- WHICH INFORMATION MAY WE COLLECT?
- HOW DO WE COLLECT PERSONAL DATA ON USERS OF THE SERVICES?
- WHAT IS THE PURPOSE OF PERSONAL DATA WE COLLECT?
- SHARING DATA GATHERED by the IE WITH THIRD PARTIES
- INTERNATIONAL DATA TRANSFERS
- MODIFICATION OR DELETION OF PERSONAL DATA GATHERED by the IE
- DATA RETENTION
- WEBSITE DATA COLLECTION AND COOKIES
- SECURITY AND STORAGE OF INFORMATION
- DATA SUBJECT RIGHTS
Last Updated August 19, 2018
The Israel Experience – Educational Tourism Services Ltd. (“Israel Experience”, “we”, “our”, “us” etc.) respects the privacy of its users, visitors, delegates, employees and staff, candidates, representatives (“you” etc.), and is committed to protect the Personal Data that its Users share with it. We are transparent about our practices regarding personal data which we may collect and use.
Please read the following carefully to understand our practices regarding your personal data and how we will treat it.
For the purposes of European Economic Area data protection law (the “Data Protection Law“), including the Regulation EU 2016/679 – the General Data Protection Regulation (“GDPR“), the IE will generally be regarded as a data controller (the “Controller“).
Categories of information and data we may collect from our Users.
Data we collect about you prior to, and from, your use of the Services
We collect and process non-identifiable and anonymous information, and also collect several categories of personal data (“Personal Data“), including sensitive personal data (known in the EU as Special Categories of Personal Data) through your use of the Services. This may include your, and your spouse and dependents’, name (first and last), nickname, birthdate, gender, nationality, job title, phone number(s), department you work in, national security number, address, country, city, postcode, email and other contact details, family status, your bank account, credit card and other such payment and billing details, credentials regarding the right to work in your jurisdiction, employment history, vocational and academic skills and qualifications, interests and preferences, preferences concerning Aliya and Israel, gender, information regarding your health including any physical or mental health conditions and allergies.
IE may also collect the email addresses of people who communicate with IE via email or via messenger services or other social media platforms or create accounts and login credentials. By your registering on IE’s web sites and event pages, IE may collect your name, phone number and email you provided. IE may use this information to offer IE’s services and support to you.
IE may collect Personal Data about an individual’s racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership (or non-membership), physical or mental health or condition, criminal offences, or related proceedings or any other data considered as sensitive under applicable law (“Sensitive Personal Data“).
You do not have any legal obligation to provide any information to IE. However, we require certain information in order to provide the Services. If you choose not to provide us with certain information we may not be able to provide you with the Services.
We will never sell your Personal Data to third parties. (for more information see the Section titled: “Sharing Data gathered by the IE with third parties”).
There are two main methods we use:
We collect Personal Data through your use of our Website. In other words, when you are using the website or application, we are aware of it and may gather, collect and record the information relating to such usage, either independently or through the help of third-party services as detailed below. This may include technical information and behavioral information such as the User’s Internet protocol (IP) address used to connect your computer to the Internet, your uniform resource locators (URL), operating system, type of browser, browser plug-in types and versions, screen resolution, Flash version, time zone setting, the User’s ‘click-stream’ on the website, the period of time the User visited the website, methods used to browse away from a page, and any phone number used to call our customer service number. We likewise may place cookies on your browsing devices (see section ‘Cookies’ below).
We collect Personal Data required to provide the Services when you register with us. In addition, we collect your Personal Data, when you provide us such information by engaging with us. This may also include recording incoming calls.
We will use Personal Data to provide and improve the Services and meet our contractual, ethical and legal obligations, including for example:
- carrying out our obligations arising from any contracts entered into between you and IE and/or any contracts entered into between a Customer and the IE and to provide you with the information, products and Services that you request from the IE;
- administering your file with IE;
- verifying and carry out financial transactions in relation to payments you make in connection with the Services;
- notifying you about changes to our Services;
- contacting you for the purpose of providing you with technical assistance and other related information about the Services;
- replying to your queries, troubleshooting problems, detect and protect against error, fraud or other criminal activity;
- contacting you to give you information and inviting you to take part in other programs offered by the IE and or its affiliates or third parties;
- contacting you to inform you of additional services which may be of interest to you;
- compliance and audit purposes, such as meeting our reporting obligations in our various jurisdictions, and for crime prevention and prosecution in so far as it relates to our staff, members, facilities etc.;
- for security purposes and to identify and authenticate your access to the Services.
Personal Data which you provide us may be combined with personal data which may be provided by other sources, all of which will be used for the purposes set out above.
We may transfer Personal Data to:
Related organizations, The Jewish Agency and affiliates. This includes: any member of our group, which means our affiliates, in the EU, in Israel, in the US and elsewhere, as well our joint-venture partners who support our processing of personal data under this policy. It also includes affiliates or other partners that help us provide our Services. For example:
- The Jewish Agency
We transfer personal data to third parties in a variety of circumstances. We endeavor to ensure that these third parties use your information only to the extent necessary to perform their functions, and to have a contract in place with them to govern their processing on our behalf. These third parties may include business partners, funding bodies and fund recipients, suppliers, affiliates, agents and/or sub-contractors for the performance of any contract we enter into with you. They may assist us in providing the Services we offer, processing transactions, fulfilling requests for information, receiving and sending communications, analyzing data, providing IT and other support services or in other tasks, from time to time. These third parties may also include analytics and search engine providers that assist us in the improvement and optimization of our website and our marketing.
We periodically add and remove third party providers. At present our third-party providers to whom we may transfer personal data include also the following:
- Google Analytics
- Social media such as Facebook, Instagram. And Twitter.
- Recruiting and applicant management software
- Human resource management software
- Travelling services and insurance companies
- Israeli Governmental offices
- Payroll management services
In addition, we may disclose your Personal Data to third parties: if we are under a duty to disclose or share your personal data in order to comply with any legal or audit or compliance obligation, in the course of any legal or regulatory proceeding or investigation, or in order to enforce or apply the terms of a contract we have with you or for you; or to protect the rights, property, or safety of IE, our staff and users, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction and to prevent cybercrime.
For avoidance of doubt, IE may transfer and disclose non-personal data to third parties at its own discretion.
- To Israel. IE headquarters are based in Israel. Israel is considered by the European Commission to offer an adequate level of protection for the personal data of EU Member State residents;
- To the United States of America; where we transfer personal data of European persons to the USA, we will do so pursuant to one of the bases described in EU data protection laws, such as consent, or to parties who are certified as part of the Privacy Shield, or subject to standard contractual clauses etc.;
- Within the EU.
We may transfer your personal data outside of the EEA, in order to:
- Store or backup the information;
- Enable us to provide you with the Services and fulfill our contract with you;
- Fulfill any legal, audit or compliance obligations which require us to make that transfer;
- Facilitate the operation of our organization, where it is in our legitimate interests and we have concluded these are not overridden by your rights;
- To offer our Services across multiple jurisdictions; and
- To operate our organization, subsidiaries and affiliates in an efficient and optimal manner.
Users may have a legal right under certain applicable laws (for instance if the user is in the EU) to receive, rectify, erase, and restrict Personal Data about them that is held by us, to object to processing and, if processing occurs based on consent, to withdraw their consent
If, for any reason, a user wishes to modify, delete or retrieve their Personal Data, they may do so by contacting the IE: [email protected]. IE shall perform the necessary process to identify the user as a user who has the right to retrieve the specific information and then furnish the data required to be amended, deleted or retrieved together with a specific identification of the user and data.
Please note that Personal Data may be either deleted or retained in an aggregated manner without being linked to any identifiers or Personal Data, depending on technical commercial capability. Such information may continue to be used by IE for the purpose of operating the Services.
In addition, specific types of Personal Data may be kept in accordance with our data retention policy, if and as is in force at IE.
When you access or use our Services, we may use industry standard technologies such as Cookies, pixels and similar technologies, which store certain information on your computer or browsing device and which will allow us to identify the computer or device with the user, and to enable automatic activation of certain features, and make your Service experience much more convenient and effortless. We use different types of Cookies: some cookies are strictly necessary, they are required for the operation of our Site and under our terms with you; this includes for example, cookies that enable you to log into secure areas of our Service. We also use analytical and performance monitoring cookies, which allow us to recognize and count the number of visitors and to see how visitors move around our website when they are using it. Finally, we use functionality cookies which are used to recognize you when you return to our Site. This enables us, subject to personalize content to your preferences, including for example, your choice of language or region.
Different cookies are kept for different periods. Session cookies are used to keep track of your activities online in a given browsing session; these cookies generally expire when the browser is closed but may be retained for a period on your device. Permanent cookies remain in operation even when you have closed the browser; they are used to remember your login details and password. Third-party cookies are installed by third parties with the aim of collecting certain information to research behavior, demographics. Third party cookies on our site include, for example, Google Analytics. Likewise, pixels from Facebook and others enable integration of third party service providers (e.g. Facebook, Twitter) on our site. Third party cookies will be retained according to the terms of those third parties, and you can control those cookies in your browser settings.
Most browsers will allow you to erase cookies from your computer’s hard drive, block acceptance of cookies, or receive a warning before a cookie is stored. However, if you block or erase cookies your online experience on our website will be limited.
How to disable cookies: The effect of disabling cookies depends on which cookies you disable but, in general, the website and some services delivered through it may not operate properly, may not recognize your device, may not remember your preferences and so on, if cookies are disabled or removed. However, allowing or disabling cookies is your choice and in your control. If you want to disable cookies on our site, you need to change your browser settings to reject cookies. How you can do this will depend on the browser you use. Further details on how to disable cookies can be found here: Internet Explorer, Google Chrome, Firefox, Safari.
Our websites may, from time to time, contain links to external sites. We are not responsible for the operation, privacy policies or the content of such sites.
We take a great care in implementing, enforcing and maintaining the security of the personal data we process. IE endeavors to implement, enforce and maintain security measures, technologies and policies to prevent the unauthorized or accidental access to or destruction, loss, modification, use or disclosure of Personal Data. We likewise take steps to monitor compliance of such policies on an ongoing basis. Where we deem it necessary in light of the nature of the data in question and the risks to data subjects, we may encrypt data. Likewise, we take industry standard steps to ensure our website is safe.
Note however, that no data security measures are perfect or impenetrable, and we cannot guarantee that unauthorized access, leaks, viruses and other data security breaches will never occur.
IE shall act in accordance with its policies to promptly notify the relevant authorities and data subjects in the event that any Personal Data processed by IE is lost, stolen, or where there has been any unauthorized access to it, all in accordance with applicable law and on the instructions of qualified authority. We shall promptly take reasonable remedial measures.
Data subjects have rights under GDPR and local laws, including, in different circumstances, rights to access data, move data, rectify data, object to processing, and erase data. It is clarified for the removal of doubt, that data subject rights cannot be exercised in a manner inconsistent with the rights of IE’s employees, with Our proprietary rights, and third-party rights. As such, job references, reviews, internal notes and assessments, documents and notes including proprietary information or forms of intellectual property, cannot be accessed or erased or rectified. If processing occurs based on consent, data subjects may have a right to withdraw their consent.
If, for any reason, a data subject wishes to modify, delete or retrieve their Personal Data, they may do so by contacting [email protected] Note that IE may have to undertake a process to identify a data subject exercising their rights, and may keep details of such rights exercised for its own compliance and audit requirements. Please note that Personal Data may be either deleted or retained in an aggregated manner without being linked to any identifiers or Personal Data, depending on technical commercial capability. Such information may continue to be used by IE.
In the event of any concerns about data protection practices at IE, you may contact our Data Protection Officer at [email protected]. EU persons have the right to lodge a complaint with a supervisory authority.
With regard to Personal Data about a minor under 16 years old, the IE will endeavour to process personal data only with the consent of the holder of parental responsibility over the minor. IE will make reasonable efforts to verify that consent is given or authorised by the holder of parental responsibility of the child but cannot generally take responsibility for misrepresentation by persons as to their age.