Privacy Policy

Last Updated: July 14, 2022

Aquapass Ltd. (“we“, “us” or the “Company“) is dedicated to providing you with the transparency and control over the use of your data (“user” or “you“). In order for us to provide you with our services, we are required to collect and process certain personal information about you. This Privacy Policy outlines our practices with respect to the information we may collect from you when you use our Site, the manners in which we may use such information and the choices available for you.

The definitions in our Terms of Use apply to this Privacy Policy unless stated otherwise.

This Privacy Policy does not apply to the practices of companies that we do not own or control, or to individuals whom we do not employ or manage, including any of the third parties to which we may disclose information as set forth in this Privacy Policy.

Grounds for Data Collection

Processing of your Personal Information (as defined below) is necessary for the provision and operation of our Site, including any domain or subdomain associated with it, to protect our legitimate interests and for compliance with legal and regulatory obligations. By accessing or using our Site, you expressly consent to the terms of this Privacy Policy, and to the collection, storage, use, disclosure and other uses of your information, including Personal Information, in accordance with the terms of this Privacy Policy. If you disagree to any term provided herein, please do not use our Site.

What Information We Collect?

Personal Information – To use certain services in our Site you may be asked to provide personal information, namely information that identifies an individual or may with reasonable means identify an individual (“Personal Information”). This Personal Information may include your name, email address and phone number, and any other information you wish to provide; we may use such information to enable you to use features on the Site.

Non-Personal Information – We collect certain non-Personal Information pertaining to a user, which may be made available or gathered via the user’s use of the Site (“Non-personal Information”) in order to operate the Site and improve it. We are not aware of the identity of the user from which the Non-personal Information was collected. Non-personal Information which is being collected consists of technical information transmitted by your device or browser and aggregated usage information, and contains certain software and hardware information about your device, the referring page that linked you to our Site, including the type of browser and operating system your device uses, operator, language preference, access time, and the domain name of the website from which you linked or registered to the Site.

How We May Collect Your Information?

We collect Personal Information submitted directly by you (by filling out a form or contacting us), or non-Personal Information transmitted automatically from your device using various standard technologies, such as cookies, digital identifiers, log files, web beacons or other similar technologies.

Our Site may automatically send cookies to your system. We may store information which correlates with those cookies, for the purposes stipulated below. You may block and remove our cookies through your browser and operating system, but this may impair and hinder the Site functionality and availability. We may use logs and cookie information to improve quality and design of the Site, including without limitation, saving you the trouble of re-entering data, and queries, personalize and customize your experience on the Site, track your use of the Site and generate statistics regarding the Site.

What is a “cookie”? When you use our Site we may assign your device with a log file or a cookie (session or persistent). A “cookie” is a small piece of information that a website assign to your computer’s hard drive while you are viewing a web site. Cookies are very helpful and can be used for various different purposes. These purposes include allowing you to navigate between pages efficiently, enable automatic activation of certain features, remembering your preferences and making the interaction between you and the Site quicker and easier. Cookies are also used to help ensure that the advertisements you see are relevant to you and your interests. You can find more information about cookies at You may remove our cookies by following the instructions of your browser preferences; however, if you choose to disable cookies, some features of our Site may not operate properly and your online experience may be limited.

What Are We Using It For?

We may use cookies, log files, web beacons and other technologies to collect Non-Personal Information with respect to your activity on our Site and track your use of our Site, your type of browser, pages you visited, the time and date of your visits or the links you click on. We may also allow third parties, e.g. Site service providers (e.g. third parties that perform Sites on our behalf, or that provide marketing assistance, analytics, ad tracking, Site functionality and support, surveys, etc.), ad networks and advertising companies, to display advertisements on our Site. These parties may also use the technologies stated above to collect information about our users. We do not provide any Personal Information to third parties, unless indicated otherwise in our Privacy Policy.

How We Use the Information We Collect?

  • To respond to your inquiries, support request, feedbacks or questions, and update you with important information, and respond to claims concerning our Site;
  • To provide you with our Site and certain features;
  • To communicate with you (via email, phone number, etc.);
  • To resolve disputes and enforce our policies and rights, including investigation of potential violations thereof, or in accordance with any applicable law or regulation, or for the purpose of law enforcement;
  • To perform research, development, testing, technical diagnostics, analytics or for statistical purposes;
  • To provide you with the most relevant additional Sites, offers and updates (including for direct marketing purposes as detailed below);
  • To detect, prevent, or otherwise address fraud, security or technical issues, or in order to take precautions against liabilities, investigate and defend ourselves against any third party claims or allegations, or protect the rights and property of the Company, its users or partners.

With Whom We Share the Information, and For What Purpose?

Internal Concerned Parties and Business Partners – We share your information, including Personal Information, with our affiliated companies and our business partners, who are allowed to use the information only for the purposes stipulated above, and with our affiliated companies and third party professional Site providers (e.g. providers of storage services, CRM, and providers conducting promotions, marketing assistance, technical support, analytics, etc.). These third parties may have access to your Personal Information so that they may perform these tasks on our behalf. The information will be disclosed only to the extent required to perform the purposes as stipulated herein.

You hereby warrant and consent that your Personal Information may be processed, transmitted, used or stored with our authorized third parties, for the purposes disclosed herein, which are located across the world.

Compliance with laws and law enforcement entities – We may share your information, including Personal Information, in the event that we are required by law enforcement or other governmental agency or private parties to enforce and comply with the law; in response to a subpoena, warrant or an investigative demand, or a court order, or with respect to any legal process; in order to enforce intellectual property rights or to exercise other legal rights; to establish or exercise our rights to defend against legal claims; if we believe, in our sole discretion, it is necessary or appropriate to investigate, prevent, respond to claims and legal processes, or take action regarding illegal, unethical, inappropriate or legally actionable activities, suspected fraud or other wrongdoing, to protect our or a third party’s property or rights or the safety of person or property, violation of our policies, to enforce our policies or as otherwise required in order to comply with applicable laws and regulations. In such circumstances, we may raise or waive any legal objection or right available to us.

Affiliates; Merger and acquisitions – We may share Information, including Personal Information, with our parent company, any subsidiaries, joint ventures, or other companies under a common control (collectively “affiliated companies”). We may share Information, including Personal Information, in the event of a corporate transaction (e.g. sale of a substantial part of our business, merger, consolidation or asset sale).

In the event of the above, our affiliated companies or acquiring company will assume the rights and obligations as described in this Privacy Policy and may continue to use your information in accordance with the terms of this Privacy Policy.

Aggregated Information

Non-Personal Information, aggregated information or Personal Information in non-human readable form (de-identified) may be shared with third parties (including ad networks, advertising companies and Site service providers) in any of the above circumstances, as well as for the purpose of developing or delivering tailored or targeted advertising (whether via our Site, or websites or applications of third parties), or for the purpose of improving our Site, conducting business analysis or other business purposes. This information may be combined with information we collect from other sources, to the extent that the information remains Non-Personal Information.

Third Party Collection of Information

Our policy only addresses the processing, use and disclosure of information we collect from you. As part of the Site, we may provide links or access to third party websites. To the extent that you disclose your information to other parties via our Site (whether our website or application; e.g. by clicking on a link to any other website or location) or via other sites throughout the internet, different rules may apply to their processing, use or disclosure of the information you disclose to them. We are not responsible for the privacy practices employed by those websites, or the information or content therein. We prompt you to review the privacy policies of those sites before providing your Personal Information to them.

For How Long We Retain the Information We Collect?

We will retain your Personal Information for as long as necessary to provide and operate our Site, and as necessary to comply with our legal obligations, resolve disputes, and enforce our policies and rights. Retention periods will be determined taking into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time. We may rectify, replenish or remove incomplete or inaccurate information, at any time and at our own discretion. To remove your email address, please contact us at

Direct Marketing

You may receive from time to time information, updates or promotional material concerning our Site or our products and services, or our partners’ services, which we believe might interest you. At any time, you can choose to no longer receive commercial or promotional emails by contacting us at or by clicking on the “unsubscribe” link in the emails that you receive from us. It may take up to 10 days for us to process such request. Please note that even if you have unsubscribed from receiving promotional emails from us, we may still use, and share your Personal Information with third parties, for non-marketing purposes (for example to fulfill your requests and orders, communicate with you and respond to your inquiries, etc.). In such cases, third parties with whom we share your Personal Information are authorized to use your Personal Information only as necessary to provide these non-marketing purposes.

How Do We Safeguard Your Information?

The security of your Personal Information is important to us. We follow generally accepted industry standards, including the use of appropriate administrative, physical and technical safeguards, to protect your Personal Information, and to help prevent unauthorized access, use, or disclosure thereof. However, no method of transmission over the Internet, or method of electronic storage, is absolutely secure. Therefore, while we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security or confidentiality. You should be aware that there is always some risk involved in transmitting information over the internet, and you do so at your own risk.

EU User Rights

As an EU resident, you may request to:

  1. Receive confirmation as to whether or not Personal Information concerning you is being processed, and access your stored Personal Information.
  2. Receive a copy of Personal Information you directly volunteer to us in a structured, commonly used and machine-readable format.
  3. Request rectification of your Personal Information that is in our control.
  4. Request erasure of your Personal Information.
  5. Object to the processing of Personal Information by us.
  6. Request to restrict processing of your Personal Information by us.
  7. Lodge a complaint with a supervisory authority.

Please note that these rights pertain to EU residents only, are not absolute, and may be subject to our own legitimate interests and regulatory requirements.

Users Outside the EU – Some of the aforementioned rights are applicable in certain jurisdictions outside the EU as well. Users residing outside the EU are welcome to contact us for any questions or requests at the details below.

Transfer of Data Outside the EEA

If you reside in the European Union (“EU”), please note that your Personal Information may be transferred outside the EEA. In such cases, we will transfer your data only to such countries as approved by the European Commission as providing adequate level of data protection, or enter into legal agreements ensuring an adequate level of data protection.

Updates or Amendments to the Privacy Policy

This Privacy Policy may be subject to periodical revisions or amendments at our sole discretion; we encourage you to review the Privacy Policy regularly. The last revision will be reflected in the “Last Updated” heading. Any change of this policy will be posted in this Privacy Policy. Your continued use of our Sites following any such amendments will be considered as your consent to the amended Privacy Policy.

How to Contact Us

If you wish to exercise any of the aforementioned rights, or receive more information, please contact us using the details provided below:



Our Policy toward Children We understand the importance of protecting children’s privacy, especially in an online environment. The Site is not designed for or directed at children under the age of 18 years old (“Minors”). If you are a Minor, you should not register or provide Personal Information through the Site. We do not knowingly collect Personal Information from Minors. If a parent or guardian becomes aware that his or her child has provided us with Personal Information, they should contact us using the details provided above. If we later obtain actual knowledge that a user is under 18 years of age, we will take steps to remove that user’s Personal Information from our systems.