Privacy Policy

Avital Sher Fialkow, operating an HR and placement service (the “Business”, “we”, “us”, or “our”) are committed to protecting your personal information and your right to privacy. This privacy policy (the “Privacy Policy”) describes the ways we collect information from and about you, how we use it and what rights you have in relation to it, so that you may decide whether or not to provide information to us. If there are any terms in this Privacy Policy that you do not agree with, please discontinue use of our Services (as defined below). By using our Services you agree to this Privacy Policy in addition to any other agreements we might have with you. In the event that such agreements contain terms that conflict with this Privacy Policy, the terms of those agreements will prevail. This Privacy Policy does not govern the practices of entities that our Business does not own or control, or entities that do not own or control our Business or people that our Business does not employ or manage.

This Privacy Policy applies to all information collected through applications we use or might use, websites, cloud based services, and/or any related services, sales, or other business activities and any other platform by which we may choose to provide our services (we refer to them collectively in this Privacy Policy as the “Services”).

Please read this Privacy Policy carefully as it will help you make informed decisions about sharing your personal information with us.

?WHAT INFORMATION DO WE COLLECT

Personal information you disclose to us
In Short: We collect personal information that candidates and/or employers provide to us such as full name, contact information, personal information contained in CVs and information regarding a candidate during his recruitment process.
We collect personal information that you voluntarily provide to us when registering to the Services, when you contact us through the Services, expressing an interest in obtaining information about us or our services, when we correspond with you as a customer or prospective customer or otherwise contacting us.
The personal information we collect can include the following:
• Your first and last name, second name, phone number, email address, age, gender, CV file or public information about a candidate's job experience appearing in public social network pages (such as Linkedin).
• We might also collect personal data related to your current or past employment, and about your recruitment process(es), such as:
o Date of birth;
o Gender;
o Marital status;
o Information about your contract of employment including start and end dates of employment, role and location, working hours, details of promotion, salary (including details of previous remuneration), pension, and benefits;
o Information in relation to your immigration status and right to work for us;
o Information regarding your current and past salary rates;
o References and recommendations including their contact information and full name;
o Qualifications and memberships;
o Pre-employment assessments;
o Comments made as part of your recruitment process;
o Other special circumstances which might be defined as sensitive personal data.
• Credentials. We collect passwords, password hints, and similar security information used for authentication and account access.
All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.
Information automatically collected
In Short: Some information – such as user timezone is collected automatically when you use our Services.
We might automatically collect certain information when you visit, use or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include your timezone, country, and location. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

?HOW DO WE USE YOUR INFORMATION

In Short: We process your information for purposes based on your consent and for the fulfillment of our contract with you, compliance with our legal obligations, and/or other legal reasons.
We use personal information collected via our Services for a variety of business purposes described below. We process your personal information for these purposes in reliance on your consent (“Consnet”) and for our legitimate business interests (the “Business Purposes”), in order to enter into or perform a contract with you (“Contractual”), and/or for compliance with our legal obligations (“Legal Reasons”). We indicate the specific processing grounds we rely on next to each purpose listed below.
We use the information we collect or receive:
• To facilitate account creation and login process with your Consent.
• To send administrative information to you, based on your Consent, we might send you administrative information via SMS or email for Business Purposes, Legal Reasons and/or possibly Contractual resons. We may use your personal information to send you product, service and new feature information and/or information about changes to our terms, conditions, and policies.
• To collect you feedback, with your Consent. We might post testimonials on our Services that may contain personal information. Prior to posting a testimonial, we will obtain your consent to use your name and testimonial. If you wish to update, or delete your testimonial, please contact us and be sure to include your name, testimonial location, and contact information.
• To protect our Services for Business Purposes and/or Legal Reasons. We may use your information as part of our efforts to keep our Services safe and secure (for example, for data breach monitoring and prevention).
• To enforce our terms, conditions and policies for Business Purposes, Legal Reasons and/or Contractual reasons.
• To respond to legal requests and prevent harm for Legal Reasons. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
• For other Business Purposes. We may use your information for other Business Purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Services, products, services, marketing and your experience.

?WILL YOUR INFORMATION BE SHARED WITH ANYONE

In Short: We only share information with your consent, to comply with laws, to protect your rights, or to fulfill business obligations.
We only share and disclose your information in the following situations:
• Compliance with Laws. We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
• Vital Interests and Legal Rights. We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
• Vendors, Consultants and Other Third-Party Service Providers. We may share your data with third party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples may include: the Comeet platform on which your personal data is managed and stored during your recruitment process. We may allow selected third parties to use certain technologies on the Services, which will enable them to collect data about how you use the Services over time. This information may be used to, among other things, analyze and track data, determine the use of certain content and better understand online activity. Unless described in this Privacy Policy, we do not share, sell, transfer, rent or trade any of your information with third parties for their promotional purposes.
• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
• Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include our parent company and any subsidiaries or other companies that we control or that are under common control with us.

?DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES

In Short: We may use cookies and other tracking technologies to collect and store information. For more information – visit Comeet's Cookie Notice page.
• We may use "cookies" for our regular and proper operation, including in order to collect statistical data about the use of our Services, to verify user details, to adapt the Services to your personal preferences and for information security purposes.
• Modern browsers include an option to avoid receiving cookies. If you don't know how to do this, check the help file of the browser you are using.
• We may allow other parties to manage our marketing activities. Ads you may see when visiting the Services may come from the computers of those parties. To manage their advertisements, these parties place cookies on your computer. The cookies allow these parties to collect information about viewing the advertisements they have placed and which advertisements you have viewed. The use of cookies by these parties is subject to their privacy policy and not to this Policy. See for example Google's privacy policy on the subject.

?IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY

In Short: We may transfer, store, and process your information in countries other than your own.
Our servers or our vendor's servers may be located in remote cloud environment located outside of your territory of residence. In addition, please be aware that your information may be transferred to, stored, and processed by us in any other country in which our Business or agents or contractors maintain facilities, and by using our Services, you consent to any such transfer of information outside of your country.
The Business is committed to subjecting all personal information received from Israel, in reliance on the Israeli law applicable law and regulations.

?HOW LONG DO WE KEEP YOUR INFORMATION

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Policy unless otherwise required by law.
We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements).
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

?HOW DO WE KEEP YOUR INFORMATION SAFE

In Short: We aim to protect your personal information through a system of organizational and technical security measures.
We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the services within a secure environment.

?WHAT ARE YOUR PRIVACY RIGHTS

In Short: You have rights that allow you access to and control over your personal information. You may ask to review or change your personal data stord in our databases at any time.
You have certain rights under applicable data protection laws. These include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification of non correct personal data. To make such a request, please contact us at sheravital at gmail.com. We will consider and act upon any request in accordance with applicable data protection laws.
If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal.
Cookies and similar technologies: Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services.

?DO WE MAKE UPDATES TO THIS POLICY

In Short: Yes, we will update this policy as necessary to stay compliant with relevant laws.
We may update this Privacy Policy from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this Privacy Policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Policy frequently to be informed of how we are protecting your information.

?HOW CAN YOU CONTACT US ABOUT THIS POLICY

If you have questions or comments about this policy, email us at sheravital at gmail.com.