Privacy Notice

Last Updated: April 2022

IntraPosition Ltd (“IntraPosition”, "us", "we", or "our") operates the IntraPosition Website and Services (as defined below).

This Privacy Notice (“Privacy Notice”) governs the processing and transfer of Personal Data collected in connection with our websites, available at: https://www.intraposition.com/ (“Website”) to each person (“User” or “You”) accessing or using the Website and/or services provided on the Website or otherwise provided by us (“Services”).

If you choose to interact with the Website, register or use the Services, or otherwise provide data to us, you explicitly agree to the use of such data in accordance with this Privacy Notice. You may not use the Website or Services or submit any data through it if you do not agree to any of the terms hereunder. By using the Service, you agree to the collection and use of information in accordance with this Privacy Notice.

OVERVIEW

  • You are not required by law to provide us with any Personal Data. Sharing Personal Data with us is entirely voluntary.

  • Our Services are intended for Users over the age of 18. If you are under such age you should cease to use the Services immediately.

  • You may be entitled under applicable law to request to review, amend, erase or restrict the processing of your Personal Data. In case you request to erase or restrict the processing of your Personal Data, your use of the Services may be restricted or disabled.

  • We do not sell, trade, or rent Users' Personal Data to third parties. We only share Personal Data with third parties in connection with the provision of the Services to our Users, or other limited circumstances as specified herein.

  • If you have any questions or requests regarding the processing of your Personal Data, or would otherwise like to contact us in connection with this Privacy Notice, please send us an email to: info@IntraPosition.com.

AMENDMENTS
We reserve the right to periodically amend or revise the Privacy Notice, which will immediately affect the
implementation of the revised Privacy Notice on our website. The last revision date will be reflected in
the “Last Updated” heading located at the top of the Privacy Notice. We will make a reasonable effort to
notify you if we implement any changes that substantially change our privacy practices. We recommend
that you periodically review this Privacy Notice to ensure that you understand our privacy practices and
check for any amendments.

CONTACTING US

IntraPosition Ltd. incorporated under the laws of Israel is the controller of your Personal Data.

You may contact us and our privacy team as follows:

  • Through the "Contact Us" webpage available in our website

  • By Email: info@IntraPosition.com

  • By Mail: 14 Menachem Begin St., Ramat Gan, Israel

Questions, comments, requests and complaints regarding this Privacy Notice and the information we hold are welcome and should be addressed to us by using the contact details above. All requests will be dealt with promptly and efficiently.

ROLE OF THE PARTIES

Under the European Union ("EU") General Data Protection Regulation (Regulation 2016/679) (“GDPR”), we act, in the course of the processing of your direct personal data, as the Data Controller.

COLLECTION OF NON-PERSONAL DATA

Depending on your interaction with our website and Services, we may collect aggregated, non-personal information (“Non-Personal Data”), meaning, information which does not identify a specific natural person and cannot reasonably be used for such identification. We collect Non-Personal Data regarding use of the Services, such as the scope, frequency, latency, pages accessed and viewed, time and date you have accessed the Services, interactions with content and materials displayed through our Services, language preference, and other technical information regarding the device used to access the Services, for example type of device, type of browser, operating system, etc. This data is considered as Non-Personal Data when collected on an aggregate basis, or otherwise no combined with online identifiers.

Also, we may sometimes process and anonymize or aggregate personal data and identifiable information in a manner that shall create a new set of data that will be Non-Personal Data. Such a new data set can no longer be associated with any identified person.

Non-Personal Data may be used by us without limitation and for any purpose, including for commercial, research, or statistical purposes, without further notice to you.

COLLECTION OF  PERSONAL DATA

During your interaction with the website, we will collect individually identifiable information, namely information that identifies an individual or may with reasonable effort be used to identify an individual (“Personal Data”). This may include online identifiers, first and last name, email address, phone number, resume, cover letters, country, company’s name and additional information you decide to share with us, subject to applicable law.

If we combine Personal Data with Non-Personal Data, we will treat the combined data as Personal Data.

We may collect the data, either by automatic means and tracking technologies such as cookies (as further elaborated below), or when you voluntarily provide us your information, for example, when you sign up to our newsletter and provide us with your email address.

 

We have included in the table below information about which data is processed, how we process and use your data and the lawful basis for which we do so subject to the GDPR.

Type of Data

Online Identifiers 
When you interact with the website and use our Services, we will collect your Internet Protocol address (“IP”). 

Purpose of Processing

Collection of online identifiers is needed for website’s operation, security and fraud detection purposes, as well as in order to operate our business and provide our services to you. In addition, this data might be collected for internal statistics and analysis, for example, to analyses how many users have accessed certain content and from which country (where the country is extracted from the IP address) in order to enhance and improve our website and its content.

We may combine Online Identifiers with technical No-Personal Data. In such event, the combined data will be treated as Personal Data.

In addition, please note that Online Identifiers may be collected by us, or by third party services (as detailed under the paragraph below, including for remarketing purposes.

Lawful Basis

We process this information for the purpose of our business operation, fraud detection, and internal development, etc., based on our legitimate interests.

Where required under applicable laws, we will obtain your consent for the purpose of data collection through third-party cookies.  In any such case you always have the right to withdraw your consent.

Processing Actions

Collection of data, aggregation and statistical analysis, report generation, record keeping and storage.

Contact Us

If you voluntarily contact us through any means of communication we provide (e.g., send us an email, book a meeting, use the live chat function, or use any other online form or contact option available in our website), you will be requested to provide us with your contact information such as your name, Company, phone number and email address.

 We will use your contact details and save your contact history with us in order to respond to your inquiry, provide you with support, assistance or any other service requested by you. We will retain our contact history and correspondence, in the event we find it applicable.

Where you approach us as a customer of our services, the lawful basis for processing your contact us details will be the contract between you and us, meaning we will use the data for addressing your requests and inquiries.

After completing any such request, we will retain your information as part of our business records under our legitimate interest.

Some of our Services’ data might be processed under our legal obligation, such as safety requirements or our marketing efforts as a business.

We are collecting your data, transmitting it to our system and storing it in it (including third party systems, e.g., our email, CRM), and responding to you by email or any other means of contact provided by you. We also keep record of all our correspondence with you.

COOKIES & PIXEL USAGE

Our website includes tracking technologies such as Cookies and Pixels Collectively “Cookies”). These technologies are used for the purpose of gathering some information automatically, by ourselves or by third party service providers on our behalf.

We may use various types of Cookies:

  • Essential – which are necessary for the site to work properly (usually appears under our name/cookie tag);

  • Functional – designated to save your settings on the website - your language preference or other view preferences;

  • Targeting - used to collect information from you to help us improve our products and services and serve you with targeted advertisements that we believe will be relevant to you (e.g., Google’s Cookies);

  • Social networks - Social Plug-In Cookies (e.g., Facebook, Twitter, LinkedIn Cookies, or pixels, etc.) enable sharing your usage information with your social network’s accounts;

  • Analytics - give us aggregated and statistical information to improve the website and further developing it (e.g., Google analytics, Google Firebase Crashlytics, etc.);

  • Third-party services used by us – an external service which provides us with services which allow us to provide you with the services.

Please note that the data collected by the use of Cookies may be linked to and combined with any other data, including Personal Data. In any such case we will treat the combined data as Personal Data.

Cookies data is usually collected through the use of third-party services, e.g., Google, LinkedIn and Facebook. In those cases, your Personal Data will be transferred to those third parties, which might use it as a “joint controller” or “Co-Controller” of the data - meaning that the data is also “owned” and processed by them under their terms and conditions. That means that your Personal Data will be linked to other data collected by the relevant third party and processed in its systems, for its purposes, under its management and responsibility.

YOUR CHOICES REGARDING COOKIES

If you’d like to delete cookies or instruct your web browser to delete or refuse cookies, please visit the help pages of your web browser, or use the designated Cookies Bar in the Website.

Please note, however, that if you delete cookies or refuse to accept them, you might not be able to use all of the features we offer, you may not be able to store your preferences, and some of our pages might not display properly.

For the Chrome web browser, please visit this page from Google

For the Edge web browser, please visit this page from Microsoft

For the Firefox web browser, please visit this page from Mozilla

For the Safari web browser, please visit this page from Apple

For any other web browser, please visit your web browser’s official web pages.

You can learn more about cookies in the following third-party websites:

SHARING DATA WITH THIRD PARTIES

We do not share any Personal Data collected from you with third parties or any of our partners except in the following events:

  • Legal Requirement: We will share your information in this situation only if we are required to do so to comply with any applicable law, regulation, legal process, or governmental request (e.g., to comply with a court injunction, comply with tax authorities, etc.);

  • Policy Enforcement: We will share your information, solely to the extent needed to (i) enforce our policies and agreements; or (ii) to investigate any potential violations thereof, including without limitations, detect, prevent, or take action regarding illegal activities or other wrongdoings, suspected fraud or security issues;

  • Company’s Rights: We will share your information to establish or exercise our rights, to prevent harm to our rights, property, or safety, and to defend ourselves against legal claims, when necessary, subject to applicable law;

  • Third Party Rights: We will share your information, solely to the extent needed to prevent harm to the rights of our Users, yourself, or any third party’s rights, property, or safety;

  • Business Purpose: we may disclose your personal information to a third-party for a business purpose, as detailed above.

  • Service Providers: we share your information with third parties that perform services on our behalf (e.g. customer service, tracking, servers, service functionality, marketing, and support, etc.) these third parties may be located in different jurisdictions.

  • Corporate Transaction: we may share your information in the event of a corporate transaction (e.g. sale of a substantial part of our business, merger, consolidation or asset sale). In the event of the above, our affiliated companies or acquiring company will assume the rights and obligations as described in this Policy;

  • Authorized Disclosures: we may disclose your information to third-parties when you consent to a particular disclosure. Please note that once we share your information with another company, that information becomes subject to the other company’s privacy practices.

DATA RETENTION

Unless you instruct us otherwise and subject to applicable laws, we retain the information we collect for as long as needed to provide our services and to comply with our legal obligations, resolve disputes and enforce our agreements if applicable.

Also, we may keep some of your Personal Data as a user of our Services for more extended periods for protecting our legal interests or under any safety or other legal requirements.

As for Cookies data, usually the data will be retained in an identified manner for periods of 14-36 months, subject to the relevant system. However, as explained before, once you delete the Cookies from your computer or otherwise restrict the use of cookies, we will have no linkage between your identity and your Cookies data (yet, the third-party provider may retain such data relating to you, under the separate terms between you and any such third party, e.g., Facebook’s terms of use as a user of Facebook).

Recruitment data will be retained up to 7 years after the last recruitment activity, for allowing to protect ourselves from any potential legal suit, in accordance with Israel’s statute of limitations.

DATA PROCESSING LOCATION

We may store or process your Personal Data in a variety of countries, including the United States.

Any transfer of data that originates in the European Union ("EU") to a country outside of the European Economic Area (EEA), shall be made in compliance with the provisions of chapter 5 of the GDPR, e.g.:

  • transfer to a country that is recognized as providing an adequate level of legal protection;

  • transfer under a proper agreement containing the Standard Contractual Clauses published and authorized by the relevant EU authorities;

  • where we can be satisfied those alternative arrangements are in place to protect your privacy rights through the use of any other mechanism under the GDPR.

It is important to note that we are headquartered in Israel, a country that the European Data Protection Board considers offering an adequate level of Personal Data protection regulation.

 Suppose you are a resident of a jurisdiction where the transferring of your Personal Data requires your consent. In that case, your consent to this Privacy Policy includes your express consent for such transfer of your data.

SECURITY & DATA TRANSFER

We take great care in implementing physical, technical, and administrative security measures that we believe comply with applicable regulation and industry standards for securing your personal data. However, unfortunately, the transmission of information online cannot be 100% secure. As such, we cannot guarantee the full security of data transmitted via the Website, Platform and App and any use of any of it is done at your own risk.

As we may use third party service providers and our website uses third party cookies as described above, your Personal Data might be processed in other territories outside your jurisdiction. We will take appropriate measures to ensure that your Personal Data receives an adequate level of data protection upon its transfer, in accordance with applicable law. You may exercise your rights, where applicable, to receive information on such a transfer mechanism.

YOUR RIGHTS UNDER PRIVACY PROTECTION LAWS

We acknowledge that different people have different privacy concerns and preferences. Our goal is to be clear about what information we collect, so that you can make meaningful choices about how it is used. We provide you with the ability to exercise certain choices, rights and controls in connection with your information. Data protection and privacy laws provide you with some of the following principal rights regarding your Personal Data, including (and depending on your jurisdiction): The right to access your Personal Data that we process; The right to ensure your Personal Data is accurate, complete and up to date; The right to have your Personal Data amended (by correcting, deleting or adding information); The right to object to the processing of your Personal Data, to the extent applicable; The right to send or “port” your Personal Data; The right to file a complaint with a supervisory authority in your jurisdiction;  The right to withdraw consent, subject to legal or contractual restrictions and reasonable notice; Right to Non-Discrimination, etc.

If you wish to exercise any of your rights, please contact us through the means of contact detailed above. Where we are not able to provide you with the information for which you have asked, we will endeavor to explain the reasoning for this and inform you of your rights. We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any such information in accordance with applicable law.

In addition to your rights detailed above, you may opt-out of data collection and sharing process made through cookies. 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. For more information about cookies and your controls in this regard, please review your browser settings as well as the part above relating to Cookies usage.

In addition, you have the right to lodge a complaint at any time before the relevant supervisory authority for data protection issues. However, we will appreciate the chance to deal with your concerns before you approach the authorities, so please feel free to contact us in the first instance.

LINKS TO OTHER SITES

Our Service may contain links to other sites that are not operated by us. If you click on a third party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Notice 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.

CHILDREN PRIVACY AND DATA

The Website is not intended for individuals under the age of eighteen (18). Accordingly, we do not use the website to knowingly solicit data from or market to children as defined under applicable law (i.e., eighteen (18) in Israel, thirteen (13) regarding US individuals and sixteen (16) regarding European Economic Area ("EEA") individuals). We request that such individuals do not provide Personal Data. If you become aware or have any reason to believe that a child has shared any Personal Data with us, please contact us through the means of contact detailed above.

 

APPLICABLE LAWS

The provisions included in this Notice relating to matters regulated under the GDPR will apply only to the processing of Personal Data which is subject to the GDPR in accordance with the applicability provisions contained therein. If the GDPR does not apply to the processing of your Personal Data, some of the provisions above may not apply to you