Jeeng (PowerInbox Ltd., PowerInbox Inc. and any and all subsidiaries, together: “Jeeng”, “we”, “us”, “our”) respects the privacy of its customers, employees and candidates, and is committed to protecting the personal information you share with us. We also protect the privacy of our website visitors, followers, vendors, service providers, partners and others who come in contact with Jeeng (these and any others with respect to whom we collect personal data, shall collectively be referred to as “Customers” or “you” or “Data Subjects”).
For the purposes of EU’s General Data Protection Regulation (“GDPR”) and other applicable data protection law, (together, the “Data Protection Law”), Jeeng is the Controller of personal data of its employees, candidates and customers.
1. WHICH INFORMATION WE COLLECT
There are several categories of information and data we collect from our Customers.
One type of Data is non-identifiable and anonymous information (“non-personal data”). We also collect several categories of personal data (“Personal Data”). This includes personally identifiable data provided consciously and voluntarily by you, or by an organization you represent or are associated with or through your use of the Services. This may include personal information, such as email and IP address, view, click and conversion history and other information you choose to provide to Jeeng.
Additionally, we may obtain location data related to the geographic location of your laptop, mobile device or other digital device on which the Services are used.
You do not have any legal obligation to provide any information to Jeeng, however, we require certain information in order to perform contracts or 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.
Jeeng also collects the email addresses of people who communicate with Jeeng via email or via messenger services or other social media platforms or create accounts and login credentials.
By registering for the Services, Jeeng will collect details, including also your name, your company name, your phone number and the personal or company email you provided, your address and other such information. Jeeng uses this information to offer the Services and support, and will share this data across Jeeng group companies and affiliates to optimize the Services.
Payments are collected mainly by our payment gateway service provider. During checkout, you will be asked to provide your payment method, your billing information and other contact information. The billing information (such as credit card details) you enter through our payment gateway service provider is not stored on our servers. Similarly, our vendors are paid through our payment facilitator platform, which collects the relevant billing and tax information required for proper payment and store it securely solely on its own servers.
When you use the Services, Jeeng may collect further information, such as session durations, page impressions, advertisements viewed or clicked on, Internet protocol (IP) addresses, the domain name that served you to access the Services, the geographic location of the computer system that you are using to log-in, and content types and origins. Jeeng may also track further information relating to you, when you activate and access the Services, such as the frequency and the extent of your use of the Services.
Jeeng may automatically collect information through the use of log files and other means. If you register with the Services, information gathered may then be personal data. If you are not a registered user, then we will not knowingly make use of any information, which personally identifies you, except as specifically indicated in this policy, or on the Website. Further information may be collected when we exchange communications with you, for example, when you submit an inquiry, or a request, or if our designated copyright agent contacts you.
Jeeng also collects data relating to employees. This is governed by a specific notice we have made available to our employees.
Jeeng also collects data relating to employment candidates. This includes CVs and the data contained therein, notes on meetings, standardized tests, reports, references, interviewer impressions and such industry standard data, as well as collecting data made publicly available or available to us on social networks. We collect such data based on the intention of the candidate to enter into an employment agreement with Jeeng.
2. WHAT ARE THE PURPOSES OF PERSONAL DATA WE COLLECT?
Jeeng will use Personal Data to provide and improve the Services and to meet our contractual, ethical and legal obligations, including for example:
- To enable us to meet our legal, contractual, ethical and business obligations as an employer and a potential employer for our employees and job applicants;
- Carrying out our obligations arising from any contracts entered into between you or your employer or organization and Jeeng and/or any contracts entered into with Jeeng and to provide you with the information and services that you request from Jeeng;
- Administering your account with Jeeng including to identify and authenticate you.
- Verifying and carrying out financial transactions in relation to payments you make in connection with the Services;
- To provide and operate the Services;
- To notify you about changes to the 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, detecting and protecting against error, fraud or other criminal activity;
- To send you updates and notices, to provide you with information relating to the Services, and to provide you with further marketing and advertising material. At any time, you may opt out of the mailing lists by changing your preferences in your personal account.
- Soliciting feedback in connection with your use of the Services;
- Tracking use of the Services to enable us to optimize them;
- 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, customers, facilities etc.;
- If necessary, we will use personal data to enforce our terms, policies and legal agreements and rights, to comply with court orders and warrants and assist law enforcement agencies as required by law, to collect debts, to prevent fraud, infringements, identity thefts and any other service misuse, and to take any action in any legal dispute and proceeding;
- For security purposes;
- To detect and prevent damage to Jeeng, its employees and third parties.
3. HOW WE USE AGGREGATED INFORMATION?
Jeeng may use anonymous, statistical or aggregated information related to the use of the Services, including any aggregated information related to your personal account, and share, publish, post, disseminate, transmit or otherwise communicate or make available such information, to suppliers, business partners, sponsors, affiliates and any other third party, at Jeeng’s sole discretion, provided however, that the information will not identify you personally and that Jeeng will not knowingly, or intentionally use the information to reveal your identity without your consent or another lawful basis, under the terms of this policy.
Jeeng may also use anonymous, statistical or aggregated information to properly operate the Services, to improve the quality and functionality of the Services, to enhance your experience, to create new services, including customized services, to change or cancel existing content or services and for other internal and statistical purposes.
4. SHARING PERSONAL DATA WITH OTHERS
We may transfer Personal Data to:
Members of our Group: This includes also our parent company or our subsidiaries – whether wholly or partially owned by Jeeng, in the EU, in Israel, in the US and elsewhere.
Third Parties: We transfer personal data to third parties in a variety of circumstances. We endeavor to ensure that these third parties use your information 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 include business partners, suppliers, affiliates, agents and/or sub-contractors for the performance of any contract we enter into with you. They may assist us in providing the Services, 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 and our marketing.
We periodically add and remove third party providers. At present, third-party providers to whom we transfer personal data include also the following:
- Website analytics;
- Document management and sharing services;
- Customer ticketing and support;
- On-site and cloud-based database services;
- Vendor and customer Interface;
- Payroll and pension management systems and providers, and other HR management software;
- Time and attendance software;
- CRM software;
- ERP software;
- Project Management system;
- Web Virtual Conferencing and meeting room platforms;
- Call center systems;
- Customer service providers;
- Recruiting and applicant management software and partners;
- Our lawyers, accountants, and other standard business service providers, software and partners.
In addition, we may disclose your personal data to third parties: if some or all of our companies or 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 may 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 and other agreements with you or with a third party; or to assert or protect the rights, property, or safety of Jeeng, our customers, or others. This includes also exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction and to prevent cybercrime.
For avoidance of doubt, Jeeng transfers and discloses non-personal data to third parties at its own discretion.
5. WHERE DO WE STORE YOUR DATA?
We keep Personal Data in servers which will be owned or controlled by Jeeng in our various sites, or processed by third parties on behalf of Jeeng, by reputable cloud-service providers. Including in any and all Jeeng group locations, such as USA, Israel, EU and more.
6. INTERNATIONAL DATA TRANSFERS
- to Israel. PowerInbox Ltd. is based in Israel. Israel is considered by the European Commission to offer an adequate level of protection for the personal information of EU Member State residents; we may transfer data to other countries with an adequacy ruling too; and
- to the United States of America and additional non-EU locations. Transfer to the US and elsewhere is done subject to Standard Contractual Clauses approved by the EU Commission, or some other mechanism valid under GDPR Chapter V; and
- within / to the EU.
- In addition to the above, Jeeng has certified to the EU-US Privacy Shield and the Swiss-US Privacy Shield.
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 fulfill our contract with you;
- Fulfill any legal, audit, ethical or compliance obligations which require us to make that transfer;
- Facilitate the operation of our group businesses, where it is in our legitimate interests and we have concluded these are not overridden by your rights;
- Serve our customers across multiple jurisdictions;
- Operate parent company, subsidiaries and affiliates in an efficient and optimal manner;
- Detect and prevent damage to Jeeng, its employees and third parties, and in accordance with the purposes detailed in part 2 above.
7. DATA RETENTION
Jeeng will retain personal data it processes only for as long as required in our view, to provide the Services and as necessary to comply with our legal and other obligations, to resolve disputes and to enforce agreements. We will also retain personal data to meet any audit, compliance and business best-practices.
8. WEBSITE DATA COLLECTION AND COOKIES
When you access or use our website(s), Jeeng uses 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 from which you connect and in some cases to identify them with the user, and to enable automatic activation of certain features, and make your website experience more convenient and effortless. We use different types of cookies: some cookies are strictly necessary, they are required for the operation of our site(s) and under our terms with you; this includes 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 recognize and count the number of visitors and to see how visitors move around our website when they are using it. Finally, we use functionality cookies which are used to recognize you when you return to our Website. This enables us to personalize content to your preferences, including 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 behavior, 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. Twitter, YouTube and Instagram) are embedded 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.
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 choose to block or erase cookies your online experience on our website(s) will be limited.
How to disable 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 websites may, from time to time, contain links to external sites. We are not responsible for the operation, privacy policies and practices or the content of such sites.
9. SECURITY AND STORAGE OF INFORMATION
We take great care in implementing, enforcing and maintaining the security of the personal data we process. Jeeng 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 nature of the data in question and the risks to data subjects, we may encrypt data. Likewise, we take industry standard steps to ensure our websites are 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.
Jeeng shall act in accordance with its policies and with applicable law to promptly notify the relevant authorities and data subjects in the event that any personal data processed by Jeeng 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. Jeeng shall promptly take reasonable remedial measures.
10. DATA SUBJECT RIGHTS
Data subjects with respect to whose data GDPR applies, have rights under GDPR and local laws, including, in different circumstances, rights to: data portability, access data, rectify data, object to processing, and erase data. It is clarified for the removal of doubt, that where personal data is provided by a customer being the data subject’s employer, such data subject rights will have to be effected through that customer. In addition, data subject rights cannot be exercised in a manner inconsistent with the rights of Jeeng employees and staff, with Jeeng proprietary rights, and third-party rights. As such, job references, reviews, internal notes and assessments, documents and notes including proprietary information or forms of intellectual property, cannot be accessed or erased or rectified. In addition, these rights may not be exercisable where they relate to data that is not in a structured form, for example emails, or where other exemptions apply. If processing occurs based on consent, data subjects have a right to withdraw their consent. In any case, Jeeng will not share your personal identifiable details with any advertisers without your consent.
If, for any reason, a data subject wishes to exercise these rights and modify, delete or retrieve their Personal Data, they may be able to do so by contacting Jeeng (email@example.com). Note that Jeeng has to undertake a process to identify a data subject exercising their rights. Jeeng may keep details of such rights exercised for its own compliance and audit requirements. 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 Jeeng.
Data subjects in the EU have the right to lodge a complaint, with a data protection supervisory authority in the place of their habitual residence. A list of Supervisory Authorities is available here: https://edpb.europa.eu/about-edpb/board/members_en
11. Your Rights Under Privacy Shield: For EU and UK Individuals
With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, Jeeng is subject to the regulatory and enforcement powers of the U.S. Federal Trade Commission.
Pursuant to the Privacy Shield Frameworks, EU individuals have the right to obtain our confirmation of whether we maintain personal information relating to you in the United States. Upon request, we will provide you with access to the personal information that we hold about you. You may also correct, amend, or delete the personal information we hold about you. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data transferred to the United States under Privacy Shield, should direct their query to firstname.lastname@example.org. If requested to remove data, we will respond within a reasonable timeframe.
We will provide an individual opt-out choice, or opt-in for sensitive data, before we share your data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. To request to limit the use and disclosure of your personal information, please submit a written request to email@example.com.
In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
Jeeng’s accountability for personal data that it receives in the United States under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, Jeeng remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process personal data on its behalf do so in a manner inconsistent with the Principles, unless Jeeng proves that it is not responsible for the event giving rise to the damage.
In compliance with the Privacy Shield Principles, Jeeng commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to Privacy Shield. European Union individuals with Privacy Shield inquiries or complaints should first contact Jeeng by email at firstname.lastname@example.org
Jeeng has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU Privacy Shield. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit http://www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint. This service is provided free of charge to you. Under certain conditions, individuals may have the right to invoke binding arbitration.
12. YOUR CALIFORNIA PRIVACY RIGHTS
If you are a California resident, California Civil Code section 1798.83 permits you to request in writing a list of the categories of personally identifiable information relating to third parties to whom we have disclosed certain categories of personally identifiable information during the preceding year, for the third parties’ direct marketing purposes and to obtain such information free of charge up to twice in a 12-month period.
Pursuant to California Civil Code sections 1798.110 and 1798.115, you have the right to request disclosure from Jeeng of the following:
- The categories of personal information Jeeng has collected about you.
- The categories of sources from which the personal information is collected.
- The business or commercial purpose for collecting personal information.
- The categories of third parties with whom the business shares personal information.
- The specific pieces of personal information Jeeng has collected about you.
To make any such requests, please contact us at: email@example.com.
Jeeng will disclose and deliver the required information to a consumer free of charge within 45 days of receiving a verifiable customer request from the customer. Jeeng shall promptly take steps to determine whether the request is a verifiable customer request, but this shall not limit Jeeng’s duty to disclose and deliver the information within 45 days of receipt of the customer’s request. The time period to provide the required information may be extended once by an additional 45 days when reasonably necessary, provided the customer is provided notice of the extension within the first 45-day period.
Pursuant to California Civil Code section 1798.125, Jeeng shall not discriminate against a consumer because the consumer exercised any of the consumer’s rights, including, but not limited to, by:
- Denying goods or services to the consumer;
- Charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
- Providing a different level or quality of goods or services to the consumer;
- Suggesting that the consumer will receive a different price or rate for goods or services or a different level or quality of goods or services.
Minors. We do not knowingly collect or solicit information or data from children under the age of 16 or knowingly allow children under the age of 16 to register for the Services. If you are under the age of 16, do not register or attempt to register for any of the Services or send any information about yourself to us. If we learn that we have collected or have been sent Personal Data or from a child under the age of 16, we will delete that Personal Data as soon as reasonably practicable without any liability to Jeeng. If you believe that we might have collected or been sent information from a minor under the age of 16, please contact us at: firstname.lastname@example.org as soon as possible.
Do Not Sell Personal Information. Jeeng does not sell any data subjects’ personal information.
15. CONTACT US OR OUR DATA PROTECTION OFFICER
You may contact us or our data protection officer, as may be required. Any access requests may be lodged with us at email@example.com.
(Version date of this policy: April 5, 2021)