We at QualiTalk Ltd. (“QualiTalk” “us“, “we“, or “our“) recognize and respect the importance of maintaining the privacy of our customers. This Privacy Notice describes the types of information we collect from you when you visit our website (“Site“). This Privacy Notice also explains how we process, transfer, store and disclose the information collected, as well as your ability to control certain uses of the collected information. “You” means any adult user of the Site.
If you are an individual located in the European Union (“EU Individual“), some additional terms and rights may apply to you, as detailed herein. Qualitalk Ltd. is the data controller in respect of the processing activities outlined in this Privacy Notice. Our registered office is 6 Hativat Golani, Kfar Saba, Israel 4440837 and our registration number is 516063609.
“Personal Data” means any information that refers, is related to, or is associated with an identified or identifiable individual or as otherwise may be defined by applicable law. This Privacy Notice details which Personal Data is collected by us in connection with provision of the Site.
Privacy Notice Key Points
The key points listed below are presented in further detail throughout this Privacy Notice. These key points do not substitute the full Privacy Notice.
- Personal Data We Collect, Uses and Legal Basis. We collect certain Personal Data that you provide to us including registration information, contact information and the content of your inquiry. We also collect certain Personal Data automatically when you use the Site. We use your Personal Data for various reasons, including to provide you with the Site, improve our Site, and to contact you with newsletters and marketing offers. These processing activities are based on different legal bases including performance of a contract and legitimate interests.
- Sharing the Personal Data We Collect. We share the Personal Data we collect with our service providers, business partners and subcontractors who use such information to assist us in the operation of the Site, aid in their understanding of how users are using the Site and for our marketing purposes.
- International Transfer. Some of our service providers and/or subcontractors who have access to your Personal Data are located in countries other than your own. We will ensure that we have agreements in place with such parties that ensure the same level of privacy and data protection as set forth in this Privacy Notice.
- We implement measures aimed at protecting your Personal Data, but they do not provide absolute information security.
- Your Rights. Subject to applicable law and in addition to other rights as set forth below, you may have a right to access, update, delete, and/or obtain a copy of the Personal Data we have collected about you. You also have the right to object at any time to processing your Personal Data for certain purposes, including marketing purposes.
- Data Retention. We retain Personal Data for as long as necessary for the purposes set forth in this Privacy Notice. We consider a number of different factors when determining the appropriate retention periods.
- We do not knowingly collect Personal Data from children under the age of sixteen (16).
- We may send you e-mail or other messages about us or our services. You will have the opportunity to opt-out of receiving certain messages that are not service-related.
- Changes to the Privacy Notice. We may change this Privacy Notice from time to time and shall notify you of such changes by indicating on the Site that the Privacy Notice has been amended by publishing an updated Privacy Notice on the Site.
- Comments and Questions. If you have any comments or questions about this Privacy Notice, or if you wish to exercise your legal rights with respect to your Personal Data, please contact us at [email protected].
Personal Data We Collect, Uses and Legal Basis
Depending on your usage, we collect different types of data and we and any of our third-party sub-contractors and service providers use the data we collect for different purposes, as specified below. It is your voluntary decision whether to provide us with certain Personal Data, but if you refuse to provide such Personal Data we may not be able to register you to the Site or provide you with the Site or part thereof.
Registration Data – If you register an account on the Site, you will be required provide us with your name and email address. If you register by logging in through a third-party login/account registration service (such as Facebook or Gmail) (“Third Party Service“), we also receive Personal Data about you as provided by such Third-Party Service, as determined by such third party’s policies and your preferences. We also collect any additional profile information you provide to us in connection with your QualiTalk account, including information you provide through a Third-Party Service.
How we use this data: (1) to create your account on the Site and to respond to your inquiries and requests and to contact and communicate with you; (2) to prevent fraud, protect the security of and address any problems with the Site; and (3) to provide you with informational newsletters and promotional materials relating to our products and services, including via email. For more information about our direct marketing activities and how you can control your preferences, please see the Direct Marketing section below.
Legal Basis: (1) We process this Personal Data for the purpose of creating your account the Site, which is considered performance of a contract with you, including responding to your inquiries and requests. (2) When we process your Personal Data for the purpose of providing you with informational newsletters and promotional materials relating to our products and services and/or for the purposes of preventing fraud, protecting the security of and/or addressing problems with the Site, such processing is based on our legitimate interests.
Contact Information – When you request information from us or contact us for any other reason, we will collect any data you provide, such as your name, email address, country, the organization for which you work and the content of your inquiry. When you sign up for newsletters or email lists we collect your name, email address and any other information you provide.
How we use this data: To respond to your request, inquiry and provide you with newsletters and for retargeting purposes. For more information about our direct marketing activities and how you can control your preferences, please see the Direct Marketing section below.
Legal Basis: We process this Personal Data based on performance of a contract when we respond to your request and provide you with newsletters. Processing your Personal Data for retargeting purposes is based on our legitimate interests.
Automatically Collected Data – When you visit the Site, we automatically collect information about your computer or mobile device, as well as your browsing history and any information regarding your viewing history on our Site. For more information about the cookies and similar technologies we use and how to adjust your preferences, please see the section “Cookies and Similar Technologies” below.
How we use this data: (1) to review usage and operations, including in an aggregated non-specific analytical manner, to improve current content, products and services; (2) to prevent fraud, protect the security of our Site, and address any problems with the Site.
Legal Basis: We process this Personal Data for our legitimate interests to develop and improve our services, review usage, perform analytics, prevent fraud, for our recordkeeping and protection of our legal rights.
Statistical Information [By analyzing all information we receive, including all information concerning users we may compile statistical information across a variety of platforms and users (“Statistical Information“). Statistical Information helps us understand trends and customer needs so that new products and services can be considered and so that existing products and services can be tailored to customer desires. We may share such Statistical Information with our partners, without restriction, on commercial terms that we can determine in our sole discretion.
As described above, we may use Personal Data to let you know about our products and services that we believe will be of interest to you. We may contact you by email or through other communication channels and we will respect your preferences for how you would like us to manage marketing activity with respect to you. To protect privacy rights and to ensure you have control over how we manage marketing with you:
- We will take steps to limit direct marketing to a reasonable and proportionate level and only send you communications which we believe may be of interest or relevance to you.
- You can ask us to stop sending email marketing by following the “unsubscribe” link you will find on all the email marketing messages we send you. Alternatively, you can contact us at [email protected].
- You can change the way your browser manages cookies, which may be used to deliver online advertising, by following the settings on your browser as explained below.
Sharing the Personal Data We Collect
We share your information, including Personal Data, as follows:
Business Partners, Service Providers, and Subcontractors
We disclose information, including Personal Data we collect from and/or about you, to our trusted service providers, business partners and subcontractors, who use such information to: (1) help us provide you with the Site; (2) aid in their understanding of how users are using our Site; (3) for the purpose of direct marketing (see above for more details).
Your Personal Data may be disclosed as part of, or during negotiations of, any merger, sale of company assets or acquisition (including in cases of liquidation) in such case, your Personal Data shall continue being subject to the provisions of this Privacy Notice.
Law Enforcement Related Disclosure
We may share your Personal Data with third parties: (i) if we believe in good faith that disclosure is appropriate to protect our or a third party’s rights, property or safety (including the enforcement of the Terms and this Privacy Notice); (ii) when required by law, regulation subpoena, court order or other law enforcement related issues, agencies and/or authorities; or (iii) as is necessary to comply with any legal and/or regulatory obligation.
We may use your Personal Data as required or permitted by any applicable law, for example, to comply with audit and other legal requirements.
We use subcontractors and service providers who are located in countries other than your own and send them information we receive (including Personal Data). We conduct such international transfers for the purposes described above. We will ensure that these third parties will be subject to written agreements ensuring the same level of privacy and data protection as set forth in this Privacy Notice, including appropriate remedies in the event of the violation of your data protection rights in such third country.
Whenever we transfer your Personal Data to third parties based outside of the European Economic Area (“EEA“), we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your Personal Data to countries that have been deemed to provide an adequate level of protection for Personal Data by the European Commission.
- Where we use certain service providers not located in countries with an adequate level of protection as determined by the European Commission, we may use specific contracts approved by the European Commission which give Personal Data the same protection it has in the EEA.
- Where we use service providers based in the US, we may transfer Personal Data to them if they have been certified by the EU-US Privacy Shield, which requires them to provide similar protection to Personal Data shared between the EU and the US or any other arrangement which has been approved by the European Commission or other body having jurisdiction to approve such arrangement.
Please contact us at [email protected] if you would like further information on the specific mechanism used by us when transferring your Personal Data out of the EEA.
We have implemented and maintain appropriate technical and organization security measures, policies and procedures designed to reduce the risk of accidental destruction or loss, or the unauthorized disclosure or access to Personal Data appropriate to the nature of such data.
However, no method of transmission over the Internet or method of electronic storage is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.
As the security of information depends in part on the security of the computer you use to communicate with us and the security you use to protect user IDs and passwords, please take appropriate measures to protect this information.
Your Rights – How to Access and Limit Our Use of Certain Personal Data
Subject to certain exemptions, and in some cases dependent upon the processing activity we are undertaking, you have certain rights in relation to the Personal Data that we hold about you, as detailed below. We will investigate and attempt to resolve complaints and disputes and make every reasonable effort to honour your wish to exercise your rights as quickly as possible and, in any event, within the timescales provided by applicable data protection laws. We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any information and/or comply with any of your requests, as detailed below:
- Right of Access. You have a right to know what Personal Data we collect about you and, in some cases, to have such Personal Data communicated to you. Subject to applicable law, we may charge you with a fee. Please note that we may not be able to provide you with all the information you request, and, in such case, we will endeavor to explain to you why.
- Right to Data Portability. If the processing is based on your consent or performance of a contract with you and processing is being carried out by automated means, you may be entitled to (request that we) provide you or another party with a copy of the Personal Data you provided to us in a structured, commonly-used, and machine-readable format.
- Right to Correct Personal Data. Subject to the limitations in applicable law, you may request that we update, complete, correct or delete inaccurate, incomplete, or outdated Personal Data.
- Deletion of Personal Data (“Right to Be Forgotten”). You have a right to request that we delete your Personal Data if either: (i) it is no longer needed for the purpose for which it was collected, (ii) our processing was based on your consent and you have withdrawn your consent, (iii) you have successfully exercised your Right to Object (see below), (iv) processing was unlawful, or (iv) we are required to erase it for compliance with a legal obligation. We cannot restore information once it has been deleted. We may retain certain Personal Data (including following your request to delete) for audit and record-keeping purposes, or as otherwise permitted and/or required under applicable law.
- Right to Restrict Processing. You can ask us to limit the processing of your Personal Data if either: (i) you have contested its accuracy and wish us to limit processing until this is verified; (ii) the processing is unlawful, but you do not wish us to erase the Personal Data; (iii) it is no longer needed for the purposes for which it was collected, but we still need it to establish, exercise, or defend of a legal claim; (iv) you have exercised your Right to Object (below) and we are in the process of verifying our legitimate grounds for processing. We may continue to use your Personal Data after a restriction request under certain circumstances.
- Right to Object. You can object to any processing of your Personal Data which has our legitimate interests as its legal basis, if you believe your fundamental rights and freedoms outweigh our legitimate interests. If you raise an objection, we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms.
- Right to Lodge a Complaint with Your Local Supervisory Authority. You may have the right to submit a complaint to the relevant supervisory data protection authority if you have any concerns about how we are processing your Personal Data, though we ask that as a courtesy you please attempt to resolve any issues with us first.
Subject to applicable law, we retain Personal Data as necessary for the purposes set forth above. We may delete information from our systems without notice to you once we deem it is no longer necessary for these purposes. Retention by any of our processors may vary in accordance with the processor’s retention policy.
In some circumstances, we may store your Personal Data for longer periods of time, for instance where we are required to do so in accordance with legal, regulatory, tax, audit, accounting requirements and so that we have an accurate record of your dealings with us in the event of any complaints or challenges, or if we reasonably believe there is a prospect of litigation relating to your Personal Data or dealings. To determine the appropriate retention period, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data, and whether those purposes can be achieved through other means, as well as applicable legal requirements.
Please contact us at [email protected]. if you would like details regarding the retention periods for different types of your Personal Data.
Cookies and Similar Technologies
What are Cookies?
A cookie is a small piece of text that is sent to a user’s browser or device. The browser provides this piece of text to the device of the originating user when this user returns.
- A “session cookie” is temporary and will remain on your device until you leave the Site.
- A “persistent” cookie may be used to help save your settings and customizations across visits. It will remain on your device until you delete it.
- First-party cookies are placed by us, while third-party cookies may be placed by a third party. We use both first- and third-party cookies.
- We may use the terms “cookies” to refer to all technologies that we may use to store data in your browser or device or that collect information or help us identify you in the manner described above, such as web beacons or “pixel tags”.
The specific names and types of the cookies, web beacons, and other similar technologies we use may change from time to time. However, the cookies we use generally fall into one of the following categories:
|Type of Cookie||Why We Use These Cookies|
|Necessary||These cookies are necessary in order to allow the Site to work correctly. They enable you to access the Site, move around, and access different services, features, and tools. Examples include remembering previous actions (e.g. entered text) when navigating back to a page in the same session. These cookies cannot be disabled.|
|Functionality||These cookies remember your settings and preferences and the choices you make (such as language or regional preferences) in order to help us personalize your experience and offer you enhanced functionality and content.|
|Security||These cookies can help us identify and prevent security risks. They may be used to store your session information to prevent others from changing your password without your login information.|
|Performance||These cookies can help us collect information to help us understand how you use our Site, for example whether you have viewed messages or specific pages and how long you spent on each page. This helps us improve the performance of our Site.|
|Analytics||These cookies collect information regarding your activity on our Site to help us learn more about which features are popular with our users and how our Site can be improved.|
How to Adjust Your Preferences
Most Web browsers are initially configured to accept cookies, but you can change this setting so your browser either refuses all cookies or informs you when a cookie is being sent. In addition, you are free to delete any existing cookies at any time. Please note that some features of the Site may not function properly when cookies are disabled or removed.
Additionally, cookies may be placed in messages we send in order to track your interaction with such emails.
Third-Party Applications and Services
All use of third-party applications or services, is at your own risk and subject to such third party’s terms and privacy policies.
We reserve the right to send you service-related communications, including service announcements and administrative messages, without offering you the opportunity to opt out of receiving them. Should you not wish to receive such communications, you may unsubscribe.
We do not knowingly collect Personal Data from children under the age of sixteen (16). In the event that you become aware that an individual under the age of sixteen (16) has enrolled without parental permission, please advise us immediately.
Changes to the Privacy Notice
We may update this Privacy Notice from time to time to keep it up to date with legal requirements and the way we operate our business, and we will place any updates on this webpage. Please come back to this page every now and then to make sure you are familiar with the latest version. If we make material changes to this Privacy Notice, we will seek to inform you by notice on our Site or per email.
Comments and Questions
If you have any comments or questions about this Privacy Notice or if you wish to exercise any of your legal rights as set out herein, please contact us at [email protected].
Last updated: November 2019