MRJ People-Tech Ltd. (“Emerj,” or “us,” “our,” “we“) recognizes and respects the importance of maintaining the privacy of its Users and, as a result, has established this Privacy Notice. This Privacy Notice describes the types of information we collect and how we may use, process, transfer, store, and disclose the information collected through the Platform and/or Services, as well as your ability to control certain uses of the collected information. If not otherwise defined herein, capitalized terms have the meanings given to them in the Terms of Service, which is available at http://emerj-work.com/pp.pdf (the “Terms“). The use of the Platform and/or the Services is subject to the Terms and this Privacy Notice.
Emerj is the data controller in respect of certain processing activities outlined in this Privacy Notice related to processing details of Administrators. Our registered office is 7 Harav Levin Mereisha, Bnei Brak, Israel and our registration number is 515564169. Our representative in the European Union is Delia Levy. Her contact details are: Mobile phone: +41774885978, home phone : +41442018750, email: [email protected], address: Stauffecher Quai 58 Zurich 8004 Switzerland. In addition, Emerj serves as a processor of data relating to Users on behalf of the applicable Company.
“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.
- Privacy Notice Key Points
The key points listed below are presented in further detail throughout this Privacy Notice. These key points do not substitute the full Privacy Notice.
- Personal Data We Collect. When you register, we collect Personal Data provided by you, such as your full name, e-mail address, job function, department in which you work, and a picture. Additionally, we will collect Personal Data relating to the Users and/or Administrator(s) and their use of the Platform, which may, subject to your explicit consent, include of Special Categories of Data (as defined in the Terms). We also (automatically) collect information about your use of the Platform and Services. If you contact us for questions or complaints, we will collect the information related to your inquiry.
- How We Use Information. We use the information (including Personal Data) we collect mainly to administer and provide the Platform and Services, contact you with administrative information, and improve the Platform and Services.
- Basis for Processing Your Personal Data. Processing your Personal Data is necessary for the performance of the Terms and the provision of the Services to you. Processing for the purposes of developing and enhancing new features and our products and services, for analytics and usage analysis, for fraud prevention and security and for our recordkeeping and protection of our legal rights – are all necessary for the purposes of legitimate interests that we pursue.
- Disclosure of Information. We may share the Personal Data we collect with our service providers and subcontractors who assist us in the operation of the Platform and process the information on our behalf and under our instructions.
- International Transfer. We may use service providers and/or subcontractors and/or cooperate with or have business partners and affiliates located in countries other than your own, and send them your Personal Data. We will ensure to have agreements in place with such parties ensuring the same level of privacy and data protection as set forth in this Privacy Notice. You hereby consent to such international transfer.
- Retention. We retain information for as long as necessary for the purposes set forth in this Privacy Notice.
- Security. We implement industry standard measures aimed at reducing the risks of damage and unauthorized access or use of Personal Data, but they do not provide absolute information security.
- How to Access and Limit Our Use of Certain Information and User Rights. Subject to applicable law and additional rights as set forth below, you may have a right to access, update and/or delete your Personal Data and obtain a copy of the Personal Data we have collected about you.
- Changes to the Privacy Notice. We may change this Privacy Notice from time and shall notify you of such changes.
You are under no obligation to provide us with any Personal Information and provision of such information is entirely at your discretion and with your consent, however, if you do not consent to provide such information, you may not be able to register to the Platform and/or use (a portion of) the Services.
Personal Data We Collect
We collect information from anyone who utilizes the Platform and/or Services, including any information provided by you or by an Administrator when utilizing the Platform and/or Services. In order to utilize our Services, you will be required to register an account and provide us with certain Personal data, , including your full name, e-mail address, job function, department in which you work, and a picture. We may also collect Personal Data when Users or Administrator(s) utilize the Platform and/or Services, request information from us, sign up for newsletters or our email lists, complete online forms, or contact us for any other reason. Subject to your explicit consent, personal data you upload to the Platform may include Special Categories of Data.
In addition to the Personal Data detailed above, certain information may be automatically gathered about your computer or mobile device, such as operating system, IP address, or browser.
Please note that we do not collect records of any specific conversations held between Users through the Platform’s chat function. However, for our records we may retain information relating to the topic(s) discussed during each such chat on the Platform, the Users involved, the wording of a Requesting User’s question, the length of the conversation, the chosen Advising User, and certain keywords related to the question.
How We Use Information
Emerj and/or any of its trusted third-party subcontractors and service providers may use the Personal Data collected from and/or about you for any of the following purposes: (1) to provide the Services to you and to the Participating Company; (2) to develop and optimize new services and conduct analyses to improve our current content, products, and services; (3) to respond to your inquiries or requests, contact and communicate with you; (4) to review the usage and operations of our Platform and Services; (5) to use your data in an aggregated, non-specific format for analytical purposes (as detailed below); (6) to prevent fraud, protect the security of our Platform and Services, and address any problems with the Platform and/or Services; (7) to maintain our records and protect our legal rights and (8) to provide customer support.
By analyzing all information we receive, including all information concerning Users, we may compile statistical information across a variety of such platforms and Users (“Statistical Information“). Statistical Information helps us better understand trends and Users’ needs such that new products and services may be considered and such that the Platform and Services may be tailored to the needs and preferences of Users and the Participating Company. Statistical Information is anonymous and aggregated and we will not link Statistical Information to any Personal Information. We may share such Statistical Information with the Participating Company or our business partners, without restriction, on commercial terms that we can determine at our sole discretion.
Basis for Processing Your Personal Data
Processing your Personal Data is necessary for the performance of the Terms and the provision of the Services to you, including responding to your inquiries or requests, contacting and communicating with you and providing customer support.
Processing for the purposes of analytics and usage analysis, for fraud detection and prevention, for our recordkeeping and protection of our legal rights, compliance with legal and regulatory requirements, network and information security, and product development and enhancements – are all necessary for the purposes of legitimate interests that we pursue.
Disclosure of Information
We may use and share your information, including Personal Data, as follows:
Business Partners, Service Providers, Affiliates, and Subcontractors
We may disclose information, including Personal Data we collect from and/or about you to the Participating Company for the purpose of providing the Services, or to certain service providers, subcontractors, affiliates and business partners (together with the Participating Company, “Authorized Third Parties“), who may use such information to: (1) help us provide you and the Participating Company with the Services and (2) to aid in the understanding of how Users are utilizing our Platform and Services.
Authorized Third Parties may be located in countries other than your own. All Authorized Third Parties will be subject to written agreement ensuring the same level of privacy and data protection as set forth in this Privacy Notice. You hereby consent to such international transfer.
We may transfer our databases containing your Personal Data if we sell our business or part of it, including in cases of liquidation. Information about our users, including Personal Data, may be disclosed as part of, or during negotiations of merger, sale of company assets or acquisition and shall continue being subject to the provisions of this Privacy Notice.
Law Enforcement Related Disclosure
We will fully cooperate with any law enforcement authorities or court order requesting or directing us to disclose the identity, behavior or digital content of any user suspected to have engaged in illegal or infringing behavior. We may also share your Personal Data with third parties (i) if we believe in good faith that disclosure is appropriate to protect our rights, property or safety (including the enforcement of the Terms and this Privacy Notice); (ii) or to protect the rights, property or safety of third parties; (iii) when required by law, regulation subpoena, court order or other law enforcement related issues; or (iv) as is necessary to comply with any legal and/or regulatory obligation. You can request such Personal Information as specified herein by emailing us at [email protected].
We keep the collected information as long as it remains necessary to provide our Users with access to and use of the Platform and Services, comply with our legal obligations, resolve disputes, or enforce our agreements and as necessary for the purposes set forth above. We may delete information from our systems, without notice to you, once we deem it is no longer necessary for the purposes set forth herein.
How We Protect Information
We make efforts to follow generally-accepted industry standards to protect the Personal Data submitted to and collected by us, both during transmission and once we receive such information. The physical, electronic, and procedural safeguard we employ to protect your data are in accordance with our legal data protection requirements. For example, we have implemented certain specific technologies and procedures that are designed to protect your privacy, such as secure servers, encryption of personal data, ongoing reviews of security measures, secure coding, redundancy and backup facilities, and regular security testing. 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.
Cookies and Similar Technologies
What are Cookies?
A cookie is a small piece of text that is sent to a user’s browser or device. The browser provides this piece of text to the device of the originating user when this visitor returns.
- A “session cookie” is temporary and will remain on your device until you leave the website.
- A “persistent” cookie may be used to help save your settings and customizations across visits. It will remain on your device for much longer or until you delete it.
- First-party cookies are placed by us, while third-party cookies may be placed by a third party. We use both first- and third-party cookies.
- Information may also be collected through web beacons, which are small graphic images (“pixel tags”), which usually work together with cookies in order to identify users and user behavior. These may be shared with third parties.
We may use the terms “cookies” to refer to all technologies that we may use to store data in your browser or device or that collect information or help us identify you in the manner described above.
The specific names and types of the cookies, web beacons, and other similar technologies we use may change from time to time. However, the cookies we use generally fall into one of the following categories:
|Type of Cookie||Why We Use These Cookies|
|Necessary||These cookies are necessary in order to allow the Platform to work correctly. They enable you to access the Platform, move around, and access different services, features, and tools. Examples include remembering previous actions (e.g. entered text) when navigating back to a page in the same session. These cookies cannot be disabled.|
|Functionality||These cookies remember your settings and preferences and the choices you make (such as language or regional preferences) in order to help us personalize your experience and offer you enhanced functionality and content.|
|Security||These cookies can help us identify and prevent security risks. They may be used to store your session information to prevent others from changing your password without your login information.|
|Performance||These cookies can help us collect information to help us understand how you use our Platform, such as whether you have viewed messages or specific pages and how long you spent on each page. This helps us improve the performance of our Platform.|
|Analytics||These cookies help us learn more about which features are popular with our users and how our Platform can be improved.|
How to Adjust Your Preferences
Most Web browsers are initially configured to accept cookies, but you can change this setting so your browser either refuses all cookies or informs you when a cookie is being sent. In addition, you are free to delete any existing cookies at any time. Please note that some features of the Services may function improperly when cookies are disabled or removed.
Third Party Cookies
Mixpanel places an Analytics cookie.
Subject to your consent and applicable law, we may send you e-mails and/or other messages about us or the Platform and/or Services, including service announcements and administrative messages, relating either to your account or to your use of the Platform and/or Services. By accepting this Privacy Notice or using the Platform and/or Services you affirmatively consent to receive such communications.
You may remove your Personal Data from our mailing list and stop receiving future communication from us by following the UNSUBSCRIBE link located at the bottom of each communication or by emailing us at [email protected] You will also be given the opportunity to unsubscribe from commercial messages in any such e-mail or message we send. Please note that 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 you may terminate your account.
How to Access and Limit Our Use of Certain Information and User Rights
You have a right to know what information we or other controllers hold about you, as detailed below. For any requests to exercise such rights with respect to information held by other controllers, please contact the applicable controller directly. 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 and Data Portability. You have a right to know what Personal Data we collect about you and, in some cases, to have the information communicated to you. Subject to the limitations in applicable law, you may be entitled to obtain from us a copy of the Personal Data you provided to us (excluding information that we obtained from other sources) in a structured, commonly-used, and machine-readable format, and you may have the right to (request that we) transmit such Personal Data to another party. If you wish to exercise this right please contact us letting us know what information in particular you would like to receive and/or transmit. 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, for instance, if the information includes Personal Data about another person. Where we are not able to provide you with information that you have asked for, we will endeavor to explain to you why. We will try to respond to any request for a right of access as soon as possible.
- Right to Correct Personal Data. Subject to the limitations in applicable law, you may request that we update, correct or delete inaccurate or outdated Personal Data and/or that we suspend the use of Personal Data, the accuracy of which you may contest, while we verify the status of that Personal Data. We will correct your Personal Data within a reasonable time from the receipt of your written request thereof.
- Deletion of Personal Data (“Right to be Forgotten”). In certain circumstances you have a right to have Personal Data that we hold about you deleted. Should you wish to have any Personal Data about you deleted, please contact us, using the contact information specified in this Privacy Notice. Subject to applicable law, we will delete Personal Data provided to us by a user within a reasonable time from the receipt of a written (including via email) request by such user to delete such collected Personal Data. 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 terminate your account with us and clear our cookies from any device where you have used our App. We may retain certain Personal Data (including following your request to delete) for audit and record-keeping purposes, as well as other purposes, all as permissible and/or required under applicable law. We may also retain your information in an anonymized form.
- Account Deactivation. You can ask us to deactivate your account by contacting us using the information below. In order to deactivate your account, we may ask you for additional information.
- Right to Object. Subject to applicable law, you may have the right to object to processing of your Personal Data for certain purposes.
- Supervisory Authority. If you are a European Citizen, you may have the right to submit a complaint to the relevant supervisory data protection authority.
By using our Platform, you automatically accept the terms of this Privacy Notice. If you do not agree with the terms, please do not use the Platform associated with such terms. We reserve the right to update this Privacy Notice from time to time at our sole discretion. We will notify you of any changes and require you to click “I agree” to signify your consent to the amended Privacy Notice. If you do not agree with the terms hereof (including any amendments hereto), please do not click the button marked “I agree” or use the Platform and/or any Services.
We do not knowingly collect Personal Information from or market to children under the age of 13. In the event that you become aware that an individual under the age of 13 has enrolled without parental permission, please advise us immediately.
Users and the Administrator(s) must all be above the age of eighteen (18).
Comments and Questions
If you have any comments or questions about our privacy notice, please contact us at [email protected].
Last updated: July 2018