Privacy

Privacy Statement

Last revised: December 3rd, 2018

Privacy Policies of Deloitte Israel

This is the privacy protection policy (hereafter: “the privacy policy”) of Brightman Almagor Zohar & Co. at its registered office 132 Menahem Begin st., Tel-Aviv Israel (hereafter: “our firm”, “Deloitte Israel”, “our”, “we”), which is designated to arrange the Privacy aspects of our firm’s clients, our potential clients and other users of our firm’s websites and/or applications. Personal information (as defined below) is gathered and processed by our firm in various frameworks in order to provide services to our clients. Our services are provided to our clients in different ways and will be called in general “the services” or “our services”.

Deloitte Israel is committed to protect the personal data in our possession and your privacy and also to act with maximum transparency in everything connected with the gathering and use of the information collected with regard to you in our systems, in our Internet sites, in our applications and/or as to the remaining services which we provide to our clients.

What is “personal information’: Personal information enables us to identify our clients individually (and/or their employees, customers, suppliers, etc.), the users of our sites and/or applications and/or the different participants in our services. This information generally has a personal or sensitive character, and it is protected by the Protection of Privacy Law-1981, including its regulations (hereafter; “the Law”).

Your consent to our use of personal information: By ordering services from Deloitte Israel, by participating in the activities of our firm (including competitions and conferences) and by your use of our Internet sites and applications, you express your consent to the conditions as appear in these privacy policy, including your approval to collect your personal information (as defined below), to process it, and to maintain it in the databases of Deloitte Israel. Your personal information will serve us solely for purposes in accordance to this Privacy Policy.

In the event that there are additional conditions which apply to specific services which we anticipate providing to you, we will inform you about these conditions. These privacy policies represent an additional layer to the conditions of the service relevant to you.

Consent to the sending of newsletters and mail notifications: You hereby consent that in the context of the services, various newsletters and/or mail notifications connected to them and to additional services offered by us, will be sent to you. When you give your consent to receive the services, you will be requested to agree to receive such messages. Without derogating from the above, by giving your consent as mentioned in this paragraph and by the use of our services, you agree to receive notices by e-mail and/or notices to your mobile instrument (to the extent that the details have been submitted to us by you).

Connecting with Deloitte Israel: For any question and/or problem which arise from the privacy policies which are detailed below, you can contact our Privacy Officer by means of the e-mail: GDPRIsrael@deloitte.co.il.

What type of information is collected?

In the context of the services which we offer to our clients as well as in the context of the services available to the general public (such as use of our websites and/or the use of our applications), we will occasionally request or collect personal information such as:

·        Full name;

·        Contact details of the undertaking;

·        Date of birth;

·        Identity card number;

·        Information regarding employment/professional experience/education/curriculum vitae;

·        Financial data and/or tax information;

·        Other personal information included in a complaint which you submitted;

·        Other personal information submitted by the client for purposes of receiving the services or in their course (such as the condition of the client’s health or relative which is necessary for purposes of providing tax services, etc.).

This data will be transferred and kept in our firm’s database in accordance with the Law provisions. Submission of this personal data is not required by law, but without access to this data, we may not be able to provide the various services, including those which are offered in our websites and/or applications (such as enrolling as a client, making a connection, submitting candidacy to fill a position, questions by means of the application, registration for conferences, competitions, participation in surveys. etc.)

How do we collect the information?

The personal information detailed above which is collected by our firm was submitted in most cases by you (the client of the firm) or by your employer (who is our client). This personal information may have been collected by any means, including discussions, telephone conversations and online forms and by any electronic or written means of communication.

To the extent that you communicate with our firm and/or anyone on our behalf by means of sending electronic mail notices, completion of a form in our websites or applications, social networks or in any other way, the information collected with regard to you will be that submitted in the context of any communication. Furthermore, you might possibly give us the details of how to communicate with you for purposes of the receipt of professional/marketing mail, invitations to events and/or newsletters.

In some cases, we might receive information about you from third parties, such as cases in which we supply service to a client regarding his customers, suppliers and/or employees, for example when we perform surveys for our clients, from information that we obtain from operators of conferences, etc.

We may obtain information about you from other Deloitte entities in the world or from government authorities, to the extent that this is necessary for purposes of providing services.

As stated above, it is possible that we will provide services to our clients which necessitate use of personal information of third parties. Therefore, you may be requested by us to provide personal information about other possessors of information (hereafter: “personal data regarding third parties”). To the extent that you transfer personal data regarding other data subject (for example, regarding your employees, your customers, your relatives, etc.), by the very act of transferring this personal information, you declare and consent that (a) you are authorized to transfer personal information with regard to another data subject; (b) the other data subject consented and gave his explicit approval to the different uses to be made of his personal information by Deloitte Israel and/or anyone on its behalf in accordance with what this privacy policy. If you wish, you may transfer these policy to the data subject.

Information from social networks and Internet sites: subject to the personal definitions which will be defined in your accounts with the various social networks, our firm might receive data from operators of the social networks in which you have an account. For example, in a case in which you will be identified in websites or applications of our firm by means of your Facebook account, we might receive the data in your account, including information about your contacts and your areas of interest. In order to obtain details about the information which we are likely to receive from the operators of the different social networks as well as how to alter the personal definitions in your accounts with the social networks, it is important that you review the privacy policies of those networks.

Objectives of the collection and use of the information

It is possible that our firm will process personal information about you or personal information about a third party in order to create/maintain contact and/or in order to provide various services to a client and/or to another Deloitte branch in the network with which you have entered into an agreement so as to perform the services.

The legal grounds we use for processing personal information:

We could make use of personal information about you for the purpose of the following objectives:

1.      Compliance with requirements of relevant laws and regulations in order to meet professional demands (such as a “know your client” process in the framework of the Money Laundering Act);

2.      In connection with an investigation or enforcement of the privacy policy and/or in the context of demands, complaints, claims and legal proceedings;

3.      following a contractual agreement between us, to provide you with services, and collection or processing of the information is necessary in order to fulfill our commitments in accordance with the contractual agreement;

4.      In order to provide various services to users of our websites or applications;

5.      Updates regarding products or services which are relevant to you as well as to provide you with information (in various newsletters and e-mail notifications), except if you have stated that you are not interested that we do this, as was specified above;

6.      To estimate, to adjust, to open and to improve our services and products;

7.      To reply to various questions, communications, complaints, requests;

8.      To grant technical support services for our online services.

9.      Storage and management of the information in our firm’s databases for purposes of providing services;

10.   In order to evaluate your candidacy for a position in our company to the extent that you have presented such a request (see details below);

11.   Use for statistical, analytical, research and marketing purposes.                                      

 

To whom will we disclose the information with regard to you?

In accordance with the above objectives and subject to them, it is possible that we will disclose the personal information about you to the following factors:  

·        The relevant department of our firm in Israel or in the other Deloitte entities in the network;

·        Factors to which you requested that we disclose the information;

·        Authorities, courts and government ministries which have demanded the information from us or from another entity in the network to meet the requirements of the law, ordinance or professional regulation;

·        Suppliers, contractors, service providers and third parties which process the information about you in their name solely for the above purposes. In these cases, these service providers will be subject to the conditions of confidentiality and privacy in an agreement signed with them based upon the principles of these privacy policies;

·        In a case of a change of control vis-à-vis another organization, including by way of merger, acquisition or purchase of all or most of its assets, it is possible that we will disclose the information to that organization.

Except for the uses described above, we do not trade in or sell your private information to others. For the avoidance of doubt, the company is permitted to collect, to disclose and to transfer non-personal data (i.e. anonymous and aggregated information which does not allow identification of an individual) to third parties in its exclusive discretion.

Please note that it is possible that some of the above third parties are located in countries or areas without laws for protection of privacy matching those in our area of residency. In this case, appropriate means of security should be provided which will be defined in the agreement with them, based on the principles of these privacy policies, so as to protect your personal information.

Information gathered in the framework of presentation of your application for a position with our firm:

To the extent that you wish to submit an application for a position via our website, you will be required to complete your personal details concerning yourself, such as name, identity card number, telephone number, e-mail address, date of birth, gender, year of immigration, citizenship, medical fund of which you are member, residence, curriculum vitae documents and recommendations to be submitted in the context of presenting your candidacy, data on your education and experience, data concerning languages skills, your military service, the source through which you presented your application for our firm and relatives who might be employees of our firm. This information will be available to our human resources department and/or to our firm’s management and may be transferred to other Deloitte entities in the world for the purpose of execution of assessment and classification of the applicants and to permit contacting them in connection with the process of the classification and the recruitment.

Installation of cookies files:

When you visit our website, a cookie file is installed in your device through which you have access to the website, and an identification number is issued for this device in our systems. Our firm or third parties may use the cookies files in order to monitor your patterns of activities in the website, to improve and to intensify the experience of your visit to the website, to conform and to offer you services and products which might interest you (pursuant to the information collected by these files) and to provide support services to you to the extent that you may need them. The cookies files may be deactivated, For example, most of the Internet browsers allow users to expunge cookies files from the device of the user, to block their acceptance or to receive warnings prior to their storage. Nevertheless, one should be aware that if the user will expunge or will not permit storage of cookies files and/or will change the characteristics of the Flash, the online experience of the user will be limited. For further details (in English), see the cookies policies in the network website.

How long we keep your personal data for:

Our firm will save the personal data related to you for the length of time necessary to realize the objectives of the use of the information specified in these privacy policies, including, but not limited, to complying with requirements, obligations or our legal or business commitments to solve conflicts and to enforce conditions and in any case, during the period of time which will be required as per the relevant law provisions.

The personal information with regard to you will be saved for the most part according to the statute of limitations in the relevant local law, for purposes of litigation or pursuant to the regulatory provisions applying to our firm, to the extent that they obligate it to save the information for longer periods.

Transfer of personal information to other countries:

Personal information with regard to you could be transferred outside of the borders of the State of Israel, including to countries whose laws assure a level of protection lower than the level of protection over personal information which is set by the law in Israel. In cases such as these, our firm will take steps to assure an adequate level of protection for the personal information with regard to you, as specified in these privacy policy and as required by the applicable law.

Minors:

Our services (including but not only the websites and the applications) are available and designated for adults. We have no intention of collecting personal information from minors. To the extent that the client is interested in collecting or processing personal information regarding minors under his protection (for example, in a case of a guardian and his children), the client must provide us with such personal information only after he has obtained all of the consents which are necessary by law. In a case that it will be brought to our knowledge that we have received personal information regarding a minor without the consent of his legal guardians and/or in another manner which is contrary to law, we will make every effort to immediately expunge all such personal information. For further details in this matter, please contact our privacy officer at the relevant e-mail address.

Information security:  

We are using technical and organizational measures and our firm is implementing Standard ISO27001 to assure protection at a high level of your personal information, and strictness as to inflexible access authorizations. Additionally, in every case in which we transfer or share information about you with third parties, we also obligate those third parties to institute technical and organizational means which are necessary in order that the level of protection of the information will not decline. Nevertheless, we clarify hereby that we may be required by force of legal or other obligations which are not under our control, to transfer personal information about you to third parties, such as public authorities. In these cases, we have limited control over the level of information security which is instituted in practice by those third parties.

Your rights with regard to the personal information about you:

·        Receipt of confirmation that we indeed are processing information about you and that you requested a copy of the information which we are retaining with regard to you;

·        A request to update details of the personal information about you or to amend information which you believe is inaccurate or lacking;

·        Request to expunge the personal data retained by us or to limit the use made of it;

·        Withdrawal of your consent that we process information about you;

·        Request from us to stop or to begin to send you marketing information;

·        Refusal to allow us to process the personal information about you.

Upon receipt of your request, we will make reasonable efforts in order to change, to update or to expunge the above personal information in accordance with the applicable privacy laws. In the event that you will choose to withdraw your consent to process the personal information about you, it is possible that we will be forced to cease to provide services to you. Despite the aforesaid, we may be forced to save copies of the relevant information in accordance with the above section” length of time that your personal information will be saved“.

Changes in the privacy policy:

The provisions of these privacy policies are an inseparable part of our different services. Our firm is permitted to change the provisions of these policies from time to time and requests that all of the users return to and visit this page frequently. In any case that material changes will be made to these policy, we will make efforts to inform you of them by means of the accepted communication channels in the circumstances of the situation and also by means of publishing an relevant explicit notification in the sites and the applications, and subject to the requirements of the relevant law-to obtain your consent to material changes as stated in relation to the use by our firm of the personal information about you. Without derogating from the above mentioned, use of services after the date of the latest update will represent consent of the user to the changes obligating him. In case the privacy policy will be revised in order to respond to any legal demand, the revisions might become effective immediately or as is required by any law and without any advance notice.