PRIVACY POLICY

Last revised on 17/08/2020

Introduction

Thank you for accessing https://www.the-weisses.com/ (the “Website“). This Website is operated by A. A. Hamitugiya Ltd., a company registered in Israel (“we“, “us“, “our“, or “Company“). This privacy policy (“Privacy Policy“) sets out the basis on which any Personal Information (as this term is defined below) we collect from you (“you”, “your”, or “User”), or that you provide to us, will be processed by us, either through the use of the Website or your use of any of the products or service offerings that are being offered from time to time on the Website, including the course offered by the Company (“Services”).

We encourage you to read this Privacy Policy carefully and use it to make informed decisions.

From Whom Do We Collect Personal Information?

This Policy applies to the Company’s collection, use, and disclosure of the Personal Information of the following categories of Users:

  • Website Visitors: Individuals who visit our Websites and who may volunteer certain contact data (such as their email address) to receive communications from us.
  • Customers: Those who register on their own or on behalf of an entity or organization to use any of the Company’s Services.

Collection and Storage of Your Personal Information

We collect and use the following types of information about you:

Personal Information

Personal Information is information that identifies an individual or that may, with reasonable effort, identify an individual. We gather the following types of Personal Information:

Website Visitors:

  • Name, email address, and other contact information: We ask for and—at your option—collect your contact data (such as name, email address and phone number) from you when you submit web forms on our Website, including opportunities to sign up for and agree to receive email communications from us. We will send such communications in accordance with the applicable laws.
  • Cookies and Other Tracking Technologies: We may use cookies and other information gathering technologies for a variety of purposes, such as providing us with information about how you interact with our Websites. See more under the “Cookies” section in this Privacy Policy.
  • Voluntary information: We collect Personal Information that Website Visitors provide us voluntarily. For example, when they respond to communications from us, or when they share additional information through their use of the Website.
  • Device information: We collect from our Website Visitors specific types of connection details and information with regard to their device, software or hardware that may identify them, such as online identifiers, device unique identifiers (e.g. UDID, MAC address), IP address and geolocation.

Customers:

In addition to the above information, we collect the following types of Personal Information from the Company’s Customers:

  • Customer Account Information: When you register for an account with us, we collect your email address and other contact data (such as your name and phone number). This information is required to identify you as a Customer and permit you to access your account and to the Services offered by the Company.
    • Registering through third party accounts: When you register or sign-in to the Services via a third party account (such as Google), we will have access to basic information from such account, such as your full name, email address, profile picture (or similar, depending on the third party account), personal description, as well as any other information you made publicly available on such account or agreed to share with us. At all times, we will abide by the terms, conditions and restrictions of the third party platform.
  • Payment Information: When you sign up for our paid Services, you need to provide billing information, including your credit card number. Please note that your billing information, to the extent provided by you, is forwarded directly to a third party billing or clearing company engaged by us and is not kept by us.
  • Information collected during participation in “live” lectures: Some of the Services that the Company offers may allow you to participate in “live” lectures, which will be conducted via video conferences. By participating in such “live” lecture, you are aware that the name you provided to the third party video conference service will be shown during the lecture . Also, at your option, you can use your camera and audio during these lectures. As we record such lectures as a whole for our further use, audio and video of Customers who chose to share this information may be retained, as part of the recoded lecture. It is up to your decision whether to open the camera and audio during the lecture or not, and you can change your preference at any time during the lecture, with prospective effect.

Non-personal Information

Non-personal Information is non-identifiable information that, when taken alone, cannot be used to identify you. As such, we are not aware of the identity of the User from which the Non-personal Information was collected.

We may anonymize or de-identify the information collected by the Website or the Services or via other means so that the information cannot, on its own, personally identify you. We also collect aggregate user data regarding your use and activity on our Website and Services. Our use and disclosure of such aggregated or de-identified information is not subject to any restrictions under this Privacy Policy, and we may disclose it to others without limitation and for any purpose.

For the avoidance of doubt, if we combine Personal Information with Non-personal Information (e.g. analytics data), the combined information will be treated as Personal Information as long as it remains combined.

How we Use Personal Information

In addition to the purposes listed herein, the Personal Information we collect is used for the following purposes:

  • Provide, operate, maintain, improve, and promote our Website and Services;
  • Enable you to access and use our Website and Services;
  • Send transactional messages, including responses to your comments, questions, and requests; provide customer service and support; and send you technical notices, updates, security alerts, and support and administrative messages;
  • To serve you advertisements that are relevant to you and your interests when you use our Website (see more under “Advertising“)
  • Send commercial communications, in accordance with your communication preferences, such as providing you with information about products and services, features, surveys, newsletters, offers, promotions, contests, and events about us and our partners; and send other news or information about us and our partners. See more under “Marketing”;
  • monitor and analyze trends, usage, and activities in connection with the Websites and Services and for marketing or advertising purposes;
  • Comply with legal obligations as well as to investigate and prevent fraudulent transactions, unauthorized access to the Website and Services, and other illegal activities;
  • Process for other purposes for which we obtain your consent.

With whom do we share the Personal Information we collect?

We work with other companies who help us run our business (“Service Providers”). These companies provide services to help us store information (such as cloud storage companies), deliver customer support, monitor and analyze the performance of our Services, provide marketing support, and otherwise operate and improve our Website and Services. These Service Providers may only process Personal Information pursuant to our instructions and in compliance both with this Privacy Policy and other applicable confidentiality and security measures and regulations. Specifically, we do not permit our Service Providers to use any Personal Information we share with them for their own marketing purposes or for any other purpose than in connection with the services they provide to us.

Also, please note that if you participate in the Company’s “live” lectures via video conferences, such lectures may be recorded and shared or otherwise be made public by the Company. By participating in such “live” lecture, you are aware that the name you provided to the third party video conference service will be shown during the lecture, and you agree that this lecture can be recorded by the Company for further use. To the extent that you choose to open your camera and audio during the lecture, you may appear in certain videos and your voice may be included in audio recorded during the lecture.  You can choose, at any time during the “live” lecture, to close your camera and audio, and such change will be effective prospectively.

In addition to the above, we may also share your Personal Information with others in the following circumstances:

  • With other subsidiaries or affiliate companies;
  • In the event of a merger, sale, change in control, or reorganization of all our part of our business;
  • When we are required to disclose Personal Information to respond to subpoenas, court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims;
  • Where we have a good-faith belief sharing is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our policies, or as otherwise required to comply with our legal obligations; or
  • As you may otherwise consent from time to time.

Third-parties who we may share your Personal Information with will be required to meet our standards on processing information and security. The Personal Information we provide them will only be provided in connection with the performance of their function.

Why we use your Personal Information

Please note that our legal basis for collecting and using your Personal Information will depend on the Personal Information collected and the specific context in which we collect it. We normally collect Personal Information from you only where: (a) we have your consent to do so, (b) where we need your Personal Information to perform a contract with you (e.g. to deliver the service you have requested), (c) where the processing is in our legitimate interests; or (d) where we are required to collect, retain or share such Personal Information under applicable laws.

In some cases, we may need the Personal Information to protect your vital interests or those of another person.

Where we rely on your consent to process your Personal Information, you have the right to withdraw or decline consent at any time. Where we rely on our legitimate interests to process your Personal Information, you have the right to object by contacting us through the contact details provided below.

If you have any questions about or need further information concerning the legal basis on which we collect and use your Personal Information, please contact us through the contact details available below.

Cookies

When you visit or access our Website we use (and authorize 3rd parties to use) pixels, cookies, events and other technologies (collectively, “Tracking Technologies“). Those allow us to automatically collect information about you, your device and your online behavior, in order to enhance your navigation in our Websites, improve our Websites’ performance, perform analytics and customize your experience. In addition, we may merge data we have with data collected through these tracking technologies and data we may obtain from other sources and, as a result, such data may become Personal Information. For more information about the cookies we use please read our cookie policy, a copy of which can be found here: https://www.the-weisses.com/cookie-policy/.

We also use a tool called “Google Analytics” to collect information about your use of the Websites. Google Analytics collects information such as how often users access the Websites, what pages they visit when they do so, etc. We use the information we get from Google Analytics only to improve our Websites and Services. Google Analytics collects the IP address assigned to you on the date you visit sites, rather than your name or other identifying information. 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 the Websites is restricted by the Google Analytics Terms of Use and the Google Privacy Policy.

Advertising

We may use a third-party advertising technology to serve advertisements when you access the Site. This technology uses your information with regard to your use of the Website and Services to serve advertisements to you (e.g., by placing third-party cookies on your web browser).

You may opt-out of many third-party ad networks, including those operated by members of the Network Advertising Initiative (“NAI”) and the Digital Advertising Alliance (“DAA”). For more information about this practice by NAI and DAA members, and your choices regarding having this information used by these companies, including how to opt-out of third-party ad networks operated by NAI and DAA members, please visit their respective websites: http://optout.networkadvertising.org/#!/ and http://optout.aboutads.info/#!/.

Marketing

We may use your Personal Information, such as your full name, email address, etc., ourselves or by using our third-party partners for the purpose of providing you with promotional materials, concerning our Website and Services.

At any time, you may request to unsubscribe and discontinue receiving marketing offers by sending us a blank message with the word “remove” to the contact details available below.

Please note that even if you unsubscribe from our marketing mailing list, we may continue to send you Services-related updates and notifications.

Your Rights

Certain jurisdictions provide Users with certain statutory rights to their Personal Information. You may have the right to certain actions to your Personal Information such as:

  • To receive confirmation as to whether or not Personal Information concerning you is being processed, and access your stored Personal Information, together with certain supplementary information.
  • To receive Personal Information you directly volunteer to us in a structured, commonly used and machine-readable format.
  • To request rectification of your Personal Information that is in our control.
  • To request erasure of your Personal Information.
  • To object to the processing of Personal Information by us.
  • To request to restrict processing of your Personal Information by us.

However, please note that these rights are not absolute, and may be subject to our own legitimate interests and regulatory requirements. 

If you wish to raise a complaint on how we have handled your Personal Information, you can contact us at the contact details available below.

If you are not satisfied with our response or believe we are collecting or processing your Personal Information not in accordance with the laws, you can file a complaint to the applicable data protection authority.

For how long do we retain the Personal Information that we collect?

We retain the Personal Information that we collect from Users for as long as needed to operate the Website and to provide our Services and to comply with our legal obligations, resolve disputes and enforce our agreements (unless we are instructed otherwise). Retention periods will be determined taking into account the type of the Personal Information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused Personal Information at the earliest reasonable time. Under applicable regulations, we will keep records containing your Personal Information, account opening documents, communications and anything else as required by applicable laws and regulations.

International Transfer (for EEA residents)

Since we operate globally, it may be necessary to transfer data, including Personal Information, to countries outside the EEA. In these instances, we will transfer your Personal Information only to such countries as approved by the European Commission as providing adequate level of data protection or enter into legal agreements ensuring an adequate level of data protection.

How do we safeguard your Personal Information?

We take great care in implementing and maintaining the security of the Website and the Services and of your Personal Information. We employ industry standard procedures to ensure the confidentiality, integrity, and availability of our Users’ data, safety of your Personal Information, and prevent unauthorized use of any such information.

However, we cannot guarantee that hackers or unauthorized personnel will not gain access to Personal Information despite our efforts. You should note that by using our Website and Services, your Personal Information will be transferred through third party infrastructures which are not under our control. 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 Information, we cannot guarantee its absolute security.

If you feel that your privacy was treated not in accordance with this Privacy Policy, please contact us directly through the contact details available below.

Minors

We do not knowingly collect or solicit personal information from anyone under the age of consent (as determined under the applicable laws where the individual resides; “Age of Consent”).  By accessing, using or interacting with our Websites or Services, you certify to us that you are not under the Age of Consent. In the event that we learn that we have collected personal information from an individual under the Age of Consent without verification of parental consent, we will delete that information upon discovery. If you believe that we might have any information from or about an individual under the Age of Consent, then please contact us through the contact details available below.

Changes to the Privacy Policy

We reserve the right to change this Privacy Policy at any time, so please re-visit this page frequently. We will provide notice of substantial changes of this Privacy Policy through our Websites or we will send you an e-mail regarding such changes to the e-mail address that you volunteered (if you have volunteered it). Such substantial changes will take effect seven (7) days after such notice was provided on any of the above mentioned methods. Otherwise, all other changes to this Policy are effective as of the stated “Last Revised” date, and your continued use of the Website and Services after the Last Revised date will constitute acceptance of, and agreement to be bound by, those changes.

How to contact us

If you have any questions about this Privacy Policy, please contact us at

[email protected]

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