Israel Experience – Privacy Policy and Notice

The Israel Experience – Educational Tourism Services Ltd (“Israel Experience”,      “we”, “us”, “our”, etc.)           respects the privacy of its      programs participants, partners, visitors, delegates, employees and staff, candidates and website users and visitors     , and is committed to protect the Personal Data that      you may share with it. We are transparent about our practices regarding personal data which we may collect and use (these and any others with respect to whom we collect personal data, shall collectively be referred to as “user”, “you” or “Data Subjects”).

Israel Experience provides educational and heritage travel packages for groups and free individual travellers     , teens, university students and adults to and outside Israel. Our clients may be individual travellers or represent communities, movements, organizations and schools from all over the world (the “Services”). Individuals making use of      our Services are entitled to protection for their data as described in this policy and notice (the “Privacy Policy”).      In addition, we may collect personal data from individuals, or individuals may provide personal data when using the Services, at our sites, websites, in the course of employment or as candidates for staff positions, and others.

We are transparent about our practices regarding the information we collect, use, maintain and process and describe our practices in this Privacy Policy. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

For the purposes of the EU General Data Protection Regulation (the “GDPR”),Israel’s protection of privacy laws, US State privacy laws and any other applicable data protection and privacy laws      ,      Israel Experience will generally be regarded as a data controller (or ‘business’, ‘owner’ etc.)     . However, However, we generally act as a data processor (‘service provider’, ‘holder’ etc.) for data provided to us by our customers regarding their own travellers. In these instances, the customer serves as the data controller, and their privacy policy governs the processing of your data and not ours.

. WHICH INFORMATION DO WE COLLECT?

Summary: we collect various categories of personal data in order to meet our contractual obligations, and also to meet various legitimate interests, such as fraud prevention and marketing.

Categories of information and data we may collect from      users.

Data we collect about you prior to, and from, your use of the Services

We collect and process non-identifiable and anonymous information, and also collect several categories of personal data (“Personal Data”), including sensitive personal data                    through your use of the Services. This may include your, and your spouse and any of your dependents’, name (first and last), nickname, birthdate, gender, nationality, job title, phone number(s), department you work in, national security, passport or      identification number, address, country, city, postcode, email and other contact details, family status, your bank account, credit card and other such payment and billing details, credentials regarding the right to work in your jurisdiction, employment history, vocational and academic skills and qualifications, interests and preferences, preferences concerning Aliya and Israel, information regarding your health including any physical or mental health conditions and allergies.

Israel Experience may also collect the email addresses,      phone numbers and other contact details of people who communicate with      Israel Experience via email or      chat services or other social media platforms or create accounts and login credentials. By your registering on Israel Experience     ’s web     sites and event pages,      Israel Experience may collect your name, phone number and email you provided.      Israel Experience may use this information to offer Israel Experience     ’s services and support to you.

You do not have any legal obligation to provide any information to Israel Experience     . However, we require certain information in order to provide the Services. If you choose not to provide us with certain information, we may not be able to provide you with some or all of the Services.

By contacting us or submitting requests for information or support via the website, email etc., Israel Experience will collect details, including also your name, phone number and personal or company email you provided, country and other information provided by you. Israel Experience may use this information to offer Israel Experience’s Services and support.

  1. HOW DO WE COLLECT PERSONAL DATA ON USERS OF THE SERVICES?

Summary: we collect personal data when you or your organization send it to us, or when a vendor or other business partner sends it to us     ; we collect personal data through our websites and services, and through our interactions with you.

We collect Personal Data required to provide the Services when you register with us. We collect Personal Data required to provide the Services when you register interest, or when you provide us such information by entering it manually or automatically, or through your use of our facilities and Services, in the course of preparing a contract, or otherwise in engaging with us. We also may collect Personal Data when you call us for support, in which case we collect the information you provide us.     .

We collect Personal Data through your use of our      website. In other words, when you are using the website      we are aware of it and may gather, collect, and record the information relating to such usage, either independently or through the help of third-party services as detailed below. This may include technical information and behavioral information such as the User’s Internet protocol (IP) address used to connect your computer to the Internet, your uniform resource locators (URL), operating system, type of browser, browser plug-in types and versions, screen resolution, Flash version, time zone setting, the User’s ‘click-stream’ on the website, the period of time the User visited the website, methods used to browse away from a page, and any phone number used to call our customer service number. We likewise may place cookies on your browsing devices (see section ‘Cookies’ below).

  1. WHAT ARE THE PURPOSES OF PERSONAL DATA WE COLLECT?

Summary: we process personal data to meet our obligations, protect our rights, and manage our business

We will use Personal Data only to provide and improve the Services and meet our contractual, ethical, and legal obligations. All Personal Data will remain accurate complete and relevant for the stated purposes for which it was processed, including for example:

Processing which is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract (GDPR Article 6(1)(b)) such as:

  • carrying out our obligations arising from any contracts entered into between you and Israel Experience and/or any contracts entered into between a      business partner and      Israel Experience and to provide you with the information, products, support and Services that you request from Israel Experience and its business partners     ;
  • administering your file with Israel Experience ;
  • sharing relevant information with vendors and partners (such as hotels, guest houses, travel companies, catering services – regarding allergies etc.);
  • connecting between participants in different programs;
  • verifying and carrying out financial transactions in relation to payments you make in connection with the Services.

Processing which is necessary for compliance with a legal obligation to which      Israel Experience is subject (GDPR Article 6(1)(c)) such as:

  • providing information to any official authority or any entity authorized by the State of Israel, in cases where Israel Experience is under a legal obligation to do so;
  • compliance and audit purposes, such as meeting our reporting obligations in our various jurisdictions, and for crime prevention and prosecution in so far as it relates to our staff, members, facilities etc.
  • if necessary, we will use Personal Data to enforce our terms, policies and legal agreements, to comply with court orders and warrants and assist law enforcement agencies as required by law, to collect debts, to prevent fraud, infringements, identity thefts and any other service misuse, and to take any action in any legal dispute and proceeding.

Processing which is necessary for the purposes of the legitimate interests pursued by      Israel Experience or by a third party (GDPR Article 6(1)(f)) of providing and promoting an efficient and      wide-ranging service to customers, such as:

  • notifying you about changes to our Services;
  • contacting you for the purpose of providing you with technical assistance and other related information about the Services;
  • replying to your queries, troubleshooting problems, detect and protect against error, fraud or other criminal activity;
  • contacting you to give you information and inviting you to take part in relevant events, such as events for Jewish communities in Israel and overseas;
  • contacting you to give you information and inviting you to take part in other educational programs organized by Israel Experience or other affiliates and partners (such as Birthright and Masa programs);
  • contacting you to inform you of additional services which may be of interest to you;
  • soliciting feedback in connection with your use of the Services;
  • informing our graduates about employment opportunities with us.
  • for security purposes and to identify and authenticate your access to the Services.
  • taking and using photographs of you if you attend our programs or events of any kind and publishing them in our brochures, on our website etc.

Personal Data which you provide us may be combined with Personal Data which an      Israel Experience partner provides us, or which may be provided by other sources, all of which will be used for the purposes set out above. We aggregate and de-identify Personal Data (i.e., use your data in a way which no longer allows to identify you) to analyze and improve our Services, and to conduct research, and for other similar purposes. We may share non-personal aggregated information with third parties, as described below.

  1. SHARING DATA GATHERED BY ISRAEL EXPERIENCE WITH THIRD PARTIES

Summary: we share personal data with our service providers, partners, and group companies, and authorities where required.

We may transfer Personal Data to:

Related organizations, The Jewish Agency and affiliates. This includes: any member of our group, which means our affiliates, in the EU, in Israel, in the US, in Latin America and elsewhere, as well our joint-venture partners who support our processing of personal data under this policy. It also includes affiliates or other partners that help us provide our Services. For example:

  • The Jewish Agency
  • Jewish communities and affiliate organizations

Third Parties

We transfer personal data to third parties in a variety of circumstances. We endeavor to ensure that these third parties use your information only to the extent necessary to perform their functions, and to have a contract in place with them to govern their processing on our behalf. These third parties may include business partners, funding bodies and fund recipients, suppliers, affiliates, agents and/or sub-contractors for the performance of any contract we enter into with you. They may assist us in providing the Services we offer, processing transactions, fulfilling requests for information, receiving and sending communications, analyzing data, providing IT and other support services or in other tasks, from time to time. These third parties may also include analytics and search engine providers that assist us in the improvement and optimization of our website and our marketing.

We periodically add and remove third party providers. At present our third-party providers to whom we may transfer personal data include also the following:

  • Ground service providers and local partners on relevant locations
  • Airlines

In addition, we may disclose your Personal Data to third parties: if we are under a duty to disclose or share your personal data in order to comply with any legal or audit or compliance obligation, in the course of any legal or regulatory proceeding or investigation, or in order to enforce or apply the terms of a contract we have with you or for you; or to protect the rights, property, or safety of IE, our staff and users, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction and to prevent cybercrime.

For purposes of the California Consumer Privacy Act as amended (CCPA) and other US State privacy laws, we do not “sell” or “share” personal information, nor do we allow any personal information to be used by third parties for their own marketing. However, we use analytics tools and other technologies (as described above), which may be construed as a “sale” under CCPA to which you may opt- out of. For avoidance of doubt,      Israel Experience may transfer and disclose non-personal data to third parties at its own discretion.

  1. INTERNATIONAL DATA TRANSFERS

Summary: we transfer Personal Data within and to the EEA, USA, Israel and elsewhere, with appropriate safeguards in place.

We store Personal Data in databases owned or controlled by us, or processed by third parties on our behalf, by reputable cloud-service providers. Personal Data may be transferred to, and stored and used at, a destination outside the European Economic Area (EEA) that may not be subject to equivalent Data protection laws to those of the EU. Where your Data is transferred outside of the EEA, we will take all steps reasonably necessary to ensure that your Data is subject to appropriate safeguards (such as transfers to adequate countries, or signing standard contractual clauses), and that it is treated securely and in accordance with this privacy policy.      Israel Experience transfers data from its various locations and jurisdictions to other jurisdictions as follows:

  • To Israel. Israel Experience’s main headquarters are based in Israel. Israel is considered by the European Commission to offer an adequate level of protection for the personal data of EU Member State residents;
  • To the United States of America; where we transfer personal data of European persons to the USA, we will do so pursuant to one of the bases described in EU data protection laws, such as standard contractual clauses etc.;
  • Within the EU – Israel Experience’s regional headquarters in charge of the delivery of Services related under the Jewish Experience brand is are located in Warsaw, Poland.

We may transfer your personal data outside of the EEA, in order to:

  • Store or backup the information;
  • Enable us to provide you with the Services and fulfill our contract with you;
  • Fulfill any legal, audit or compliance obligations which require us to make that transfer;
  • Facilitate the operation of our organization, where it is in our legitimate interests and we have concluded these are not overridden by your rights;
  • To offer our Services across multiple jurisdictions; and
  • To operate our organization, subsidiaries and affiliates in an efficient and optimal manner.
  1. DATA RETENTION

Summary: we retain personal data according to our data retention policy, as required to meet our obligations, protect our rights, and manage our business.

Israel Experience will retain Personal Data in accordance with our data retention policy, as long as required to provide the services and as necessary to comply with our legal and other obligations, to resolve disputes and to enforce agreements. We will also retain personal data to meet any audit, compliance and business best-practices.

Data that is no longer retained may be anonymized or deleted. Likewise, some metadata and statistical information concerning the use of our services are not subject to the deletion procedures in this policy and may be retained by IE. We will not be able to identify you from this data. Some data may also be retained on our third-party service providers’ servers or backups until deleted in accordance with their privacy policy and their retention policy. Personal Data may also be retained in our backups until cycled out and overwritten.

  1. WEBSITE DATA COLLECTION AND COOKIES

Summary: with your consent, we place cookies on your device. You control our use of cookies through a cookie management tool on our websites, or through your device and browser. 

When you access or use our Services or website, we may use industry standard technologies such as Cookies, pixels and similar technologies, which store certain information on your computer or browsing device and which will allow us to identify the computer or device with the user, and to enable automatic activation of certain features, and make your Service experience much more convenient and effortless. We use different types of Cookies: some cookies are strictly necessary, they are required for the operation of our Site and under our terms with you; this includes for example, cookies that enable you to log into secure areas of our Service. We also use analytical and performance monitoring cookies, which allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. Finally, we use functionality cookies which are used to recognise you when you return to our Site. This enables us, subject to personalise content to your preferences, including for example, your choice of language or region.

Different cookies are kept for different periods. Session cookies are used to keep track of your activities online in a given browsing session; these cookies generally expire when the browser is closed but may be retained for a period on your device. Permanent cookies remain in operation even when you have closed the browser; they are used to remember your login details and password. Third-party cookies are installed by third parties with the aim of collecting certain information to research behavior, demographics. Third party cookies on our site include, for example, Google Analytics. Likewise, pixels from Meta (Facebook) and others enable integration of third-party service providers (e.g.      Meta, Instagram) on our site. Third party cookies will be retained according to the terms of those third parties, and you can control those cookies in your browser settings.

We use Cookies and other technologies on the basis that they are necessary for the performance of a contract with you, or because using them is in our legitimate interests and these are not overridden by your rights.

Most browsers will allow you to erase cookies from your computer’s hard drive, block acceptance of cookies, or receive a warning before a cookie is stored. However, if you block or erase cookies your online experience on our website will be limited.

How to disable cookies: The effect of disabling cookies depends on which cookies you disable but, in general, the website and some services delivered through it may not operate properly, may not recognize your device, may not remember your preferences and so on, if cookies are disabled or removed. However, allowing or disabling cookies is your choice and in your control. If you want to disable cookies on our site, you need to change your browser settings to reject cookies. How you can do this will depend on the browser you use. Further details on how to disable cookies can be found here: Microsoft EdgeGoogle ChromeFirefoxSafari.

Our websites may, from time to time, contain links to external sites. We are not responsible for the operation, privacy policies or the content of such sites.

  1. SECURITY AND STORAGE OF INFORMATION

Summary: we take data security very seriously, invest in security systems, and train our staff. In the event of a breach, we will notify the right people as required by law.

We take great care in implementing, enforcing and maintaining the security of Personal Data.      Israel Experience implements, enforces and maintains security measures, technologies and policies to prevent the unauthorized or accidental access to or destruction, loss, modification, use or disclosure of personal data. We likewise take steps to monitor compliance of such policies on an ongoing basis. Where we deem it necessary in light of the nature of the data in question and the risks to data subjects, we may encrypt data. Likewise, we take industry standard steps to ensure our websites are safe.

Note however, that no data security measures are perfect or impenetrable, and we cannot guarantee that unauthorized access, leaks, viruses and other data security breaches will never occur.

Within Israel Experience     , we limit access to personal data to those of our personnel who: (i) require access in order for      Israel Experience to fulfil its obligations, and (ii) have been appropriately and periodically trained in Personal Data practices, and (iii) are under confidentiality obligations as may be required under applicable law.

Israel Experience shall act in accordance with its policies and with applicable law to promptly notify the relevant authorities and data subjects in the event that any personal data processed by      Israel Experience is lost, stolen, or where there has been any unauthorized access to it, all in accordance with applicable law and on the instructions of qualified authority.      Israel Experience shall promptly take reasonable remedial measures.

  1. DATA SUBJECT RIGHTS

Summary: depending on the law that applies to your personal data, you may have various data subject rights, such as rights to access, erase, and correct personal data, and information rights. We will respect any lawful request to exercise those rights.

Data subjects with respect to whose data GDPR CCPA or other data protection or privacy laws apply     , have rights under      applicable laws and local laws, including, in different circumstances, rights to: data portability, access data, rectify data, object to processing, and erase data. It is clarified for the removal of doubt, that where personal data is provided by a customer being the data subject’s employer, such data subject rights will have to be effected through that customer. In addition, data subject rights cannot be exercised in a manner inconsistent with the rights of      Israel Experience employees and staff, with      Israel Experience proprietary rights and other      Israel Experience rights and legal interests, and third party rights. As such, job references, reviews, internal notes and assessments, documents and notes including proprietary information or forms of intellectual property, cannot generally be accessed or erased, and may not be rectifiable. In addition, these rights may not be exercisable where they relate to data that is not in a structured form, for example emails, or where other exemptions apply. If processing occurs based on consent, data subjects have a right to withdraw their consent.

Cookies and any rights associated with cookies may be exercised through our cookie management tool, or your own device and browser settings.

If, for any reason, a data subject wishes to exercise these rights and modify, delete or retrieve their Personal Data, they may contact      Israel Experience by email (iedpo@israelexperience.org). Note that      Israel Experience will undertake a process to identify a data subject exercising their rights.      Israel Experience may keep details of such rights exercised for its own compliance and audit requirements.

Data subjects in the EU have the right to lodge a complaint, with a data protection supervisory. If the supervisory authority fails to deal with a complaint you may have the right to an effective judicial remedy.

  1.                                                                                                                                                                                                                                                           10. GENERAL

Israel Experience aims to process only adequate, accurate and relevant data limited to the needs and purposes for which it is gathered. It also aims to store data for the time necessary to fulfil the purpose for which the data is gathered. We only collect data in connection with a specific legitimate purpose and only processes data in accordance with this Privacy Policy.

In the event of any concerns about data protection practices at IE, you may contact our Data Protection Officer at iedpo@israelexperience.org. EU persons have the right to lodge a complaint with a supervisory authority.

  1. 11. MINORS

With regard to Personal Data about a minor under 16 years old,      Israel Experience will endeavour to process personal data only with the consent of the holder of parental responsibility over the minor.      Israel Experience will make reasonable efforts to verify that consent is given or authorised by the holder of parental responsibility of the child but cannot generally take responsibility for misrepresentation by persons as to their age.

  1. 12. CHANGES TO THIS PRIVACY POLICY

The terms of this Privacy Policy will govern the use of the services, website and any information collected in connection with them.      Israel Experience may amend or update this Privacy Policy from time to time. The most current version of this Privacy Policy will be available at: www.israelexperience.org/privacy. We will endeavor to provide notice of material changes to this policy on the homepage of the website or by other means. Material changes will take effect seven (7) days after such notice was provided. Otherwise, all other changes to this Privacy Policy are effective as of the stated “Last Revised” date and your continued use of Services will constitute your active acceptance of, and agreement to be bound by, the changes to the Privacy Policy.

If you have any reasonable questions or comments concerning this Privacy Policy, you are welcome to send us an email or otherwise contact      our DPO at iedpo@israelexperience.org and if we can help, we will make an effort to reply within a reasonable timeframe.

Our article 27 GDPR EU Representative is MyEDPO Limited, available at info[at]myedpo.com.

Last Revised: January 26, 2025.

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