, processed, and protected. This Policy is in accordance with the provisions of the Israeli Protection of Privacy Law, 1981 (including Amendment No. 13), the Privacy Protection (Data Security) Regulations, 2017, and the EU General Data Protection Regulation (GDPR), to the extent applicable.

Entities Using the Personal Data

The Company is the data controller of the personal data collected when a user visits the website and is responsible for the processing and protection of such data according to applicable regulations.
Access to personal data by the Company’s employees is granted based on necessity and job role and may also be shared with third parties as outlined in Section E below.

Please read this Policy carefully to understand our views and practices regarding your personal data. The Company reserves the right to update this Policy at any time.

Glossary of Terms

• Personal Data: Any information that identifies or can be used to identify an individual, directly or indirectly (e.g., name, ID, IP address, phone number, geolocation, or user ID).
• Database: Any structured collection of personal data held electronically and accessible according to specific permissions.
• Processing: Any action or series of actions performed on personal data, including collection, recording, storage, use, transfer, deletion, backup, or any other operation.

Types of Data Collected

If the user consents to the use of cookies when browsing and searching content on the website, the Company may automatically collect, store, and use the following information:

• Technical information, such as the device used to access the website, the IP address, login data, browser type and version, time zone setting, browser plug-in types and versions, operating system, wireless network information, and platform type.
• Usage information such as website visit history including URL, date and time of access, pages visited, page response times, download errors, time spent on specific pages, and user interactions (scrolling, clicks, mouse movements).

How the Company Uses the Data

The Company processes personal data based on how the user interacts with the website (e.g., user type, usage purpose). Processing is carried out to meet the Company’s legitimate interests, such as improving and securing the website and Services.

The Company uses the data only for the purposes for which it was collected unless another purpose is reasonably compatible. If processing is required for a new, unrelated purpose, the Company will request additional consent.

Sharing Personal Data with Third Parties

The Company may share personal data with third parties that provide services on its behalf, such as website hosting or support services. All such third-party service providers are required to implement appropriate security measures and may only process the data under specific Company instructions and for defined purposes.

Additionally, the Company may share personal data with third parties:

• To comply with legal obligations.
• To enforce website Terms of Use.
• To protect the rights, property, or safety of the website, users, or others.

Data Storage Location

Personal data collected via the website may be stored manually or electronically on secure servers operated by or on behalf of the Company.
Although the Company takes reasonable steps to protect your data, the transmission of information over the internet is not completely secure. Therefore, any data transmission is at the user’s own risk.

Third-Party Websites

The website may contain links to third-party websites. These websites operate under separate privacy policies, and the Company assumes no responsibility for their practices. Users are encouraged to read those privacy policies before submitting any personal data.

Data Security

The Company implements technological, organizational, and legal safeguards in accordance with data security regulations. These include access controls, encryption, authentication systems, intrusion detection, and employee training.

Despite these efforts, no online transmission is 100% secure, and users are ultimately responsible for their own data transmissions. In case of a data breach that may expose your personal information, the Company will act in accordance with applicable law.

Data Retention

The Company retains personal data only for as long as necessary to fulfill its purposes, in accordance with legal and regulatory requirements.

Data Subject Rights

Depending on the circumstances and applicable law, you may have the following rights:

• Right to Access – Obtain a copy of your personal data and confirm lawful processing.
• Right to Rectification – Request correction of incomplete or inaccurate data.
• Right to Erasure – Request deletion of your personal data under specific circumstances, including after objecting to processing.
• Right to Object – Object to processing based on the Company’s or a third party’s legitimate interests.
• Right to Restrict Processing – Request a pause in data processing (e.g., while verifying accuracy).
• Right to Data Portability – Request transfer of your data to another controller.

Please note that in some cases, the Company may not be able to fulfill your request (e.g., due to legal or contractual obligations). To exercise any of your rights or raise concerns about how the Company handles your data, please contact the Company’s Data Protection Officer at:

Top-privacy@Top-Group.co.il

Requests will be handled without delay. The Company may retain records of your communication to help resolve any issues.

Cookies

The Company’s website uses cookies to distinguish between users. This helps enhance the user experience and improve website functionality.
For more information about the cookies used and their purpose, please refer to the Company’s Cookies Policy.

Policy Updates

Any changes to this Privacy Policy will be posted on this page. Please check back regularly for updates.

Contact

For questions or concerns regarding this Privacy Policy, contact the Company’s Data Protection Officer at:
Top-privacy@Top-Group.co.il
or via the Company’s headquarters.

This policy is written in the masculine form for convenience only and refers to all genders equally.