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Privacy Policy

Yesod Notice and Policy for the Collection and Use of Personal Information

Yesod is a program of the American Jewish Joint Distribution Committee Europe, Asia and Africa Foundation (“AJJDC EAA”).  This Privacy Policy describes how Yesod collects, uses, shares, and retains personally identifiable information you provide. It is important that this information is handled lawfully and appropriately in line with pertinent law, including, where applicable, the requirements of the EU General Data Protection Regulation (“GDPR”). Yesod takes our data protection duties seriously, because we respect the trust that is being placed in us to use personal information appropriately and responsibly.  This Privacy Policy does not cover the practices of our licensees or business partners (such as vendors, sponsors, or advertisers).

The Policy is effective as of 25 May 2018. The policy was last modified on 16 July 2018.

 

What is Personal Data?

Personal data means data (whether stored electronically or paper based) relating to a living individual who can be identified directly or indirectly from that data (or from that data and other information in our possession). 

Processing is any activity that involves use of personal data. It includes obtaining, recording or holding the data, organising, amending, retrieving, using, disclosing, erasing or destroying it. Processing also includes transferring personal data to third parties.

Sensitive personal data includes personal data about a person’s racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic, biometric, physical or mental health condition, sexual orientation or sexual life. It can also include data about criminal offences or convictions. Sensitive personal data can only be processed under strict conditions, including with the consent of the individual.

 

Data Protection Principles

In processing personal data, Yesod will take all reasonable measures to ensure that data is:

 

Collection and Processing for Limited Purposes

In the course of Yesod’s operations, we may collect and process the personal data as set out in this Notice. This may include data we receive actively and passively.

Active Collection of Personally Identifiable Information

Yesod collects information directly from you through, for example, online application and registration forms, when subscribing to our mailing list as well as offline, through event registration forms, or meetings. Information is collected and maintained from participants in Yesod programs, application forms, current and past website users, survey respondents, and others. To the extent that information requested is not required for your participation in a given Yesod program/opportunity, you will be told which information is optional.

We may process the following of your personal data collected from you during your application, registration and participation in Yesod programs and in the course of your interactions with us:

 

Passive Online Data Collection

Yesod also collects certain information passively, such as collecting online, non-identifying information through the use of cookies technology and/or Internet Protocol (“IP”) address tracking. Non-personal identification information might include the browser used by you, the type of computer, the operating systems, the Internet service providers, and other similar information. Through trusted third party services Yesod also automatically gathers information about the areas you visit on the Site and about the links you may select from within the Site to other sites. Most browsers are set to accept cookies. You can set yours to refuse cookies, or to alert you when cookies are being sent; however, if you disable cookies, the full functionality of our sites may not be available to you.

 

Use, Sharing and Retention of Personally Identifiable Information

Yesod uses personally identifiable information gathered and stored on the Yesod database for the purposes described at the time of collection, including for the purpose of receiving information about general Yesod initiatives and specific initiatives that we think will be of interest to you; and for Yesod to evaluate the reach and impact of its initiatives. We may also use your personally identifiable information to tailor your experience at our sites, to compile and display content and information that we think you might be interested in, and to provide you with content according to such preferences.

 

Legal Bases for Data Processing

The GDPR is not intended to prevent the processing of personal data, but to ensure that it is done fairly and without adversely affecting the rights of the individual. In accordance with the GDPR, Yesod will only process personal data where it is required for a lawful purpose.

The legal grounds we are most likely to rely on for processing data in relation to you are outlined below:

 

We will only process sensitive personal data about you if one or more of the grounds for processing sensitive personal data applies. Yesod’s activities serve ideological purposes; therefore, we may process information about your religious affiliation, such as your participation in movements, events, or organizations relative to the Jewish culture, to the extent data processing relates to persons who have regular contact with us. The additional legal grounds we are most likely to rely on for processing sensitive personal data in relation to you are outlined below:

 

Recipients of Personal Data

We may transfer your personal data to the below third parties for the following reasons:

 

Duration of Data Processing

Your personal data will not be kept in a form that allows you to be identified for any longer than is reasonably considered necessary by us for achieving the purposes for which it was collected or processed or as required by applicable laws related to data retention periods. We will retain your data during our relationship with you and thereafter, for varying periods of time, depending on the reason for which we are required to retain the particular data.  There are several reasons for which we must retain your data, including: relevant statute of limitations under civil laws; the statutory data retention obligation applicable to personal data in contracts, communication and business correspondence which constitute accounting documents. The personal data will be removed from our records or properly anonymized when it is no longer needed.

 

Security

Yesod uses reasonable measures to safeguard sensitive personally identifiable information, which measures are appropriate to the type of information maintained, and follows applicable laws regarding safeguarding any such information under our control. In addition, on our website, Yesod uses Secure Socket Layer (“SSL”) to enhance data privacy and help prevent loss, misuse, or alteration of the information under Yesod control.

Yesod cannot guarantee, however, that your information will remain secure. The Internet by its nature is a public forum, and Yesod encourages you to use caution when disclosing information online. Often, you are in the best situation to protect yourself online.

 

International Visitors

Yesod office is located in the United Kingdom If you are providing personally identifiable information and are not a resident of the United Kingdom, your country’s laws governing data collection and use may differ from those in the United Kingdom, in particular, the United Kingdom may not provide the same level of protections as those in your own country. By providing information to Yesod, you are transferring your personal data to the United Kingdom, and you consent to the transfer to, retention of and processing of your data in the United Kingdom.

 

International Transfer of Data

We may transfer any personal data we hold to a country outside the European Economic Area (‘EEA’) or to an international organization, provided that one of the following conditions applies:

Subject to the requirements above, personal data we hold may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Those staff may be engaged in, among other things, the fulfilment of contracts with the data subject, the processing of payment details and the provision of support services.

 

Links to Third-Party Sites

Yesod provides links to third-party web sites. For example, Yesod may link to a third party who is providing online resources. These links are provided as a service to you. These sites are operated by independent entities that have their own privacy policies. Yesod’s Privacy Policy does not apply to such other sites or to the use that those entities make of your information. Yesod has no control over the content displayed on such sites, nor over the measures, if any, that are taken by such sites to protect the privacy of your information.

 

Your Rights:

  1. Right of access

You have the right to obtain from us confirmation as to whether or not personal data concerning you is processed, and, where that is the case, to request access to the personal data. The accessed information right includes, among others, the purposes of the processing, the categories of personal data concerned, and the recipients or categories of recipient to whom the personal data have been or will be disclosed.  You may have the right to obtain one copy of the personal data undergoing processing. If you request additional copies, we may charge you a reasonable fee based on administrative costs.

  1. Right to rectification

You have the right to obtain from us the rectification of inaccurate personal data concerning you. Depending on the purposes of the processing, you may have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

  1. Right to deletion or erasure (right to be forgotten)

Under certain circumstances, you have the right to obtain from us the erasure of personal data concerning you and we may be obliged to erase such personal data.

  1. Right to restriction of processing

Under certain circumstances, you have the right to obtain from us restriction of processing your personal data. In this case, the relevant data will be marked and may be processed by us only for certain purposes.

  1. Right to data portability

Under certain circumstances, you have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and you may have the right to transmit those data to another entity without hindrance from us.

  1. Right to object and rights relating to automated decision-making
 

You have the right to object, on grounds relating to your particular situation, at any time to the processing of your personal data, including profiling, by us and we can be required to cease processing your personal data. If you have a right to object and you exercise this right, your personal data will no longer be processed for such purposes by us. Exercising this right will not incur any costs. Such right to object may not exist, in particular, if the processing of your personal data is necessary to take steps prior to entering into a contract or to perform a contract already concluded.

Furthermore, under certain circumstances, in case of automated individual decision-making, you have the right to obtain human intervention, to express your point of view and to contest the decision.

 

If your data processing is based on consent, you have the right to withdraw your consent at any time, without affecting the lawfulness of the processing based on consent before its withdrawal. Moreover, if your personal data is processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing. In this case your, personal data will no longer be processed for such purposes by us.

 

Right to Complaint and Legal Remedies

If you believe we have violated the General Data Protection Regulation, you also have the right to lodge a complaint with the competent data protection supervisory authority. You may also turn to courts if your data protection rights have been infringed.

 

Modifications to this Policy

From time to time, Yesod may need to update or modify this Privacy Policy, including to address new issues or to reflect changes on our site located at www.yesodeurope.eu. To the extent required by law, Yesod will notify you of material changes to this Privacy Policy, including by posting the most recent version of the Privacy Policy and information about the changes from the previous version on the Yesod website.

 

Data Controller:

American Jewish Joint Distribution Committee Europe, Asia and Africa Foundation (“AJJDC EAA”) (registered seat: H- 1053 Budapest, Ferenciek tere 7-8. II. lph. I/5.; tax number: 18908226-2-41; e-mail: info@jdc.org. You may contact our Data Protection Officer at jdc-dpo@jdc.org.

 

How to Contact Yesod and Modify Your Information or Preferences

Questions regarding this Privacy Policy should be directed to Yesod by email at info@yesodeurope.eu . If you would like to modify the types of email messages you receive from Yesod, you may also do so by following the instructions within the body of any email message that you receive from us.

To help us keep your personal information up to date, or to request access to the personal information Yesod maintains about you, you may contact us at JHub, Haskell House, 152 West End Lane, London NW6 1SD, UK or by email:  info@yesodeurope.eu

To remove yourself from our database please contact info@yesodeurope.eu or use this link

[1] The legal basis for this is Article 6 (1) (b) of the GDPR.

[2] The legal basis for this is Article 6 (1) (c) of the GDPR.

[3] The legal basis for this is Article 6 (1) (f) of the GDPR.

[4] The legal basis for this is Article 6 (1) (a) of the GDPR.