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A User may be either an entity, for example a community organization which has executed an agreement with Masa or with Masa’s resellers or distributors who provide Masa’s services (“Organizer”) or a Organizer’s users of the Services, for example an individual participating in a program advertised by a community organization (“End User(s)”). Organizer and End User shall collectively be referred to as “Users” or “you”).

This Policy (the “Privacy Policy“) explains the types of information we may collect from Users or that Users may provide when using the Services. This Policy also describes Masa’s practices for collecting, using, maintaining and processing information.

Users who wish to use the Service may be asked to provide Masa with certain information including Personal Data and Sensitive Information as further detailed in this Privacy Policy (“Data”). Masa’s use of this Data in connection with the Services will be undertaken in accordance with this Privacy Policy and Masa’s Terms of Use.

Please read the following carefully to understand practices regarding your personal data and how we will treat it.

For the purposes of European Economic Area data protection law the EU Regulation 2016/679 (the General Data Protection Regulation), (the “Data Protection Law“ or “GDPR”), Masa will generally be regarded as a data controller (the “Controller”).

1. WHICH INFORMATION MAY WE COLLECT?

Categories of information and data we may collect from our Users.

Data we collect about you from your use of the Service

One type of Data is non-identifiable and anonymous information (“Non-Personal Data”). We also collect several categories of personal data (“Personal Data “).

Personal Data which is being gathered consists of any personal details provided consciously and voluntarily by a User through your use of the Services. This may include your name (first and last), I.D. or passport number, scanned copy of your I.D. or passport, birthdate, gender, nationality, email address, phone number(s), home address, billing information such as your credit card details or your bank account details, emergency contact details (name, relation, phone number(s), email address, home address), information regarding your health including any pre-existing physical or mental health conditions and allergies, demographic and specific Personal Data such as personal preferences for different types of activities, educational background, previous work experience, participation in a previous program. We may also collect financial information including family financial situation to assess your situation in relation to requested scholarships, financial aid or bursaries for the programs as well as previous Jewish engagement and visits to Israel

You do not have any legal obligation to provide any information to Masa. However, we require certain information in order to provide the Services. If you choose not to provide us with certain information we may not be able to provide you with some or all of the Services. We may keep such Personal Data in a database which will be owned and controlled by the Controller.

Masa may also collect the email addresses and other contact information of people who communicate with Masa via email or via messenger services or other social media platforms or create accounts and login credentials.

By registering on Masa’s general website, Masa will collect your name and any email address and phone number you provided. Masa may use this information to offer Masa’s services and support.

Masa may collect Personal Data about an individual’s Jewish affiliation, physical or mental health or condition, or any other data considered as sensitive under applicable law (“Sensitive Information“).

2. HOW DO WE COLLECT PERSONAL DATA ON USERS OF the Services?

We collect Personal Data through your use of our Website. In other words, when you are using the Services we are aware of it and may gather, collect and record the information relating to such usage, either independently or through the help of third-party services as detailed below. This may include technical information and behavioural information such as the User’s Internet Protocol (IP) address used to connect your computer to the Internet, your Uniform Resource Locators (URL), operating system, type of browser, browser plug-in types and versions, screen resolution, Flash version, time zone settings, the User’s ‘click-stream’ on the website, the period of time the User visited the website, methods used to browse away from a page, and any phone number used to call our customer service number. We likewise may place cookies on your browsing devices (see section ‘Cookies’ below).

We collect Personal Data required to provide the Services when you or the Organizer’s administrator register with us. In addition, we collect your Personal Data when you provide us such information by entering it manually or via an Organizer, whether through our Website, in the course of preparing a contract, or otherwise in engaging with us. We also collect Personal Data entered voluntarily by a Organizer administrator, and it is the responsibility of every Organizer administrator to ensure that they are entitled to provide such Personal Data to us for use in line with this Privacy Policy.

3. WHAT IS THE PURPOSE OF PERSONAL DATA WE COLLECT?

We will use Personal Data only to provide and improve the Services and meet our contractual, ethical and legal obligations, including for example:

Processing which is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract (GDPR Article 6(1)(b))

• carrying out our obligations arising from any contracts entered into between you and Masa and/or any contracts entered into between a Organizer and Masa and to provide you with the information, products and Services that you request from Masa;
• administering your file with Masa;
• assessing and confirming eligibility for programs and for financial aid and/or scholarships
• sharing relevant information with vendors and partners (such as hotels, guest houses, travel companies, catering services – regarding allergies etc.);
• connecting between participants in different programs;
• verifying and carrying out financial transactions in relation to payments you make in connection with the Services.

Processing which is necessary for compliance with a legal obligation to which Masa is subject (GDPR Article 6(1)(c))

• providing information to any official authority or any entity authorized by the State, in cases where Masa is under a legal obligation to do so;
• compliance and audit purposes, such as meeting our reporting obligations in our various jurisdictions, and for crime prevention and prosecution in so far as it relates to our staff, programs etc.

Processing is necessary for the purposes of the legitimate interests pursued by Masa or by a third party (GDPR Article 6(1)(f)) of providing an efficient and wide ranging service to customers

• notifying you about changes to our Services;
• contacting you for the purpose of providing you with technical assistance and other related information about the Services;
• replying to your queries, troubleshooting problems, detect and protect against error, fraud or other criminal activity;
• contacting you to give you information and inviting you to take part in relevant events, such as events for Jewish communities in Israel and overseas;
• contacting you to give you information and inviting you to take part in other educational programs organized by Masa or other affiliates;
• soliciting feedback in connection with your use of the Services;
• Engaging our graduates and providing them with information relevant to Masa and its activities (such as employment opportunities, invitations to special events and programs provided by Masa community or our partners).

Personal Data which you provide us may be combined with Personal Data which a Masa Organizer provides us, or which may be provided by other sources, all of which will be used for the purposes set out above.

4. SHARING DATA WITH THIRD PARTIES

We may transfer Personal Data to:

Members of our Group

This includes any member of our group, which means our ultimate holding company The Jewish Agency for Israel and its subsidiaries and the government of Israel.

Third Parties

We transfer Personal Data to third parties in a variety of circumstances. We endeavour to ensure that these third parties use your Personal Data only to the extent necessary to perform their functions, and to have a contract in place with them to govern their processing on our behalf.

These third parties may include business partners, suppliers, affiliates, agents and/or sub-contractors for the performance of any contract we enter into with you (such as hotels, guest houses, travel companies, catering services etc). They may assist us in providing the Services we offer, processing transactions, fulfilling requests for information, receiving and sending communications, analyzing data, providing IT and other support services or in other tasks, from time to time.

These third parties may also include analytics and search engine providers that assist us in the improvement and optimization of our website.

We periodically add and remove third party providers. At present our third-party providers to whom we might transfer Personal Data include the following:

Google (display, search, youtube)
Facebook & Instagram
Linkedin
Twitter
Pinterest
Reddit
Jswipe
Jdate
Bing
Yahoo
Tiktok

In addition we may disclose your Personal Data to third parties if all or substantially all of our assets are acquired by a third party including by way of a merger, share acquisition, asset purchase or any similar transaction, in which case personal data held by us about our Users will be one of the transferred assets.

Likewise, we may transfer Personal Data to third parties if we are under a duty to disclose or share your personal data in order to comply with any legal or audit or compliance obligation, in the course of any legal or regulatory proceeding or investigation, or in order to enforce or apply our terms of supply and other agreements with you; or to protect the rights, property, or safety of Masa, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction and to prevent cybercrime.

For the avoidance of doubt, Masa may transfer and disclose non-personal Data to third parties at its own discretion.

5. WHERE DO WE STORE YOUR DATA?

We may keep Personal Data in a database which will be owned and controlled by the Controller. The Data we collect is hosted on FormAssembly, Oracle and Salesforce.

6. INTERNATIONAL DATA TRANSFERS

Personal Data may be transferred to, and stored and used at, a destination outside of the European Economic Area (EEA) that may not be subject to equivalent data protection laws to those of the EU. Where your data is transferred outside of the EEA, we will take all steps reasonably necessary to ensure that your data is subject to appropriate safeguards and that it is treated securely and in accordance with this Privacy Policy. Masa transfers data from its various locations and jurisdictions as follows:

• To Israel: Masa headquarters are based in Israel. Israel is considered by the European Commission to offer an adequate level of protection for the Personal Data of EU Member State residents.
• Within the EU
• To other countries where Masa operates. These transfers will be subject to standard contractual clauses that have been pre-approved by the EU Commission as contractually guaranteeing an adequate level of protection.

We may transfer your personal data outside of the EEA, in order to:

• Store or backup the information;
• Enable us to provide you with the Services and fulfil our contract with you;
• Fulfill any legal, audit or compliance obligations which require us to make that transfer;
• Facilitate the operation of our representatives, where it is in our legitimate interests and we have concluded these are not overridden by your rights;
• To serve our Organizers across multiple jurisdictions; and
• To operate parent company, subsidiaries, and affiliates in an efficient and optimal manner.

7. MODIFICATION OR DELETION OF PERSONAL DATA GATHERED by Masa

Data held by Masa may contain errors and omissions.

Users may have a legal right under certain applicable laws (for instance if the User is in the EU) to receive, rectify, erase, and restrict Personal Data about them that is held by us, to object to processing and, if processing occurs based on consent, to withdraw their consent

If, for any reason, a User wishes to modify, delete or retrieve his/her Personal Data, s/he may do so by contacting Masa masadpo@masaisrael.org. Masa shall perform the necessary process to identify the User as a User who has the right to retrieve the specific information and then furnish the data required to be amended, deleted or retrieved together with a specific identification of the User and data.

Please note that Personal Data may be either deleted or retained in an aggregated manner without being linked to any identifiers or Personal Data, depending on technical commercial capability. Such information may continue to be used by Masa for the purpose of operating the Services.

8. DATA RETENTION

Masa will retain data it processes only for as long as required to provide the Services and as necessary to comply with its legal obligations, resolve disputes and enforce its agreements.

Please note that some data will not be deleted and shall be kept in an anonymized manner. Some metadata and statistical information concerning the use of the Services are not subject to the deletion procedures in this policy and may be retained by Masa. We will not be able to identify you from this data. Some data may also be retained on our third-party service providers’ servers until deleted in accordance with their privacy policy and their retention policy

9. WEBSITE DATA COLLECTION AND COOKIES

When you access or use the Services, we may use industry standard technologies such as “Cookies”, pixels and similar technologies, which store certain information on your computer or browsing device and which will allow us to identify the computer or device with the user, and to enable automatic activation of certain features, and make your Service experience much more convenient and effortless.

We use different types of Cookies. Some cookies are strictly necessary. They are required for the operation of our Site and under our terms with you. They include, for example, cookies that enable you to log into secure areas of our Services. We also use analytical and performance monitoring cookies, which allow us to recognise and count the number of visitors and to see how visitors move around our Site when they are using it. Finally, we use Functionality cookies, which are used to recognise you when you return to our Site. This enables us, subject to your choices and preferences, to personalise our content, greet you by name and remember your preferences (for example, your choice of language or region).

Different cookies are kept for different periods. Session cookies are used to keep track of your activities online in a given browsing session; these cookies generally expire when the browser is closed but may be retained for a period on your device. Permanent cookies remain in operation even when you have closed the browser; they are used to remember your login details and password. Third party cookies are installed by third-parties with the aim of collecting certain information to research behaviour and demographics. Third party cookies on our site include for example Google Analytics. Likewise, pixels from Facebook and others enable integration of third-party service providers (e.g. Facebook, Twitter) on our site. Third party cookies will be retained according to the terms of those third parties, and you can control those cookies in your browser settings.

We use Cookies and other technologies on the basis that they are necessary for the performance of a contract with you, or because using them is in our legitimate interests and these are not overridden by your rights.

Most browsers will allow you to erase cookies from your computer’s hard drive, block acceptance of cookies, or receive a warning before a cookie is stored. However, if you block or erase cookies your online experience on our website may be limited.

Disabling cookies

The effect of disabling cookies depends on which cookies you disable but, in general, the website and some services delivered through it may not operate properly, may not recognize your device, may not remember your preferences and so on –  if cookies are disabled or removed.

However allowing or disabling cookies is your choice and in your control. If you want to disable cookies on our site, you need to change your browser settings to reject cookies. How you can do this will depend on the browser you use. Further details on how to disable cookies can be found here:

Internet Explorer – http://windows.microsoft.com/en-GB/internet-explorer/delete-manage-cookies
Google Chrome – https://support.google.com/chrome/answer/95647?hl=en

Firefox – https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences

Safari – http://help.apple.com/safari/mac/8.0/#/sfri11471

Our website may, from time to time, contain links to external sites. We are not responsible for the operation, privacy policies, or the content of such sites.

10. SECURITY AND STORAGE OF IFORMATION

We take a great care in implementing, enforcing and maintaining the security of the Personal Data we process. Masa implements, enforces and maintains security measures, technologies and policies to prevent the unauthorized or accidental access to or destruction, loss, modification, use or disclosure of personal data.  We likewise take steps to monitor compliance of such policies on an ongoing basis. Where we deem it necessary in light of the data in question and the risks to data subjects, we may encrypt data. Likewise, we take industry standard steps to ensure our website is safe.

Note however, that no data security measures are perfect or impenetrable, and we cannot guarantee that unauthorized access, leaks, viruses and other data security breaches will never occur.

Personal data is stored on Salesforce, Oracle and Cellcom, which hold the relevant security industry standard certifications (eg. ISO, PCI) and are GDPR compliant.

Within Masa, we limit access to personal data to those of our personnel who: (i) require access in order for Masa to fulfil its obligations under this Privacy Policy and its agreements and (ii) have been appropriately and periodically trained on the requirements applicable to the processing, care and handling of the Personal Data (iii) are under confidentiality obligations as required under applicable law. Masa takes steps to ensure that its staff who have access to personal data are honest, reliable, competent and trained.

Masa shall act in accordance with its policies to promptly notify the relevant authorities and data subjects in the event that any personal data is lost, stolen, or where there has been any unauthorized access to it, all in accordance with applicable law and on the instructions of qualified authority. Masa shall promptly take reasonable remedial measures.

11. GENERAL

Masa aims to process only adequate, accurate and relevant data limited to the needs and purposes for which it is gathered. It also aims to store data for the time period necessary to fulfill the purposes for which the data is gathered. Masa only collects data in connection with a specific legitimate purpose and only processes data in accordance with this Privacy Policy.

In the event of any concerns about data protection practices at Masa, you may contact our data protection office at masadpo@masaisrael.org. EU persons have the right to lodge a complaint with a supervisory authority  in case of a breach of any EU data protection and privacy regulations. If the supervisory authority fails to deal with a complaint or inform you within the time frame set under applicable law, you have the right to an effective judicial remedy.

Minors

Masa is an organisation for young Jewish adults and, as such, does not usually process Personal Data of minors knowingly. In the event that Masa does collect Personal Data about a minor under 17 years old, Masa will process personal data only with the consent of the holder of parental responsibility over the minor. Masa will make reasonable efforts to verify that consent is given or authorised by the holder of parental responsibility of the child.

Changes to this privacy policy

The terms of this Privacy Policy will govern the use of the Services and website and any information collected in connection with them. Masa may amend or update this Privacy Policy from time to time. The most current version of this Privacy Policy will be available at: https://www.masaisrael.org/privacy. We will endeavour to provide notice of material changes to this policy on the homepage of the website or by other means. Material changes will take effect seven (7) days after such notice was provided. Otherwise, all other changes to this Privacy Policy are effective as of the stated “Last Revised” date and your continued use of Services will constitute your active acceptance of, and agreement to be bound by, the changes to the Privacy Policy.

If you have any questions or comments concerning this Privacy Policy, you are welcome to send us an email or otherwise contact us at masadpo@masaisrael.org and we will make an effort to reply within a reasonable timeframe.