MyEDPO Ltd Privacy and Data Protection Policy and Notice

Last Updated: December 2, 2018

 

 

 

 

 

 

 

MyEDPO Israel Ltd ("MyEDPO", "we", "our") respects the privacy of its clients, employees and interviewees, and is committed to protecting the personal information that its Users (as defined below) 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 office sites, visit our websites, or otherwise engage with us, and describe our practices in this policy and notice.

MyEDPO is a Data Protection consultancy that provides full range of data protection and GDPR services to European and Global clients - from early stage startups to public companies, universities and government entities.

 A User may be either an entity, or an individual. Anyone with respect to whom we collect personal data, shall collectively be referred to as "Users" or "you" or “Data Subjects”).

This Policy (the "Privacy Policy") explains the types of information we may collect from Users or that Users may provide when engaging with us, and which may likewise be collected from site visitors, website visitors, employment candidates and others. This Policy also describes MyEDPO’s practices for collecting, using, maintaining and processing information through the MyEDPO Website.

Users may be asked to provide MyEDPO with certain information including Personal Data as further detailed in this Privacy Policy ("Data"). MyEDPO’s use of this Data will be undertaken in accordance with this Privacy Policy.

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"), MyEDPO will usually be a data controller (the "Controller").

 

1. WHICH INFORMATION MAY WE COLLECT?

One type of Data is non-identifiable and anonymous information ("Non-personal Information"). We also collect several categories of personal data ("Personal Data"). Personal Data which is being gathered consists of any details which are personally identifiable provided consciously and voluntarily by a User or through your use of the MyEDPO website (as described below). This may include your name (first and last), email address, phone numbers, postal address, birthdate, gender, position and organization name, and other information User may choose to provide to MyEDPO.

Additionally, we may obtain location data related to the geographic location of your laptop, mobile device or other digital device on which the MyEDPO website is used.

If you are visiting our office, we may ask you for your name, email address, phone number and the name and position of the person you are visiting. We use this information to facilitate our legitimate interest of informing the MyEDPO team member of the impending meeting, as well as to ensure the safety and security of our staff and premises.

You do not have any legal obligation to provide any information to MyEDPO, however, we may sometimes require certain information in order to provide any services or share information with you. If you choose not to provide us with certain information, we may not be able to engage with you fully.

MyEDPO may also collect the email addresses and contact details of people who communicate with MyEDPO via email or via messenger services or other social media platforms.

MyEDPO also collects data relating to employees, which data is governed in accordance with the law applicable to such data.

MyEDPO also collects data relating to employment candidates. This includes CVs and the data contained therein, notes on meetings, references, interviewer impressions and such industry standard data, as well as collecting data made publicly available or available to us on social networks. We collect such data based on the intention of the candidate to enter into an employment agreement with MyEDPO.

2. HOW DO WE COLLECT PERSONAL DATA ON USERS OF MyEDPO

We collect Personal Data through your use of our Website. In other words, when you are using the website, 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 number. We likewise may place cookies on your browsing devices (see section 'Cookies' below).

We collect your Personal Data, when you provide us such information orally or in writing, by entering it manually whether through site visits, in the course of preparing a contract, or otherwise in engaging with us.

3. WHAT ARE THE PURPOSES OF PERSONAL DATA WE COLLECT?

We will use Personal Data to engage in professional strategic thinking and planning on data protection issues and to meet our contractual, ethical and legal obligations, including for example:

  • to enable us to meet our legal, contractual and business obligations as an employer and a potential employer for our employees and job applicants;

  • carrying out our obligations arising from any contracts entered into between you or your employer and MyEDPO;

  • notifying you about new or updated judicial and regulatory decisions and reports, evolving best practice and other consulting activities;

  • replying to your queries;

  • contacting you to give you information about events by MyEDPO;

  • soliciting feedback in connection with your engagement with MyEDPO;

  • compliance and audit purposes and for crime prevention and prosecution, especially in connection with our staff etc;

  • for security purposes.

 

4. SHARING DATA WITH THIRD PARTIES

We may transfer Personal Data to:

  • Members of our Group: This includes any member of our group, which means our controlling organization, or organizations under common control with us in the EU and in Israel.

  • Third Parties. 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 partners, service providers, suppliers, affiliates or agents. They may assist us in providing the services we offer, 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.

Likewise, we may transfer 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 our terms of supply terms and other agreements with you; or to protect the rights, property, or safety of MyEDPO, or others. This includes exchanging information with other companies and organisations to prevent fraud and cybercrime.

For avoidance of doubt, MyEDPO 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 or controlled by the Controller, and managed either onsite or online.

 

6. INTERNATIONAL DATA TRANSFERS

Personal Data may be transferred to, and stored and used at, a destination outside the European Economic Area (EEA) that may not be subject to equivalent Data protection laws to those of the EU. Where your Data is transferred outside of the EEA, we will take all steps reasonably necessary to ensure that your Data is subject to appropriate safeguards, and that it is treated securely and in accordance with this privacy policy. MyEDPO transfers data from its various locations and jurisdictions to other jurisdictions as follows:

  • MyEDPO is based in Israel. Israel is considered by the European Commission to offer an adequate level of protection for the personal information of EU Member State residents; we may transfer data to other countries with an adequacy ruling too;

  • We may transfer your personal data outside of the EEA, in order to: store or backup the information, fulfill any legal, audit or compliance obligations which require us to make that transfer. Where this happens, MyEDPO will ensure that suitable safeguards are in place – including for example, Privacy Shield or Standard Contractual Clauses - to protect the personal information of people in EU Member States in accordance with the provisions of the Data Protection Law.

 

7. DATA RETENTION

MyEDPO will retain personal data it processes only for as long as required in our view, to fulfill its aims and as necessary to comply with our legal obligations, to resolve disputes and to enforce agreements. We will also retain personal data to meet any audit, compliance and industry best-practices.

Data that is no longer retained may be anonymized or deleted. Likewise, some metadata and statistical information concerning the use of the Services are not subject to the deletion procedures in this policy and may be retained by MyEDPO. We will not be able to identify you from this data. Some data may also be retained on our third-party service providers’ servers until deleted in accordance with their privacy policy and their retention policy.

 

8. WEBSITE DATA COLLECTION AND COOKIES

When you access or use our website, MyEDPO 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 may use different types of Cookies: some cookies are necessary, they are required for the operation of our Site and under our terms with you. 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 may use functionality cookies which are used to recognise you when you return to our Site. This enables us, 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, LinkedIn) 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.

We use Cookies and other technologies on the basis of our legitimate interests of improving, optimizing and personalizing our services, and these are not overridden by your rights.

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:

 

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.

9. SECURITY AND STORAGE OF INFORMATION

We take a great care in implementing, enforcing and maintaining the security of the personal data we process. MyEDPO implements, enforces and maintains 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.

Within MyEDPO, we limit access to personal data to those of our personnel who: (i) require access in order for MyEDPO to fulfil its obligations under this Privacy Policy and its agreements and (ii) have been appropriately and periodically trained on the requirements applicable to the processing, care and handling of the Personal Data (iii) are under confidentiality obligations as required under applicable law. MyEDPO takes steps to ensure that its staff who have access to personal data are honest, reliable, competent and trained.

MyEDPO 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 MyEDPO 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. MyEDPO shall promptly take reasonable remedial measures.

 

10. DATA SUBJECT RIGHTS

Data subjects may have rights under GDPR and local laws, including, in different circumstances, rights to data portability, rights to access data, rectify data, object to processing, and erase data. Data subject rights cannot be exercised in a manner inconsistent with the rights of MyEDPO employees and staff, with MyEDPO 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 modify, delete or retrieve their Personal Data, they may be able to do so by contacting MYEDPO. Note that MyEDPO may have to undertake a process to identify a data subject exercising their rights. MyEDPO 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 MyEDPO.

Data subjects may have the right to lodge a complaint, with a data protection supervisory authority in the place of their habitual residence. If the supervisory authority fails to deal with a complaint or inform you within the time frame set under applicable law, you may have the right to an effective judicial remedy.

 

11. GENERAL

MyEDPO aims to process only adequate, accurate and relevant data limited to the needs and purposes for which it is gathered. It also aims to store data for the time period necessary to fulfill the purpose for which the data is gathered. MyEDPO only collects data in connection with a specific legitimate purpose and only processes data in accordance with this Privacy Policy.

Minors. We do not knowingly collect or solicit information or data from children under the age of 16 If you are under 16, do not register or attempt to register for any of the MyEDPO services or send any information about yourself to us. If we learn that we have collected or have been sent Personal Data or from a child under the age of 16, we will delete that Personal Data as soon as reasonably practicable without any liability to MyEDPO. If you believe that we might have collected or been sent information from a minor under the age of 16, please contact us, as soon as possible.

Changes to this Privacy Policy. The terms of this Privacy Policy will govern the use of the services, websites and application, and any information collected in connection with them. MyEDPO may amend or update this Privacy Policy from time to time. The most current version of this Privacy Policy will be available at: https://www.myedpo.com/privacy/. All changes to this Privacy Policy are effective as of the stated "Last Revised" date and your continued use of Services will constitute your active acceptance of, and agreement to be bound by, the changes to the Privacy Policy.

If you have any questions or comments concerning this Privacy Policy, you are welcome to send us an email or otherwise contact us at info[at]myedpo[d0t]com and we will make an effort to reply within a reasonable timeframe.

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MYEDPO - EUROPEAN DATA PROTECTION OFFICER SERVICES

Data Protection and Privacy Policy and Notice

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