1. INTRODUCTION

We at Profimex LTD, are committed to respecting our customers’ and their users’ (candidates and/or employees) privacy, protecting their Personal Data and making sure it is used properly by us.

This Policy explains our privacy practices for processing Personal Data on our Services and Platform. We process your Personal Data subject to the terms of this policy.

You can access our full Policy policy below to help you understand better how we use your Personal Data. In it, we explain in more detail the types of Personal Data we collect, how we collect it, what is legal basis of collection, what we may use it for, who we may share it with, what our retention periods and are and what are your rights in relation to the Personal Data we collect.

FULL PRIVACY POLICY

Profimex LTD provides this Privacy Policy (“Policy”) to inform you of our policies and procedures regarding the collection, use and disclosure of information we receive when you use our infromation processing services. By using the Services you agree to be bound by the terms of this Policy and you hereby agree and confirm that you will not have any claims or demands with respect to the Policy.

  1. DEFINITIONS 

“Personal Data” means any details, data or information which may personally identify you or may be used to identify you as an individual, such as your ID number, picture and Registration Data

“Non Personal Data” means any details, data or information that does not personally identify you and does not reveal your specific identity as an individual and/or cannot be attributed to you, such as anonymized information.

“Content” means any Personal Data or Non Personal Data collected or uploaded into the Platform, either by you, your Employer or us.

“GDPR” means the General Data Protection Regulation (EU) 2016/679.

“Applicable Laws” means privacy laws and regulations which may be applicable to you, the Platform or the Services, as may be amended from time to time, including – to the extent applicable – the GDPR.

  1. WHEN DOES THIS POLICY APPLY

This Policy applies to Personal Data about you that we collect, use or otherwise process regarding your relationship with us when you register to or use our Service or Platform, contact our representatives or service desk. This Policy does not apply to services that have separate privacy policies that do not incorporate this Policy.

  1. DATA COLLECTION

In the course of using our services, you or your Employer may provide us with certain information relating to you, including without limitation Registration Data, public information that we collect as part of the Services, data that is provided by your Employer and information related to you that is added to the Services through any interface or mechanism, third parties sites, such as Facebook and LinkedIn, or any other means detailed in this Policy.

The Content shall include both Personal Data and Non Personal Data, and both data that you provide us or those we otherwise legally obtain (as such terms are defined below).

  1. PERSONAL DATA

You should note that we may collect the following categories of Personal Data : your name, address, email address, telephone number, current position at the Employer, skills, professional history (positions), educational history, user photo (avatar), military experience, career development desires (salary, tech stack, perks, partiality of position, active/passive seeker, open to remotes and/or relocation offers), volunteering history, projects history, resume (CV), professional connections, social and professional connections, username and password for registration, IP address, operating system. Personal Data collected may be provided by you, your Employer or collected by us from publicly available sources.

We will receive Personal Data from you through the Registration Data. In addition, we may receive Personal Data about you from third parties, such as companies contracted by us to provide the Services to you, our customer – which is your Employer, or companies who provide details to us under privacy polices providing information to be shared with us.

Your representations regarding Personal Data you provide. By using the Platform or the Services, you hereby warrant and represent that: (i) such Personal Data is yours; (ii) you have the legal right to provide us such Personal Data; (iii) to the extent the Personal Data was obtained from a third party, it was lawfully obtained in compliance with all applicable laws; (iv) you grant us a license to use the Content, and provide your specific, informed freely given and unambiguous consent for the use of the Content, including Personal Data from your social media accounts and from your personal files and HR systems used by your Employer, by us (and/or third parties on our behalf as detailed in this Policy) for the Purpose set forth in the Terms and Conditions; (v) the Personal Data is complete, accurate and true; and (vi) the Personal Data may be stored in our database(s), anywhere in the world.

  1. NON PERSONAL DATA

We may collect Non Personal Data in the following ways:

The ways we collect Personal Data.

Information that your browser sends when you use our Services (“Log Data”). This Log Data may include, but is not limited to, your computer’s Internet Protocol address, location, browser type, the web page you were visiting before you access the Services and information you search for using the Services.

We use permanent first party “cookies” to collect information. A cookie is a small data file that we transfer to your computer’s hard disk for record-keeping purposes. We use “session ID cookies” to enable certain features of the Services, to better understand how you interact with the Services and to monitor web traffic routing and aggregate usage of the Services. You can instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from the website you visit. If you do not accept cookies, however, you may not be able to use all portions or all functionality of the Services.

We may use GIFs in order to collect information. Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web pages.

We may use automated devices and applications, such as Google Analytics, to evaluate usage of our Services. We use these tools to help us improve our Services, performance and user experience. We may also engage third parties to track and analyze Services data or provide other services on our behalf. Such third parties may combine the information that we provide about you with other information that they have collected from other sources. This Policy does not cover such third parties’ use of the data and such use is governed by such third parties’ privacy policies.

Other websites and applications may also place or read cookies on your computer’s browser. Please see below the section “DATA SHARING AND DISCLOSURE”.

By using the Services and when you provide us Non Personal Data, you hereby acknowledge and consent that Non-Personal Data will be considered as non-confidential, non-proprietary, and unprotected.

  1. CONSENT AND LICENSE TO USE INFORMATION

According to Applicable Laws, you hereby acknowledge that you are not legally required to provide us with any Content, and the provision of it is solely based on your free will. Personal Data received from your Employer is based on the consents you have provided directly to your Employer or on your Employer’s legitimate interests or performance of your Employer’s contract with you. However, you acknowledge that we will not be able to provide you or your Employer with the Services without receiving your Content.

We do not claim ownership of the Personal Data provided to us in the use of the Services and we serve only as a Processor of such Personal Data. However, by using the Services and when you provide us with Personal Data and Non Personal Data, you hereby freely grant us an irrevocable, royalty-free, non-exclusive, unlimited license and specific informed consent to use and process the Personal Data and the Non Personal Data (each obtained in any manner detailed in this Policy) and transfer it to third parties in accordance with the terms of this Policy and the Terms and Conditions.

However, Profimex LTD owns all Personal Data collected or obtained by us (as opposed to Personal Data provided by you or your Employer) and any Non Personal Data collected or obtained by us, including but not limited to Personal Data that has been anonymized.

  1. HOW WE USE PERSONAL DATA

Personal Data is used for the following primary purposes (as may be updated from time to time): (i) to provide the Services, including, without limitation, opening your profile, creating your Platform account and profile and disclosure of such profile (including Personal Data and Non Personal Data) to such persons designated by your employer and its group or alliance for the Purpose and Services, (ii) to transfer Personal Data to your Employer for the Purpose and in order to update your personnel file or other legitimate processing by your Employer, ( (iii) for the technical administration and troubleshooting of the Services and to provide support and maintain the Services.  

We may use your email address to contact you when necessary, including in order to send you reminders, offers and to provide you information and notices about the Services. Note that we may include commercial and marketing information in such emails. If you do not wish to receive commercial and marketing emails, please see the Section titled “ADVERTISING AND MARKETING MATERIAL; CHOICE”.

  1. THE LEGAL BASIS FOR USE OF DATA

We will only process your Personal Data where we have a legal basis to do so. The legal basis will depend on the reason or reasons we collected and need to use your data. In almost all cases the legal basis will be:

  • To provide the Services and otherwise perform our agreement we have with you or our client (your employer).
  • There is a legitimate interest to use your Personal Data in relation to our Services.
  • To comply with a legal obligation.
  • Because you consented to us using your data for a particular purpose.

It is hereby clarified that the legal bases detailed above are the legal bases for actions to process Personal Data, carried out by us in accordance with the GDPR. If processing of Personal Data is subject to other applicable laws, then the legal basis for processing Personal Data may differ according to those applicable laws. 

  1. ACCESSING, REVIEWING, AMENDING AND DELETING YOUR PERSONAL DATA

At any time you have the right to review your Personal Data stored in our database, and also update, amend and/or delete your related Content. by sending a request to: Profimex@profimex.com .

Under your right of access, you may obtain confirmation from us of whether we are processing Personal Data related to you, receive a copy of that data, so that you could verify its accuracy and the lawfulness of its processing, request the correction, amendment or deletion of the data if it is inaccurate, incomplete, outdated or processed in violation of applicable law.

However, we may retain certain information as deemed required by Applicable Laws, or for legitimate business reasons, for the duration as required under Applicable Laws.  

In addition, we may delete any Personal Data pursuant to our policies as then in effect.

When you ask us to exercise any of your rights under this Policy and Applicable Law, we may need to ask you to provide us certain credentials to make sure that you are who you claim you are, to avoid disclosure to you of Personal Data related to others and to ask you questions to better understand the nature and scope of data that you request to access.

We may redact from the data which we will make available to you, any Personal Data related to others.

  1. DATA SECURITY

We are concerned with safeguarding your Content. We employ a variety of measures designed to protect your Content from loss, theft, damage, unauthorized access or use and disclosure when it is in our possession or control, including reasonable physical, technical and organizational measures which restrict access to the Content. These measures provide sound industry standard security.  However, although we make efforts to protect your privacy, we cannot guarantee that the Services or Platform will be immune from any wrongdoings, malfunctions, unlawful interceptions or access, or other kinds of abuse and misuse.

You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private. In addition, you should take steps to protect against unauthorized access to Personal Data stored on your devices.

If you receive an e-mail asking you to update your information with respect to the Service, do not reply and please contact us at: Profimex@profimex.com .

  1. PROCESSING OR TRANSFER

We use third party services in providing the Services to you, such as cloud or internet-based hosting and data processing solutions, messaging solutions embedded in our Services (e.g. intercom.com) or products intended to improve user experiences from our Platform (e.g. fullstory.com). Such third party services are subject to confidentiality obligations and may use your Content only for fulfilling their obligations to us in line with the Purpose.

We do not sell, rent or lease your Personal Data. We may share your Personal Data with your Employer or anyone else to whom you have explicitly and freely consented we provide such Personal Data.

We may also share Personal Data with companies or organizations affiliated with us, such as subsidiaries and parent companies, with the express provision that their use of such Personal Data must comply with this Policy.

Additionally, a merger, acquisition or any other structural change may require us to transfer your Personal Data to another entity, provided that the receiving entity will comply with this policy.

  1. TRANSFER OF DATA OUTSIDE YOUR TERRITORY

We may store, process or maintain Content in various sites worldwide, including through cloud based service providers worldwide. If you are located in a jurisdiction where transfer of your Personal Data to another jurisdiction requires your consent, then you provide us your express and unambiguous consent to such transfer or the storage, processing or maintenance of the Content in other jurisdictions by using the Services. We will ensure in our agreements with those third parties that the third party will have at least the same levels of protection as detailed under this Policy, and if they do not, we will, inter alia, be able to delete Personal Data received by such third parties.

  1. DATA RETENTION

We retain different types of data for different periods, depending on the purposes for processing the data, our legitimate business purposes as well as pursuant to legal requirements under the Applicable Law.

We will need to keep Personal Data for as long as necessary to support the purposes of processing under this Policy which is at least as long as you use our services, unless we are required by Applicable Law to delete it, or if you exercise your data subject rights to delete the Personal Data. We will normally handle the retention of Personal Data as follows:

  • After 12 months the Personal Data will be moved to an offline storage. 
  • After 30 months Personal Data will be deleted.         
  • First 12 months Personal Data will be accessed by relevant functions (Recruiters, Area , Global Managers,)
  • After 12 months Personal Data will be accessed per request by country and global HR managers.
  • Video data is not stored or processed.
  • Photograph of the candidate during the test activity is stored for a month then deleted.
  • Photocopy of identity card is stored for a month then deleted.
  1. CHANGES TO THIS POLICY

We may change the terms of this Policy from time to time by posting notice on our Services (including the special webpage dedicated to the Services at: https://profimex-invest.de/privacy-policy/ with a five (5) day advance notice. However, substantial changes will be effective thirty (30) days after the notice was initially posted. We will make an effort to inform you of substantial changes through the channels of communication generally used in such circumstances, and subject to the requirements of applicable laws – to obtain your consent.

If we need to adapt the Policy to legal requirements, the amended Policy will become effective immediately or as required.

Registering and using our Services or your continued use of the Services following such notice shall constitute your consent to any changes made and you hereby waive any claim or demand against Gloat with respect to such changes. If you do not agree to the new or different terms, you should not use and are free to discontinue using the Services.

  1. APPLICABLE LAW AND DISPUTE RESOLUTION

This Policy shall be governed by and construed in accordance with the laws of the state of Israel, excluding its choice of law principals.

Disputes arising in connection with this Policy shall be subject to the exclusive jurisdiction of the competent courts in Tel-Aviv, Israel.

  1. CONTACTING US

f you have any concerns or questions about this Policy, please contact us at: Profimex@profimex.com