1. INTRODUCTION
This Privacy Policy applies to information that identifies you or from which you can reasonably be identified, such as your full name or name and postal address ("personal information"). This Policy describes how we handle the personal information we collect when you engage with us, including when you engage with us as a job applicant, a supplier, or a customer of any of our services. Our services include: home delivery subscription, digital services subscription, advertising, websites, mobile sites, applications ("apps"), widgets, competitions, and customer surveys. In this policy, when we refer to Company Services, we mean all of our services, including considering you for jobs you apply for and dealing with you as a supplier (collectively, "Company Services").
This Privacy Policy also applies to information about anyone who interacts with us, including advertisers, subscribers, and people who use Company Services (both registered and unregistered users).
2. WHAT INFORMATION DO WE COLLECT?
We collect personal information to provide Company Services and for our business operations. If you choose not to provide the information we request from you, we may not be able to provide you with the services you require. We describe the main types of personal information we collect and the main reasons why we collect that information below.
Registration Information: This is the information you provide to Company when you register for or acquire a Company Service. This may include information you provide us to create an account, become a subscriber, become an advertiser, post comments, receive a newsletter, or enter a competition. Registration Information includes, for example, your name, delivery or postal address, email address, gender, and birthday.
Public Information and Posts: This includes comments or content that you post to the online Company Services and the information about you that comes with those posts. This may include your name, user name, comments, likes, tweets, status, profile information, and picture(s). Public Information and Posts are available to everyone who views our websites and may be displayed in search results on external search engines, even after you cancel your account with us.
Information from Third-Party Social Media: If you access or log-in to a Company Service through a third-party social media service or connect a Company Service to your social media profile, we may also include information from that social media service. This may include your user name for that service, any information or content you have permitted the social media service to share with us (such as your profile picture(s), email address, followers, or friends lists), and any other information you have made public (including other posts you make using your social media profile). We do not collect your social media profile password.
Activity Information – Cookies and Other Technologies: When you visit Company's websites (including to access and use Company Services), we and certain third parties, such as Facebook, may collect information about your visit. This is done through the use of various technologies, including cookies, web beacons, pixels, and similar technologies. Cookies are small text files that are placed on your computer or device by a website's server. They are widely used to make websites work more efficiently and to provide information to the website owners.
Information from Other Sources: We may supplement the information we collect about you with information from other sources. This may include information from publicly available sources (such as other published content) and data providers, as well as information from our business partners or related and affiliated companies in Israel or internationally.
Information in Relation to Other Persons who Deal with Us: When you apply for a job or contract with us, we may collect information about you to help us decide whether to offer you the job or contract. For example, we may collect information about how to contact you, your education or work history, or other information included in your CV or résumé. We may collect this information from you, or from any recruitment consultant, your previous employers, or other referees. This Privacy Policy does not apply to our collection, use, and disclosure of information related to your employee relationship with us and the records we hold about you as an employee.
Information about our Suppliers and Business Partners: Company also collects personal information about our suppliers and individuals employed by our suppliers (including service and content providers), contractors, dealers, related companies, agents, and corporate customers. We will explain why we are collecting this information and how we will use that information unless it is obvious from the circumstances.
3. HOW DO WE USE YOUR INFORMATION?
We use the information we collect about you to provide Company Services to you. As part of our service to you, we may use your personal information:
4. HOW DO WE PROTECT YOUR INFORMATION?
We take the security of your personal information seriously and have implemented reasonable measures to safeguard it from loss, theft, unauthorized use, disclosure, or modification. Here are some of the steps we take to protect your information:
System Security: We employ robust security measures to prevent unauthorized access to our online and computerized systems. These measures include the use of firewalls, data encryption, virus detection methods, and password-restricted access. Our servers and databases are housed in secure data centers with restricted access, and we regularly update and maintain our security protocols to address emerging threats.
Property Security: At our business premises, we may engage security personnel and utilize ID cards to restrict physical access to sensitive areas where personal information is stored.
Staff Training: We train our employees and relevant personnel to handle your information in accordance with this Privacy Policy and applicable privacy laws. Our staff are required to follow strict data protection guidelines to ensure the confidentiality and security of your personal information.
Third-Party Protections: We take reasonable steps to ensure that third parties who store or assist us in storing your personal information adopt appropriate security measures. This includes requiring our service providers and partners to comply with industry-standard security practices and contractual obligations to protect your data.
Data Encryption: We use encryption technology to protect sensitive information during transmission over the internet. This ensures that your data is securely transmitted between your device and our servers.
Access Controls: Access to your personal information is restricted to authorized personnel who need to handle that information for the purposes outlined in this Privacy Policy. We implement role-based access controls to limit access to sensitive data.
Regular Audits and Assessments: We conduct periodic audits and security assessments to identify potential vulnerabilities and risks. These audits help us proactively address any security issues and maintain a high level of data protection.
However, despite our best efforts, no method of transmission or storage of data over the internet can be guaranteed to be 100% secure. Therefore, while we strive to protect your personal information, we cannot guarantee the security of information transmitted to or from Company Services. Any transmission of information is at your own risk.
In the unlikely event of a data breach that poses a significant risk of harm to individuals, we will comply with all applicable legal requirements, including notifying affected individuals and relevant authorities as required by law.
Please remember that it is essential for you to protect against unauthorized access to your account credentials and devices. Ensure that you keep your login credentials, passwords, and other account information confidential. If you suspect any unauthorized access to your account or notice any suspicious activities, please contact us immediately (see "HOW TO CONTACT US" section).
We are committed to continuously improving our security measures and staying up-to-date with the latest industry best practices to protect your personal information effectively. Your trust is of utmost importance to us, and we will do our utmost to maintain the privacy and security of your data.
We understand the importance of ensuring that your personal information is accurate and up-to-date. You have the right to access, review, correct, or update your personal information held by us. If you would like to exercise this right, you can contact us using the contact information provided in the "HOW TO CONTACT US" section below.
When you contact us to access or update your personal information, please provide your name and contact details (including your email address, address, and telephone number) and specify clearly what information you would like to access, review, correct, or update. We may ask for additional information to verify your identity and protect against unauthorized access.
We will respond to your request as soon as reasonably practicable, and in any event, within the timeframes required by applicable privacy laws. If we are unable to provide you with access to your personal information or to update it due to legal requirements or other reasons, we will provide you with a written explanation for the denial of your request.
In some cases, there may be a cost associated with providing access to your personal information. If applicable, we will inform you of any fees before proceeding with your request.
Please note that there may be circumstances where we are not required to provide access to your personal information, such as when it would violate the privacy rights of other individuals or if the information is subject to legal privilege or is commercially sensitive.
If you believe that any of the personal information we hold about you is inaccurate, incomplete, or outdated, you can request that we correct or update it. We will take reasonable steps to ensure that the information is corrected or updated promptly.
If you have any questions or concerns about accessing or updating your personal information, please reach out to us through the contact details provided in the "HOW TO CONTACT US" section below. We are committed to assisting you and ensuring that your personal information is accurate and up-to-date.
6. HOW CAN YOU OPT OUT?
Online advertising: You can block certain advertisements by blocking or deleting cookies in your browser settings. However, we use cookies to provide some of our Company Services, and you may not be able to use these Company Services if you do this.
Direct marketing: If you do not want to receive promotional messages from us, you can change your account settings or follow the unsubscribe instructions included at the bottom of our emails and text messages.
Updates to Privacy Policy: We may modify this Privacy Policy from time to time to reflect changes in our data practices or applicable laws and regulations. The date at the top of this Privacy Policy indicates when it was last updated. Any changes to this Privacy Policy will become effective when we publish the updated version online. We encourage you to review this Privacy Policy regularly to stay informed about how we handle your personal information.
Location of Data: Please be aware that some of the Company Services are hosted and managed outside of Israel, including in the United Kingdom, the United States of America, and Singapore. By using Company Services, you consent to the transfer of your personal information to these countries, where data protection laws may differ from those in your country of residence. We will take reasonable steps to ensure that your personal information is treated securely and in accordance with this Privacy Policy, regardless of where it is processed.
Linked Services: Company Services may include links to websites operated by unaffiliated companies, and they may offer content, functionality, games, newsletters, competitions, or applications developed and maintained by these unaffiliated companies. Please note that we are not responsible for the privacy practices of these third-party websites or services. Once you leave Company Services or click on a link to an external website, you should review the privacy policy of that website to understand how your information will be handled.
Collection of Personal Financial Information by a Payment Service Provider: At times, we may allow you to use an unaffiliated payment service to make purchases or payments for Company Services. If you choose to use a Payment Service, any personal financial information you provide during the payment process will be collected and used by the Payment Service provider in accordance with their own privacy policy. We recommend reviewing the privacy policy of the Payment Service provider to understand how your financial information will be handled.
Data Retention and Deletion: Even if you cancel your account with us, we may retain your personal information for as long as reasonably necessary to fulfill the purposes outlined in this Privacy Policy, including legal, regulatory, or business requirements. In certain circumstances, we may be legally required to retain certain personal information for specific periods. However, when we no longer require your personal information, we will securely destroy or de-identify it to prevent unauthorized access or use.
Sensitive Information: We value your privacy and ask that you avoid providing us with any sensitive information when using Company Services. Sensitive information includes data related to your racial or ethnic origin, religious or other beliefs, health, criminal background, or trade union membership. Unless specifically required for a particular purpose, we do not seek to collect sensitive information from our users, and we encourage you not to share such information with us.
Protecting your sensitive information is of the utmost importance to us. If you inadvertently provide sensitive information, we will handle it in accordance with this Privacy Policy and applicable laws. However, we cannot guarantee the security of information that is voluntarily shared by you.
If you have any questions or concerns about the collection and handling of sensitive information, please contact us using the contact information provided in the "HOW TO CONTACT US" section below. We are committed to maintaining the privacy and security of all user data.
The Children's Online Privacy Protection Act (COPPA) is a United States federal law that governs the collection, use, and disclosure of personal information from children under the age of 13. As a company, we are committed to complying with COPPA's requirements and protecting the privacy of children who use our services. We do not knowingly collect personal information from children under the age of 13 without obtaining verifiable parental consent.
If you are a parent or legal guardian and believe that we may have collected personal information from your child without your consent, please contact us immediately using the contact information provided in the "HOW TO CONTACT US" section. We will take prompt action to investigate the matter and delete any personal information associated with a child under the age of 13, if applicable.
The General Data Protection Regulation (GDPR) is a comprehensive data protection law that applies to the processing of personal data of individuals within the European Union (EU) and European Economic Area (EEA). As a company that may collect and process personal information of individuals located in the EU/EEA, we are committed to complying with the GDPR's principles and requirements.
If you are an individual in the EU/EEA, you have certain rights under the GDPR, including the right to access, correct, and erase your personal data, as well as the right to object to certain processing activities. You also have the right to withdraw your consent if we rely on consent as a legal basis for processing your personal information.
To exercise your GDPR rights or if you have any questions or concerns about how we handle your personal data, please contact us using the contact information provided in the "HOW TO CONTACT US" section below.
California residents have specific privacy rights under the California Civil Code Section 1798.83, commonly known as the "Shine the Light" law. This law allows California residents to request certain information regarding the disclosure of their personal information to third parties for direct marketing purposes.
If you are a California resident and wish to make such a request, please contact us using the contact information provided in the "HOW TO CONTACT US" section below. We will provide you with the required information within the timeframes specified by law.
Complaints:
We take privacy matters seriously, and we are committed to addressing any concerns you may have regarding the handling of your personal information. If you believe that we have breached applicable privacy laws or our obligations outlined in this Privacy Policy, you have the right to lodge a complaint with us.
To make a complaint, please contact us using the contact information provided in the "HOW TO CONTACT US" section below. When you submit a complaint, please include your name and contact details (including your email address, address, and telephone number) so that we can effectively respond to your concerns.
Upon receiving your complaint, we will acknowledge receipt of your communication and promptly initiate an internal investigation. Our team will carefully review the issues raised in your complaint and take appropriate measures to address any identified concerns.
We aim to resolve complaints as quickly and efficiently as possible. You can expect to receive an initial response from us within 7 days of us receiving your complaint. If further time is required to conduct a thorough investigation, we will inform you and provide you with an estimated timeframe for resolution.
During the complaint resolution process, we may need to seek additional information from you to better understand the circumstances surrounding your concerns. We appreciate your cooperation in providing any requested details, as it will assist us in conducting a comprehensive investigation.
If you are not satisfied with the outcome of your complaint or believe that we have not adequately addressed your concerns, you may have the right to escalate your complaint to the relevant privacy ombudsman or regulatory authority in your jurisdiction. We will provide you with information about the appropriate authority to contact if required.
We are committed to protecting your privacy rights, including your right to lodge a complaint. We will not subject you to any adverse actions or retaliation for making a complaint in good faith. Your privacy is important to us, and we respect your right to voice concerns about the handling of your personal information.
If you have any questions or wish to lodge a complaint, please contact us using the following information:
LEO MEDIA LTD
26 Yetsiat Europa st.
Tel Aviv 6770216
Israel
516835865
We value your privacy and are committed to resolving any issues or concerns you may have in a fair and transparent manner. Your feedback is essential to help us improve our privacy practices and ensure the protection of your personal information.