This is the privacy policy (“Privacy Policy“) that governs how Gan Shmuel Foods Ltd., Israeli Company No. 520039934 and its affiliates, jointly the “Gan Shmuel Group” (hereinafter: “Gan Shmuel“, “we“, “our” or “us“), use Personal Information (defined below) that we collect, receive and store about individuals in connection with the use of our main website [www.ganshmuel.com and www.ganshmuelgroup.com], and any other websites operated by us (each, together with its sub-domains, content and services, a “Site“).

As used in this Privacy Policy, “Personal Data” or “Personal Information” means information that refers to, is related to, or is associated with an identified or which may reasonably be used to identify an individual or as otherwise may be defined by applicable law, such as a name, address, telephone number, e-mail address, information about activities directly linked to a person, such as that person’s location or IP information.

This Privacy Policy may be revised or updated from time to time. Such changes shall become effective upon their publication by Gan Shmuel and upon notice to you, which may be provided by email, a notice on our website, or any other reasonable means.

This Privacy Policy forms an integral and inseparable part of our Terms of Use. Any capitalized but undefined term in this Privacy Policy shall have the meaning given to it in the Terms.

For any questions regarding the collection, processing or use of Personal Data relating to you and exercising your data subject rights (all as explained below) please contact us, at: e-mail info@ganshmuel.com.

General principles of our data protection

1. Gan Shmuel is committed to ensuring that your Personal Data and the privacy of your data is protected according to the appropriate industry standards and practices in relation to the data we collect, and all in correspondence to Gan Shmuel’s relevant legal obligations.
2. This policy explains your rights regarding the Personal Data Gan Shmuel collects, processes and uses through the Gan Shmuel Site, as well as Gan Shmuel’s use of safeguards to protect these rights.
3. This Policy further applies also to Gan Shmuel’s use of cookies and tracking tools, as specified in detail in our Cookies and Tracking Tools Policy As we use cookies and tracking tools on our Site to distinguish you from others and to improve your use of our Site, and in some cases, certain features may not function if you remove the cookies from your browser.
4. We collect and process your Personal Data in good faith, in a proportionate manner according to the declared purpose, and with the appropriate technical and organizational measures in line with the acceptable industry standard measures, while taking into account the risks represented by our collection and processing and the nature of the Personal Data and data protected by us.
5. If any collection and processing of Personal Data will be carried out, in the course of Gan Shmuel’s business and provision of services, by external data processors on our behalf, Gan Shmuel will require, within the framework of its contracts with such external processors, for them to comply with relevant legal data protection rules and legislation applicable to the services they provide to Gan Shmuel, prior to transferring your Personal Data.
6. No legal obligation to provide personal data. The Personal Data collected and used by Gan Shmuel is limited strictly to any data which is necessary for us to provide you with services you request in the course of our ongoing business while operating under our relevant legal and data protection legislation and regulations obligations. Be advised that there is no legal obligation to provide us with Personal Data, and all Personal Data is provided by you at your discretion.
   However, it is hereby clarified and understood that if you do not provide us with Personal Data we will not be able to provide you with services or respond to your queries through the Website and you shall not have any right, claim or demand against Gan Shmuel in this regard should you not provide us with Personal Data for such purposes.
7. Personal data of children and minors. The Site is only intended for individuals aged eighteen (18) years or older.  If you are under the age of thirteen (13) please do not visit or use the Site. If you are between the ages of thirteen (13) and eighteen (18) you may only use the Site with the involvement and approval of a parent or legal guardian, and after they have reviewed and consented to these Terms.
   1. We do not knowingly collect or process Personal Data relating to children and minors, and if we become aware that Personal Data was transferred to us or collected by us relating to children and minors under the age of 18 years without the informed consent of a parent or legal guardian, we will delete such Personal Data without undue delay.
      
      If you address us with a request for erasure of data relating to the Personal Data of a child or minor, please attach to the request adequate proof of your status as parent or guardian of the child or minor.
8. Important note: please refrain from browsing our Site, ordering products through our website, sending us e-mail messages or “contact me” online forms with queries or requests, or otherwise providing Us with your Personal Data, if you do not consent to the collection, use, processing or disclosure of this data as set forth herein. 
9. Consent. By using the Site, you consent to the terms of this Privacy Policy and to our collection, processing and sharing of Personal Information for the purposes set forth herein. If you do not agree to this Privacy Policy, please do not access or otherwise use or provide us with Personal Data through the Site.
10. Modification. We reserve the right, at our discretion, to change this Privacy Policy at any time. Such a change will be effective ten (10) days following posting of the revised Privacy Policy on the Site, and your continued use of the Site thereafter signifies your acceptance of those changes.
    
    Notwithstanding the above, if we wish to collect additional types of Personal Data or process existing personal data for new or additional purposes, we will notify you directly through the contact details we have on record and will provide your prior consent before any such new processing activities
    

    Your rights as a data subject regarding the personal data we process on the Site.
    

    All users visiting our Site have certain rights in relation to the Personal Data that we hold about you, as detailed below:

11. Processing subjects to consent. Where you provide your Personal Data subject to a consent mechanism implemented in our Site, we will only process it if you have provided your informed consent to such processing, provided that We do not have alternative lawful grounds for processing or overriding legal obligations to further process your Personal Data, as further elaborated on herein below. 

    We will only use the data for the purposes stated in the consent procedure and within the scope outlined below in line with our “purpose limitation” obligations under applicable law.

12. Transparency. You are entitled to ask us for information about what type of Personal Data about you has been collected by GAN SHMUEL as per the provisions of articles 13 of the Israeli Privacy Protection law, and equivalent provisions in applicable laws.

13. Right of rectification. Upon reviewing your Personal Data under the Right of Transparency, You may request the erasure or correction of all or part of your Personal Data that is incorrect, inaccurate, outdated or false, insofar as it is held by Gan Shmuel in accordance with section 14 of the Israeli Privacy Protection law, and equivalent provisions in applicable laws.
    
    Upon your request, Gan Shmuel will accommodate your request and delete (or irreversibly anonymize) or correct your Personal Data, as soon as reasonably possible and technically feasible, unless there is a legitimate legal basis to retain it. In such cases, we will notify you accordingly.

    European economic area jurisdictions’ residents have additional rights in relation to the Personal Data that we hold, as detailed below:

14. Data portability. You are entitled to obtain (in a commonly used and machine-readable form) and reuse your Personal Data as you have provided to us (following your consent or to allow us to perform services under a contract) and which We process, for your own purposes across different services and free of charge, subject to technical feasibility and lawfulness considerations.

15. Withdrawal of consent. You may revoke or withdraw your consent to any processing we perform on your Personal Data at any time by contacting us, and We will stop processing your Personal Data, unless as set out in article 8 above We have overriding legal obligations or have alternative lawful grounds for processing your personal data which permit us to continue processing your information, including for ongoing legitimate business interests, which we shall notify you in our response to your request on such grounds, where applicable. 

16. The right of deletion (“to be forgotten”). Regardless and without derogating from your general right of rectification, European Union residents have further rights, and You may at any time request the erasure of your Personal Data we process about You in our records and systems, and will accommodate your request and delete or irreversibly anonymize your Personal Data or remove from part or all of our records, as per your request, as soon as reasonably possible and when technically feasible, and, as stated relating to other Data Subject rights unless there is an overriding legal interest or other authorized basis for the continuation of the processing of your Personal Data.
    
    Please be aware that in the event of deletion of Personal Data upon your request, Gan Shmuel may not be able to further provide you the services you applied for through the Site, in whole or in part and by requesting such deletion/correction, you irrevocably agree and waive any claim against Gan Shmuel’s inability to provide the services in such an event.

17. Automated decision-making. Gan Shmuel does not employ automatic decision-making mechanisms at this time and therefore shall not intentionally take any potentially damaging decision concerning you because of using automated processing and decision-making operations without human intervention; and commits that where such will be implemented, we will give you the opportunity to object and obtain human intervention in such a decision, express your point of view, and obtain an explanation of the decision.
    
    Important Notes:
    

18. In the implementation of these data protection rights, Gan Shmuel is committed to providing a timely and transparent response to your requests and upholding your right to contact Gan Shmuel at: info@ganshmuel.com. 

19. Any data subject you wish to uphold by Us, may not be fulfilled if you do not provide Us with relevant and/or sufficient information required for us to identify you as the data subject of said Personal Data, and we shall inform you accordingly in such an event.

20. If you believe Gan Shmuel has violated any of your data subject rights, you are entitled to:

    1. For European economic area countries – file a complaint to the Data Protection Supervisory Authority in your jurisdiction of residence about the alleged data protection breach.

    2. For all other jurisdictions – file a lawsuit in accordance with the   Governing Law and Dispute Settlement provisions set out herein.
       
       

       If you desire to exercise your data subject rights as set out herein, contact us at: info@ganshmuel.com and we shall assess your application and respond as per your rights under the applicable law governing your data protection rights.

       What personal information we collect and how we collect it. 

21. We do not currently require you to provide Personal Information in order to have access to general information available on the Site. But we do receive and/or collect Personal Information from you in the following ways:
    1. ‘Contact Us’ Information. If you send us a “Contact Us” request, through the “Contact Us” electronic form, we may collect the following types of Personal Data:
       1. Full Name
       2. Content of your Query (Free text in “Your Message” box)
       3. Contact Details (E-mail Address, Mobile Phone Number, Landline Number)
       4. Your Position in the Business You represent / manage / own
       5. Country in which your business operates 
    2. Customer Service Center. If you contact our Customer Service Center by phone or email, your communication may be recorded or documented. This may include your full name, phone number, email address, and any other Personal Information you choose to share during the interaction with our representative. 
    3. Automated Browsing Data and Log Files. We may make use of log files. The information inside the log files includes internet protocol (IP) addresses, type and any non-identifying anonymous data your browser may send to us. 
    4. Cookies and Other Tracking Technologies. Our Site may utilize “cookies”, anonymous identifiers and other tracking technologies in order to for us to provide our Site and present you with information that is customized for you.
       
       For more information on our use of cookies and other Tracking Tools please apply to our Cookies and Tracking Tools Policy
       
       The way we use personal information. 

22. If you submit or we collect Personal Information through the Site, then we may use such Personal Information in the following ways:

    1. to ensure that content on the Site is presented in the most effective manner for you, including personalization.

    2. to process your contact request when you contact us through e-mail and/or online forms to revert to you accordingly. 

    3. Subject to your consent, for performance of analytics such as trend analysis, site administration, statistical analysis of usage of the site, enhance and review integrity and stability of the website and study trends to improve our website. 

    4. Subject to your consent, to use data tracking technologies (i.e: browsing and history data) for the purpose of providing you with personalized advertisements.
    5. To ensure the integrity, security and fulfillment of the Terms of Use and this Privacy Policy by your users, including but not limited to detecting, monitoring, and preventing fraud and/or monitoring account activity.
    6. To enforce this Privacy Policy and the Terms and Conditions of the Website and/or to act in accordance with law or any other legal obligations Gan Shmuel is subject to.
    7. To transfer your Personal Information to our subsidiaries or affiliated companies for the purpose of storing or processing such information on our behalf for our regular business needs as needed to respond to your inquiry or manage ongoing interactions.  
    8. To process your Personal Information with our Third Party sub-processors, solely to the extent required to assist us directly either with our business operations and to operate, secure or respond to your queries through the Site.
       
       

       The lawful grounds for processing your personal data:

       Processing Activity	Type of Personal Data	Purpose	Lawful Basis (Art. 6 GDPR)
       Contact us via ‘Contact Us’ form	Name, email, phone number, Country, Position in your business, Mobile Phone, query content	Responding to your inquiry	Contract or pre-contractual steps / Consent
       Customer Service Center	full name, phone number, email address, and any other Personal Information you choose to share during the interaction with our representative.	Responding to your inquiry	Contract or pre-contractual steps / Consent
       Using the website (essential cookies)	IP address, session ID	Ensuring website functionality	Legitimate interest /
       Using analytics cookies	IP address, device info, behavior	Measuring website performance	Consent
       Showing personalized ads	Browsing behavior, identifiers	Targeted advertising	Consent
       Fulfilling legal obligations (e.g., tax, accounting)	Name, contact, transaction records	Compliance with record-keeping laws	Legal obligation

       
       Transfer of your information to Third Parties and/or outside of Israel: 
       
       
23. We do not sell, trade, or otherwise transfer to outside parties your Personal Data, except as specifically stated in this Privacy Policy.
24. This does not include trusted third parties service providers and/or affiliates who assist us in operating our Site and/or providing the framework which we use for our routine business and/or servicing you directly. 
25. Such processing is conducted on our behalf and under our instructions, subject to legally binding written agreements. These agreements require such trusted third-parties to keep your Personal Data confidential, implement appropriate organization and technical data protection measures when processing your Personal Data, use your Personal Data solely for any purpose other than to fulfill their obligations to us (e.g. Data Processing Agreements, Standard Contractual Clauses, Business Corporate Rules, as applicable and permissible) and refrain from using or disclosing your data for their own purposes. 
26. We undertake to refrain from transferring Your Personal Data outside of Israel, the European Economic Area (EEA) or any Country recognized as providing adequate protection by the European Commission’s Adequacy Decision, however, in cases where such transfers are strictly necessary, we will: ensure the receiving party is bound by appropriate safeguards (as required by the Israeli Privacy Protection (Transfer of Data to a Database outside of the Country), 2001, or where applicable the GDPR) and obtain your explicit informed consent, where no other legal mechanism is applicable.
27. Beyond the above we may share your Personal Data solely for the following purposes:
    1. Legal obligations and law enforcement: Where required by applicable law, regulation, court order, or competent authority, including to establish or defend legal claims.
    2. Prevention of harm or fraud: To detect, investigate, and prevent fraud, security breaches, or any behavior that threatens safety or legal rights
    3. Protection of our legitimate interests: To enforce our rights under this Privacy Policy, our Terms of Use, or in relation to any legal claim or defense.
    4. Prevention of Damages or Harm. To prevent harm, damage or to protect the rights, property or safety of Gan Shmuel, our users, Yourself or the public.
    5. Service infrastructure and operations (sub-processors): Including, but not limited to:
       1. Network and cybersecurity providers;
       2. Cloud service providers, CRM and SaaS tools used in our routine operations.
       3. IT maintenance, development, or hosting providers.
       4. Analytics and statistical service providers.
    6. In the event that we are acquired by or merged with a Third Party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer or assign Personal Information in connection with the foregoing events
       
       

       Note: We may share non-personally identifiable information (aggregated, anonymized, or de-identified data) for purposes such as usage trends, statistical research, or website optimization, provided it cannot reasonably be linked to an identifiable individual.

       Links to and interaction with Third Party products. 

28. The Site may enable you to interact with or contain links to your Third Party Account and other Third Party websites, mobile software applications and services, including social media platforms that are not owned or controlled by us (each a “Third Party Service”). We have no control over third-party sites or services, and all use of third-party sites or services is at your own risk.
29. Gan Shmuel cannot accept responsibility for the privacy policies of any such Third Party Service and such Third Party Services are governed solely by such third parties’ privacy policies. 
30. Please be aware that the Third Party Site may collect Personal Information from you. Accordingly, we encourage you to read the terms and conditions and privacy policy of each Third Party Service that you choose to use or interact with.
    
    Data retention and deletion
    
31. Gan Shmuel deletes (or equivalently irreversibly anonymizes) personal data where the purpose for which the data was being collected or processed ceases to apply, except the extent it is prohibited to do so under local, Israeli law (and in such cases only to the extent required) or other applicable laws governing our activities and/or we have overriding legal grounds to continue the processing as will be notified to you should you address up to exercise an applicable data subject right for deletion of Personal data.
32. Please be advised that, notwithstanding the foregoing, we may continue to retain your Personal Data in certain circumstances. Such retention will be limited to what is necessary for the continued provision of the Gan Shmuel Services and for legitimate and essential business interests, such as maintaining service performance and preserving minimal data required to protect our legal rights in the event of disputes, within applicable statute of limitations periods. We may also retain data when necessary to comply with legal obligations or to resolve disputes, including but not limited to the following circumstances:
    1. Where we are required to retain the personal data for our legal, tax, audit, and accounting obligations and/or regulatory requirements, we will retain the necessary personal data for the period required by applicable law; and/or,
    2. Where necessary for our legitimate business interests relating to the website’s operation and security such as fraud prevention or to maintain the security of our users.
    3. Where necessary to cooperate with a criminal investigation by law enforcement agencies and/or any regulatory authority’s inquiry and/or audit, only in response to a formal request, and as required by applicable law.
33. The above notwithstanding, there are types of Personal Data we process that will only be kept for as long as you use Gan Shmuel Services, such as your e-mail address and other information sent as part of a request or when browsing as long as your consent to usage of Cookies and Tracking Tools is intact. 
34. Where such a request has been withdrawn or sufficiently fulfilled and no longer relevant, we shall delete such data as part of our commitment to data minimization.
    
    Note: We will also actively delete your Personal Data upon your expressed request to fulfill your data subject right, provided you forward such a request by email at: info@ganshmuel.com, as also mentioned above, unless there is an overriding legal obligation or lawful justification which we shall communicate to you in response to your request to the extent we cannot accommodate it fully or partially.
    
    Data protection and security
    
35. The security of Personal Information is important to us. We follow generally accepted industry standards, including the use of appropriate administrative, physical and technical safeguards, to protect the Personal Information submitted to us. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. 
36. Therefore, while we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security or confidentiality.
37. If you have any questions about security on the Site, you can contact us at: info@ganshmuel.com. 
    
    General.
    
38. Notices and correspondences. 
    1. By providing us with your contact information – whether during registration, via the “Contact Us” form, or through email correspondence – and by accepting these Terms and our Privacy Protection Policy, you expressly consent to being contacted by Gan Shmuel using the contact details you provided. Such communications may include, but are not limited to, emails, SMS or text messages, and phone calls.
    2. Notices sent by electronic means shall be deemed received when they are sent and will be responded to as soon as reasonably possible according to the nature of the correspondence/notice. 
39. Entire agreement.
    These Terms represent the entire agreement between the parties regarding the subject matter hereof and supersede any and all other previous agreements between the parties regarding the subject matter hereof. Gan Shmuel may assign its rights or obligations pursuant to these Terms. Users shall not assign any rights under these Terms and any attempted assignment shall be void. If any provision of these Terms shall be deemed invalid or unenforceable by a court of competent jurisdiction, such provision shall be interpreted to give maximum effect to its terms as permitted under law, and such invalidity or unenforceability shall not affect the validity or enforceability of any other part or provision of these Terms which shall remain in full force and effect.
40. Contact details for queries and data subject requests:
    If you have any questions or concerns regarding this Policy, believe your rights have been violated/impeded on or wish to exercise any of your Data Subject Rights hereunder, please contact us at: info@ganshmuel.com and we shall address your inquiry as soon as practically possible and according to the mandatory response periods under applicable data protection laws.
41. Additional privacy protection terms for California residents
    1. Beginning January 1, 2020, the California Consumer Privacy Act (“CCPA”) as amended by Proposition 24 titled the “California Privacy Rights Act” (“CPRA”) gives California residents certain rights with respect to the processing of personal data (known as “personal information” under the CCPA and CPRA).
    2. This supplement provides additional privacy disclosures and privacy protection provisions in light of the above for California residents accessing our website.
       
       Notice at collection on personal information collected and processed
       
    3. Under the California Privacy Rights Act, we provide this Notice at Collection to inform California residents, at or before the point of collection, about the categories of Personal Information we collect, the purposes for which it will be used, the retention periods, and whether it is sold or shared
       
       

       Category of Personal Information	Purpose of Use	Retention Period	Sold or Shared?
       Identifiers (e.g., name, email)	Customer support,	| As long as necessary for transactions + 7 years for tax/accounting	Not sold, shared with CRM provider
       Internet Activity (e.g., IP address, cookies)	Website functionality, analytics, advertising	Session + up to 36 months	Functionality Shared for security and stablity Analytics and Advertising Can be shared for targeted advertising, pending consent
       Location Data (e.g., via IP)	Security, fraud prevention	Up to 12 months	Can Shared with analytics and/or security services provider

       If we collect Sensitive Personal Information (such as geolocation, biometric identifiers, or racial/ethnic data), we use it only for purposes permitted under applicable law and do not sell or share such information. California residents may limit the use of SPI by contacting us at: info@ganshmuel.com. 

       Requests to exercise your rights under the CCPA

    4. You are afforded and entitled to forward requests to exercise your rights as a California resident. We will not discriminate against you for exercising any of your rights under the California Consumer Protection Act (“CCPA”).
    5. Please note, we may not have enough information about you to verify your identity to exercise your rights under the CCPA and may ask you to provide personal identification information in order to verify your identity.
    6. You may designate, in writing or through power of attorney, an authorized agent to make requests on your behalf to exercise your rights. Before accepting such a request from an agent, we will require the agent to provide proof you have authorized it to act on your behalf, and we may need you to verify your identity directly with us.
       
       Right To know 
       
    7. Under the CCPA, you have a right to request information about our collection, use, and disclosure of your personal information over the prior 12 months prior to the date of your request, and ask that we provide you with the following information:
       1. The Categories of and specific details of the personal information we have collected about you.
       2. The Categories of sources from which we collect personal information about you.
       3. The Purposes for collecting personal information as per 1 and 2 above.
       4. The Categories of Third Parties with which we shared your personal information.
       5. Categories of personal information disclosed about you for business purposes.
       6. If applicable, categories of personal information sold about you and the categories of third parties to which the personal information was sold, by category or categories of personal information for each third party to which personal information was sold.
    8. To make a verifiable request for information about the personal information we have collected about you, please forward a request through email at: info@ganshmuel.com or send us a request through the “Contact Us” online form on the Site.
    9. You may make a verifiable consumer request related to access or “knowing” what personal information we process relating to You, twice per 12-month period.
       
       Right to delete 
       
    10. You also have a right to request that we delete personal information, subject to certain exceptions. 
    11. To make a verifiable request for information about the personal information we have collected about you, please forward a request through email at: info@ganshmuel.com or send us a request through the “Contact Us” online form on the Site.
        
        Household Requests
        
    12. We do not collect household data and only process information about individual users making orders and/or operating an account on our website. If all the members of a specific household make a Right to Know or Right to Delete request, we will respond to each such request individually and not process all the data as a “Household”.
        
        Disclosures of personal information for a business purpose
    13. In the preceding 12 months, Gan Shmuel has disclosed certain data from the following categories of personal information to the categories of recipients listed in Section 5 of our Privacy Policy titled “Transfer of Your Information to Third Parties” for one or more business purposes:
        1. User Data
        2. Analytics
           
           Objection to the sale or sharing of personal information
           
    14. We do not sell personal information. We have taken substantial steps to identify and remediate any data sharing arrangements that could constitute a “sale” under the CCPA and California Privacy Rights Act of 2020.
    15. While we do not sell any personal information, we do provide Usage Data to advertising partners to enable us to provide you with interest-based advertising based on cookies and tracking tools. For more information on interest-based advertising, please see our Privacy Policy and Cookies Policy ().
    16. Be advised that we honor Global Privacy Control (GPC) signals as a valid request to opt out of the sale or sharing of personal information. If your browser or extension sends a GPC signal, we will process it in accordance with the California Privacy Rights Act. 

Last updated: August 2025