Privacy Policy
The following statement sets out details of the policy adopted by Comsec Ltd (the “Company” or “We”) to gather and disseminate information (the “Privacy Policy”).
The Privacy Policy outlines the types of personal and non-personal data (as defined below) that We gather about individuals, how We collect and make use of such data, including saving, processing and sharing the data with third parties, etc.
Whenever in this Privacy Policy we refer to “you” or “yours”’ the intention is to all users who make use of the Website and the personal data and non-personal data (as defined below) which refers to him or her.
We collect personal data and non-personal data (as defined below) through the Website )www.comsecglobal.com) (the “Website”) operated by us from which you are accessing this Privacy Policy .
By using the Website, you agree to this Privacy Policy. Please read this Privacy Policy carefully. If you do not agree with this Privacy Policy, do not access or use our Website.
The Company is the data controller in respect of the processing activities outlined in this Privacy Policy.
You are aware that your Personal Data as defined below, may be stored on Company’s database and that providing the Personal Data is subject to your wish and your consent. However, if you do not provide us with the Personal Data that we request, or prohibit us from collecting such Data, we may not be able to provide you with the services.
Collection of Personal and Non Personal Data
- When you make use of our Website, we collect the following types of information, which may also include individually identifiable information that identifies you as an individual or relates to an identifiable individual or may – with reasonable effort – identify an individual (“Personal Data”). In addition we collect data that does not reveal your individual identity or does not relate to an individual directly (“Non Personal Data“)
- When you request information from us, make an inquiry regarding our products and services or contact us for any other reason, we will collect Personal Data about you so that we can communicate with you and respond to your request or inquiry, and to manage our relationships with our clients, potential clients and business partners. Such Personal Data may include your name, e-mail address, phone numbers, the company you work for, the content of your inquiry, the Internet Protocol address (“IP”) related to the electronic device from which the request is sent, etc.
- When you visit our Website, we will collect Personal Data from your device, such as IP address and other online identifiers (i.e. online data collected from the user’s devices and protocols). In addition, we will automatically collect Non Personal Data such as your mobile module, your operating system version, device time zone, device language etc. We use this information to optimize your experience and to help us to improve our Website and the ways we communicate with you.
- When you contact us about an employment opportunity on the Website, we will collect and use Personal Data about you in order to help assess your skills and your suitability for the relevant position. We may also use such data to contact you in regard to a specific job opportunity. Such Personal Data may include your name, email address, CV, telephone number, employment history and other data.
- By analyzing the information we receive, including all information concerning users, we may compile statistical information (“Statistical Information“). Statistical Information is anonymous and aggregated and we will not link Statistical Information to any Personal Data.
- In addition, we use analytics tools, including “Google Analytics” to collect information about the use of the Website. Such tools collect information such as how often users visit the Website, what pages they visit when they do so, and what other sites and mobile applications they have used prior to visiting the Website. We use the information we get from the tools to improve our Website. Google Analytics Terms of Service can be found at: https://marketingplatform.google.com/about/analytics/terms/us/ and the Google Privacy Policy can be found at: https://policies.google.com/privacy?hl=en-US
- In some instances, we may combine Non Personal Data with Personal Data. If we do so, we will treat the combined data as Personal Data as long as it is combined.
- If you submit any Personal Data about other people to us or to our service providers, you are representing that you have the authority to do so and that you are permitting us to use the Data in accordance with this Privacy Policy.
Use of Personal Data
9. We use Personal Information as described in this Privacy Policy for the following purposes
9.1. To identify and authenticate your access.
9.2. To conduct analytics in order to improve and customize our Website and the ways we communicate with you.
9.3. To present you and your company with business opportunities regarding our products and services.
9.4. To support our services, to respond to your queries and to conduct surveys. We will contact you through email, phone calls, and other ways.
9.5. To send you marketing communications, updates and newsletters and present personalized content (“Marketing Communications”). Please note that by providing us with your Personal Data, you hereby agree that we may use the data for marketing and promotional purposes and send you Marketing Communications by email, post, telephone, text messages (SMS) and through other communication channels such as social media platforms.
You may withdraw your consent at any time by sending us written notice by email to the following address: marketing@comsecglobal.com or by pressing the “Unsubscribe” link at the bottom of each of our Marketing Communications.
Please note that even if you unsubscribe from our Marketing Communications, we may still use your Personal Data for non-marketing purposes (for example to fulfill your requests, respond to your inquiries, etc.).
9.6. To manage your application for a job position (as applicable);
9.7. To investigate violations and enforce our policies, and as required by law, regulation or other governmental authority, or to comply with legal process or in response to a government request.
Legal Basis for Using Personal Data
10. We will collect, use and share your Personal Data where we are satisfied that we have an appropriate legal basis to do this. This may be because:
10.1. We need to use your Personal Data to perform a contract or take steps to enter into a contract with you. For example, when you provide your information to us in order to apply for a job position.
10.2. We need to use your Personal Information for our legitimate interest as a commercial organization. For example, we may collect your Personal Data in order to communicate with you and present you marketing materials and opportunities regarding our products and services. You may withdraw your consent at any time as detailed in this privacy policy.
10.3. We need to use your Personal Data to comply with a relevant legal, regulatory obligation to which we are subject.
10.4. We have your consent to use your Personal Data.
Disclosure of Personal Data and Non Personal Data
11. We share your information, including Personal Data, with the following:
11.1. Service providers and suppliers who assist us in providing services. Examples of such service providers and suppliers are: IT service providers, legal advisers, accountants, suppliers of payment services, data analysis, social media services etc.;
11.2. Our marketing and advertising partners, in order to provide you with more relevant advertising on our Website and to encourage you to return to our Website.
11.3. We may disclose and transfer your Personal Data to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of the Company’s business and assets (including in any bankruptcy or similar proceedings).
11.4. We may disclose and share your Personal Data with our affiliates. For example, when you provide your information with us in order to apply to a job position offered by one of the affiliates. Currently our affiliates are Comsec UK and Comsec BV.
11.5. We may share your Personal Data with third parties: (a) when required by law, regulation, court order or other law enforcement; (b) if we believe that disclosure is appropriate to protect our and/or a third party’s rights, property or safety (including the enforcement of this Privacy Policy); (c) as is necessary to comply with any legal and/or regulatory obligation.
How You Can Access, Change, or Limit the Use of Your Personal Data
12. If you reside in the European Union, you have certain rights under European Data Protection Law with regard to your Personal Data. You have the right to:
12.1. Request access to your Personal Data (commonly known as a “data subject access request”). This enables you to receive a copy of the Personal Data we hold about you and to check that we are processing it lawfully.
12.2. Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
12.3. Request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to keep and/or process it. You also have the right to ask us to delete or remove your Personal Data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your Personal Data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which, if applicable, will be notified to you at the time of your request.
12.4. Object to the processing of your Personal Data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you wish to object to processing on this ground, as you believe that it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
12.5. Request restriction of the processing of your Personal Data. This enables you to ask us to suspend the processing of your Personal Data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it, as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your Data but we need to verify whether we have overriding legitimate grounds to use it.
12.6. Request the transfer of your Personal Data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
12.7. Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you.
12.8. To lodge a complaint to a supervisory authority.
13. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances
14. We may need to request specific information from you to help us confirm your identity and to ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
15. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or if you have made a number of requests. In this case, we will notify you and keep you updated.
16. If you reside anywhere outside the European Union (including Israel) your rights to review, edit or amend Personal Data held on our Databases will be in accordance with applicable Israeli law, including the provisions of the Protection of Privacy Law, 5741-1981.
Security
17. The security and confidentiality of your Personal Data is extremely important to us. We implement reasonable administrative, organizational and technical safeguards and security measures to protect Personal Data from unauthorized access, disclosure, destruction or alteration, accidental loss, misuse or damage. We regularly review and monitor such safeguards and security measures.
18. Please keep in mind that no method of transmission over the Internet, or method of electronic storage, is 100% secure. As a result, although we strive to protect your Personal Data, we cannot promise or guarantee that such information will be immune from any wrongdoing, malfunction, unlawful interception or access, or other kinds of abuse and misuse.
19. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contact Us” section, below.
Retention
19.1. To the extent permitted by applicable law, we will retain your Personal Data for such period as is necessary to satisfy or to fulfill the following:
19.1.1. The purposes for which that Personal Data was provided;
19.1.2. An identifiable and ongoing business need, including record keeping;
19.1.3. A requirement to retain records that may be relevant to any notified regulatory investigations or active legal proceedings;
19.1.4. To comply with any applicable law, regulation or legal process, including, without limitation, court orders and/or compulsory disclosures required by governmental authorities.
19.2. Please note that we may store your Personal Data for longer periods of time, for instance where we are required to do so in accordance with legal and/or regulatory requirements and in order that we will have an accurate record of your dealings with us in the event of any complaints or challenges, or if we believe that we need to store your Personal Data in order to fulfill the legitimate interests of the Company and third parties, such as, to provide a defense in the case of legal procedures, etc .
Sensitive Data
20. Unless specifically requested, we ask you not to disclose any Sensitive Personal Data (e.g., social security numbers, national identification number, data related to racial or ethnic origin, political opinions, religion, ideological or other beliefs, health, biometrics or genetic characteristics, criminal background, trade union membership, or administrative or criminal proceedings and sanctions).
Minors
21. Our services and products as well as our Website are not directed to children under age of 18. We do not knowingly collect Personal Data from any individuals under the age of 18. In the event that you become aware of our collection of Personal Data of an individual under the age of 18 who has used our Website and/or our services without parental permission, please update us immediately.
Updates
22. We are entitled to change and update this Privacy Policy from time to time, at our sole discretion, without having to provide notice thereof. Responsibility for being acquainted with the changes, if any, made to and/or by this Privacy Policy, rests with you alone.
Cookies
23. Our Cookie Policy is available at: https://comsecglobal.com/cookie-policy/
Data Protection Officer (“DPO”)
24. In matters pertaining to European laws for the protection of privacy, our DPO can be reached at: dpo@comsecglobal.com
Contact Us
25. If you have any questions about this Privacy Policy or our privacy practices, please contact us at: dpo@comsecglobal.com
Governing Laws
26 .Use of the Website and/or the services, and this Privacy Policy, is subject to the laws of Israel. The sole jurisdiction for any matter and/or dispute relating to issues of privacy regarding the Website and any content available through the Website will be exclusively subject to the jurisdiction of the competent courts in Tel Aviv, Israel.
