Privacy Policy

1. INTRODUCTION

Yarzin-Sella Group Ltd, a company registered in Israel with its Registered Office at Yigal Alon 82, Tel Aviv, Israel, and its Subsidiaries, as defined below (Yarzin-Sella Group Ltd. and the Subsidiaries, together: „Yarzin Sella„, „we„, „us„, „our„) are committed to protecting the privacy of individuals and to complying with personal data protection laws and regulations, as detailed below.

In this Privacy Policy, „Subsidiaries” means: Yarzin Sella SARL; Yarzin Sella UG; YS UKR; Yarzin Sella BUH; Yarzin Sella INC; Yarzin Sella Poland S.P.Z.O.O; Yarzin Sella BE; Yarzin Sella B.V.; Yarzin Sella Spain S.L.; D.O.O. Yarzin Sella.

We want you to feel comfortable about how we collect, process, secure and share your personal data. This Privacy Policy details the types of personal data we collect, how we use your personal data, who we share it with and how you can control its use.

This Privacy Policy applies to the Personal Data processing activities Yarzin Sella performs, in related to the Data Subjects which are users of the https://yarzin-sella.com/ website (the „Website„), including, inter alia, customers, business partners, collaborators, employees of our or potential customers or business partners, candidates for positions available at Yarzin Sella  and/or employees of Yarzin Sella. It should be noted that this Privacy Policy will not derogate from any other privacy policy and/or privacy notice which may apply in relation to Yarzin Sella actions regarding the Data Subject’s Personal Data, including, inter alia, employees privacy policy/ privacy notice, and/or job candidates privacy policy/ privacy notice, if such policies/ notices apply.

Yarzin Sella processing of Personal Data will be in accordance with the applicable law (including, if applicable, Israel’s Protection of Privacy Law, 5741-1981, and the regulations under it, including but not limited to the Protection of Privacy (Data Security) Regulations, 5717-2017 and any guidance issued by Israel’s Privacy Protection Authority („Israel’s Data Protection Laws„), and/ or any other relevant applicable regulation), and also with the Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (“GDPR”).

In the event of a conflict between the applicable law or the GDPR, and the provisions specified in this Privacy Policy, the applicable law and/ or the GDPR, will prevail. Even if stated otherwise in this Privacy Policy – (1) Yarzin Sella will act and/or grant rights to the Data Subject, regarding the collection, processing, securing and/or sharing of the Personal Data, in accordance with the applicable law and the GDPR, and/or if such actions and/or rights are required by the applicable law and/ or the GDPR. (2) Yarzin Sella will not be obliged to any commitments regarding the collection, processing, securing and/or sharing of the Personal Data, other than those in which it is obligated in accordance with the applicable law and/ or the GDPR. In case of a conflict between the applicable law and the GDPR, the provisions which provide the Data Subjects a greater protection of their right for privacy, will prevail.

In the following sections, you will find relevant information on how we process your personal data.

2.DEFINITIONS

• Personal Data means any information relating to an identified or identifiable natural person;
• Data Subject means a user of the Website (including, inter alia, a customer, business partner, collaborator, employee of our or potential customers or business partners, candidate for  positions available at the Website, and/or employee of Yarzin Sella) who is an identifiable natural person, and/or one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;
• Usage Data represents data collected automatically either generated by the use of the Website or from the Website infrastructure itself (for example, the duration of a page visit);
• Data Controller: Data Controller means the natural or legal person who (either alone or jointly with others) determines the purposes and means of the processing of personal data. For the purpose of this Privacy Policy, Yarzin Sella is the Data Controller of your Personal Data.

3. WHAT PERSONAL DATA DO WE USE?

Depending on the nature of your relationship with Yarzin Sella, we collect, use and process the following categories of Personal Data:

Identification data such as name, sure name, contact details (e-mail address, telephone number), citizenship;

Professional data and/ or data related to your job application, if relevant, such as your curriculum vitae, including all the information detailed by you in the CV document and/or in your job application, current/previous job (including, if you worked with us previously), salary expectations, years of experience, data about the persons who can provide references about you (first and last name, telephone number, e-mail address), profession, professional skills and behavioral/personal skills, education and employment history, data about professional experience, preferred language, preferred job locations, preferred or relevant roles or job positions, the ways in which you have heard about us, links to your social media profiles, such as Facebook and /or Linkedin profiles (including all of the information which can be viewed in such profiles) and/or other details and other information as contained in your job application or CV, as well as any references provided or obtained for the purposes of processing your application. The purpose of collecting, using and/or processing such Personal Data is for general recruitment and selection purposes, when you apply for an available position within Yarzin Sella including which of the Subsidiaries, and for examine your suitability for other positions offered by Yarzin Sella including by which of the Subsidiaries (and including positions in countries which are different from the country which the original position you applied to is held and/ or including positions in other companies and/or Subsidiaries in Yarzin Sella, which are different than the company and/ or Subsidiary which the original position you applied to is held), all subject to receiving a suitable consent by you, if such consent is required according to the applicable law. Please note that the additional privacy notice that will apply in regard of job candidates, is as follows.  By applying for position offered by Yarzin Sella, you declare that you have read the said notice and accepted its conditions.

Usage Data that may include information such as your computer’s Internet Protocol address, browser type, browser version, the time and date of your visit on our website, the time spent on the website, unique device identifiers and other diagnostic data;

Cookies – Please see our separate dedicated section about cookies (Section 11).

We may collect this Personal Data:

• directly from you, when you provide us such information, and/or
• indirectly through the organisation you are working for if needed for a purpose listed below or information made publicly available.

4. WHAT ARE THE PURPOSES OF THE COLLECTION AND/OR OF THE PROCESSING OF YOUR PERSONAL DATA?

Yarzin Sella may process your Personal Data for the following purposes:

• Website /Administration

We may use your Personal Data for administrative purposes, including to help us better understand how the Data Subjects access and use our Websites; to provide reports to business partners or potential business partners, service providers, regulators, and others; to implement and maintain security, anti-piracy, fraud prevention, and other services designed to protect our customers, partners and us and to enforce our policies, directives and processes.

• Marketing

Under the conditions permitted by law and when relevant, we may use your Personal Data for prospecting and marketing purposes, including communications through e-mail or equivalent electronic means, and „Direct Mail”, as defined in the Israel’s Data Protection Laws. For example, we may use your Personal Data, such as your e-mail address or telephone number, to send news and newsletters regarding our products or to otherwise contact you about services or information regarding Yarzin Sella we think will interest you, subject to the law and to receiving your specific consent to receive such mailings (if such consent is required by law).

• Communication

We may use your Personal Data to communicate with you, including responding to requests for assistance; and/or regarding to job applications made by you or regarding to other job positions you may be interested in, at Yarzin Sella (including in other companies and/ or subsidiaries at Yarzin Sella), subject to your consent if needed according to applicable law. The said communication with you may be done in a variety of ways, including e-mail, telephone and/or text messages, and subject to law.

• Recruitment

We may use your Personal Data to ensure, inter alia, that we recruit and select appropriate individuals to work at Yarzin Sella.

• Performance of Yarzin Sella business activities and Customer services

We may use your Personal Data for Yarzin Sella sales and customer services activities, including customer relationship management, for technical support or other similar purposes and to establish and maintain customer accounts.

We may process your Personal Data in the course of Yarzin Sella procurement activities such as new products or services contracts and supplier management.

• To comply with legal obligations

We may use your Personal Data to comply with applicable legal obligations, including responding to an authority or court order or discovery requests.

• To protect us and others

Where we believe it is necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person or violations of policies, terms, and other policies.

We will use your Personal Data for the above purposes only, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose (for preserving particular evidence or in the context of legal statutes of limitation for example). If we need to use your Personal Data for an unrelated purpose, we will notify you prior to this further Personal Data processing and provide you with the relevant privacy information notice.

5. WHAT IS THE LEGAL BASIS FOR THE PROCESSING OF YOUR PERSONAL DATA?

Subject to the applicable law, we process your Personal Data under the following legal basis:

• To comply with contractual obligations. Following a contractual agreement between us, to provide you with our products or services, processing of Personal Data is necessary in order to fulfil our commitments in accordance with the contractual agreement;
• As a result of your consent. For example, if you have agreed to receive marketing communications.

• Within the scope of a legitimate interest. On occasion, taking into account the minimum privacy impact for you, the processing of your Personal Data might be necessary:

• For the administration, management and performance of our business relationship, if any, including accounting, auditing, performance of contracts;
• For the analysis and optimisation of our Website or services;
• For ensuring IT security (to detect security threats, frauds or other malicious or criminal activities) and the IT operation of Yarzin Sella;
• For prevention and investigation of criminal acts;
• For communication purposes to keep you up-to-date on the latest information about our services, solution and/or business activities, events, marketing campaigns, market analysis or other promotional activities and for analysis and improving the quality of our products and services and communication with you (subject to the law and to receiving your specific consent to receive such information, if such consent is required by law);
• For monitoring the compliance with our policies and standards;

• On the basis of Yarzin Sella legal obligations or in the public interest. Yarzin Sella, as any other company, is subject to legal obligations and regulations. In some cases, the processing of your Personal Data will be necessary for Yarzin Sella in order to fulfil these legal obligations.

6. WHO WILL RECEIVE YOUR PERSONAL DATA?

Subject to the applicable law, we may disclose your Personal Data to the following recipient(s), on a need-to-know basis:

• Authorised persons working for or on behalf of Yarzin Sella, including our agents, service providers and advisers providing the variety of products and services we need (including IT, procurement, communication, compliance, security services, marketing service providers, delivery service providers, payment processors, website operation service providers), and for the purpose of providing such products and/or services to Yarzin sella;
• Other companies and/ or Subsidiaries at Yarzin Sella, for the purposes of recruitment to such companies and/ or Subsidiaries and for examining your suitability to positions in such companies and/ or Subsidiaries, which may be different than the company and/ or Subsidiary which the original position you applied to is held, all subject to receiving a suitable consent by you, if such consent is required according to the applicable law.
• Yarzin Sella business partners and/ or service providers in connection with Yarzin Sella activities (including recruitment entities and/ or recruitment platforms or websites, inter alia, platforms or websites in which, or via which, you may be able to apply for open positions in Yarzin Sella, law firms, auditors, consultants, insurance companies), and for the purpose of performing Yarzin Sella relevant activities (for example, recruitment, legal advice and/ or auditing);
• Other authorised third parties in connection with any merger, reorganisation, sale of Yarzin Sella assets, or a financing or acquisition of our business by another company, and for the purpose of such merge, reorganisation, sale and/or acquisition, and/or for examining the feasibility of such action;
• Courts, law enforcement, regulatory or other government ministries, agencies and authorities, or to other third parties, and for the purpose of complying with legal, regulatory, professional regulations or national security obligations or requests.

7. TRANSFER OF PERSONAL DATA

Personal Data may be transferred to third countries or to international organizations, in accordance with the applicable law and/ or the GDPR. To the extent that, in the context of the processing activities described above, your Personal Data may be transferred abroad, to states located in the EEA or outside the EEA, any transfer performed by Yarzin Sella will observe the relevant legal requirements. In such circumstances, we shall take appropriate safeguards to ensure the protection of your Personal Data and to provide that enforceable Data Subject rights and effective legal remedies for Data Subjects are available, if such safeguards are required by the applicable law and/ or the GDPR.

8. DATA RETENTION

We will retain your Personal Data for only as long as it is necessary for the uses set out in this Privacy Policy and/or to meet legal and regulatory requirements, and/or for as long as permitted by the applicable law. After this period, we will securely erase Personal Data. If data is needed after this period for analytical or other legitimate business purposes, we will take appropriate measures to anonymise this data.

For marketing activities, we may process your Personal Data (for example, for newsletters) until you unsubscribe.

9. YOUR DATA PROTECTION RIGHTS UNDER GDPR

You may have certain rights with respect to your Personal Data under the GDPR as detailed below:

• Right of Access: You may be able to ask for confirmation as to whether or not Personal Data concerning you is being processed, and, where that is the case, access to the Personal Data.
• Right to Rectification: You may have the right to obtain from us the rectification of inaccurate Personal Data concerning you.
• Right to Erasure: Under certain circumstances, you may have the right to obtain from us the erasure of Personal Data concerning you.
• Right to Restriction of Processing: Under certain circumstances, you may be able to ask us to restrict the processing of your Personal Data.
• Right to Data Portability: Under certain circumstances, you may have the right to receive Personal Data concerning you in a structured, commonly used and machine-readable format and may have the right to transmit those data to another controller.
• Right to Object: Under certain circumstances, you may have the right to object to the processing of Personal Data concerning you.
• Right to lodge a complaint with your local supervisory authority: You may have a right to lodge a complaint with your local supervisory authority if you have concerns about how we are processing your Personal Data.

You may exercise the aforementioned rights, by submitting a request to Yarzin Sella using at the following e-mail address: info@yarzin-sella.com

In case of doubt of your identity, we may ask you to justify it by enclosing a copy of any identity document, subject to the applicable law and/ or the GDPR.

10. SECURITY

In accordance with the applicable law, we may implement appropriate technical and organizational measures to ensure an appropriate level of security to Personal Data, taking into account the risks that are presented by processing, in particular from accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to Personal Data transmitted, stored, or otherwise processed.  We do not guarantee however, that it will not be subject to a security event. We may be required, due to legal or other obligations outside our control, to transfer the Personal Data about you to third parties, such as public authorities. In such circumstances, we have limited control over the level of protection provided to the Personal Data by such third parties. Any transfer of Personal Data via the internet cannot be fully secured.

11. COOKIES

As mentioned above, we may collect Usage Data and Personal Data via Cookies. In general, Cookies are text files containing small amounts of information which are downloaded to your device when you visit a website. For information about our collection of Usage Data and Personal Data via Cookies and similar tracking technologies, and the choices you have regarding our use of Cookies and related information collection, please see our Cookie Statement, in the following link: https://yarzin-sella.com/cookie-policy/.

12. PERSONAL DATA OF THIRD PARTIES

If you provide Yarzin Sella with Personal Data of third parties, you warrant and represent that you will provide such Personal Data in accordance with the applicable law and/ or GDPR, inter alia, provide all appropriate notices required under the applicable law and/ or GDPR, if required; And/or obtain all required informed consents and/or establish any and all ongoing legal bases, if required by applicable law and/ or GDPR, for allowing Yarzin Sella and/or its affiliates, third-party vendors and other entities to use and process Personal Data in accordance with this Privacy Policy, for the purposes detailed in this Privacy Policy.

13. CHANGES TO THE PRIVACY POLICY

We may modify or amend this Privacy Policy from time to time at our discretion. When we make changes to this Privacy Policy, we will amend the revision date at the bottom of this page and such modified or amended Privacy Policy shall be effective as to you and your information as of that revision date.

We encourage you to review this Privacy Policy regularly to stay informed about our information practices and the choices available to you.

–––-

Israel Supplement

1. This Supplement (“Supplement”) will be an integral part of the Privacy Policy of the Website (https://yarzin-sella.com/) (the „Website„) of Yarzin-Sella Group Ltd, a company registered in Israel, and its Subsidiaries, as defined below; (Yarzin-Sella Group Ltd. and the Subsidiaries, together: „Yarzin Sella„); (“Yarzin Sella Website Privacy Policy”), that this Supplement is attached to, in case you provide Personal Data, as defined in Yarzin Sella Website Privacy Policy („Personal Data„), to Yarzin Sella.In this Supplement, „Subsidiaries” means: Yarzin Sella SARL; Yarzin Sella UG; YS UKR; Yarzin Sella BUH; Yarzin Sella INC; Yarzin Sella Poland S.P.Z.O.O; Yarzin Sella BE; Yarzin Sella B.V.; Yarzin Sella Spain S.L.; D.O.O. Yarzin Sella.
2. In the event of any conflict between the Supplement and Yarzin Sella Website Privacy Policy and/or the Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (“GDPR”), the provisions which provide the Data Subjects a greater protection of their right for privacy, will prevail.
3. By providing Personal Data to Yarzin Sella, you agree that your Personal Data will be maintained and stored in Yarzin Sella database in accordance with Israel’s Protection of Privacy Law, 5741-1981, and the regulations under it, including but not limited to the Protection of Privacy (Data Security) Regulations, 5717-2017 and any guidance issued by Israel’s Privacy Protection Authority (collectively: “Israel’s Data Protection Laws”). The said Personal Data is collected by Yarzin Sella for the purposes mentioned in Yarzin Sella Website Privacy Policy.
4. Please note that there is no legal obligation which applies to you to provide Yarzin Sella your Personal Data, and the provision of your Personal Data by you is subject to your free will and consent.
5. By providing the Personal Data, you agree that Yarzin Sella may share your Personal Data with other third parties, as detailed in Yarzin Sella Website Privacy Policy, and for the purposes mentioned therein.
6. Subject to Israel’s Data Protection Laws and the GDPR, the Personal Data may be transferred by Yarzin Sella to third parties, including entities which are located outside the State of Israel and outside the European Economic Area, including entities located in the United States, as well as in other countries. Such third parties, which the Personal Data may be transferred to, may be located in countries where the level of protection of the Personal Data does not comply with the provisions of the Israeli law, including Israel’s Data protection Laws, and which may provide less protection than the protection level provided according to the Israeli law. By providing Personal Data to Yarzin Sella, you hereby consent to such transfer of the Personal Data.
7. If you provide Yarzin Sella with Personal Data of third parties, you warrant and represent that you will:
   1. Act in accordance with Israel’s Data Protection Laws and the GDPR; and
   2. Provide all appropriate notices required under Israel’s Data Protection Laws and GDPR;  and
   3. Obtain all required informed consents and/or establish any and all ongoing legal bases, for allowing Yarzin Sella and/or its affiliates, third-party vendors, other entities and/or third parties as mentioned in Yarzin Sella Website Privacy Policy, to collect, use, process and transfer Personal Data in accordance with Yarzin Sella Website Privacy Policy, for the purposes detailed in it.
8. Subject to the Israel’s Data Protection Laws and the GDPR, you may ask Yarzin Sella to review and correct your Personal Data that is incorrect, incomplete, not clear or not updated, all in accordance with the conditions set forth in the Israel’s Data Protection Law. As far as you wish to do so, it is possible to contact us through the following email address: info@yarzin-sella.com . You must note that some of the information may be excluded from inspection and correction rights subject to the Israel’s Data Protection Laws and the GDPR.

Last updated: 18 July, 2024