Privacy Policy for Semerenko Group

Last Updated: April 8, 2025

Semerenko Group (“the Company”, “We”, “Us”, or “Operator”) operates the Semerenko Group website (semerenkogroup.com), including all sub-sites and associated websites (“the Website”). This Privacy Policy outlines our practices regarding the collection, use, and disclosure of information when you use our Website and associated services. For questions regarding privacy matters, contact us at [email protected].

1. Scope This policy applies to all information collected through our Website and associated services, including Browse activity, interactions with listings (for sale, rent, projects, investment opportunities, services, and informational content), data provided when registering an account or submitting forms, and interactions with our AI Chatbot assistant.

2. Information We Collect We may collect the following types of information:

• Information You Provide Voluntarily: When using our services, registering an account, contacting us, or interacting with features like the Chatbot, you may provide personal information such as your name, phone number, email address, username, password, address, payment details (processed by secure third-party providers), messages you send via chat or forms, and other relevant contact or identification details. Providing such data is voluntary, but certain services may require mandatory information, which will be clearly indicated.
• Information Collected Automatically: We may automatically collect information about your device and Browse activity using cookies and similar technologies (see Section 7). This may include your IP address, browser type, operating system, referring URLs, pages viewed, links clicked, and timestamps.
• Chatbot Interaction Data: When you interact with our AI Chatbot assistant, we collect the messages you send, the responses provided by the AI, conversation metadata (like timestamps), and potentially the text content of the specific page you are viewing (used as context for the AI).

3. How We Use Your Information Collected data is used for the following purposes:

• Creating and managing user accounts.
• Authenticating user access.
• Processing transactions and facilitating purchases (via secure third-party processors).
• Providing, managing, and improving our Website, services, and listings.
• Providing responses and assistance via the AI Chatbot.
• Sending system notifications, service updates, and responding to inquiries.
• Personalizing content and user experience based on your preferences and interactions.
• Conducting internal analytics to understand usage patterns and improve website functionality and service offerings.
• Analyzing anonymized or aggregated chat interactions to improve Chatbot performance and service quality.
• Marketing purposes (e.g., sending newsletters or promotional offers), only where we have your explicit consent or another valid legal basis according to applicable law. You can opt-out of marketing communications at any time.
• Complying with legal obligations and protecting our legal rights.

4. Third-Party Sharing and Disclosures

• AI Service Provider (OpenAI): To provide the AI Chatbot functionality, we send data from your chat interaction (including your messages, conversation history, and potentially scraped text content from the page you are viewing) to our third-party AI service provider, OpenAI, L.L.C., which is located in the United States. OpenAI processes this data solely to generate responses for the Chatbot according to our instructions and their API data usage policies (which typically state they do not use API data to train their models unless explicitly opted-in). Your use of the Chatbot signifies your understanding that this data transfer and processing by OpenAI in the US occurs. We rely on OpenAI’s security and privacy practices for the data while it is being processed by them.
• Affiliates and Service Providers: We may use affiliate links or share non-personal, publicly available information related to listings with third-party affiliates or service providers to facilitate related commercial services or analyse website performance. We use third-party payment processors for transactions; we do not store your full payment card details.
• Explicit Consent: Your personal contact information (like email or phone number provided directly by you) will only be shared with other third parties (e.g., specific property representatives for inquiries, if applicable) with your explicit prior consent, unless required by law.
• Legal Requirements: We may disclose your information if required to do so by law or in the good faith belief that such action is necessary to comply with legal processes, protect and defend our rights or property, or protect the personal safety of users or the public.
   

5. Disclaimers for Independent Listings Independent listings on the Website are clearly identified with appropriate disclaimers (e.g., “Independent Listing – Not an Official Project Page,” “Independent Third-Party Listing”). These listings are provided for informational purposes. Semerenko Group does not claim affiliation with, endorsement of, or official representation for these independent/third-party listings unless explicitly stated. Details are based on publicly available information or independent research. We bear no responsibility for the accuracy or legality of such third-party content.

6. Owner/Developer Rights for Listings Upon verified request from a property owner or their authorized representative, we will review and, if appropriate, remove the relevant listing information from our Website. If legally mandated or agreed upon, inquiries received specifically regarding such properties via the Website may be transferred to the rightful property representatives.

7. Cookies and Tracking Technologies The Website utilizes cookies (small text files stored on your device) and other tracking technologies (like pixels or web beacons) provided by us and third parties such as Google Analytics, Microsoft Clarity, and HubSpot. These technologies help us:

• Operate the Website effectively (e.g., session management).
• Enhance user experience (e.g., remembering preferences).
• Analyze website traffic and usage patterns.
• Deliver personalized content and targeted advertising.
• Measure the effectiveness of marketing campaigns.

By using the Website, you consent to the use of these cookies and technologies as described. You have the right to disable cookies through your browser settings; however, please note that disabling cookies may limit certain functionalities of the Website. For more information on how these third parties use your data, please review their respective privacy policies. 

8. User Rights (Data Subject Rights) In compliance with Israel’s Protection of Privacy Law, 1981, and other applicable data protection regulations (such as GDPR for relevant users), you have certain rights regarding your personal data:

• Right to Access: You may request to review the personal data we hold about you.
• Right to Rectification: You may request correction of inaccurate or incomplete personal data.
• Right to Erasure (“Right to be Forgotten”): You may request the deletion of your personal data under certain conditions (e.g., if it’s no longer necessary for the purpose it was collected, or if you withdraw consent where consent was the basis). This includes identifiable chat log data associated with your account or contact information.
   
• Right to Restrict Processing: You may request limitations on how we process your data under certain circumstances.
• Right to Object: You may object to processing based on legitimate interests or for direct marketing purposes.

To exercise these rights, please contact us at [email protected] with sufficient information to identify you and verify your request. Registered users may also be able to access, update, or delete some account information directly through their account settings. We will respond to verifiable requests within the timeframe required by applicable law. 

9. Data Security Semerenko Group implements reasonable technical and organizational security measures designed to protect user information against unauthorized access, disclosure, alteration, or destruction. However, no internet transmission or electronic storage method is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.  

10. Chatbot Data and Sensitive Information While using the AI Chatbot, please refrain from providing highly sensitive personal information unless specifically necessary for your real estate inquiry (e.g., general budget range is okay, specific bank account details are not). Do not input confidential business information, health details, national identification numbers, or any illegal content into the chat interface.

11. Data Retention We retain personal data, including chat logs associated with identifiable users, only for as long as necessary to fulfill the purposes outlined in this policy, provide our services, resolve disputes, enforce agreements, or comply with legal and regulatory obligations. Data may be anonymized or aggregated for analytical purposes and retained indefinitely in that form.

12. Changes to this Privacy Policy We reserve the right to amend this Privacy Policy at any time to reflect changes in our practices or legal requirements. If we make material changes, we will notify you either through the email address you have provided (if any) or by placing a prominent notice on our Website prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices. Your continued use of the Website after changes signifies your acceptance of the revised policy. 

13. Governing Law This Privacy Policy and any disputes related thereto shall be governed by and construed in accordance with the laws of the State of Israel, without regard to its conflict of law provisions. All disputes related to this policy will be subject to the exclusive jurisdiction of the competent courts located in Tel Aviv-Jaffa, Israel.