Last update – October 30, 2023
Privacy notice
To contact the reporting center for cyber events and information security incidents or weaknesses related to the company please send an e-mail to: [email protected]. This address is intended for information security reports only. No other matters will be answered. Upon learning of a cyber event or an information security incident, or suspecting one of these, we will investigate the reported case and if it is indeed a valid report, we will act in accordance with our privacy policy below and in accordance with the company’s internal procedures.
General
We at Adam-Milo Ltd. (the company, “we”, “our”) respect your privacy.
This privacy policy describes how we collect your personal information, process and hold it, if and when you visit our website (www.adam-milo.com, www.adam-milo.co.il) (collectively, the “Site”), use our services available through our web platform (ama.veritas-hr.com, ama.vce-hr.com, amr.veritas-hr.com) (the “Web Platform”), or if you provide us with personal information through other means.
Our main office is located at 5B Yarakon Street, LYFE Towers, Bnei Brak Israel.
Wherever in this privacy policy we refer to the “subject of the information”, or “you” or “your”, the reference is to any user who uses the Site and/or the Web Platform, and to whom the personal information pertains.
Your personal information, which will be collected for use on the Site and/or Web Platform, as detailed below, will be stored in the company’s and/or its customers’ databases, respectively, and the company will be entitled to use it in accordance with the conditions set forth in this privacy policy.
In accordance with the privacy laws in Israel, we act as the owner of the database when it comes to personal information collected for use on the Site, and as the manager of the database and/or the holder of our customers’ personal information database when we process your personal information for the purpose of using our Web Platform.
In accordance with the European privacy laws (GDPR), as detailed below, we act as the data controller of your personal information, if and when you use our Site, and as the data processor of your personal information, if and when you use our Web Platform. When using our Web Platform our customers are the data controllers of your personal information.
Our existing and/or potential clients use our Web Platform to schedule and perform computerized tests for candidates who have applied for a position, job, academic studies or other purposes. Our tests are used as a decision support tool in connection with screening and/or evaluation processes of these candidates.
While parts of customers’ evaluation and/or screening processes may be automated, our evaluations alone do not serve for automated screening decisions, but only to support customers’ human decision-making processes. A detailed description of our tests can be found on our Site.
This policy affects your legal rights and obligations, so we recommend that you to read it carefully. In any case where you would like to exercise your rights in relation to personal information, you are welcome to contact the Company and we will handle your request.
Please contact us at [email protected] or call us at +972-3-645-0000.
In relation to the European Privacy Protection Laws (GDPR) only, the Company’s Privacy Protection Officer (DPO) is Mr. Dima Mazaricki, Tel: +972-54-2288836 who can be contacted by e-mail [email protected] in any question regarding the operations of processing personal information about you.
By using our Site and/or the Web Platform for any purpose (including for the purpose of using the services and content offered therein, including the purchase of various services offered on the Site and/or the Web Platform), you declare that you have read, understood and that you agree to all the conditions detailed in this privacy policy, and you give your informed consent to all the uses that the Company performs or may perform with your personal information that you provide on the Site and/or on the Web Platform, as the case may be (including its transfer to third parties for the purposes specified in this policy) and/or information that will be collected about your use of these, and everything else, either by the Company or through someone on its behalf.
Personal information we collect
When you browse our Site, subscribe to our newsletter, log in to our Web Platform (with or without a username and password), or otherwise use one of our web services, we may collect, process or store your personal information including, but not limited to, your name, telephone number, mobile phone number, physical address, email address, company name, Internet (“IP”) address, your access device details and your browsing history.
When you schedule or perform a computerized test on our Web Platform, these tests may include, among others, personality tests, ethics and compliance tests, and skills tests, all of which are designed to assess your suitability for the position, the organization, the academic track or the purpose for which you are being tested, as the case may be. Accordingly, Personal Information may also include your username and password (if relevant), your personal identification code and available information associated with these tests.
Some of the tests may request additional personal information, which may include one or more of the following: educational, academic, employment history, professional background and work experience, the need for accessibility or for making adjustments for the purpose of performing the tests and/or additional information you can provide regarding your personal work experiences and professional ethics at work. Sometimes, you may also be asked to provide your demographic information, but providing such information will always be voluntary and your refusal to provide such information will not adversely affect the results of the tests.
In some tests, you may be asked to provide a verbal answer to several open-ended questions and record your answers using the microphone and camera of the computer/device, as the case may be. Similarly, in some tests you may be asked to agree to the use of your device’s camera for the purpose of verifying your identity during the test and/or to test your rhetorical abilities. In these cases, your image and/or voice can be collected and processed and this information constitutes sensitive personal information, the collection and processing of which requires your explicit consent. Please note that providing such sensitive personal information is always voluntary and your refusal to provide such information will not adversely affect your grades in these tests.
When you purchase a product or service through the Site and make any payment using credit cards or Pay Pal: the company collects personal information including, among other things, the name of the credit card holder through which the payment is made, credit card details, payment terms, order number, service details and/or the product ordered, the ID number of the cardholder, the IP address of the device from which the payment is made and the details of the browser and internet provider of the device through which the payment is made.
Whenever you purchase services or products from third parties who are our business partners, we will receive the details of the transactions you will make with them. These details include, among others, the transaction dates, a description of the product or service purchased by you, its price, and more.
Notwithstanding the above, please note that personal information does not include information that has become irreversibly anonymous information in a way that does not allow anyone to identify you, either in combination with other information or in some other way.
Our tests are used as a decision support tool in the selection and/or testing processes, together with other information collected by the company independently, and which may include interviews, your resume (CV), references and other information.
All information you provide us must be true, complete and accurate. If you provide us with inaccurate or false information, and we detect signs of this, we reserve the right to note this in connection with the results of the relevant test.
Please remember that you do not need to provide us with personal information in order to browse our Site. However, we may still automatically collect certain information as described below. When you contact us by email we may keep a record of the correspondence and we may also record any telephone conversations we have with you.
Personal information we collect automatically
When you visit our Site or Web Platform, we, or third parties on our behalf, automatically collect and store information about your device and your activities. This information may include (a) information about your computer or a unique identifier number of another device you use; (b) technical information about the internet browser or operating system you are using; (c) your preferences and settings, such as region, time and language; and (d) statistics about your browsing activities and patterns.
We collect this information through cookie files in accordance with our “Cookie Policy” described below and we use this information to improve our Site and the experience of using it, the services we provide and for analytical and research purposes.
Marketing communications
We use your personal information for our legitimate interests such as sending you marketing communications, which may include newsletters, blog posts, surveys and information about new products and services.
You can choose not to receive further marketing communications by contacting us at [email protected] or by clicking cancel subscription or “unsubscribe” from marketing e-mails.
If you do unsubscribe from marketing communications, it may take up to 5 business days for your new preferences to take effect. Therefore, we will keep your personal information in our records for marketing purposes until you inform us that you no longer wish to receive marketing emails from us.
Why we process personal information
We will use your personal information to comply with our contractual obligations, to provide you with the products or services you have purchased, if necessary, including to contact you regarding the provision of the products or services and to address any request, question, comment or complaint you may have in relation to these, if any.
If you have been referred to our Web Platform for the purpose of conducting a test in connection with a screening and/or assessment process for a particular client, we will process your personal information to assess your suitability for the position, organization, academic track or other purpose.
Our computerized tests may use algorithms and other analytical tools to process your personal information and rate or evaluate your suitability, or your level of risk and performance relative to other candidates for the same job, organization, academic track or other purpose. These tests have been developed professionally and their validity has been verified and validated from time to time.
We may also use your personal information for our legitimate interests, including providing customer service that you may require, enforcing the terms of any other agreement between us, for regulatory and legal purposes, for auditing purposes and to contact you regarding this policy, if necessary.
Sharing personal information
We will never sell your personal information. We will share your personal information with third parties only in accordance with this Privacy Policy.
We may share your personal information with our customers, if we have collected the personal information on their behalf. Specifically, if you are a candidate, we may share your personal information and the results of the tests you have completed on our Web Platform with our customers. We may also share personal information with our employees, service providers, subcontractors and agents whom we use to perform functions on our behalf and in accordance with our guidelines, including marketing service providers (such as Google Analytics), email communication providers, information technology service providers, accountants and lawyers. In certain circumstances we may need to disclose your personal information in accordance with the relevant laws and/or regulations, for example, as part of anti-money laundering processes or to protect the rights, property or safety of a third party.
We may also share your personal information in connection with the negotiation of any merger, sale of assets, consolidation or reorganization, financing or acquisition of all or part of our business by a third party or into another company.
Transfer of personal information outside the territory
We may share personal information about you with our employees, consultants and external service providers outside of your country, but only to perform the services for which you provided your personal information.
Personal information about you may be transferred outside the borders of the State of Israel (or your country), including to countries whose laws guarantee a level of protection that is lower than the level of protection for personal information established by Israeli law (or the law of the country where you reside). In such cases, the company will take steps to ensure an adequate level of protection for your personal information as detailed in this policy and as required by applicable law.
Personal information about you may be transferred outside the European Economic Area (that is, to countries that are not members of the European Union and that are not Iceland, Liechtenstein and Norway) and to international organizations. In such cases:
The information will be transferred to a country or an international organization for which a valid decision of the Council of the European Union has been made regarding the adequacy of the protection of the personal information transferred to that country or such organization (in accordance with regulation 45 of the GDPR); and/or
Transfer of information relying on binding and valid agreements between public entities and authorities (in accordance with regulation 46.2(a) of the GDPR); and/or
Transfer of information in accordance with the contractual instructions approved by the Council of the European Union and which impose on the recipients of the information a contractual obligation to protect the information at the level accepted in the European Economic Area (in accordance with regulation 46.2(c) of the GDPR) and while implementing additional protective measures as required by European law.
Notices and updates
Our Site and/or Web Platform may send new registered users a welcome email to verify a password and username. After registering on our Site and/or Web Platform and providing consent to receive marketing emails, we may send you information about other services or products that we believe may be of interest to you, on a regular basis via email. We give you the option to unsubscribe or opt-out of receiving these types of communications.
We may also send you notifications regarding updates to our Site and/or Web Platform and services only if you have provided consent to receive updates about our opportunities, services and products. We may also communicate with you to provide the requested services or in relation to matters related to your account by email or telephone.
Data Security
We will take steps to ensure an appropriate level of security for your personal information, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organizational measures.
All information you provide to us is stored on our secure servers. If necessary, all payment transactions are encrypted using SSL technology. You are responsible for maintaining the confidentiality of the password you have created or provided to you.
Notwithstanding the foregoing, you acknowledge that no software is completely secure. Therefore, although we take these steps to protect your personal information, we cannot guarantee that it will always remain completely secure.
Links
Our Site and/or Web Platform may contain links to other websites. If you choose to use these links to leave the Site and/or our Web Platform, you should know that we have no control over the other websites and/or the information contained therein. Therefore, we cannot be responsible for the protection and privacy of any information you provide when visiting these websites, and these websites are not subject to this policy. You should exercise caution and review the privacy policies applicable to those websites.
Data Storage
If you register with us, we will keep your personal information until you close your account with us or until we no longer need it for the purposes it was provided to us. If you receive marketing communications from us, we will retain your personal information until you opt out of receiving such communications.
If you have otherwise used our services or contacted us with a question or comment, we will retain your personal information for at least 6 months after the completion of the service to respond to further queries you may have. Remember that you can always request that we suspend or remove your personal information at any time.
General
If a competent court determines that any provision of this policy is invalid or unenforceable, then such provision shall be interpreted, to the extent possible, to reflect the intent of the parties and all other provisions shall remain in full force and effect. The Site and services are intended for use by persons over the age of 18.
If we become aware that we have collected personal information from a person under the age of 16, we will take steps to delete the information as soon as possible.
Please contact us immediately by emailing [email protected] if you become aware that a person under the age of 16 has provided us with personal information.
Unless otherwise explicitly stated, this policy shall be subject to and interpreted in accordance with the laws of the State of Israel and you consent to the exclusive jurisdiction of the Israeli courts. As far as it refers to the European privacy laws, the laws of the member state of the union where the user is located will apply.
We may change the terms of this policy from time to time. You are responsible for regularly reviewing this policy in order to be aware of any changes to it, if and when they occur.
If you continue to use our Site and/or our web platform after the changes take effect, it means that you agree to such changes.
“Cookies policy”
A cookie file is a small text file containing a unique identification number that is transferred (via the browser) from a website to the computer’s hard drive. The cookie identifies your browser but does not provide the website with information about you, such as your name and/or address. These files are used by websites to recognize when users revisit that website. Our Site and/or Web Platform use cookies so that we can recognize you when you return and customize your settings and preferences. Most browsers are initially configured to accept cookies. You can change your browser settings so that it notifies you when you have received a cookie, or refuse to receive cookies. Please note that our Site and/or web services may not function effectively if you refuse to accept cookies.
We may use third-party cookies such as Google Analytics for marketing purposes. These cookies allow us to show you promotional materials on other sites you visit around the web. If necessary, we may also share information about your behavior on our site with third parties (including operators of third-party websites and/or social networking sites) to segment advertisements and other content. In some cases, we use cookies to associate user activity with the third-party website that referred the user to our site, or to associate user activity that we referred to a third-party site. We do not share personal information or information about individual user activities with these partners. We also use cookies to associate user activity with the email campaign that referred the user to our site.
We use cookies to limit certain types of cyber-attacks. We also use cookies during audits and fraud investigations. Some of our cookie/device tracking occurs through third-party vendors, and other times we use our own indexes to identify activity related to specific cookies.
Session cookies are temporary cookies that remain in your browser’s cookie file until you leave our Site.
Persistent cookies, on the other hand, generally remain in your browser’s cookie file for longer periods, depending on the lifetime of the particular cookie.
When we use session cookies to track the total number of visitors to our Site, for example, this is done on an anonymous aggregate basis.
We also use Google Analytics to track how the Site and/or the Web Platform are used. Google Analytics collects information anonymously and produces reports detailing information such as the number of visits to the Site and/or the Web Platform, where the visitors usually came from, how long they stayed and which pages they visited. Google Analytics places a number of persistent cookies on your computer’s hard drive. These do not collect personal information.
If you do not agree to this use, you can disable persistent cookies in your browser. This will prevent Google Analytics from recording your visits.
Legal basis for processing personal data of residents of the European Economic Area and the GDPR
If you reside in the European Economic Area (EEA), the processing of your personal information is subject to the provisions of the General Data Protection Regulations (EU) 2016/679 (“GDPR”).
Therefore, whenever we need your consent to process your personal data, such processing will be justified in accordance with Article 6(1) (a) of the GDPR.
If the processing of your personal data is necessary to perform a contract between you or to take pre-contractual steps at your request, such processing will be based on Article 6(1) (b) of the GDPR.
When the processing is necessary for us to comply with a legal obligation, we will process your information on the basis of Article 6(1)(c) of the GDPR. Where the processing is necessary for the purposes of our legitimate interests, such processing will be done in accordance with Article 6(1)(f) of the GDPR.
Your rights under the privacy protection laws in Israel and the European privacy laws (GDPR)
You have the right to receive from us a copy of your personal information that we hold, and to require us to correct errors in the personal information if it is inaccurate or incomplete or to restrict its processing, in whole or in part. You also have the right to demand that we delete your personal information or that we transfer it (right to data portability) to a third party. In addition, you may at any time revoke your consent to the use of personal information about you when the company uses it based on your consent, from the moment of the cancellation onwards, without thereby detracting from the legality of the use of the personal information about you prior to the cancellation of the consent.
To exercise these rights, or any other rights you may have under applicable law, please contact us at [email protected]. To the extent that you have a complaint regarding your personal information and/or this policy, you may contact the Company’s Privacy Protection Officer (DPO), with the details listed above.
However, please note that we reserve the right to charge handling fees if your request is clearly unreasonable or excessive.
In addition, these rights of correction, restriction, access, portability and deletion are subject to certain limitations, as provided by applicable laws. Individual requests will be completed as soon as possible after their receipt and in any case within thirty (30) days of confirmation of their receipt.
To the extent that you are not satisfied with the handling of your complaint and you are the subject of European data, you may submit a complaint to the data protection authorities in the European Union, mainly to the data protection authority located at your place of residence, at your place of work or at the place where the violation of your rights occurred in relation to your personal information by virtue of European privacy protection laws. List of Supervisory authorities is available at the following address: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
The company will provide a response regarding your request to exercise any of your rights mentioned in this section vis-à-vis the company without delay and in any case within one month from the date of receipt of your request. The time period may be extended by an additional month where this is required, considering the complexity and number of requests; The Company will inform you, within one month of the date of receipt of the request, of the aforementioned extension along with the reasons for it.
If you need further assistance regarding your rights, please contact us using the contact information provided below and we will consider your request in accordance with applicable law. In some cases our ability to enforce these rights for you may depend on our obligations to process personal information for reasons of security, safety, fraud prevention, compliance with regulatory or legal requirements, or because processing is necessary to provide the services you have requested. In this case, we will inform you of specific details in response to your request.
For more information about the GDPR please go to: https://eugdpr.org/ — https://gdpr.algolia.com/.
Transfer of Personal Data Outside the European Union
We may share personal information with our employees, consultants and external service providers outside your country, but only to perform the services for which you have provided your personal information, even to countries that may not offer the same level of protection as that offered in your country of residence for your personal information or in countries that do offer protection similar to your personal information. However, we will obtain your explicit consent before we use your personal information for any purpose other than performing the services for which you provided it.
For users in the European Union and Switzerland only – transfer of your information outside the European Economic Area
As part of the services offered to you through this Site or this Web Platform, as applicable, information you provide to us may be transferred to countries outside the European Economic Area (EEA) and Switzerland. This can happen if one of our servers is located from time to time in a country outside the EEA or Switzerland. These countries may not have laws that provide similar protection to that of the European Union or Switzerland for personal information. In such circumstances, we will enter into agreements adopted by the European Commission or adopt binding corporate rules that our affiliates and/or our consultants or service providers will adopt as binding policy. If you use our services while you are outside the EEA or Switzerland, your information may be transferred outside the EEA or Switzerland to provide you with those services.