Last Revised: May 14, 2018

Pesto Harel Shemesh Ltd. d/b/a PubPlus (“PubPlus”, “Company”, “our”, “we” or “us”) respects the privacy of the users (“User” or “you”) of its Services and/or our website [http://www.pubplus.com], and is committed to protect the personal information that its Users share with it. This Privacy Policy (the “Privacy Policy”) is intended to describe our practices regarding the information we may collect from you when you use the Services, the manners in which we may use such information, and the options and rights available to you.

Capitalized terms which are not defined herein, shall have the meaning ascribed to them in our Terms of Use at http://www.pubplus.com/terms-of-service/, which this Privacy Policy is incorporated thereto by reference.

 

1. Your Consent (PLEASE READ CAREFULLY!)

BY ACCESSING THE SERVICES AND/OR USING THE SERVICES, YOU AGREE TO THE TERMS AND CONDITIONS SET FORTH IN THIS PRIVACY POLICY, INCLUDING TO THE COLLECTION AND PROCESSING OF YOUR PERSONAL INFORMATION (AS DEFINED BELOW) IN THE EVENT YOU DECIDE TO PROVIDE US WITH SUCH. IF YOU DISAGREE TO ANY TERM PROVIDED HEREIN, YOU MAY NOT USE THE SERVICES.

Please note: you are not obligated by law to provide us with any Personal Information. You hereby acknowledge and agree that you are providing us with Personal Information at your own free will, for the purpose of providing you with the Services. You hereby agree that we may retain such Personal Information pursuant to this Privacy Policy and any applicable laws and regulations.

 

2. Which information we may collect on our Users?

 

3. How Do We Collect Information on Our Users?

There are two main methods we use:

a.          We collect information through your use of the Services. In other words, when you are using the Services. In other words, we are aware of your usage of the Services and may gather, collect and record the information relating to such usage. We also collect Non-Personal and Personal Information derived from information we receive from third party services and providers we work with.

b.          We collect information which you provide us voluntarily. For example, we collect Personal information which you voluntarily provide when you use our Services.

 

 

4. What are the Purposes of the Collection of Information?

Non-personal Information and Personal Information is collected in order to:

• Provide and operate our Services and related services in connection with our Services, including by our business partners and pursuant to your consent.
• Verify our User’s identity.
• Be able to deliver and enhance the Services, provide the Users with technical assistance and support and to provide the Users with updates regarding the Company’s developments etc.
• Use it to create cumulative statistical data and other cumulative information and/or other conclusive information that is non-personal, in which we and/or our business partners might make use of in order to operate and improve our Services.
• Manage and make risk evaluations, improve our cyber security abilities, prevent and defend from frauds, faults or any other illegal or forbidden activity.
• Act according to the law, and obey all judicial or regulatory demands.
• Be involved in other activities that may require the use of the User’s Personal Information, for which we will request your prior consent.

 

5. Where Do We Store Personal Information?

Information regarding the Users will be maintained, processed and stored by PubPlus and our authorized affiliates and service providers in the United States and in Israel, and as necessary, in secured cloud storage, provided by our third party service provider.

While the data protection laws in the above jurisdictions may be different than the laws of your residence or location, please know that the Company, its affiliates and service providers that store or process your Personal Information on the Company’s behalf are each committed to keep it protected and secured, pursuant to this Privacy Policy and industry standards, regardless of any lesser legal requirements that may apply in their jurisdiction.

You hereby accept the place of storage and the transfer of information as described above.

 

6. Non-Personal and Personal Information of Third Parties

You represents and warrant to PubPlus that you shall not make available or provide in any manner any personal information of third parties. You are responsible to company with all applicable laws and regulations, including without limitation, any privacy and data protection laws and regulations in connection with your end users.

You shall ensure that each of its websites and/or mobile applications contains a privacy policy that: (a) discloses the usage of third-party technology and the data collection and usage resulting from the Tracker and Services; (b) contains a conspicuous live hyperlink to an opt-out website that provides the End User the ability to opt out of interest-based advertising through the Tracker and Services; and (c) complies with all applicable privacy laws, rules and regulation, including in connection with the communication of commercial advertisements (including anti-spam). To the extent required by applicable law, rule or regulation, You shall provide PubPlus, with respect to the provision of the Services, a copy of Your privacy policy consistent with the foregoing requirements.

 

 

7. Job Candidates:

PubPlus welcomes all qualified Candidates to apply to any of the open positions posted at [http://www.pubplus.com], Facebook or LinkedIn, by sending us their contact details and CV (“Candidates Information”). Since privacy and discreetness are very important to our Candidates, we are committed to keep Candidates’ Information private and use it solely for our internal recruitment purposes (including for identifying Candidates, evaluating their applications, making hiring and employment decisions, and contacting Candidates by phone or in writing).

Please note that the Company may retain Candidates Information submitted to it even after the applied position has been filled or closed. This is done so we could re-consider Candidates for other positions and opportunities at the Company; so we could use their Candidates Information as reference for future applications submitted by them; and in case the Candidate is hired, for additional employment and business purposes related to their work.

If you previously submitted your Candidates Information to the Company, and now wish to access it, update it or have it deleted from our systems, please contact us at [info@pubplus.com]

 

8. Sharing Information with Third Parties

PubPlus may share your Personal Information with third parties (or otherwise allow them access to it) only in the following manners and instances:

a.          Third Party Services: PubPlus has partnered with a number of selected service providers, whose services and solutions complement, facilitate and enhance our own. These include hosting and server services, data and cyber security services, web analytics, session recording, e-mail distribution and monitoring services, and our business, legal and financial advisors (collectively, “Third Party Services”). Such Third Party Services may receive or otherwise have access to our Users’ Personal Information, depending on each of their particular roles and purposes in facilitating and enhancing our Services and business, and may only use it for such purposes. PubPlus remains responsible and liable for any Personal Information processing done by Third Party Services on its behalf, except for events outside of its reasonable control.

b.          Governmental/Law Enforcement Agencies and Legal Requests or Duties: We may disclose or otherwise allow access to your Personal Information pursuant to a legal request, such as a subpoena, search warrant or court order, or in compliance with applicable laws, with or without notice to you, if we have a good faith belief that we are legally required to do so, or that disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, counter terrorist financing verification requirements, fraud, or other wrongdoing.

c.           Protecting Rights and Safety: We may share your Personal Information with others, with or without notice to you, if we believe in good faith that this will help protect the rights, property or personal safety of PubPlus, any of our Users, or any member of the general public

d.          PubPlus Subsidiaries and Affiliated Companies: We may share Personal Information internally within our family of companies, for the purposes described in this Privacy Policy and in accordance with Section 5 above. In addition, should PubPlus or any of its affiliates undergo any change in control, including by means of merger, acquisition or purchase of substantially all of its assets, your Personal Information may be shared with the parties involved in such event. If we believe that such change in control might materially affect your Personal Information then stored with us, we will notify you of this event and the choices you may have you via e-mail and/or prominent notice on our Website or Services.

For the avoidance of doubt, PubPlus may share your Personal Information in additional manners, pursuant to your explicit approval, or if we are legally obligated to do so. Additionally, we may transfer, share or otherwise use Non-personal Information in our sole discretion and without the need for further approval. Additionally, PubPlus may transfer and disclose Non-personal Information to third parties at its own discretion.

 

 

9. Deletion or modification of Personal Information

If the law applicable to you grants you such rights, you may ask to access, correct, or delete your Personal Information that is stored in our systems. You may also ask for our confirmation as to whether or not we process your Personal Information.

Subject to the limitations in law, you may request that we update, correct, or delete inaccurate or outdated information. You may also request that we suspend the use of any Personal Information whose accuracy you contest while we verify the status of that data.

Subject the limitations in law, you may also be entitled to obtain the Personal Information you directly provided us (excluding data we obtained from other sources) in a structured, commonly used, and machine-readable format and may have the right to transmit such data to another party.

If you wish to exercise any of these rights, contact us at: info@pubplus.com . When handling these requests we may ask for additional information to confirm your identity and your request. Please note, upon request to delete your Personal Information, we may retain such data in whole or in part to comply with any applicable rule or regulation and/or response or defend against legal proceedings versus us or our affiliates

To find out whether these rights apply to you and on any other privacy related matter, you can contact your local data protection authority if you have concerns regarding your rights under local law.

10. Minors

To use our Services, you must be over the age of sixteen (16). Therefore, PubPlus does not knowingly collect Personal Information from minors under the age of sixteen (16) and does not wish to do so. We reserve the right to request proof of age at any stage so that we can verify that minors under the age of sixteen (16) are not using the Services.

11. Security

We take a great care in implementing and maintaining the security of PubPlus’s Services and its User’s Personal Information. PubPlus employs industry standard procedures and policies to ensure the safety of its Users’ Personal Information, and prevent unauthorized use of any such information.  However, we do not guarantee that unauthorized access will never occur.

12. Third Party Software/Service

We use certain monitoring and tracking technologies, including ones offered by Third Party Services. These technologies are used in order to maintain, provide and improve our Services on an ongoing basis, and in order to provide a better experience to our visitors and Users. For example, these technologies enable us to keep track of our Users’ preferences and authenticated sessions, to better secure our Services and detect abnormal behaviors, to identify technical issues, to provide advertising and track ad performance, for our analytics, and to monitor and improve the overall performance of our Services.

• Cookies: In order for some of these technologies to work properly, a small data file (“cookie”) must be downloaded and stored on your device, for purposes of session and user authentication, security, keeping the User’s preferences, to provide tailored advertising and track ad performance, connection stability, monitoring performance and generally providing and improving our Services.

In order to delete or block any cookies, please refer to the “Help” area on your internet browser for further instructions, or You may also opt out of third party cookies by following the instructions provided by each third party in its privacy policy listed below. You can also visit these helpful resources for more information: www.allaboutcookies.org or www.youronlinechoices.eu. Please note however that deleting any of PubPlus’s cookies or disabling future cookies or tracking technologies may prevent you from accessing certain areas or features of our Services, or may otherwise adversely affect your user experience.

• Google Analytics: We use Google analytics, a web analytics service provided by Google, Inc. Non-personal Information is transmitted to and stored by Google on their servers. Please visit Google Analytics find out how Google uses such information or how you can opt out of being tracked.
• Forensiq: We use Forensiq for fraud detection services. Please visit Forensiq find out how Forensiq uses your information, which privacy policy is available at: https://forensiq.com/privacy-policy/
• Hotjar, Please visit Hotjar find out how Hotjar uses your information or how you can opt out of being tracked. which privacy policy is available at: https://uxcam.com/privacy
• Redis Labs: Please visit Redis Labs find out how Redis Labs uses your information or how you can opt out of being tracked. which privacy policy is available at: https://redislabs.com/privacy/
• Logentries: Please visit Logentries find out how Logentries uses your information or how you can opt out of being tracked. which privacy policy is available at: https://www.rapid7.com/privacy-policy
• Twilio: Please visit Twillo find out how Twillo uses your information or how you can opt out of being tracked. which privacy policy is available at: https://www.twilio.com/legal/privacy

 

 

13. Direct Marketing

Direct Marketing: You hereby agree that we may use your contact details provided during registration, for the purpose of informing you regarding our products and Services which may interest you, and to send to you other marketing material. You may withdraw your consent via sending a written notice to PubPlus by email to the following address: [info@pubplus.com] or by pressing the “Unsubscribe” button in the mail.

Please note that the Company may also contact you with important information regarding our Services. For example, we may notify you (through any of the means available to us) of changes or updates to our Services, payment issues, service maintenance, etc. You will not be able to opt-out of receive such service messages

14. Changes to the Privacy Policy

The terms of this Privacy Policy are un-separated part of the Services and will govern the use of the Services and any Information collected therein, the Privacy Policy should not be separated in any way from PubPlus’s Terms of Use. PubPlus reserves the right to change this policy at any time, so please re-visit this page frequently. We will notify you regarding substantial changes of this Privacy Policy by changing the link to the Privacy Policy in the Service and/or by sending you an e-mail regarding such changes to the e-mail address that you provided during registration. Such substantial changes will take effect seven (7) days after such notice was provided on our Services or sent by email. Otherwise, all other changes to this Privacy Policy are effective as of the stated “Last Revised” date and your continued use of the Services after the Last Revised date will constitute acceptance of, and agreement to be bound by, those changes.

15. General

This Privacy Policy, its interpretation, and any claims and disputes related hereto, shall be governed by the laws of the State of Israel, without respect to its criminal law principles. Any and all such claims and disputes shall be brought in, and you hereby consent to them being litigated in and decided exclusively by a court of competent jurisdiction located in Tel Aviv, Israel.

This Privacy Policy was written in English, and may be translated into other languages for your convenience. If a translated (non-English) version of this Privacy Policy conflicts in any way with the English version, the provisions of the English version shall prevail.

16. Have any Questions?

If you have any questions (or comments) concerning this Privacy Policy, you are welcome to send us an email at: [info@pubplus.com] and we will make an effort to reply within a reasonable timeframe.

By contacting the Company you warrant and agree that you are free to do so, and that you do not provide PubPlus with information which violate any third party intellectual rights (the “Information”). Without degrading from the aforesaid, all rights, including intellectual property, arising from the communication will be owned by the Company and will be considered as PubPlus’ confidential material. It is clarified that any use of the Information, will be done in the sole discretion of the Company, and the Company is not obligated to use all or part of this Information.

Candidate Privacy Notice

This privacy notice (the “Notice”) describes the ways that Pesto Harel Shemesh Ltd. d/b/a PubPlus and its affiliates  (collectively, “Company”, “we”, “us”, “our”), collects and uses your Personal Data as a candidate (“you” or “candidate”). We work with data processors to whom we have instructed to collect, store and process Personal Data on our behalf for the purposes of facilitating, assessing and operating your candidacy and recruitment process at the Company, including for example, Comeet, as a recruiting and applicant tracking platform’s platform (the “Platform”) in order to handle your personal data as a candidate. It also describes the rights and options available to you with respect to your personal data.

We may have an additional privacy notice(s) explaining our own specific privacy practices related to your personal data (“Company Notice”).

If you have any questions related to your personal data, please contact us at info@pubplus.com.

1. PERSONAL DATA PROCESSED

We receive Personal Data about you as a candidate for positions at the Company, such as: contact information, address, Curriculum Vitae (resumé) information (including information such as skills, work experience, education), notes or any other document submitted with the application, URL of your LinkedIn and other online profiles, the position for which you have been or are being considered, the source who submitted your candidacy (e.g., recruiting agency, referral), email correspondences between you, the Company and between the Company and other sources (such as recruiting agency and referrals) about your candidacy, information from references, events in the lifecycle of your candidacy, your responses to questionnaires sent to you by us, information about your candidacy and employment options (such as availability to be hired and salary expectations), evaluations of your candidacy, internal discussions within the Company about your candidacy, materials you or other parties (such as evaluators or background check providers) submitted in relation to your candidacy (collectively, “Personal Data”). If you submit your candidacy by email, or online, then you are the main source of the Personal Data. Your personal data can also originate from other sources, such as LinkedIn profile, recruitment agencies, headhunters and referrals. 

2. HOW YOUR PERSONAL DATA IS USED. LEGAL BASIS.

We will use your personal data in accordance with our Company Notice (if any is made available to you), including to evaluate and consider you as a candidate for positions, in accordance with its processes and policies for evaluating employment candidates, to contact you for your candidacy status and interviews, to schedule meetings and interviews, amongst others.

The lawful bases we rely on for processing personal information are (if applicable to us under privacy law): 

1. You gave us your consent to the processing of your personal data (for one or more specific purposes);
2. Processing is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract;
3. Processing is necessary for the purposes of our legitimate interests; and/or
4. Processing is necessary for compliance with a legal obligation to which we are subject.

If you have questions about these uses, please contact us. 

3. WHO WILL PROCESS YOUR DATA

1. We may share your Personal Data with our service providers and vendors who assist us to collect, process and store your personal data as further described in our Company Notice, including, Comeet (who provides us with the Platform) in the context of your candidacy. These companies are authorized to use your personal data as necessary to provide these services or as otherwise authorized by us. 
2. Personal Data may be shared with, or transferred to, our affiliated corporate group entities (entities controlled by, under common control with, or controlling us, directly or indirectly).
3. We may share your general recruitment status with third parties who submitted your candidacy to us.
4. If your details are submitted to the Company by a third-party (such as an employee of the Company or a recruiting agency), the Company can give the third-party access to your name, photo and some of the general recruitment status.
5. If you apply to a job opening using a unique referral link that was provided to you by an employee of the Company to which you are applying, the Company may share some of your general recruitment status, without identifying you by name, with the person that provided you the referral link.
6. The purpose of sharing the above information is to operate incentive programs (i.e. employee referral bonus programs) of the Company and to provide feedback to third-parties who submit candidates to the Company regarding their submission.
7. If we are required to disclose your Personal Data by a judicial, governmental and/or regulatory authority to comply with applicable laws, regulations and rules (including, without limitation, federal, state or local laws), and requests of law enforcement, regulatory and other governmental agencies or if required to do so by court order. 
8. If, in the future, we sell or transfer, or we consider selling or transferring, some or all of our business, shares or assets to a third party, we will disclose your Personal Data to such third party (whether actual or potential) in connection with the foregoing events. 
9. In the event that we are acquired by, or merged with, a third party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer, disclose or assign your Personal Data in connection with the foregoing events, including, in connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or to another company.

If you wish to receive further information, please contact us.

4. SECURITY AND DATA RETENTION

1. Retention. We will retain your Personal Data for as long as we need it to assess you as a candidate or as long as we have a valid legal basis (should any such legal basis apply to the processing of your Personal Data). In accordance with our internal data retention policies and practices, we can decide whether to keep your personal data, delete it or pseudonymize/anonymize it. 
2. Security. We implement industry standard measures to reduce the risks of damage, loss, unauthorized access, or use, of your Personal Data. Despite these measures, Company cannot provide absolute information security or eliminate all risks associated with Personal Data, and security breaches may happen. If there are any questions about our security practices, please contact us. . 

5. INTERNATIONAL DATA TRANSFERS

We host your personal data in connection with our use of the Platform either in the European Economic Area,  in Israel, or in countries deemed as providing an adequate level of data protection. 

6. YOUR RIGHTS

Your rights may vary, depending on the applicable law. These rights may not be available in certain jurisdictions and/or may be subject to certain derogations or limitations. You may have the following rights:

1. To ask us to receive a copy of your Personal Data that is stored on our servers, including the Platform;
2. to update, correct and/or delete your Personal Data; 
3. to request the restriction of processing concerning your Personal Data or to object the processing of your Personal Data; 
4. to request to obtain a copy of your Personal Data in a structured, commonly used and machine-readable format; 
5. If we rely on consent, please note that you have the right to withdraw consent at any time; and/or
6. to lodge a complaint with a supervisory authority. 

If you wish to exercise any of these rights, please contact us. If you choose to exercise any of your rights, we will handle these requests in accordance with applicable law but please note that exercise of some of those rights may have some consequences in your application as a candidate.

In the context of the Platform we do not use any automated decision-making related to your Personal Data.

7. MINORS

We do not intend to collect personal data of children. If you have reason to suspect that personal data pertaining to children under the age of 16 is collected, you are kindly requested to immediately report it to us. If you have questions regarding children’s personal data contact us.

8. CHANGES TO THIS PRIVACY NOTICE

From time to time, we may change or update this Notice. If we do so, we will make efforts to notify you of such changes by any means.