Last revised: July 3, 2023
- YOUR CONSENT
- WHAT TYPES OF INFORMATION DO YOU COLLECT?
- Non-Personal Information: “Non-Personal Information” is un-identified and non-identifiable information pertaining to a Visitor, which may be made available to us, or collected automatically via your use of the Website. Such Non-personal Information does not enable us to identify the person from whom it was collected, and mainly consists of technical and aggregated usage information which is not linked to an identifiable individual, such as system data related to your operating system and browser, duration of usage of the Website, a Visitor’s ‘click-stream’ activity, keyboard language, etc.
- Personal Information: “Personal Information” is information that identifies an individual or may with reasonable efforts or together with additional information we have access to, enable the identification of an individual, or may be of a private or sensitive nature relating to an identified or identifiable natural person. Identification of an individual also includes the association of such individual with a persistent identifier such as a name, an identification number, persistent cookie identifier etc. Personal Information does not include information that has been anonymized or aggregated; provided, that, such information can no longer be used to identify a specific natural person. Such Personal Information that is collected by us consists of the following types of information: IP address, device identifier, and personal details provided by you in connection with your request to receive our communication and updates or to sign up for our services waiting list, your request to contact us including your name and e-mail address.
- HOW DO YOU COLLECT INFORMATION FROM ME?
- We collect information through your use of the Website. In other words, we are aware of your usage of the Website and may gather, collect and record the information relating to such usage, including by using “cookies” and other tracking technologies, as further detailed in Section 9 below.
- We collect information which you provide us voluntarily. For example, we collect Personal information which you voluntarily provide when you request to receive communications from us or when you contact us directly via the Website.
- In addition, we may publish open positions at Mrkter via our Website. In connection with such opportunities, we collect information that is voluntarily provided to us by the job candidates (“Candidates”) when they apply to any of the open positions published by us, by e-mail, via the Website or otherwise, and only as necessary for the recruitment process, as further detailed in Section 13 below.
- WHY DO YOU COLLECT AND PROCESS MY INFORMATION?
- To provide and operate our Website and related services.
- To be able to deliver and enhance our Website, and to provide Visitors with technical assistance and support.
- To send you updates, notices, notifications, newsletters, and additional information related to the Website and related services.
- To create cumulative statistical data and other cumulative information that is non-personal, with which we and/or our business partners might make use in order to operate and improve our Website and provide related services.
- To comply with any applicable rule or regulation and/or response or defend against legal proceedings versus us or our affiliates.
- WHAT ARE YOUR LEGAL GROUNDS FOR COLLECTING MY PERSONAL INFORMATION?
- WHO DO YOU SHARE MY INFORMATION WITH AND WHY?
We may share information with third parties (or otherwise allow them access to it) only in the following manners and instances:
- Third Parties & Business Partners – We may share your information with a number of selected service providers, whose services and solutions are required or otherwise facilitate achievement of the purposes of processing set forth under Section 5 above. Our third party services providers act as our sub-processors and may only process your information according to our instructions (which are given in accordance with the terms hereof). We remain responsible for any processing of your information done by such third party service providers on our behalf not in accordance with the terms hereof, except for events outside of such service providers’ reasonable control.
- Law Enforcement – We may cooperate with government and law enforcement officials to enforce and comply with the law. We may therefore disclose any information to government or law enforcement officials as we believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), to protect our or a third party’s property and legal rights, to protect the safety of the public or any person, or to prevent or stop any activity we may consider to be, or to pose a risk of being, illegal, unethical, inappropriate or legally actionable.
For avoidance of doubt, we may share anonymized or de-identified information with any other third party, at our sole discretion.
- WHERE DO YOU TRANSFER OR STORE MY INFORMATION?
Your information may be transferred to, maintained, processed and stored by us and our authorized affiliates and service providers in the EU and in Israel. Please note that Israeli data and privacy laws may not be as comprehensive as those in your country of residence. Residents of certain countries may be subject to additional protections, as set forth in below.
GDPR (EEA Visitors): This section applies only to natural persons residing in the European Economic Area (for the purpose of this section only, “you” or “your” shall be limited accordingly). It is Mrkter’s policy to comply with the EEA’s General Data Protection Regulation (“GDPR”). In accordance with the GDPR, we may transfer your Personal Information from your home country to Israel, the U.S. and/or other countries, provided that the transferee has provided appropriate safeguards, and on condition that enforceable data subject rights and effective legal remedies for data subjects are available. Specifically, we may cause such transfer if we ensured that at least one of the following applies:
- The country to which Personal Information has been transferred, has been determined by the EU Commission to be a country providing adequate protection to the privacy rights of EU residents.
- Application of Standard Contractual Clauses (also known as “Model Clauses“) where appropriate.
You have additional rights regarding your personal data under the GDPR, please refer to Section 8 below.
- WHAT ARE MY RIGHTS?
If applicable to you under your country’s jurisdiction, you may have certain rights in connection with your Personal Information and how we handle it. You can exercise your rights at any time by contacting us via any of the methods set out in Section 16 below. Those rights may include, but are not limited to, the following:
- Right of access. You may have a right to know what information we hold about you and in some cases to have the information communicated to you. We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any information.
- Right to correct Personal Information. We endeavor to keep the information that we hold about you accurate and up to date. Should you realize that any of the information that we hold about you is incorrect, please let us know and we will correct it as soon as we can.
- Data deletion. In some circumstances you have a right to request that some portions of the Personal Information that we hold about you be deleted or otherwise anonymized.
- Data portability. In some circumstances, you may have the right to request that data which you have provided to us is provided to you, so you can transfer this to another data controller.
- Restriction of processing. In some cases, you may have the right to request a restriction of the processing of your Personal Information, such as when you are disputing the accuracy of your information held by us.
- When you access or use the Website, Mrkter may use industry-wide monitoring and tracking technologies such as “cookies” or “pixel tags” (or similar technologies), which store certain information on your computer (“Local Storage“) and which will allow us to enable automatic activation of certain features, and make your service experience much more convenient and effortless. The Local Storage is created per session and may be deleted by you or otherwise your browser may be configure by you to not accept any such local storage items.
For example, these technologies enable us to: (i) provide you with the Website, (ii) keep track of our users’ preferences and authenticated sessions, (iii) secure our Website by detecting abnormal behaviors, (iv) identify technical issues and improve the overall performance of the Services, and (v) deliver targeted advertisements that are more tailored to their audience and track ad performance (For more information about this practice, click here: http://www.aboutads.info/choices/).
We may also use Google Adwords, Facebook, Twitter and LinkedIn’s functionality of re-marketing tracking cookies and pixel-based retargeting. This means that if you provide your consent to Google, Facebook, Twitter or LinkedIn (the “Social Ad Platforms”) to be provided with personalized commercial offers, you may be served with ads based on your use of the Website, outside of the Website and across the internet. In such event the Social Ad Platforms, will place cookies or pixels on your web browser and use such technologies to serve you ads based on past visits to our Website.
- Google Adwords: https://policies.google.com/technologies/ads
- Facebook: https://www.facebook.com/about/privacy/
- Twitter: https://business.twitter.com/en/help/ads-policies/other-policy-requirements/policies-for-conversion-tracking-and-tailored-audiences.html
- LinkedIn: https://www.linkedin.com/legal/cookie-policy
If you wish to opt-out of such re-targeting and tracking functionality of the Social Ad Platforms, you may do so at the following links:
- Google Adwords: https://adssettings.google.co.il/authenticated
- Facebook: https://www.facebook.com/settings/?tab=ads
- Twitter: https://help.twitter.com/en/safety-and-security/privacy-controls-for-tailored-ads
- LinkedIn: https://www.linkedin.com/help/linkedin/answer/62931?query=opt-out%20cookies&hcppcid=search
In addition, if you wish not to receive ads from us based on your use of the Website, please send us an e-mail to [email protected] and we will respond within a reasonable timeframe and in accordance with applicable laws.
- HOW DO YOU KEEP MY INFORMATION SECURE?
We have implemented administrative, technical, and physical safeguards to help prevent unauthorized access, use, or disclosure of your Personal Information. Your information is stored on secure servers and isn’t publicly available. We limit access of your information only to those employees, third party service providers or partners on a “need to know” basis, and strictly in order to enable us to perform the agreement between you and us.
Despite these measures, Mrkter cannot provide absolute information security or eliminate all risks associated with Personal Information, and security breaches may happen. If there are any questions about security, please contact us at [email protected].
- HOW LONG WILL YOU RETAIN MY INFORMATION?
We will retain your Personal Information only for as long as necessary to achieve the purposes for collection and processing set forth above. Retention periods will be determined taking into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time. If you withdraw your consent to our processing your Personal Information, we will delete your Personal Information from our systems (except to the extent retaining such data in whole or in part is necessary to comply with any applicable rule or regulation and/or to respond to or defend against legal proceedings brought against us or our affiliates).
- HOW DO YOU PROTECT THE PRIVACY OF CHILDREN?
To use our Website, Visitors must be over the age of eighteen (18). Therefore, we do not knowingly collect Personal Information from individuals under the age of eighteen and do not wish to do so. We reserve the right to request proof of age at any stage so that we can verify that individuals under the age of eighteen are not using the Website. If you believe that we might have any information from or about an individual under the age of eighteen, please contact us at [email protected].
- HOW DO YOU USE THE INFORMATION OF JOB CANDIDATES?
We may allow you to apply to any of the open positions posted at our Website by sending us your contact details and CV or resume, (“Candidate Information”). Since privacy and discreetness are very important to our Candidates, we are committed to keep Candidate Information private and will use it solely for our internal recruitment purposes (including for identifying Candidates, evaluating their applications, making hiring and employment decisions, and contacting Candidates by phone or in writing).
Please note that we may retain Candidate Information submitted to us even after the applied position has been filled or closed. This is done so we could re-consider Candidates for other suitable positions and opportunities at Mrkter; so we could use the Candidate Information as a reference for future applications; and in case the Candidate is hired, for additional employment and business purposes related to their employment with us.
If you previously submitted your Candidate Information to us, and now wish to access it, update it or have it deleted from our systems, please contact us at [email protected].
- GENERAL INFORMATION
- HOW CAN I CONTACT YOU?
If you wish to exercise any of the aforementioned rights, or receive more information, please contact us using the details provided below:
Mrkter Technologies L.B.O Ltd
IMPORTANT INFORMATION AND WHO WE ARE
Mrkter Technologies L.B.O Ltd is a business that offers an operating system for marketing purposes, including payment services.
THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name, last name, maiden name, username or similar identifier, marital status, title, date of birth, gender.
- Contact Data includes address, email address and telephone numbers.
- Emergency Contact Data includes name, surname and contact details of emergency contact.
- Marketing Data: includes your preferences in receiving marketing from us and our third parties.
- Communication Data includes email conversations and the personal information that you might freely share with us in the communications.
- Financial Data includes transaction and bank account details.
- Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
- Usage Data includes details of your use of this website such as traffic data and other communication data, and the resources that you access.
HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
- Information you give us. This is information (including Identity, Contact, and Marketing and Communications Data) you consent to giving us about you by filling in forms on the website, or by corresponding with us (for example, by email or chat). It includes information you provide when you register to use the website or any of our services. If you contact us, we will keep a record of that correspondence.
- Automated technologies or interactions. As you interact with our website, we will automatically collect personal data, including Technical Data and Usage Data. about your equipment, browsing actions and patterns. We collect this data by using cookies, and other similar technologies.
- Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
- Technical Data from the following parties:
advertising networks; and
search information providers.
- Contact, Financial and transaction data from providers of technical, payment and delivery services.
- Identity and Contact Data from data brokers or aggregators
- Identity and Contact Data from publicly available sources.
HOW WE USE YOUR PERSONAL DATA
We take your privacy very seriously. We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:
- Where you have consented before the processing.
- Where we need to perform a contract that we are about to enter or have entered with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- To provide you with technical support and assistance.
- To send you transactional communications, notices, announcements, and additional information related to us or our website.
- To develop and send you newsletters and information about our products and services by email, SMS, phone or otherwise
- Where we need to comply with a legal or regulatory obligation.
To find out more about the types of lawful basis that we will rely on to process your personal data.
(v) To send you transactional communications, notices, announcements, and additional information related to us or our website;
(vi) To develop and send you newsletters and information about our products and services by email, SMS, phone or otherwise
(vii) Where we need to comply with a legal obligation.
DISCLOSURES OF YOUR PERSONAL DATA
In addition to using the information collected by us for the purposes described above, we may also share your personal data in the following cases:
Mrkter Personnel: Personal data that we collect and process may be transferred to or accessed by our personnel for the sole purpose of enabling the operation of the website and to contact you. Please note that all of our personnel that will have access to your personal data have an obligation of strict confidentiality with respect to such personal data.
Service Providers: We may share personal data with vendors, commercial software providers, consultants and data processors who perform services on our behalf, including without limitation, companies that provide analysis, messaging services and services which host our website. Please note that we collect, hold and manage your personal data through third parties’ cloud-based services, as reasonable for business purposes, which may be located in countries outside of your jurisdiction.
Professional advisers, We may share personal data with professional advisers, including lawyers, bankers, auditors and insurers based who provide consultancy, banking, legal, insurance and accounting services.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
FOR HOW LONG WILL YOU RETAIN MY PERSONAL DATA?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
[Request access to your personal data].
[Request correction of your personal data].
[Request erasure of your personal data].
[Object to processing of your personal data].
[Request restriction of processing your personal data].
[Request transfer of your personal data].
[Right to withdraw consent].
If you wish to exercise any of the rights set out above, please contact us at [email protected]
No fee usually required
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 could refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and 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.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
From time to time, we may update this policy. Changes to this policy will be made available on our website: www.mrkter.io. We recommend that you check this policy regularly so that you are aware of any changes.
If you have any questions or concerns, or would like more detail about how we process your Personal Data, you can contact us at [email protected]
Our full details are:
- Full name of legal entity: Mrkter Technologies L.B.O. Ltd.
- Email address: [email protected]
In addition, you always have the right to make a complaint at any time to a supervisory authority.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
YOUR LEGAL RIGHTS
You have the right to:
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 lawfully processing it.
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.
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 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 will be notified to you, if applicable, at the time of your request.
Object to 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 want to object to processing on this ground as you feel 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.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
If you want us to establish the data’s accuracy.
Where our use of the data is unlawful but you do not want us to erase it.
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.
You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
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.
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. We will advise you if this is the case at the time you withdraw your consent.