1.Introduction and General Background
Lahav Executive Education Ltd. (“Lahav Executive Education”, “we” or “us”) presents this privacy policy, as may be amended from time to time (the “Privacy Policy” or “Policy”) in order to provide our Users (defined below) comprehensive information about Lahav Executive Education’s privacy and data protection practices in relation to Personal Information that is collected, used and/or otherwise processed by us and/or third parties acting on our behalf, when you apply for, subscribe or receive our Services.
We strongly urge you to read this Privacy Policy CAREFULLY before you start to use our Services and make sure that you fully understand and agree to it. If you do not agree to the terms of this Policy, whether in whole or in part, please discontinue using our SERVICES.
2. Legal basis for use of Personal Information
2.1 By using our Services, you hereby provide your informed consent to the collection, process and use of your Information by Lahav Executive Education (including the transfer of such information to third parties, as set forth in the Privacy policy), all, for the purposes and the terms set forth in this Privacy Policy.
2.2 The Personal Information you provide will be stored in our Database(s) (as defined in the PPL), and will be processed by Lahav Executive Education (including, third parties acting on our behalf) for the purposes and the terms as specified in this Privacy Policy.
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. Definitions
For the purpose of this Privacy Policy, the following terms shall have the respective meanings set forth besides them:
3.1 “Information” means Personal Information and Non Personal Information, together.
3.2 “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.).
3.3 “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.
3.4 “User”, “you” or “your” (including any alterations thereof) means any individual that uses our Services.
3.5 “Services” means any service provided by Lahav Executive Education to a User, including a 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, 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, 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:
5.3.1 Registration and purchase: if you choose to purchase one of our courses and training classes, you will have to provide your first and last name, telephone number and email address, your job and workplace, education, address and details of credit card or any other means of payment. We accept certain online payment methods, using online payment processors. These online payment processors and not Lahav will collect your Personal Data required to complete your purchase. We are not affiliated with such online payment processors as each is an independent contractor, and the collection and use of any Personal Data by such online payment processors is subject to their privacy policy and terms of use. We will only receive from such online payment processors an indication for the payment.
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:
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.
6.1.7 We may use Personal Information in order to enforce this Privacy Policy, resolve disputes, comply with any applicable law, or other requests from authorized authority(ies), and/or as otherwise authorized by you.
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:
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 determine and improve the usefulness, effectiveness and quality of the Services;
7.2.6 For commercial research and further development also in cooperation with third parties; ;
7.2.7 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
7.2.8 For any other legitimate
8. Cookies and Information Collected by Other Automated Means
8.1 We use cookies and other tracking technologies. Cookies are small pieces of text sent by your browser to your device. Cookies can be persistent (cookies that remain on your device for a set period of time or until you delete them) or session (cookies that are deleted as soon as you close your browser). When you use the Services, we and our third-party providers may place a number of cookies on your device. These cookies include:
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.
8.1.3 Analytics Cookies. Our analytics providers use cookies as part of their tools. Analytics cookies allow us and our analytics providers to recognize and count the number of users to the Site, see how users interact with the Site and different functions, and when users are using the Site. We use this information to improve the Site.
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.
8.2 To disable cookies and limit the collection and use of information through them, you can set your browser to refuse cookies or indicate when a cookie is being sent. When you opt-out, an opt-out cookie will be placed on your device. The opt-out cookie is browser and device-specific and will only last until cookies are cleared from your browser or device. The opt-out cookie will not work for essential cookies. If the cookie is removed or deleted, if you upgrade your browser or if you visit us from a different computer, you will need to return and update your preferences. To find out how to see what cookies have been set on your device, and how to reject and delete the cookies, please visit: https://www.aboutcookies.org/ For information on reviewing or deleting cookies from specific browsers, click on the appropriate browser: Firefox, Firefox IOS, Firefox Android, Safari, Safari Mobile, Chrome, Internet Explorer, Microsoft Edge, Opera. However, if you choose to decline cookies, you may not be able to fully experience the full features our Services.
8.3 Particular third-party cookies for our Site to note include:
8.3.1 Facebook (META) 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/.
8.3.2 Google Analytics. We use Google Analytics to collect information on your use of the Site to improve our Site. In order to collect this information, Google Analytics may set cookies on your browser, or read cookies that are already there. Google Analytics may also receive information about you from applications you have downloaded that partner with Google. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Google’s ability to use and share information collected by Google Analytics about your visits to our Site or to another application which partners with Google is restricted by the Google Analytics Terms of Use and the Google Privacy Policy, available for review at https://policies.google.com/technologies/partner-sites. To prevent your data from being used by Google Analytics, you can download the Google Analytics opt-out browser add-on for Google Analytics which can be found at https://tools.google.com/dlpage/gaoptout.
8.3.3 LinkedIn Pixel. We use LinkedIn Marketing Solutions Pixel (also known as the LinkedIn InsightTag) which is a snippet of Javascript code implemented on our Site to track page views and conversions and to provide insight into post-click and view-through conversions of our ad campaigns on LinkedIn. LinkedIn collects information relating to your visit to our Site, including referring address, IP address, device, and browser characteristics. LinkedIn does not share this information with us and only provides us with aggregated reports and alerts about the Site visitors and ad performance. However, LinkedIn may use this information to serve you ads elsewhere. For more information on how LinkedIn uses this information, see their privacy notice available at https://www.linkedin.com/legal/privacy-policy. LinkedIn members can control the use of their information for advertising purposes through their LinkedIn account settings.
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.
10.4 Enforce Our Rights or Legal Proceedings. We may transfer Personal Data in order to establish, protect, or exercise our legal rights, as required to enforce our terms of use or other contracts; to defend against legal claims or demands; to detect, investigate, prevent, or take action against illegal activities, fraud, or situations involving potential threats to the rights; or take any action in case of a dispute involving you with respect to the Services.
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 with 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 have the right to access your Personal Information that is stored in our database(s) and request for update, amendment and/or deletion if it is inaccurate, outdated 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 and the deletion right is wider in scope.
12.2 When you ask us to exercise any of your rights under this Privacy Policy and applicable law, we may need to ask you to provide us certain credentials to make sure that you are who you claim you are, to avoid disclosure to you of Personal Information which is related to others that you are not authorized to receive, and to ask you questions to better understand the nature and scope of Information that you request to access.
12.3 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 data protection 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
Our Site may contain links to other sites that are not operated by us. If you click a third party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit.
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
15. Children
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.
16. Changes to this Privacy Policy
This Privacy Policy may change from time to time. If we decide to change our Privacy Policy, we will post the new privacy policy in our Site accompanied with a notice indicating that some changes have been made. The new privacy policy will be effective from the date mentioned at the top page of the new policy. Each version of this Privacy Policy will be identified by its effective date, which you can find at the top of this Policy. Your continued use of the Services after we post such notice constitutes your agreement to any such changes. Where such changes will require your specific consent, we shall obtain it before applying the changes to the processing of your Personal Information.
17. Contacting us
If you have any questions about this Privacy Policy, please contact us by email to [email protected]
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