1.Introduction and General Background
2. Legal basis for use of Personal Information
2.3 For Users located in the EU – In almost all cases the legal basis will be: (i) to provide our Services to Users; (ii) for the performance of a contract between us and Users; (iii) To fulfill a legitimate interest that we have as a business; (iv) because a User consented to us using Personal Data for a particular purpose.
3.1 “Information” means Personal Information and Non Personal Information, together.
3.2 “Israeli Data Protection Legislation” means the Privacy Protection Law 5741-1981 (the “PPL”) and any regulations promulgated therefrom, as amended, supplemented and superseded from time to time.
3.3 “Non-Personal Information” means any information processed by Lahav Executive Education in connection with the use of the Services by a User which is anonymous and/or does not personally identify the User and/or reveal the User’s specific identity as an individual, and/or cannot reasonably be attributed to the User (such as your browser type, technical device information, etc.).
3.4 “Personal Information” means any information processed through our Services or otherwise collected and processed by us, that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual.
3.5 “User”, “you” or “your” (including any alterations thereof) means any individual that uses our Services.
3.6 “Services” means any service provided by Lahav Executive Education to a User, including subscription to our courses and training classes and services in connection with our website available at: https://www.lahav.ac.il/ (“the Site”).
4. Collection of Personal Information – General Provisions
4.1 We collect and Process two types of Information: Personal Information and Non-Personal Information.
4.2 No legal requirement. We hereby inform you, and you hereby acknowledge that you have no legal obligation to provide us with any Personal Information (or any other Information) when you use the Services, or contact us, and the provision of it is solely based on your free will. However, you are aware that without the provision of your Personal Information, we will not be able to provide you with Services.
5. The Personal Information we process and the purposes of processing
The types of Personal Information each User will be required to provide or which we collect, may include (by way of non-exhaustive list), the following:
5.1 Personal Information provided by Users through the Site:
The types of Personal Information each User will be required to provide may include (by way of non-exhaustive list), the following:
5.1.1 Contact us: when you choose to contact us and/or when you apply for more information regarding the different programs we suggest, you will have to provide your first and last name, telephone number and email address, optionally your job and workplace, and any other free content you will choose to share with us.
5.1.2 Newsletter: when you choose to register to our Newsletter, you will have to provide your email address.
5.2 Personal Information provided by Users through our call center:
5.2.1 When you choose to contact us through our call center, you will have to provide your first and last name, telephone number and email address, optionally your job and workplace, and any other free content you will choose to share with us.
5.3 Personal Information provided by Users through our online payment form:
5.4 Personal Information automatically collected or generated from the Services:
5.4.1 Technical data about your device: we may collect some Personal Information about you, such as your IP address; by using certain technological tools as detailed in Section 8
6. How do we use your Personal Information
6.1 We will use the Personal Information for the following main purposes (as may be amended from time to time):
6.1.1 Providing information about our Services and providing the Services themselves;
6.1.2 operating, monitoring, facilitating the use of the Site and provide technical support;
6.1.3 To ensure that the Site is functioning correctly and to monitor, investigate any bug with, and improve the Site and/or Services;
6.1.4 We will use your email address or any other contact information you have provided us to contact our Users (by e-mail, SMS, or any other available channels) with general or personalized service-related messages, and to transmit marketing and promotional communications regarding our Services, such as our newsletter, subject to your consent. We may also contact Users through the email you provide us with in order to notify you about changes in the program schedule or content, events related to the programs, new Services, or any other information we think you will find valuable.
6.1.5 For answering inquiries from Users, including, but not limited to, data subjects requests.
6.1.6 For data security purposes.
7. Non-Personal Information we process and the purposes of processing
7.1 Non-Personal Information we automatically collected or generate about Users.
We may collect and/or otherwise generate certain Non-Personal Information from you. Such Non-Personal Information may include (by way of non-exhausting list):
7.1.1 Statistical information, such as: browser type, operating system version, referring URL, session time.
7.2 Purposes for use of Non-Personal Information. Non-Personal Information will be used (where applicable) for the purposes detailed in Section 6 above, and also for the following main purposes:
7.2.1 To monitor and analyze your use of the Services;
7.2.2 developing, customizing and improving the Services;
7.2.3 To support and enhance our data security measures, including for the purposes of preventing and mitigating the risks of fraud, error or any illegal or prohibited activity;
7.2.4 For the technical administration and troubleshooting of the Services;
7.2.5 To improve the usefulness and quality of the Services;
7.2.6 To assist in determining the effectiveness of our Services;
7.2.7 For commercial research and further development;
7.2.8 To create aggregated statistical data, inferred Non-Personal Information or anonymized or de-identified data, which we or our business partners may use to provide and improve our Services; and
7.2.9 For any other legitimate
8. Cookies and Information Collected by Other Automated Means
8.1.1 Essential Cookies. We use essential cookies to authenticate users, prevent fraudulent use of the Site, and to allow the Site and its features to function properly.
8.1.2 Functional Cookies. We use functional cookies to provide enhanced functionality and personalization, to remember your preferences, to diagnose server and software errors, and in cases of abuse, track and mitigate the abuse.
8.1.4 Advertising Cookies. Our advertising providers use advertising cookies to identify and store behaviors that users take when visiting our Site. These cookies are used in order to: (i) identify you as a prospect for our Site; (ii) deliver advertisements that are more relevant to you and your interests; (iii) limit the number of times you see an advertisement; and (iv) help measure the effectiveness of our advertising campaigns.
8.1.5 Social Media Cookies. Our Site includes social media widgets. These widgets may collect internet or other electronic network activity information, such as your IP address and which page you are visiting on our Site. These widgets may set a cookie or utilize other tracking technologies to accomplish this. Social media widgets are hosted by a third party and your interactions with those features are governed by the privacy policies of the companies that provide them.
8.3 Particular third-party cookies for our Site to note include:
8.3.1 Facebook Pixel. We use Facebook Pixel to customize our advertising and to serve you ads on your social media based on your browsing behavior. This allows your behavior to be tracked after you have been redirected to our Site by clicking on the Facebook ad. The Facebook Pixel stores a cookie on your device to enable us to measure the effectiveness of Facebook ads for statistical and market research purposes. We do not have access to the information collected through the Facebook Pixel. However, the information collected via the Facebook Pixel, on the Site as well as other websites on which Facebook Pixel is installed, is also stored and processed by Facebook. Facebook may link this information to your Facebook account and also use it for its own promotional purposes in accordance with Facebook’s Data Usage Policy. The Facebook Pixel also allows Facebook and its partners to show you advertisements on and outside of Facebook. You can opt-out of displaying Facebook ads by visiting your Facebook Ad Settings, and you can clear and control the information third parties share with Facebook in your Off-Facebook Activity page. If you do not have a Facebook account, you can opt-out of Facebook ads through the Digital Advertising Alliance here. For European users, please visit the European Interactive Digital Advertising Alliance at http://www.youronlinechoices.eu/.
9. Retention: How long do we retain the Information
9.1 We retain the User’s Personal Information for as long as such individuals are using our Services. If a User ceases to use our Services, we may continue to retain certain Personal Information of that User for the period required by our legal and regulatory obligations and/or for accounting purposes (i.e., as required by applicable laws regulating our Services, for bookkeeping purposes, and in order to have proof and evidence concerning our relationship with that User, should any legal issues arise following the User’s discontinuance of use of our Services).
9.2 Please note that except as required by applicable law, we will not be obligated to retain your data for any particular period, and we are free to securely delete it for any reason and at any time, with or without notice to you.
9.3 Unless otherwise restricted by applicable law, Non-Personal Information may be retained indefinitely.
10. Who do we share Information with
We may share your Information (including Personal Information) with certain third parties, as detailed below:
10.1 Compliance with Applicable Laws, Legal Orders and Authorities. We may disclose or allow government and law enforcement officials access to certain Personal Information, in response to a subpoena, search warrant or court order (or similar requirement), or in compliance with applicable laws. Such disclosure or access may occur if we have a good faith belief that we are legally compelled to do so, or that disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing.
10.2 Affiliates. We may share your Personal Information with any of our affiliates where we consider that it is in our legitimate interests to do so for internal administrative purposes (for example, ensuring consistent and coherent delivery of Services to our Users, corporate strategy, compliance, auditing and monitoring, research and development and quality assurance).
10.3 Service Providers and Business Partners. We may engage selected third party companies and individuals to perform the Services on our behalf (such as cloud vendors, data hosting services, external instructors or teachers, data analytics services, e-mail distribution and monitoring services, research and development services and our business, legal, financial and compliance advisors). We only provide such service providers with Information so they can perform their required functions on our behalf.
10.5 Business Transfer. We may share Information in connection with any proposed or actual financing, reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).
10.6 Marketing; Analytics. We may share Information Companies that assist us in our marketing, advertising and promotional activities; or with Analytics and search engine providers that assist us in the improvement and optimization of our Website and process Personal Information in the context of provision of analytical services to us.
11. How We Protect Information
We endeavor to maintain reasonable administrative, technical and physical safeguards designed to protect the Personal Information we maintain against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. Although we make reasonable efforts to protect the Personal Information which you provide to us, the transmission of Information over the internet and storage on IT systems and cloud-based servers is not completely secure. As such, you acknowledge and accept that we cannot ensure the security of any Information you transmit to us, or guarantee that this Information will not be accessed, disclosed, altered, or destroyed. We will make any legally required disclosures in the event of any compromise of Personal Information. To the extent the law allows us to provide such notification via e-mail or conspicuous posting on the Site, you agree to accept notice in that form.
12. Your Rights
12.1 You may have the right to review your Personal Information that is stored in our database(s) and provide a request for update, amendment and/or deletion if it is inaccurate or incorrect, by contacting us at [email protected]. We will act in accordance with applicable law in order to comply with your request. However, we may retain certain Personal Information as deemed required by and/or as otherwise permitted by applicable law. Your rights may differ depending on your jurisdiction. For example, Users located in the EU may be entitled to exercise an additional set of rights regarding their Personal Information, such as, the right to restriction of processing and the right to data portability.
12.3 Subject to the provisions set forth above, you have the right to withdraw your consent to receive marketing materials, by contacting us through the “unsubscribe” instructions in the promotional communications you receive.
13. International Data Transfers
We may host, store, process, maintain or transfer the Information to various sites worldwide, outside your jurisdiction including through cloud based service providers, where the privacy laws may not be as protective as those in your jurisdiction. By using the Services, you hereby provide your informed consent to the use and/or processing and/or hosting, storage and/or transfer of the Information to countries outside your jurisdiction or country. Where specific laws or regulations relating to data transfer apply to us, we will endeavor to ensure that the Personal Information is protected and transferred in a manner consistent with legal requirements. For example, regarding Information concerning Users located in the EU, transfer of Information to sites worldwide will be subject to the mechanisms permissible under the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (the “GDPR”).
14. Links to Third Party Sites
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
The Services are directed towards and designed for use by persons aged 18 and older, depending on the minority age in your jurisdiction. We do not solicit or knowingly collect Personal Information from children under the age of 18. If we nevertheless receive Personal Information from an individual who indicates that he or she is, or whom we otherwise have reason to believe is, under the age of 18, we will endeavor to delete such Information from our systems. If you are an individual under the age of 18, you are required not to use our Services.
17. Contacting us
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