Last updated: Feb 2021
2. Who we are and how can you contact us
Moveo HLS Ltd.
1 Har Sinai St. Tel Aviv, Israel
While you are visiting our website, we might collect some information about you. That may include any data you provide us upon your sole discretion and data regarding your use of our websites, as set forth by this Privacy Statement. Questions, comments, requests, and complaints regarding this Statement and the information we hold are welcome and should be addressed by using the contact details above. All requests will be dealt with promptly and efficiently.
3. Information we may collect from you
"Personal Data", or personal information, means any information about an individual from which that person can be identified. We collect Personal Data from you voluntarily when you provide such Personal Data to us or via our services and websites with which you voluntarily interact. We may also obtain such Personal Data about you as may be provided to us in the course of our legitimate business activities.
You do not have to provide us with your information, but in some cases, if you do not, it may mean that you won't be able to use our services. For example, we may be unable to complete a requested "contact form" inquiry unless you'll provide us with your contact details.
When you use our website and choose voluntarily to provide us with your information, we might collect and process the following information:
• Identity Data - including full name, username, or any similar identifier, title, date of birth and gender, and any other information you provide upon your sole discretion.
• Contact Data - including email address and telephone numbers.
• Usage Data - includes information about how you use our website, systems, and services.
• Technical Data - includes internet protocol (IP) address, the device you are using, browser type and version, screen resolution, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
• Job application data - include name, email, phone, and a resume file, just if you have decided to voluntarily provide us with your data as part of being recruited by us;
• Marketing and Communications Data - includes your preferences in receiving marketing content from our third parties and us, and your communication preferences.We also collect, use, and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your Personal Data but does not reveal your identity.
4. How is your Personal Data Collected
We use different methods to collect data from and about you, including through:
• Direct interactions - You may give us your Identity, Contact and other Personal Data by filling in forms (e.g. "Contact Us" or "Newsletter Subscription", "Registration Form" etc.) or by corresponding with us by phone, email, or otherwise.
• Automated technologies or interactions - As you interact with our website, we may automatically collect Personal Data (please refer to the description below, under "Cookies Usage").
• Third parties or publicly available sources - We may receive Personal Data about you from various third parties and public sources, e.g., advertising and social networks, analytics providers, search information providers.
5. Cookies Usage
• Essential Cookies – which are necessary for the site to work properly;
• Functional Cookies – designated to save your settings on the site - your language preference or other view preferences;
• Session Cookies – used to support the website's functionality – such Cookies are stored only temporarily during a browsing session and are deleted from your device when you close the browser.
• Targeting Cookies - These cookies are used to collect information from you to improve our products and services and serve you with targeted advertisements that we believe will be relevant to you (e.g., Google's Cookies, Facebook's pixels, Linkedin, Hubspot, etc.).
• Social networks Cookies - Social Plug-In Cookies (e.g., Facebook or LinkedIn pixels, etc.) enabling sharing information with your social networks accounts to be smooth and seamless.
• Analytics Cookies - give us aggregated information that enables us to improve our website works, e.g., Google analytics, or Hotjar, which provides us with “heat maps”, allowing us to analyze which areas in our website are of more interest to you.
• Third-party services used by us – for example, an external service supporting our career and recruiting options through the website (e.g., Comeet), or an external service which allows us to screen short videos on our website (e.g., Vimeo or Youtube).
Please note that the data collected using cookies may be linked to and combined with any other data, including Personal Data.Also note that Cookies data is usually collected through third-party services, like Google, Facebook, etc. In those cases, your Personal Data might be transferred to those third parties, which might use it, as a “joint controller” of the data, meaning that the data is also “owned” and processed by them under their terms and conditions. In addition, and under those terms and conditions and the direct accounts or subscriptions you have with those third parties, your Personal Data might be linked to other data collected by the relevant third-party and processed in its systems, for its purposes, and under its management. For example, suppose you have a Facebook account, the Personal Data collected through Facebook’s Cookies in Our Website might be linked to other data Facebook collects (through Facebook’s App as well as other websites) and might be used by Facebook in accordance with the independent agreements between you and Facebook.
Managing cookies and opting out: aside from the Essential Cookies described above, you can always choose to configure your browser to reject all cookies or notify you when a cookie is set, or use the installed Cookie’s bar modify your cookies preferences. However, sometimes, in that case, specific services, features, and functionality in our website may not be available to you.
6. The purposes of the processing
We might use your data to:
• enable you to use our website and services in the most effective way, including the personalization of your experience by presenting content tailored to your interests;
• meet or comply with any applicable rules, laws, regulations, codes of practice, or guidelines issued by any legal or regulatory body;
• asses or evaluate the effectiveness of our services, as well as any technical and organizational measures designated for the protection of your Personal Data;
• improve and secure our services and systems;
• protect our rights and legitimate interests, and defend against any lawsuit, legal claim or complaint;
• to conduct any other activities required to provide our services.
7. The Legal Basis for the processing of your Personal Data
We will only process and use your Personal Data when the law allows us to, i.e., when we have a Lawful Basis for such usage. Such lawful and legal basis can be any of the following:
• Processing actions related to your requests or to carry out our obligations arising from any contracts entered between you and us. For example, contacting you per "Contact" form filled by you;
• Our use of your information is necessary to meet responsibilities we have to our regulators, tax officials, law enforcement, or otherwise meet our legal obligations;
• Our use of your information is in our legitimate interest as a commercial organization. For example, to operate and improve our services and keep people informed about our products and services. In these cases, we will look after your information at all times in a way that is proportionate and respects your privacy rights, making sure our legitimate interest is not overridden by your interests or fundamental rights and freedoms;
As detailed above, we do not rely on consent as a legal basis for processing your Personal Data. Yet, in any case, in which you have provided your consent to our processing of your information, you can withdraw this consent at any time by contacting us through the contact details provided above.
8. Data Recipients
We may disclose your Personal Data to third parties in a variety of circumstances in the ordinary course of operating our business, such as:
• Disclosure of Personal Data to persons authorized to process personal data, in our organization, or third-party service providers, qualified as data processors, providing us with services supporting our website and ordinary course of business, e.g., system, storage and computing services, as well as marketing efforts, under applicable law;
• When we have a legal obligation to do so or allowed to do so under our legitimate interests.
Any such transfer will be performed after we will take steps to make sure such transfer is carefully managed to protect your privacy rights:
• transfers within our group and affiliates will be subject to an agreement/policies and procedures created to ensure that your data receives an adequate and consistent level of protection as required by applicable law;
• transfers to any subcontractor or processor will be subject to contractual terms ensuring the security and protection of any Personal Data under any such sub-processor, under applicable law provisions;
any requests for information we receive from law enforcement or regulators will be carefully validated before disclosing any Personal Data.
9. Data Processing Location
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. Such transfer can be made to countries recognized as providing an adequate level of legal protection, or under alternative arrangements to protect your privacy rights, e.g., signing the Standard Contractual Clause published by the EU committee.It is essential to note that Moveo is headquartered in Israel, which the European Data Protection Board considers as offering an adequate level of Personal Data protection regulation.
10. How we secure your information
We are committed to protecting the security of your Personal Data. We use various security technologies and procedures to help protect your Personal Data from unauthorized access and use. However, the collection, transmission, and storage of information can never be guaranteed to be completely secure. Yet, we take steps to ensure that appropriate security safeguards are in place to protect your information, and we will continue to revise our policies and implement additional security features.
11. Storage of Personal data
We will only store your Personal Data for as long as necessary to fulfill the purposes we collected it for, including to satisfy any legal, accounting, or reporting requirements. We have defined data retention periods for any data item in our systems, ensuring minimal retention periods.In some circumstances, we may anonymize your Personal Data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may save and use this information indefinitely without further notice to you.
12. Data Subjects' rights under EU data protection laws
Under EU law, EU residents and individuals have certain rights to apply to us to provide information or make amendments to how we process data relating to them. Those rights might include:
• right to access your Personal Data - you can ask us to confirm whether or not we have and use your Personal Data, and if so, you can ask for a copy of your data;
• right to correct your Personal Data - you can ask us to correct any of your Personal Data that is incorrect after verifying the accuracy of the data first;
• right to erase your Personal Data - you can ask us to erase your Personal Data if you think we no longer need to use it for the purpose we collected it from you. You can also ask for such erasure in any case in which the process of your data was based on your consent, or where we have used it unlawfully or where we are subjsect to a legal obligation to erase your Personal Data. any request for such erasure will be subject to our obligations under the law (e.g., our duty to keep some records for tax or customs purposes);
• right to restrict our use in your Personal Data - you can ask us to restrict our use of your Personal Data in certain circumstances;
• right to object to how we use your Personal Data - you can object to any use of your Personal Data which we have justified by our legitimate interest if you believe your fundamental rights and freedoms to data protection outweigh our legitimate interest in using the information;
• you can always require us to refrain from using your data for direct marketing purposes;
• you can ask us to transfer your information to another organization or provide you with a copy of your Personal Data (Portability Right);
• 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.
We may not always be able to do what you have asked. Also, not all of those rights apply in every jurisdiction. For example, if it would impact the duty of confidentiality we owe to others, or if we are otherwise legally entitled to deal with the request differently. So not always will we be able or obliged to provide you with those rights. However, we encourage you to contact us with any such request, and we will be happy to assist you.
13. Special Notification for California Residents
We do not sell your personal information for the intents and purposes of the CCPA. We can use your personal data for our purposes, but only as described above or after the de-identification or anonymization of such data, including aggregate data that can no longer be associated with you.
14. Links to other sites
Our website may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
15. Changes to this Privacy StatementWe reserve the right to change this Statement from time to time at our sole discretion. If we make any changes, we will post those changes to see what information we gather, how we might use that information, and in what circumstances we may disclose it. By using our site or our services or otherwise providing data after we post any such changes, you accept and agree to this Statement as modified.
Effective as of February 2021