Privacy Notice

Privacy Notice

We at Yigal Arnon & Co ("YA" "us", "we", or "our") recognize and respect the importance of maintaining the privacy of our clients. This Privacy Notice describes the types of information we collect from you in the course of our business, including from our website ("Site"). This Privacy Notice also explains how we collect, process, transfer, store and disclose the information collected, as well as your ability to control certain uses of the collected information. If not otherwise defined herein, capitalized terms have the meaning given to them in the Terms of Service, available above ("Terms"). "You" means any user of the Site and/or any client of YA.

Yigal Arnon & Co. is the data controller in respect of the processing activities outlined in this Privacy Notice. Our registered office is Azrieli Center, Derech Menachem Begin 132 Tel Aviv and our registration number is 513311175.

"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 Services.

Privacy Notice Key Points

The key points listed below are presented in further detail throughout this Privacy Notice. You can click on the headers in this section in order to find out more information about any topic. 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 contact information, information related to the provision of Services (as defined below) and your resume, if you apply for a position in our firm. We also collect certain Personal Data automatically when you visit the Site. We use your Personal Data for various reasons, including to provide you with the Site and Services, improve our Services, and to contact you with marketing offers. These processing activities are based on different legal basis including performance of a contract and legitimate interests, as more fully detailed below.
  • Sharing the Personal Data We Collect. We share the Personal Data we collect with our service providers and subcontractors who assist us in the operation of the Site and provision of Services and process the information on our behalf and under our instructions. We may also share Personal Data with our business partners involved in hosting or organizing events.
  • International Transfer. Some of our service providers, subcontractors or business partners 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.
  • Security. We implement measures aimed at protecting your Personal Data, but they do not provide absolute information security. Such measures include physical, electronic, and procedural safeguards (such as secure servers, firewalls, antivirus and SSL encryption), access control, and other internal security policies.
  • 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.
  • Use of Cookies and Similar Technologies. More information about our use of cookies can be found at http://www.arnon.co.il/sites/all/themes/law/files-to-show/arnon-privacy-policy.pdf.
  • Children. We do not knowingly collect Personal Data from children under the age of sixteen (16).
  • 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 privacy policies.
  • Communications. We may send you e-mail or other messages about us or our Services. You always have the opportunity to opt-out of receiving future messages. Note that you may receive personal communications from individuals within our organization without having the opportunity to opt-out of such communications.
  • 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 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 info@arnon.co.il.

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 provide you with the Services or part thereof.

Services. If you are a client, we collect certain Personal Data that you provide to us including your name, email address, the company for which you work, if relevant, and your role there, in the course of our business when you engage our legal services ("Services"), including attendance of business meetings, events and conferences related to YA. We also collect Personal Data provided to us by or on behalf of our clients or generated by us in the course of providing Services to them, which may include special categories and/or sensitive data as well as criminal data – which shall all be processed in accordance with any applicable law and/or your consent, as applicable.

How we use this data: To provide you with Services; to manage our relationships with our clients and business partners; for conflict, reputational and financial checks, business, finance, administration, KYC, anti-money laundering; and marketing purposes to contact you with informational newsletters, legal updates, invites for events and conferences and other messages about us and/or our Services, including targeted offers based upon Services you have obtained from us.

Legal Basis: (1) We process this Personal Data for the purpose of providing the Services to you or our clients, which is considered performance of a contract, including responding to your inquiries and requests. (2) When we process your Personal Data for the purposes of providing you with informational newsletters and promotional materials, 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, and the content of your inquiry. When you sign up for newsletters or email lists we collect your name and email address.

How we use this data: To respond to your request or inquiry and to provide you with newsletters, legal updates and for retargeting purposes.

Legal Basis: We process this Personal Data based on performance of a contract when we respond to your inquiry 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, including non-Personal Data such as your operating system, and Personal data such as IP address, device ID, and your browsing history, search terms, traffic data and any information regarding your viewing our Site.

How we use this data: (1) to review usage and operations, including in an aggregated non-specific analytical manner, develop new products or services and improve current content, products, and Services; (2) to prevent fraud, protect the security of our Site and Services, and address any problems with the Site and/or Services; (3) to provide you with customized content, targeted offers, and advertising related to our products and Services such as invites for events and conferences and other messages about us or our Services, including targeted offers based upon your interest based on your usage history on the Site, on other third-party sites or apps you may visit and/or use.

Legal Basis: We process this Personal Data for our legitimate interests to develop our products and Services, review usage, perform analytics, prevent fraud, for our recordkeeping and protection of our legal rights and to market our own products and Services. Additional information regarding direct marketing is provided below.

Recruitment Data – If you make a job application or inquiry, you may provide us with Personal Data, including a copy of your CV and other relevant information.

How we use this data: for recruitment and hiring purposes.

Legal Basis: For our legitimate interest for recruitment and hiring purposes.

Additional Uses

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 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. Statistical Information is anonymous and aggregated and we will not link Statistical Information to any Personal Data. We may share such Statistical Information with our partners, without restriction, on commercial terms that we can determine in our sole discretion.

Analytics

We and/or our service providers or subcontractors, use analytics tools ("Tools"), including "Google Analytics" to collect information about the use of the Site and/or Services. Such Tools collect information such as how often users visit the Site, what pages they visit when they do so, and what other sites and mobile applications they used prior to visiting the Site. We use the information we get from the Tools to improve our Site and Services. Google's ability to use and share information collected by Google Analytics about your visits to this site is restricted by the Google Analytics Terms of Service located at http://www.google.com/analytics/terms/us.html and the Google Privacy Policy located at http://www.google.com/policies/privacy/.

Direct Marketing

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, post, or telephone or through other communication channels such as through social media platforms. In all cases, 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 Here.
  • 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 in our Cookie Policy. If our marketing activities are based upon your consent, you may withdraw this consent at any time.

We recommend you routinely review the privacy notices and preference settings that are available to you on any social media platforms.

 Legal Uses

We may use your Personal Data as required or permitted by any applicable law, for example, to comply with audit and other legal requirements.

Sharing the Personal Data We Collect

We share your information, including Personal Data, as follows:

Service Providers, Subcontractors and Business Partners

We also disclose information, including Personal Data we collect from and/or about you, to our trusted service providers and subcontractors, who have agreed to confidentiality restrictions and who use such information solely on our behalf in order to: (1) help us provide you with the Site and/or Services; (2) aid in their understanding of how users are using our Site; (3) for the purpose of direct marketing (see above for more details); (4) assist us in (co-) hosting a particular event or conference. Any business partners involved in organizing events in which you participate are independent and separate controllers of your Personal Data and may contact you with offers (such as events, lectures, etc.) such party determines may be relevant to your interests.

The service providers and subcontractors specified above provide us with IT and system administration services, data backup, security, storage, and management services, data analysis, ERP systems, email distribution, social media services, and help us serve advertisements and other marketing to our clients and may assist us in (co-) hosting a particular event or conference.

Data Controllers

When you use our Site and/or Services, we also disclose your Personal Data to additional third parties, such as business partners, which act as independent, separate controllers with respect to the collection of your Personal Data. The details and contact information of such controllers are as set forth below.

Facebook, Inc. - Privacy Operations, 1601 Willow Road, Menlo Park, CA 94025, USA

Business Transfers

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.                                                                                 

Other Uses or Transfer of Your Information

If you use our Site and/or Services with or through a third party service, site and/or mobile application, we may receive information (including Personal Data) about you from those third parties. Please note that when you use third-parties outside of our Site and/or Services, their own terms and privacy policies will govern your use of those services.

International Transfer

We use subcontractors and service providers and have business partners and affiliates who are located in countries other than your own, such as Ireland, Israel and US 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, 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 info@arnon.co.il if you would like further information on the specific mechanism used by us when transferring your Personal Data out of the EEA.

Security

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. The measures we take include:

Safeguards – The physical, electronic, and procedural safeguards we employ to protect your Personal Data include secure servers, firewalls, antivirus, and SSL encryption of data.

Access Control – We dedicate efforts for a proper management of system entries and limit access only to authorized personnel on a need to know basis of least privilege rules, review permissions quarterly, and revoke access immediately after employee termination.

Internal Policies – We maintain and regularly review and update our privacy related and information security policies.

Personnel – We require new employees to sign non-disclosure agreements according to applicable law and industry customary practice.

Encryption – We encrypt the data in transit using secure SSL protocols.

Database Backup – Our databases are backed up on a periodic basis and are verified regularly. Backups are encrypted and stored within the production environment to preserve their confidentiality and integrity, are tested regularly to ensure availability, and are accessible only by authorized personnel.

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. Please note that to ensure that we do not collect any further Personal Data, you should clear our cookies from any device where you have visited our Site. 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.
  • Direct Marketing Opt Out. You can change your mind at any time about your election to receive marketing communications from us and/or having your Personal Data processed for direct marketing purposes. If you do, please notify us by contacting us at info@arnon.co.il. We will process your request as soon as reasonably possible, however it may take a few days for us to update our records before any opt out is effective.
  • 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.
  • Withdrawal of Consent. You may withdraw your consent in connection with any processing of your Personal Data based on a previously granted consent. This will not affect the lawfulness of any processing prior to such withdrawal.
  • 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.

Data Retention

Subject to applicable law and our (regulatory) obligations, we retain Personal Data as necessary for the purposes set forth above. We may maintain records of the Personal Data we collect for our recordkeeping and for protection of our legal rights.

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 info@arnon.co.il if you would like details regarding the retention periods for different types of your Personal Data.

Cookies and Similar Technologies

Please visit our Cookies Policy, available at http://www.arnon.co.il/sites/all/themes/law/files-to-show/arnon-privacy-policy.pdf, if you would like more information regarding our use of cookies, including how you can adjust your settings to determine which cookies you do or do not allow.

Children

We do not knowingly collect Personal Data from children under the age of sixteen (16). In the event that you become aware of our collection of Personal Data of an individual under the age of sixteen (16) has used our Services without parental permission, please advise us immediately.

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.

Communications

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, please contact us at info@arnon.co.il. Note that you may receive personal communications from individuals within our organization without having the opportunity to opt-out of such communications.

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 fundamental 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 info@arnon.co.il.

Last updated: March 2019

Terms of Use

Thank you for visiting the website (the “Site”) of Yigal Arnon & Co. (“we”, “us” or “YA”). YA is happy to make available to you the content on its Site for informational purposes.  Please carefully read these terms of use (the “Terms”) as well as our privacy notice, which we may update from time to time, a current version of which is available at www.arnon.co.il (the “Privacy Notice”). By using our Site, you thereby agree to the Terms. If you do not agree to the Terms, you should exit our Site..

Intellectual Property Rights.

We own all intellectual property in this Site and its content (including without limitation any documents posted on the Site) including its overall appearance, graphics design and underlying source files. Without the prior written consent of YA, you may not reproduce (in whole or in part), transmit (by electronic means or otherwise), modify, frame or use for any purpose the contents of this Site. No copyright notices, other intellectual property or legal notices or other identifying information may be removed from downloaded materials. Nothing contained in this Site should be construed as granting any license or right to use any of Company’s intellectual property rights. If you provide us with any feedback concerning any material on the Site, such feedback shall not be subject to any confidentiality restrictions and YA will be free to use such feedback, without any compensation to you, for any purpose whatsoever.

Links.

Our Site may link to third party websites.  YA provides links for ease of reference only.  YA has no control over the content or information posted on such third party websites and we do not assume any responsibility or liability therefore.  Third party websites may have policies about the use of your information that are different than ours.  You should refer to these third party websites’ respective privacy notices and terms of use.

Limitation of Liability; Disclaimers.  

YA has made and will continue to make efforts to include accurate and up-to-date information on this Site.  However, YA cannot guarantee that the information posted on this Site is accurate, complete or suitable for any purpose.  All the information and content posted on the Site are provided for informational purposes only and are not legal advice. Subscribers and online readers, even if they are already clients of YA, should not act upon this information without seeking actual legal counsel. The content of this Site contains general information and may not reflect current legal developments. Such content is designed only to give general information. It is not intended to be a comprehensive summary of recent developments in the law, treat exhaustively the subjects covered, provide legal advice or render a legal opinion. In addition, YA cannot guarantee that the content posted on this Site has not been affected by technical malfunctions or unauthorized tampering.  YA does not guarantee that material on this Site will be free from infection, viruses, worms, Trojan horses and/or other code that has contaminating or destructive properties.  It is your responsibility to take protective steps such as virus checking.  YA may alter or remove materials from this Site at any time.

TO THE FULLEST EXTENT ALLOWED UNDER APPLICABLE LAW, YA MAKES NO REPRESENTATIONS OR WARRANTIES, EXPRESS OR IMPLIED, INCLUDING WITHOUT LIMITATION ANY WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE OR NON-INFRINGEMENT, WITH RESPECT TO THE USE OF THIS SITE OR ANY INFORMATION OBTAINED THROUGH THIS SITE.  IN NO EVENT WILL YA, ITS AFFILIATES, EMPLOYEES OR OFFICERS BE LIABLE FOR ANY DAMAGES OR LOSSES OF ANY KIND WHATSOEVER RESULTING TO YOU OR TO ANY THIRD PARTY DIRECTLY OR INDIRECTLY FROM ANY USE OF THIS SITE OR DEFECT IN THIS SITE OR ANY INFORMATION CONTAINED IN THIS SITE, INCLUDING BUT NOT LIMITED TO CONSEQUENTIAL, INCIDENTAL OR OTHER INDIRECT DAMAGES.

BY USING THIS SITE, YOU EXPRESSLY ASSUME ALL RISK THAT THE INFORMATION AND MATERIALS ON THIS SITE MAY BE INCOMPLETE, INACCURATE, OUT-OF-DATE, OR MAY NOT MEET YOUR NEEDS OR REQUIREMENTS.

Some jurisdictions may not allow the exclusion of implied warranties, so some of the above exclusions may not apply to you. You are responsible for checking your local laws for any restrictions or limitations regarding the exclusion of liability.

Revision and Update of Terms.  

We may revise the Terms at any time without notice by updating this Site.  All updates to the Terms will be posted on this page.  You are bound by any revisions or updates.  You should periodically visit these Terms to review the current terms that apply to your use of our Site..

Governing Laws.  

The Terms are governed and interpreted pursuant to the laws of the State of Israel, notwithstanding any principles of conflicts of law. All disputes in respect of the Site and any content available through the Site shall be subject to the exclusive jurisdiction of the competent courts in Tel Aviv, Israel. If you access this site from another jurisdiction, you are responsible for ensuring compliance with any local laws relating to access and use of this Site.

How to Contact Us.  

If you have any questions or concerns about the Terms for this Site or its implementation you may contact us at through the functionality made available through the Site.

Last update: April 2018.

 

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