The Floor Website Privacy Notice
Fintech Next Ltd. (“The Floor”) respects your privacy and is committed to protecting your personal data. This privacy notice (“Privacy Notice”) will inform you as to how we look after your personal data when you visit our Website https://thefloorhub.com/ (“Website”) and tell you about your privacy rights and how the law protects you.
Please also use the Glossary to understand the meaning of some of the terms used in this Privacy Notice.
- IMPORTANT INFORMATION AND WHO WE ARE
- THE DATA WE COLLECT ABOUT YOU
- HOW IS YOUR PERSONAL DATA COLLECTED
- HOW WE USE YOUR PERSONAL DATA
- DISCLOSURES OF YOUR PERSONAL DATA
- INTERNATIONAL TRANSFERS
- DATA SECURITY
- DATA RETENTION
- YOUR LEGAL RIGHTS
IMPORTANT INFORMATION AND WHO WE ARE
PURPOSE OF THIS PRIVACY NOTICE
This Privacy Notice aims to give you information on how The Floor collects and processes your personal data through your use of this Website, including any data you may provide through this Website when you sign up to receive communications from us.
This Website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this Privacy Notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy Notice supplements the other notices and is not intended to override them.
The Floor is the controller and responsible for your personal data (collectively referred to as the “Company”, “we”, “us” or “our” in this Privacy Notice).
Our full details are:
Full name of legal entity: Fintech Next Ltd.
Email address: email@example.com
Postal address: TASE Building 3rd Floor 2, Ahuzat Bayit, Tel Aviv 6525216
Telephone number: +972-77-9981603
You have the right to make a complaint at any time to data protection authorities. We would, however, appreciate the chance to deal with your concerns before you approach data protection authority so please contact us in the first instance.
CHANGES TO THE PRIVACY NOTICE
This version was last updated on June 6, 2018.
This Website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows: confirmed
- Identity Data includes first name, last name, title, name of employing entity, role at employing entity, details of employing entity, curriculum vitae and a link to a personal LinkedIn profile.
- Contact Data includes email address and telephone number.
- Technical Data includes IP address.
- Usage Data includes information about how you use our Website (including when you entered the Website and how long you stayed in the Website).
We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Website feature.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes, for example, personal data you provide when you apply for a position or for membership, or subscribe to our publications;
- Third parties or publicly available sources. We may receive personal data about you from various third parties and publicly available sources, such as Identity and Contact Data that we receive from Linkedin on potential job candidates, Usage Data that we receive from analytics providers such as Google Analytics and Similar Web and Identity and Contact Data that we receive from Meetup in preparation for events that we host.
HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;
- Where it is required for the performance of a contract we may or are about to enter into, or have entered into with you.
- Where we need to comply with a legal or regulatory obligation; or
- Where you have provided your consent for such use.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out below a description of the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate:
- To deliver our newsletters to you via email. We will do so where it is necessary for our legitimate interests (to grow our business, to create business and partnership opportunities, to develop brand awareness) or where we have obtained your prior consent.
- To manage our relationship with you, including by notifying you about changes to our terms or Privacy Notice. We will do so if it is necessary to comply with a legal obligation or if it is for our legitimate interests (complying with our internal policies and procedures).
- To provide you with reports and other information we make available to you through our website. We will do so for our legitimate interests (to study who uses the information created and published by us, to develop our business, to keep our website updated) or where we have obtained your prior consent.
- To offer job opportunities and to enable you to apply for positions at the Company. We will do so where it is necessary for our legitimate interests (recruitment of personnel and handling job applications), to take steps prior to entering a contract with you or where we have obtained your prior consent.
- To enable you to apply for membership at The Floor. We will do so where it is necessary for our legitimate interests (selection of companies as members of The Floor), to take steps prior to entering a contract with you or where we have obtained your prior consent.
- To manage attendance at events that we host. We will do so if it is necessary for our legitimate interests (managing the number of participants in an event, logistical preparation for the event, etc.).
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please Contact us if you need more details about the specific legal ground we are relying on to process your personal data.
You can ask us or third parties to stop sending you messages at any time by following the opt-out links on any message sent to you or by Contacting us at any time.
Where you opt out of receiving these messages, this will not apply to personal data provided to us as a result of a product/service purchase or other transactions.
CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please Contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with third parties who provide us services in connection with the operation, maintenance and storage of our Website or third parties that provide us with other data storage services (such as Google Drive), to the extent necessary for the provision of such services. We may also share your personal data with third parties, such as MailChimp, for sending you newsletters and other informative communications.
For more information on how the third parties mentioned above handle your personal data, please see privacy policies: [Note: add links to MailChimp, Google, etc. privacy policies]
We may also share your personal data with third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Notice.
We require third parties to respect the security of your personal data and to treat it in accordance with the law. We permit our third-party service providers to process your personal data for specified purposes and in accordance with our instructions.
We are based in Israel, but we use external service providers that are based outside of Israel, so their processing of personal data will involve a transfer your personal data outside of Israel.
Whenever we transfer your personal data to countries 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:
- The data is transferred to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
- We may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
- Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed.
HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, 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 we can achieve those purposes through other means, and the applicable legal requirements.
Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by Contacting us.
YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights: [Note: these should link to the list of rights in the glossary]
- Request access to your personal data.
- Request correction of your personal data.
- Request erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Request transfer of your personal data.
- Right to withdraw consent.
If you wish to exercise any of the rights set out above, please Contact us.
NO FEE USUALLY REQUIRED
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
WHAT WE MAY NEED FROM YOU
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
TIME LIMIT TO RESPOND
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by Contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
YOUR LEGAL RIGHTS
You have the right to:
Request access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.