Privacy Policy
Review date: June 1st 2023
We at SparkBeyond Ltd. (“SB”, “we”, “us”, “our”) respect your privacy. This Privacy Policy (“Policy”) explains the privacy practices for our website at sparkbeyond.com (the “Website”). It also describes the rights and options available to you with respect to your information.
The Website provides content and information about SB, our products and services (“Content”).
Personal data we collect
We collect information you provide us voluntarily and knowingly. You are not legally required to provide us your information.
Inquiries. You can submit an inquiry through any of our online contact forms. You will be asked to provide information such as your name, email address, country of origin, the topic of your inquiry and the text of your message. The mandatory fields for completion will be marked. We refer to this entire data as “Inquiry Information”.
Open Positions. You may apply for career opportunities at SB through the Website. To do so, we will ask you to provide information such as your name, email address, home country and a copy of your résumé (curriculum vitae – CV). The CV you submit will typically include your personal information. We refer to this entire data as “CV Information”.
You do not have a legal duty to provide any of the above information. However, you will not be able to submit an inquiry or an application for an open position without providing the required information.
We also collect analytics information about your use of the Website and your interaction with our email messages. When you visit our Website, we will record and collect certain information in relation to your visit and use of the Website and your interaction with our email messages, including: IP address (and the general location corresponding to the address), time and date of access, type of browser used, language use, links clicked and the web pages you accessed. We refer to this data as “Analytics Information”.
How we use your personal data
To respond to your enquiry. We will use your Inquiry Information to contact you about your inquiry and handle your inquiry.
To consider your application for an open position. We will use your CV Information to review your candidacy, consider you for the open position (or other relevant open positions we may have), and update you as to the status of your candidacy. However, submitting your candidacy for an open position does not obligate SB to review your candidacy, consider you for an open position or update you as to the status of your candidacy.
We will send you our newsletter, if you indicated your desire to receive it. If you indicated your desire to receive our newsletter (such as ticking the newsletter box in the “Contact Us” form), we will send you our newsletter from time to time. You can always opt-out from our newsletter by following the unsubscribe link included in each newsletter, or by contacting us and with your opt-out request.
We use Analytics Information to improve and enhance the Website, our services and our email communications. We also use it for business administration purposes. We use Analytics Information to improve the Website and enrich the content on the Website, our email communications and the products services we offer to customers. We also use the Analytical Information to adapt the Website, its content, and services and our email communications, to users’ preferences. Finally, we will use the Analytics Information to understand the market in which SB operates in and for managerial reporting and business planning.
When and how we share personal data with others
We will not share your information with third-parties, except in the events listed below or when you provide us your explicit and informed consent.
We share your information with our subsidiaries. We will share your information with members of our family group of companies, who help us process the data for the purpose set out above.
We share your information with our service providers helping us operate our business, the Website and the products. We will share your personal information with our service providers, such as Comeet, Inc., as well as professional consultants such as tax advisors and auditors, who assist us with the internal operations of our Website and other aspects of our business. These companies are authorized to use your personal information only as necessary to provide these services to us and not for their own promotional purposes. We do not sell your personal information to third parties.
We will share your information with competent authorities, if you violated the terms of your engagement with SB. If you have breached the terms of use of the Website, this Policy or any other agreement you have with SB, abused your rights to use the Website, or violated any applicable law. Your information will be shared with competent authorities and with third parties (such as legal counsels and advisors), for the purpose of handling of the violation or breach.
We will share your information if we are legally required. If we are required to disclose your information by a judicial, governmental or regulatory authority.
We will share your information with third-party in any event of change in SB’s structure. If the operation of SB or the Website is organized within a different framework, or through another legal structure or entity (such as due to a merger or acquisition, we will share your information to enable the structural change.
Security and data retention
We will retain your personal information for as long as we need it to operate the Website and interact with customers, and thereafter as needed for record-keeping matters. We retain personal data for the duration needed to support our ordinary business activities operating the Website and interacting with customers. Thereafter, we will still retain your personal information as necessary to comply with our legal obligations, resolve disputes, establish and defend legal claims and enforce our agreements.
We implement measures to secure your information. We implement measures to reduce the risks of damage, loss of information and unauthorized access or use of information. However, these measures do not provide absolute information security. Therefore, although efforts are made to secure your personal information, it is not guaranteed, and you cannot expect that the Service will be immune from information security risks.
Additional information for users in the EU
SB is the data controller of the personal data we collect via the Website. The following are the data controllers for the purposes of the personal data we collect via the Website and the products and services offered through the Website.
SparkBeyond Ltd. and its corporate group affiliates.
Ha-Melakha St 5, Netanya, Israel
To contact our European representative
Our European representative, for the purposes of this Policy, is SparkBeyond UK Ltd. If you are within the European Economic Area, you may contact our European representative the at the following address: 5 Merchant Square, Paddington, London, W2 1AY, UK.
Legal bases for processing your information
The legal basis for collecting and processing your Inquiry Information is our legitimate interests in responding to your inquiry.
The legal basis under EU law for processing your CV Information is us taking pre-contractual steps in evaluating your application for an open position, as well as our legitimate interests in maintaining recruitment records, facilitating the selection process, conducting reference checks, communicating with you, business process execution and internal management and defending legal claims.
The legal basis under EU law for processing your information for sending you our newsletter is your explicit consent to receive it.
The legal basis under EU law for collecting and processing Analytics Information is our legitimate interest in managing the Website and, business development and planning.
The legal basis for disclosing your information as required by a judicial, governmental or regulatory authority is either compliance with an EU-based legal obligation that we are under, or our legitimate interests in complying with authorities.
The legal basis for disclosing your information ins the event of a structural change in our business is our legitimate interests in business continuity following such structural change.
We will transfer your information internationally in accordance with applicable data protection laws. Information we collect from you will be processed in Israel, which is recognized by the European Commission as having adequate protection for personal data.
If we transfer your information from within Europe to other jurisdictions outside Europe, we will endeavor to do so using adequate safeguards determined by the EU Commission.
You have certain rights to access, update or delete your information, obtain a copy of your information, withdraw your consent and object or restrict certain data processing activities.
If you are in the EU, you have the following rights under the GDPR:
Right to Access your personal data that we process and receive a copy of it.
Right to Rectify inaccurate personal data we have concerning you and to have incomplete personal data completed.
Right to Data Portability, that is, to receive the personal data that you provided to us, in a structured, commonly used and machine-readable format. You have the right to transmit this data to another service provider. Where technically feasible, you have the right that your personal data be transmitted directly from us to the service provider you designate.
Right to Withdraw Consent to processing your personal data, at any time. If you do that, we will still process certain information on legal basis other than consent, as described in this Policy. Withdrawing your consent will not affect the lawfulness of data processing we carried out based on your consent before such withdrawal.
Right to Object, based on your particular situation, to using your personal data on the basis of our legitimate interest. However, we may override the objection if we demonstrate compelling legitimate grounds, or for the establishment, exercise of defense of legal claims. You may also object at any time to the use of your personal data for direct marketing purposes.
Right to Restrict processing your personal data (except for storing it) if you contest the accuracy of your personal data, for a period enabling us to verify its accuracy; if you believe that the processing is unlawful and you opposes the erasure of the personal data and requests instead to restrict its use; if we no longer need the personal data for the purposes outlined in this Policy, but you require them to establish, exercise or defense relating to legal claims, or if you object to processing, pending the verification whether our legitimate grounds for processing override yours.
Right to be Forgotten. Under certain circumstances, such as when you withdraw your consent, you have the right to ask us to erase your personal data. However, we may still process your personal data if it is necessary to comply with a legal obligation we are subject to under laws in EU Member States or for the establishment, exercise or defense of legal claims.
If you wish to exercise any of these rights, contact us at info@sparkbeyond.com.
We reserve the right to ask for reasonable evidence to verify your identity before we provide you with information. Where we are not able to provide you with information that you have asked for, we will explain the reason for this.
You have a right to submit a complaint to the relevant supervisory data protection authority. Subject to applicable law, you have the right to lodge a complaint with your local data protection authority. If you are in the EU, then according to Article 77 of the GDPR, you can lodge a complaint to the supervisory authority, in particular in the Member State of your residence, place of work or of an alleged infringement of the GDPR. For a list of supervisory authorities in the EU, click here.
Additional information for users in California
When you use the Website, other parties, such as Google may collect information about your activities over time and across different websites.
The following disclosure is made pursuant to California Online Privacy Protection Act: When you use the Website, other parties, such as Google may collect personally identifiable information about your activities over time and across different websites or online services.
Minors
You must be 18 years of age or older in order to use the Service.
The Service is not intended for minors under the age of 18. IF YOU ARE UNDER THE AGE OF 18 YOU MAY NOT USE THE SERVICE IN ANY WAY.
Changes to this Privacy Policy
If we change this Policy, we will post the updated policy on the Website.
From time to time, we may change this Policy, in which case we post the updated Policy on the Website. The latest version of the Policy will always be accessible on the Website.
Contact us
You can contact us at info@sparkbeyond.com
Should you have any inquiries, complaints or suggestions, you may contact us at info@sparkbeyond.com. We will do our best to resolve your issue in a timely manner.
Last Update: September 4, 2019
