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Privacy Policy

Bring them home now – Privacy Policy EU 

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Privacy Policy for Data Subjects in the EU/EEA

 

Last updated: [05-27-24]

 

This Privacy Policy describes what personal data we, Hostages and Missing Families Forum, Israel, collect and process, why we collect it and how we use it, regarding individuals (“Users” or “you”), located in the European Union/European Economic Area (“EU/EEA”), who use the Bring Them Home Now Site at the address https://solidarity-eu.bringthemhomenow.net ( the “Site”) and/or purchase products and services via the Site.

Our Privacy Policy also describes how you may exercise your rights under the European General Data Protection Regulation (“GDPR”), including the right to object to certain types of processing, in regard to such data held with us.

Please read this Privacy Policy carefully and make sure that you fully understand and agree to it. You are not legally required to provide us with any personal data, and may do so (or avoid doing so) at your own free will, but without it we may not be able to provide the services.

 

1. Who is the Data Controller?

The controller responsible for the processing of your personal data in connection with the visit to the Site is 

The Hostages and Missing Families’ Forum Ltd. (CC) I.D. 580775674 ( The Forum”, we”, our” or us”).

 

If you are located within the EU/EEA and have any questions or suggestions regarding this information, or if you would like to contact us about asserting your rights, please send your request to our EU representative:

[(Company) Name]

[Address]

[E-mail]

 

2. What data do we collect, how do we collect it, and how do we use it?

We collect personal data regarding the Users. Such data is typically collected and generated through your interaction with us, through automatic means, directly from you, or from other third parties. Specifically, we collect the following categories of data (which, to the extent it relates to an identified or identifiable individual, will be deemed “personal data”):

  • Personal data received from you - Such as contact details, including name, telephone number, address, email, and any other information that might be relevant for your use of the Site or for the purchase process. We may collect this data directly from you, as you provide it voluntarily through any form, your purchase process. 

  • Data automatically collected and generated - Such data mainly consists of connectivity, technical and aggregated usage data, such as IP addresses, data regarding the device, operating system, browser version, and locale settings used when interacting with any of the forms, the cookies and pixels installed on such device and your activity (clicks and other interactions) in connection with your use of the Site.

  • Data received from other third parties.

We process personal data in compliance with the GDPR. Data processing by us only takes place on the basis of a legal permission. We process personal data only if we have a sufficient legal ground for the respective processing, such as: based on your consent (Art. 6 (1) (a) GDPR), for the performance of a contract to which you are a party or at your request for the performance of pre-contractual measures (Art. 6 (1) (b) GDPR), for the performance of a legal obligation (Art. 6 (1) (c) GDPR) or if the processing is necessary to protect our legitimate interests or the legitimate interests of a third party, unless your interests or fundamental rights and freedoms which require the protection of personal data override (Art. 6 (1) (f) GDPR).

In particular we use personal data as necessary for the performance of the Site and sale activities; to comply with applicable law; and to support our legitimate interests in maintaining and improving our offerings, understanding how the site  is used, optimizing our marketing, advertising, service and support operations, and protecting and securing you, ourselves and our services, as well as members of the general public.

Specifically, we may use personal data in order to provide you the services offered via the Site (such as purchase of products, support etc.), to communicate with you regarding such processes, and to communicate with you through newsletters distributed by any means. We may also use it to manage risk and enhance our security and anti-fraud measures, and to create aggregated statistical or inferred data regarding Users, for further development and improvement of our offerings, or for our future use, to comply with our contractual and legal obligations and requirements, or any other lawful purpose or other purpose you consent to in connection with your use of the Site. 

If you wish to revoke your consent, please contact us by email at eu_support@bringthemhomenow.net,

We will never sell your personal data, regardless of their place of residence.

 

3. Where do we store your data?

Your personal data will be maintained, processed, and stored by the Forum in Israel and in additional locations in which we operate.

The Forum is located in Israel, which is considered by the European Commission to be offering an adequate level of protection for the personal data of EU Member State residents (Art. 45 GDPR).

While data protection laws in certain jurisdictions may be different than the laws of your residence or location, please know that the Forum and/or its affiliates and Service Providers (as discussed below) that store or process your personal data on our behalf are each committed to keep it protected and secured, in accordance with this Privacy Notice and industry standards, regardless of any lesser legal requirements that may apply in any jurisdiction.

For data transfers from the EU to countries that are not considered to be offering an adequate level of data protection, we and the relevant data exporters and importers enter into the EU Standard Contractual Clauses as approved by the European Commission as appropriate safeguards for transfers of personal data to third countries outside of the EU (Art. 46 GDPR).

 

4. For how long may we keep your data?

Unless otherwise stated in this Privacy Policy, we store the data only for as long as is necessary to achieve the processing purpose or to fulfill our contractual or legal obligations. The information will be kept, including, for the purposes listed, in accordance with the applicable law.

Please note that except as required by applicable law, we will not be obligated to retain your personal data for any particular period, and we are free to securely delete it as soon as we have no longer legal reason to retain the data. If you have any questions about our data retention policy, please contact us by email to eu_support@bringthemhomenow.net

 

5. Who has access to your data?

In certain instances we will disclose your personal data to third parties, as described below:

  • Third-party service providers: companies that perform services on our behalf and complementary to our own (e.g. data hosting, analytics, advertising and marketing, data and cyber security, user engagement services, e-mail distribution and monitoring services, text messaging services, and our business, legal and financial advisors) (collectively, “Service Providers”).

  • We use processors (Art. 28 GDPR) as part of the processing. Processors do not use the data for their own purposes but carry out data processing exclusively for the controller and are contractually obligated to ensure appropriate technical and organizational measures for data protection;

  • Legal Compliance: in exceptional circumstances, we may disclose or allow government and law enforcement officials access to your personal data in order to comply with applicable law or any obligations thereunder, including cooperation with law enforcement, judicial orders, and regulatory inquiries. Such disclosure or access may occur if we believe in good faith that: (a) we are legally compelled to do so; (b) disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing; or (c) such disclosure is required to protect the security or integrity of our products and Services;

  • To enforce any applicable terms of service;

  • To ensure the rights, interests, safety, health and security of the Forum personnel and users.

For the avoidance of doubt, we may share your personal data in additional manners, pursuant to your explicit consent, or if we are legally obligated to do so, or if we have successfully rendered such data non-personal and anonymous.

 

6. How do we secure your data?

We implement current systems and procedures for data security. While these systems and procedures reduce the risks of unauthorized intrusion, they do not provide absolute security. Therefore, we do not guarantee that your data will be completely immune from unauthorized access to the information stored on it.

 

7. Collection of general information (server log data)

When you access our Site, information of a general nature is automatically collected. This information (server log data) includes, for example, the type of web browser, the operating system used, the domain name of your internet service provider and similar. This is exclusively information that does not allow any conclusions to be drawn about your person.

This information is technically necessary in order to correctly deliver the Site content requested by you and is mandatory when using the internet. It is processed in particular for the following purposes:

• Ensuring a smooth connection to the Site,

• Ensuring the smooth use of our Site,

• Evaluation of system security and stability and

• for further administrative purposes.

The processing of your data is based on our legitimate interest from the aforementioned purposes for data collection (Art. 6 (1) (f) GDPR). We do not use your data to draw conclusions about your person. Recipients of the data are only the controller and, if applicable, processors.

Anonymous information of this kind may be statistically evaluated by us in order to optimize our website and the technology behind it.

 

8. Cookies & Tracking Technologies Usage

Cookies are stored on our Site. Cookies are small text files that are stored in the device memory of your mobile device and/or your computer. They serve, among other things, to make the use of the Site more user-friendly and effective overall.

When you visit our Site, cookies are set that are technically necessary for the operation of the Site. The legal basis for the processing of personal data using technically necessary cookies is our legitimate interest pursuant to Art. 6 (1) (f) GDPR. Our overriding legitimate interest is the operation of our Site.

We also use non-essential cookies, for example, to collect additional information about the interests of visitors of our Site or their usage behavior in order to analyze and optimize our Site and our customer interactions in general. Non-essential cookies are only set if you have given your explicit consent. The legal basis for the processing of personal data using such non-essential cookies is your consent in accordance with Art. 6 (1) (a) GDPR.

In particular we may use cookies and other technologies for our regular and proper operation of the form or any other website, and tracking, analytics, and personalization purposes, including to collect statistical data about the use of the Site, to verify details and for information security purposes. We may even use cookies originating from third parties which are intended for displaying ads regarding products or services based on your various interactions with those services.

The following is a list that contains the current cookies used by the Site. Further information about the cookies you find in our Cookies Settings.

 

Cookie Name: XSRF-TOKEN

Purpose: Used for security reasons

Duration: Session

Cookie Type: Essential


 

Cookie Name: hs

Purpose: Used for security reasons

Duration: Session

Cookie Type: Essential


 

Cookie Name: svSession

Purpose: Used in connection with user login

Duration: 12 months

Cookie Type: Essential


 

Cookie Name: SSR-caching

Purpose: Used to indicate the system from which the site was rendered

Duration: 1 minute

Cookie Type: Essential


 

Cookie Name: _wixCIDX

Purpose: Used for system monitoring/debugging

Duration: 3 months

Cookie Type: Essential


 

Cookie Name: _wix_browser_sess

Purpose: Used for system monitoring/debugging

Duration: session

Cookie Type: Essential


 

Cookie Name: consent-policy

Purpose: Used for cookie banner parameters

Duration: 12 months

Cookie Type: Essential


 

Cookie Name: smSession

Purpose: Used to identify logged in site members

Duration: Session

Cookie Type: Essential


 

Cookie Name: TS*

Purpose: Used for security and anti-fraud reasons

Duration: Session

Cookie Type: Essential


 

Cookie Name: bSession

Purpose: Used for system effectiveness measurement

Duration: 30 minutes

Cookie Type: Essential


 

Cookie Name: fedops.logger.X

Purpose: Used for stability/effectiveness measurement

Duration: 12 months

Cookie Type: Essential


 

Cookie Name: wixLanguage

Purpose: Used on multilingual websites to save user language preference

Duration: 12 months

Cookie Type: Functional


 

9. No automated decision making, including profiling

We do not use automated decision-making processes, including profiling (Art. 22 GDPR). 

 

10. Your Rights

As a data subject you have the following rights:

  • In accordance with Art. 15 GDPR, you have the right to request information about whether and, if so, to what extent we are processing personal data relating to you or not and the right to access your personal data.

  • You have the right to demand that we correct your data in accordance with Art. 16 GDPR.

  • You have the right to demand that we delete your personal data in accordance with Art. 17 GDPR.

  • You have the right to have the processing of your personal data restricted in accordance with Art. 18 GDPR.

  • You have the right, in accordance with Art. 20 GDPR, to receive the personal data concerning you that you have provided to us in a structured, common and machine-readable format and to transfer this data to another controller.

  • If you have given us the consent to data processing, you may revoke this consent at any time in accordance with Art. 7 (3) GDPR. Such a revocation will not affect the lawfulness of the processing that was carried out on the basis of the consent until the revocation.

  • If you believe that a processing of personal data concerning you violates the provisions of the GDPR, you have the right to lodge a complaint with the relevant supervisory authority, in particular in the EU Member State of your habitual residence, place of work or of an alleged infringement of the GDPR, in accordance with Art. 77 GDPR. 

 

11. Right of Withdrawal

In accordance with Art. 21 GDPR, you have the right to object to processing based on Art. 6 (1) (e), (f) GDPR in the following circumstances:

  • on grounds relating to your particular situation when the applicable legal basis is legitimate interests; in some cases, we may demonstrate that we have compelling legitimate grounds to process your personal data, which override your rights and freedoms. If this is the case, we will let you know; and

  • at any time when your personal data is processed for direct marketing purposes.

 

12. How can you access your data or request to delete it?

If you wish to exercise your right (to the extent available to you under applicable law) to request access to your data, to correct it, to delete it or to port it, or to restrict or object to its processing, please send us an e-mail to eu_support@bringthemhomenow.net, and we will respond within a reasonable timeframe and in accordance with applicable laws.

Please note that we may require additional information, including certain personal data, in order to authenticate and process your request.

 

13. Will this Privacy Policy be updated?

We may update this Privacy Policy to reflect changes in our privacy practices. If we make any changes that we deem as “material”, we will notify you. We encourage you to periodically review this page for the latest data on our privacy practices.

 

14. What if you have any questions?

If you have any questions regarding this Privacy Policy, our data practices or the security of our services, please feel free to contact us at: eu_support@bringthemhomenow.net

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