Last updated: September 24, 2018
(i) When user access our Website, we collect certain online identifiers which we have a legitimate interest in processing such data, some of this data is processed by our third-party partners, all as detailed below;
(ii) We have legitimate interest to process a user’s email address, in the event such user has voluntarily contacted us; or
(iii) We will also process certain Personal Data where you have provided us with consent to do so, if applicable.
DATA WE COLLECT
During your access or any interaction with our Website we may collect information that identifies an individual or may with reasonable effort identify an individual (“Personal Data”) or non-identifiable information which may be made available or gathered via your use of the Website or Services (“Non-Personal Data”), the types and methods of gathering are specified in the table below:
Online Identifiers and Technical Non-Personal Data
Type of Data
We may collect certain Online Identifiers such as your IP addresses. Note that, while these Online Identifiers are considered personally identifiable information in many jurisdictions (such as the EEA), there are some jurisdictions in which such data sets are not considered as Personal Data. Therefore, we treat such information as Personal Data, in accordance with applicable laws. The information collected may be also stored on your device.
Further, we may collect technical Non-Personal Data which may be made available or gathered via your use of Services or the Website. This information includes your aggregated usage information and technical information transmitted by your device, as type of browser, type of operating system, type of device, the time and date you access the Services or the Website, connect or disconnect to the Services, user’s actions (i.e., regarding the pages viewed, duration on the page, the path taken in the Website, and interaction with the Services and the Website), Language preferences; approximate geographical location and redirecting URLs.
The Purpose of Collection
We will use the technical data as well as the Online Identifiers for the purpose of: (i) our legitimate interests of operating, providing, maintaining, protecting, managing, customizing and improving our Website and Services and the way in which we offer them; (ii) enhancing your experience with the Website and Services; (iii) our legitimate interests of auditing and tracking usage statistics and traffic flow, detecting fraud, security or technical issues in connection with the Website and Service, auditing our affiliates, and calculating payments; (iv) perform research, for analytical and statistical purposes; and (v) advertising optimization and to customize the content served through the Website based on the user’s preferences, uses and interactions with the Services.
The Online Identifiers might be collected by us or by our third-party affiliates, analytic and optimization partners which their Cookies we use in our Website, as detailed in the “Cookies” section below. Further, we may employ third-party service provider’s cookies to serve advertisement including advertisements based on your past visits (known as “targeting”)
Type of Data
If you contact us in any manner including by sending an email to an email address that we display, or in any other manner, we will process your email address as well as any information you will voluntarily choose to provides us (e.g., your name and contact history).
The Purpose of Collection
We will use your contact details and save your contact history with us in order to respond to your inquiry, provide you with support, assistance or any other service requested by you.
User Generated Content
Type of Data
While using the Service you are able to upload certain content to the Service, meaning, comment, like or share a post through social networks (e.g., Facebook) (“User Generated Content”). If you voluntarily choose to do so, it may provide us with access to certain information about you as stored therein (e.g. full name, e-mail and any other information which you made public).
The User Generated Content that you upload is accessible to other users. PLEASE USE CAUTION AND COMMON SENSE WHEN YOU UPLOAD YOUR PERSONAL DATA, ESPECIALLY ANY PERSONALLY IDENTIFIABLE INFORMATION. The content that you upload to the Service is not private.
The Purpose of Collection
We will use this information for the purpose of performing our contract with you, provide you with the Services you have requested (e.g. allow you to comment on a post, etc.).
Type of Data
If you are interested in working with us, you may voluntarily send us your CV to the applicable email address provided in our Website.
The Purpose of Collection
In the event you send us your CV, note that, your provision of Personal Data in connection with recruiting is voluntary, and you determine the extent of information you provide us. We do not request or require sensitive personal information concerning religion, health, sexual orientation, or political affiliation in connection with recruiting. We will use the information you have provided solely to communicate with you, to manage our recruiting and hiring processes, and for compliance with corporate governance and legal and regulatory requirements. If you are hired, the information may be used in connection with employment and corporate management.
The Purpose of Collection
We may use your Non-Personal Data and Personal Data in order to protect our, yours or third parties’ rights or property, resolve disputes and enforce our policies, defend legal claims, prevent fraud and other wrongdoing, as reasonably required and subject to applicable laws.
COMBINATION OF PERSONAL & NON-PERSONAL DATA
If we combine Personal Data with Non-Personal Data, the combined information will be treated as Personal Data for as long as it remains combined
HOW WE COLLECT INFORMATION
Depending on the nature of your interaction with the Services, we may collect information as follows:
Provided by you voluntarily – we will collect information if and when you choose to provide us with the information, such as contact us communications, etc.
COOKIES & THIRD-PARTY CONTENT
Should you wish to check the privacy policies of the companies that are managing the advertising scheme on the Company Websites, as well as opt-out controls, please review our Cookie Notice.
To receive further information about the advertising companies that the Company works with, please contact us at: email@example.com
SHARING DATA WITH THIRD PARTIES
We do not share any Personal Data collected from you with third parties or any of our partners except in the following events:
- If the Company reasonably believes that you have breached the Service's Terms & Conditions, or abused your rights to use the Service, or performed any act or omission that the Company reasonably believes to be violating any applicable law, rules, or regulations. The Company may share your information in these cases, with law enforcement and other competent authorities and with any third party, as may be required to handle any result of your wrongdoing;
- If the Company is required, or reasonably believes that it is required by law and/or law enforcement agencies to share or disclose your information;
- In any case of dispute, or legal proceeding of any kind between you and the Company or between you and other users with respect to, or in relation with the Service;
- In any case where the Company reasonably believes that sharing information is necessary to prevent imminent physical damage or damage to property;
- Online Identifiers - we may disclose or share Online Identifiers collected by us (as detailed above), for the purpose of operating our business and providing the Services, as well as to calculate payments and detect fraud, security or technical issues in connection with the Service;
- We may disclose Personal Data to our trusted agents and service providers so that they can perform requested services on our behalf, for example for security, fraud detection, server and data storage providers, etc. (among others, as detailed in the “Cookies, Third-Party Content & Advertising Campaigns” Section above).
Notwithstanding the above, may share aggregate or Non-Personal Data with our business partners and other third parties. Further, we reserve the right to use, disclose or transfer (for business purposes or otherwise) aggregated and processed data to third parties, including, inter alia, affiliates, for various purposes including commercial use. This information may be collected, processed and analyzed by us and transferred in a combined, collectively and aggregated manner (i.e., your information is immediately aggregated with other users) to third parties.
We retain the Non-Personal Data we collect for as long as needed to provide the Service, carry out our business purpose, perform our contract with you, and to comply with our legal obligations, resolve disputes and enforce our agreements, in accordance and compliance with applicable laws, or until an individual request us to delete its Personal Data, as detailed in the “User Rights” Section below. In addition, some of the data we receive depends on your privacy settings with the social network (i.e., Facebook) and you should always review, and if necessary, adjust your privacy settings on third-party websites and services before linking or connecting them to our Website.
We are entitled to rectify, replenish or remove incomplete or inaccurate information, at any time and at our sole discretion.
USERS CHOICES AND CONTROLS
Browser & Cookies Opt-out:
You may control how your browser responds to cookies by adjusting the privacy and security settings of your web browser. Please refer to the support page of the browser you are using. More information is detailed in our Cookie Notice.
You may opt out of certain advertisers’ cookies and browser-enabled, interest-based advertising at the Network Advertising Initiative’s (“NAI”) website- NAI consumer opt-out and the Digital Advertising Alliance’s (“DAA”) website- DAA opt-out page. If you wish to opt out of interest-based advertising, you may click here. Please note you will continue to receive generic ads.
You may also contact us at: firstname.lastname@example.org and we will be happy to assist you. Note that once you opt out, part of the Services provided by us might no longer be available and some features may not work if you revoke the data transfer.
In the event that you have any additional complaints about your privacy rights, please initially contact the Data Protection Officer. Please note that you have the right at any time to contact your local data protection authority.
Individuals have the right to know what information we hold about them and, in some cases, to have such information communicated to them. Individuals may also ask for our confirmation as to whether or not we process their Personal Data. Subject to the limitations in applicable law, individuals may also be entitled to obtain from us the Personal Data they have provided to us in a structured, commonly-used, and machine-readable format, and may have the right to transmit such Personal Data to another party.
The principal rights under applicable data protection law in relation to Personal Data are as follows: the right to access any information which is provided to us; the right to rectification; the right to erasure; the right to restrict processing; the right to object to processing; the right to data portability; the right to complain to a supervisory authority; and the right to withdraw consent (to the extent applicable).
We provide you with the ability to exercise certain choices and controls in connection with our treatment of your Personal Data, depending on your relationship with us. For more information, please review our Data Subject Right Overview and online forms available at: link .
Where we are not able to provide you with the information for which you have asked, we will endeavor to explain the reasoning for this and inform you of your rights, including the right to complain to the supervisor authority. We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any such information in accordance with applicable law. In addition, the process of locating and deleting the data may take up to one (1) month (following the receipt of the validation proof we require) in accordance with applicable law.
Data privacy and related laws in your jurisdiction may provide you with different or additional rights related to the data we collect from you, which may also apply, for example:
California Privacy Rights.
In the event you are a California resident, under California Civil Code Section 1798.83 you may request certain information regarding our disclosure of Personal Data to third parties for their direct marketing purposes. If you wish to exercise your right, please contact us at: email@example.com.
In the event you are a Canada resident, you are entitled to request certain information regarding our disclosure of Personal Data to third parties for their direct marketing purposes, where applicable. If you wish to exercise your right, please contact us at: firstname.lastname@example.org.
Your privacy is very important to the Company and we are committed to protecting your Personal Data from unauthorized access, use or disclosure. We have implemented physical, technical and administrative security measures for the Services that comply with applicable laws and industry standards. For more information please see: link. However, we can’t provide 100% security and we cannot be held responsible for unauthorized or unintended access that is beyond our control, and we make no warranty, express, implied or otherwise, that we will be able to prevent such access or use.
If you feel that your privacy was treated not in accordance with our policy, or if any person attempted gain unauthorized access to the Personal Information please contact us at: email@example.com
Further, in the event of a data incident, in which we discover your Personal Data may be at risk, then we will take reasonable efforts to notify you and the applicable authority (if required, subject to applicable laws).
IMPORTANT NOTICE ABOUT CHILDREN'S PRIVACY
If you become aware or have any reason to believe that a Child has shared any information with us, please contact us at: firstname.lastname@example.org
We may store or process your Personal Data in the United States or in other countries. If you visit our Website or use our Services from locations outside of the United States, please note that any information you provide to us through your use of our Website or Service may be transferred to and processed in countries other than the country from which you accessed our Website or Service, including the United States where our central database is operated. If you are a resident of the European Economic Area ("EEA") we will take appropriate measures to ensure that your personal data receives an adequate level of data protection upon its transfer outside of the EEA. If you are a resident of a jurisdiction where transfer of your personal data requires your consent, then you hereby expressly consent for such transfer of your data.
DO NOT TRACK DISCLOSURE
The Service does not respond to Do Not Track signals. For more information about Do Not Track signals, please see: http://www.allaboutdnt.com/.
DATA PROTECTION OFFICER
In addition to the above, if you wish to exercise your rights related to your Personal Data, or you have any requests regarding the collection of your data by us, you may contact our Data Protection Officer at:
Please be sure to include your name, and contact details in any correspondence so that we can respond to your inquiry or request.