Privacy Policy

Last updated: September 30, 2025

1. Introduction

Horizon Financial Services (“we”, “us”, “our”) respect the privacy of visitors and clients of Horizon Financial Services (“you”, “your”). This Privacy Policy describes how we collect, use, disclose, store, and protect personal data, and your rights in respect of that data, under the laws of Israel — in particular, the Protection of Privacy Law, 5741-1981 (the “PPL”) and related regulations, as amended (including Amendment 13, effective August 2025).

By using our website, services, contacting us, or otherwise providing information to us, you consent to the processing of your data as described herein.

2. Definitions

For the purposes of this Policy:

Personal Data / Information: Any information relating to an identified or identifiable natural person, including name, email address, phone number, IP address, etc. (under Amendment 13, the scope of what qualifies is broader).

Sensitive / Highly Sensitive Data: Certain categories of data that require greater protection under the law (e.g. health, biometric, location).

Controller / Database Owner: The entity (in this case us, Horizon Financial Services) that determines the purposes and means of processing personal data.

Processor / Database Holder: A third party which processes personal data on our behalf (e.g. hosting providers, email service, analytics).

Processing: Any operation performed on personal data (collection, storage, use, transfer, deletion, etc.).

3. What Data We Collect

We may collect and process the following categories of personal data:

Contact Information: name, email address, phone number (e.g. through contact forms on the site)
Communications: messages or correspondence you send to us
Technical / Usage Data: IP address, browser type and version, device type, operating system, pages visited, time and date of access, referrer URL, analytics data
Optional Additional Data: if you provide more personal data (e.g. business name, job title) in your communications or forms
Third-party Data: data we may receive from third parties (e.g. analytics providers, linked services)

We do not intentionally collect sensitive or highly sensitive personal data (unless explicitly indicated with additional consent).

4. Purposes of Processing & Legal Basis

We process your data for the following purposes:

To respond to inquiries, provide services, communicate with you
Legal Basis / Justification: Legitimate interest, contract performance, or your consent
To maintain and operate the website, improve user experience, analytics
Legal Basis / Justification: Legitimate interest
To send you updates, newsletters or promotional content (if you consent)
Legal Basis / Justification: Your explicit consent
To comply with legal obligations (e.g. recordkeeping, audits)
Legal Basis / Justification: Legal requirement under Israeli law
To enforce our rights or defend against claims
Legal Basis / Justification: Legitimate interest

If you consent to specific uses (e.g. marketing), we will rely on that consent for those uses. You may revoke consent at any time (subject to legal constraints) by contacting us (see section Your Rights).

5. Cookies & Tracking Technologies

Our website uses cookies and similar technologies (e.g. web beacons, local storage) to:

Enable basic website functionality
Improve and analyze site performance via analytics (e.g. Google Analytics)
Understand which pages are most used
Possibly support marketing or remarketing

You will be informed about use of non-essential cookies (e.g. analytics, marketing) and can disable or opt out via browser settings or a cookie banner if we implement such.

6. Disclosure & Transfer of Data

We may share your personal data:

With service providers, processors or partners who assist us (hosting, analytics, email, CRM)
When required by law, regulation, court order, governmental authority
In the event of a merger, acquisition, sale of assets or business reorganization (with necessary safeguards)
To protect rights, safety, or legal interests of Horizon or third parties

If we transfer data outside Israel or to foreign jurisdictions, we will ensure that an adequate level of data protection is maintained (e.g. via contractual safeguards) as required under the PPL / Amendment 13.

7. Data Security & Retention

We implement technical and organizational measures to protect personal data against unauthorized or unlawful processing, accidental loss, alteration, or destruction.
Access to personal data is limited to personnel, agents or processors who need it for the stated purposes, under confidentiality obligations.
We will retain personal data only for as long as necessary to fulfill the purposes for which it was collected, comply with legal obligations, resolve disputes, or enforce our agreements.
When no longer needed, data will be securely deleted, anonymized, or destroyed.

8. Your Rights

Under Israeli law (as updated by Amendment 13 and existing PPL), you have certain rights with respect to your personal data:

Right of access / inspection: You may request to see personal data held about you and the purposes of processing
Right to correction / rectification: You may request that inaccurate, incomplete or out-of-date data be corrected
Right to erasure (deletion): You may request deletion, unless there is a legal reason to retain it
Right to object / restrict processing: Under certain conditions you may object to or restrict processing
Right to withdraw consent: For processing based on consent, you may withdraw at any time (without affecting prior lawful processing)
Right to complaint: You may lodge a complaint with the Israeli Privacy Protection Authority (PPA)
Right to claim damages: Under certain violations you may be entitled to statutory or exemplary damages (even without proof of harm)

If you wish to exercise any of these rights, please contact us using the contact information below.

9. Data Breach Notification

In the event of a data breach involving personal information (e.g. unauthorized access, accidental loss), we will:

Assess the nature, scope, and potential harm
Notify you if the breach is likely to cause harm or risk to your rights
Report the breach to the Privacy Protection Authority (PPA), if required by law (under the new regime from August 2025, breach reporting obligations are stricter)
Take remedial steps to mitigate harm

10. Children & Minors

Our services are not intended for children under the age of 16. We do not knowingly collect personal data from minors. If you believe we have collected data from a minor, please contact us and we will delete it promptly.

11. Changes to Policy

We may update this Privacy Policy from time to time (e.g. to reflect changes in law or practice). The “Last Updated” date above will show when the policy was last revised. We will notify you of material changes by posting the new policy on our website and, where appropriate, by other means.

12. Contact Information

If you have questions, requests, or concerns about this Privacy Policy or our data practices, you may contact:

Horizon Financial Services
Email: ofeklevy.cpa@gmail.com