THE JEWISH AGENCY FOR ISRAEL
Privacy and Data Protection Policy and Notice
[Last updated: June 18, 2019]
The Jewish Agency for Israel (“The Jewish Agency”, “JAFI”, “we”, “our”, “us”) respect the privacy of its Customers and is committed to protect the personal information that its Customers share with it. We are transparent about our practices regarding the information we may collect and use when you use the Services, apply for a position, are employed by us, visit our websites or otherwise engage with us, and describe our practices in this policy and notice.
The Jewish Agency works to ensure that every Jewish person feels an unbreakable bond to one another and to Israel, no matter where he or she lives in the world. The Jewish Agency offers dozens of programs to reach this aim and to connect each and every Jew to the Jewish story. For example, The Jewish Agency sends Israeli emissaries (Shlichim) to Jewish communities around the world to teach about Israel and provide a personal connection to the Jewish State; offers volunteer programs in which Israeli and Diaspora Jews uplift vulnerable populations (both Jewish and non-Jewish); provides services for those immigrating to Israel; offers “Israel Experience” programs through its subsidiaries or partner organizations such as Masa Israel Journey and Birthright Israel; and operates or funds many other platforms for Jews to meet and get to know one another, to work and live together for a time. The Jewish Agency also supports vulnerable populations in Israel such as children at risk and the elderly with a wide variety of educational, recreational and residential programs (all together the “Services”).
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 Jewish Agency will generally be regarded as a data controller (the “Controller”).
1. WHICH INFORMATION MAY WE COLLECT?
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. The Jewish Agency may also collect the email addresses of people who communicate with us via email or via messenger services or other social media platforms or create accounts and login credentials.
The Jewish Agency 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 us. 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 Jewish Agency with third parties”).
2. HOW DO WE COLLECT PERSONAL DATA ON OUR CUSTOMERS OR USERS OF OUR SERVICES?
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 behavioural 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 when filling out forms or by engaging with us.
3. WHAT IS THE PURPOSE OF PERSONAL DATA WE COLLECT?
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 The Jewish Agency and/or any contracts entered into between a Customer and The Jewish Agency and to provide you with the information, products and Services that you request from The Jewish Agency;
• administering your file with The Jewish Agency;
• 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 Jewish Agency and or its subsidiaries, affiliates or third parties. We do this based on our legitimate interests in marketing our services and those of our affiliates;
• contacting you to inform you of additional services which may be of interest to you. We do this based on our legitimate interests in marketing our services;
• taking and using photographs of you if you attend our programs or events of any kind and publishing them in our brochures, on our website etc. We do this based on our legitimate interests in promoting the programs and the events held by The Jewish Agency and the services we provide;
• 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.
4. SHARING DATA GATHERED BY THE JEWISH AGENCY WITH THIRD PARTIES
We may transfer Personal Data to:
Related organizations, subsidiaries and affiliates
• Israel Experience
• Israel Tech Challenge
For avoidance of any doubt it is hereby clarified that this Policy is the policy of JAFI and not of its subsidiaries or other affiliated entities.
We transfer personal data to third parties in a variety of circumstances. We endeavor to ensure that these third parties use your data 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, 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, analysing 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 optimisation 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 Aanalytics
- Active Trail email Marketing software
- Zoom web meeting room platform
- Call Center system
- Visitors Registration system
- Project Management system
- Recruiting and applicant management software
- Human resource management software
- Travelling services and insurance companies
- Israeli Governmental offices
- Payroll management services
- Survey companies
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 The Jewish Agency, our staff and Customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction and to prevent cybercrime.
For avoidance of doubt, The Jewish Agency may transfer and disclose non-personal data to third parties at its own discretion.
5. WHERE DO WE STORE YOUR DATA?
We may keep Personal Data in a database which will be owned and controlled by the Controller. The Data we collect is hosted on internal data centers and Cloud: Microsoft Azure, Salesforce, Egnyte, Oracle (Eloqua), Google Drive and Amazon.
6. INTERNATIONAL DATA TRANSFERS
- To Israel. The Jewish Agency 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 Privacy Shield, 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 fulfil our contract with you;
- Fulfil 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.
7. MODIFICATION OR DELETION OF PERSONAL DATA GATHERED BY THE JEWISH AGENCY
Customers 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 Customer wishes to modify, delete or retrieve their Personal Data, they may do so by contacting The Jewish Agency at email@example.com. The Jewish Agency shall perform the necessary process to identify the Customer as a Customer 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 Customer 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 The Jewish Agency for the purpose of operating the Services.
8. DATA RETENTION
The Jewish Agency will retain data it processes only for as long as required to provide the Services and as necessary to comply with its legal obligations, resolve disputes and enforce its agreements. Data will be kept in accordance with applicable best business practices and legal obligations.
9. WEBSITE DATA COLLECTION AND COOKIES
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 recognise 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 recognise you when you return to our Site. This enables us, subject to personalise 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 behaviour, 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 (eg 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.
10. SECURITY AND STORAGE OF INFORMATION
We take great care in implementing, enforcing and maintaining the security of the personal data we process. The Jewish Agency 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.
The Jewish Agency 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 The Jewish Agency 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.
11. DATA SUBJECT RIGHTS
Data subjects, have rights under GDPR and local laws, including, in different circumstances, rights to: access 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 The Jewish Agency’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. In addition, these rights may not be exercisable where they relate to data that is not in a structured form, for example emails, or where other exemptions apply. 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 exercise these rights and modify, delete or retrieve their Personal Data, they may be able to do so by contacting JAFI (firstname.lastname@example.org). Note that JAFI may have to undertake a process to identify a data subject exercising their rights. JAFI 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 JAFI.
In the event of any concerns about data protection practices at The Jewish Agency, you may contact our Data Protection Officer at email@example.com. 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 Jewish Agency will endeavour to process personal data only with the consent of the holder of parental responsibility over the minor. The Jewish Agency 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.
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