PRIVACY POLICY

[Last Updated: August 2022]

This privacy policy (“Privacy Policy”) governs the data collection, processing, and usage of Talma Travel and Tours LTD, (“Company”, “we” or “us”) with respect to the data we collect from individuals who access and use our website at: https://talma.com/ and any of our Services (respectively “Website” and “Visitors” or “you”).

This Privacy Policy constitutes an integral part of any other agreement between you and us, including the Website Terms of Use to the exten applicable (together “Terms”), and provides you with information regarding what Personal Data (as defined below) do we collect and for what purposes, our data processing operations, the lawful basis pursuant to which we process your Personal Data, third parties to whom Personal Data will be transferred, data retention periods, etc. This Privacy Policy also describes how you may exercise your rights, where and to the extent applicable under relevant privacy legislation, including the EU General Data Protection Regulation (“GDPR”).

Definitions used herein but not defined herein shall have the meaning ascribed to them in the Terms or the relevant Privacy Legislation.

You are not required by law to provide us with any Personal Data. Sharing your Personal Data with us is entirely voluntary. However, without your data, we would not always be able to provide you with all or some of our services.

  1. AMENDMENTS
    We reserve the right to periodically amend or revise the Privacy Policy, which will immediately affect the implementation of the revised Privacy Policy on our Website. The last revision date will be reflected in the “Last Modified” heading at the top of the Privacy Policy. We will make a reasonable effort to notify you if we implement any changes that substantially change our privacy practices. We recommend you review this Privacy Policy periodically to ensure that you understand our privacy practices and check for any amendments.
  2. OUR DETAILS AND THE DATA CONTROLLER FOR GDPR PURPOSES
    We are Talma Shlomo Travel and Tours LTD
    Our address: 7 Metsada St., BSR Tower 4, Bnei Brak, Israel
    Phone: +972-3-7541717
    Email: info@talma.com
    Under the GDPR, we are the data controller of EU residents’ Personal Data collected on our website.
    If you have any questions or comments about this Privacy Policy, or any concerns with respect to how your privacy any information are handled, please contact our privacy team through the contact details above. Please include your name, mailing address and email address in the message.
  3. THE DATA WE COLLECT AND ITS PURPOSES
    Non-Personal Data”: means non-identifiable data, including statistical and aggregated, and “de-identified”, which can no longer be associated with any individual with no limitation (even if it was derived from Personal Data). That includes technical data transmitted to us by your device when you access and interact with the Services, such as the type of browser, operating system, type of device used, the time and date you access our services, navigation, and language preference, etc. Non-Personal Data is primarily used for technical analysis, research, and development of our services to provide, maintain, develop and enhance it, and is not used to identify individuals. Under this Privacy Policy, we can use any aggregated, statistically, and de-identified data with no limitation. Such data may be included in our proprietary information and is not deemed personal data under the law.

    Personal Data”: means information that identifies or may identify, with reasonable effort, an individual. Such data includes, inter alia, your name, address, phone number, email, and online identifiers (such as IP address or Cookie ID).

    Please see below the table which specifies the Personal Data we collect and how we use it:
    DATA SET PURPOSE AND OPERATIONS LAWFUL BASIS
    Contact Us
    If you voluntarily contact us for your interest in our products, for support, or for other inquiries, including through any form on the Website (e.g., “Contact US”) you may be required to provide us with certain information such as your name, email address, Company, phone number, your country, referral subject and other related data (“Contact Information”).

    If you are contacting us on behalf of another person, we value your assistance and care for others, please note that it is your responsibility to make sure that any person whose Personal Data you provide is aware of the principles of this statement and agrees that you will provide Personal Data to us on this basis.
    We will use this data to respond to your inquiry or provide you with information regarding our services as part of our marketing efforts.

    We may further process the content of our correspondence to improve our customer service, and if we believe it is required to provide you with any further assistance (if applicable).

    We will collect the data, store it in our data systems, such as CRM or enterprise email, analyze it, provide access to our relevant staff members, and keep records of our correspondence as part of our business records keeping.
    We process such Contact Information subject to our legitimate interest and use it soley for the purpose of responding to your inquries and provide you with the support or information you requested .

    After addressing your inquiry, we may retain your data in our systems as part of our business records keeping under our legitimate interest.
    Online Identifiers
    We use third-party cookies on the Website. As further detailed below, these cookies assist us with improving our systems and services. The Personal Data processed is an online identifier, either a cookie ID, the IP address, etc., alongside the relevant data regarding your usage of the Website (e.g., date and time of usage, pages visited, etc.)
    We will use your Online Identifiers to improve our systems and services.

    We will collect your information and analyze it, whether directly or through the use of third-party systems and services. We will aggregate the data and analyze it to produce insights regarding your usage.
    Strictly necessary cookies which are required for the proper and basic operation of the Website will be processed in our legitimate interest.

    Other cookies data will be processed subject to your consent, provided through the Cookie banner on our website.

    For more information regarding cookies, see below “Cookies Usage”.

    Please note that the actual processing operation per each purpose of use and lawful basis detailed in the table above may differ. Such processing operation usually includes a set of operations, made by automated means, such as collection, storage, use, disclosure by transmission, erasure, or destruction. Transfer of personal data to third-party countries, as further detailed in the Data Transfer section, is based on the same lawful basis as stipulated in the table above.

    In addition, we may use certain Personal Data to prevent potentially prohibited or illegal activities, fraud, misappropriation, infringements, identity thefts, and any other misuse of Our service, as well as to protect the security or integrity of our databases and Website, and to take precautions against legal liability. Such processing is based on our legitimate interests.
  4. COOKIES USAGE
    As explained above, we use cookies to improve your experience while using the Website. Cookies are small text files implemented on the user’s computer or web browser that allow some tracking and identification of the user to collect data regarding its data usage. We may use various types of Cookies:
    • Essential Cookies – which are strictly necessary for the Website to work correctly (usually appear under our name/cookie tag);
    • Functional Cookies – designated to save your settings on the Company Website - your language preference or other view preferences (also, under our name/cookie tag);
    • Session Cookies – used to support the Company Website's functionality – such Cookies are usually stored only temporarily during a browsing session and are deleted from your device when you close the browser.
    • Targeting Cookies - These cookies are used to collect information from you to help us improve our services and Company services and serve you with targeted advertisements that we believe will be relevant to you (e.g., Google’s Cookies).
    • Social networks Cookies - Social Plug-In Cookies (e.g., Facebook, Twitter, LinkedIn Cookies, or pixels, etc.) enable sharing your usage information with your social network’s accounts.
    • Analytics Cookies - give us aggregated and statistical information to improve the Company's services and further develop it e.g., Google Analytics, Google Firebase Catalytic, etc.
    • Third-party services used by us – for example, an external service supporting our recruiting options through the Company Website (e.g., Comet or Workday), or an external service that allows us to screen short videos on the Website (e.g., YouTube or Vimeo).

    Please note that the data collected by the use of Cookies may be linked to and combined with any other data, including Personal Data.

    In addition, Cookie’s data is usually collected through the use of third-party services, like Google, Facebook, etc. In those cases, your Personal Data might be transferred to those third parties, which might link it and use it together with other information they have on you from other sources. Such data is “owned” and processed separately by those third-parties under their terms and conditions and the direct accounts or subscriptions you have with those third parties. For example, if you have a Facebook account, the Personal Data collected through Facebook’s Cookies on the Company Website might be linked to other data that Facebook collects from you as a Facebook user, and might be used by Facebook per the independent agreements between you and Facebook.

    What Are Your Choices Regarding Cookies?

    If you’d like to delete cookies or instruct your web browser to delete or refuse cookies, please visit the help pages of your web browser, or use the designated Cookies Bar in the Website.
    Please note, however, that if you delete cookies or refuse to accept them, you might not be able to use all of the features we offer, you may not be able to store your preferences, and some of our pages might not display properly.

    For the Chrome web browser, please visit this page from Google

    For the Internet Explorer web browser, please visit this page from Microsoft

    For the Firefox web browser, please visit this page from Mozilla

    For the Safari web browser, please visit this page from Apple

    For any other web browser, please visit your web browser’s official web pages.

    Where Can You Find More Information About Cookies?
    You can learn more about cookies and the following third-party websites:
    - All About Cookies: http://www.allaboutcookies.org
    - Network Advertising Initiative http://www.networkadvertising.org
  5. METHODS FOR COLLECTING YOUR DATA
    According to the nature of your interaction with Company services, we may collect information as follows:
    • Provided by you voluntarily – we will collect information if and when you choose to provide us with information, such as filing any contact form.
    • Automatically – we may use cookies and similar tracking technologies (as elaborated in the Cookies Section above) to gather some information automatically when you access the Website.
    • Provided to us by third parties – as part of our digital marketing efforts as described above.
  6. DATA SHARING – CATEGORIES OF RECIPIENTS WE SHARE PERSONAL DATA WITH
    We do not share any Personal Data collected from you with third parties or any of our partners except in the following events:
    • Legal Requirement: We will share your information in this situation only if we are required to do so to comply with any applicable law, regulation, legal process, or governmental request (e.g., to comply with a court injunction, comply with tax authorities, etc.);
    • Policy Enforcement: We will share your information solely to the extent needed to (i) enforce our policies and agreements; or (ii) to investigate any potential violations thereof, including without limitations, detecting, preventing, or taking action regarding illegal activities or other wrongdoings, suspected fraud or security issues;
    • Company’s Rights: We will share your information to establish or exercise our rights, to prevent harm to our rights, property, or safety, and to defend ourselves against legal claims, when necessary, subject to applicable law;
    • Third Party Rights: We will share your information solely to the extent needed to prevent harm to the rights of our customers, yourself, or any third party’s rights, property, or safety;
    • Service Providers: We share your information with third parties that perform services on our behalf (e.g., marketing and support, etc.). These third parties may be located in different jurisdictions.
    • Corporate Transaction: We may share your information in the event of a corporate transaction (e.g., sale of a substantial part of our business, merger, consolidation or asset sale). In the event of the above, our affiliated companies or acquiring company will assume the rights and obligations as described in this Privacy Policy;
    • Authorized Disclosures: We may disclose your information to third parties when you consent to a particular disclosure. Please note that once we share your information with another company, that information becomes subject to the other Company’s privacy practices.

    Where we share information with service providers and partners, we ensure they only have access to such information that is strictly necessary in order for us to provide the services. These parties are required to secure the data they receive and to use the data for pre-agreed purposes only while ensuring compliance with all applicable data protection regulations.
  7. DATA TRANSFERS
    Any information you provide us may be transferred to and processed in countries other than the country from which you accessed the Company services. Such data transfers are subject to data processing agreements with our service providers, and the relevant obligations under the GDPR. If you are a resident of the European Economic Area ("EEA") we will take appropriate measures to ensure that your Personal Data receives an adequate level of data protection upon its transfer outside of the EEA. If you are a resident of a jurisdiction where the transferring of your Personal Data requires your consent, then your consent to this Privacy Policy includes your express consent for such data transfer.
  8. YOUR RIGHTS
    Individuals have certain rights under applicable privacy laws concerning their Personal Data. Subject to your jurisdiction (and additional conditions), these rights may include:
    • The right to be informed – you have the right to be provided with information regarding our data collection and privacy practices, as detailed in this Policy. If you have any additional questions, please contact us.
    • The right to access your Personal Data – you have the right to request a confirmation from us that we process your Personal Data, and in some cases, be provided with a copy of the Personal Data we process.
    • The right of rectification - you have the right to require to update Personal Data that is not correct;
    • The right to the erasure of your Personal Data (the right to be forgotten) – you have the right to require the erasure of certain Personal Data if specific conditions are satisfied. This right is not absolute. We may reject your request under certain circumstances, including where we must retain the data in order to comply with legal obligations or defend against legal claims, etc.;
    • The right to restrict the processing of your Personal Data – you may be entitled to limit the purposes for which we process your Personal Data if specific conditions are satisfied;
    • The right to object to the processing of your Personal Data – you have the right to object to the processing of Personal Data, in the event the basis for processing is our legitimate interests. However, we will be permitted to continue the processing if our legitimate interests override your rights, or when processing is necessary to establish, exercise, or defend a legal claim or right, etc.;
    • Data portability – you have the right to get a copy of your data in a format that may allow you to "port" it to a third-party;
    • The right to file a complaint to a supervisory authority – specifically, with regards to Personal Data collected about you in the EEA or UK, please contact the applicable EU Data Protection Authority.
    • The right to withdraw your consent – when the lawful basis for processing your Personal Data is your consent.

    You may exercise any or all your above rights concerning your Personal Data by contacting us by sending you Data Subject Request to info@ talmahomeacademy.com.

    Where we are not able to provide you with the information for which you have asked, we will endeavor to explain the reasoning for this and inform you of your rights, including the right to complain to the relevant supervisory authority. We reserve the right to ask for reasonable evidence to verify your identity before providing you with any such information per applicable law.
  9. RETENTION
    In general, we retain the Personal Data we collect for as long as it remains necessary for the purposes set forth above, all under the applicable regulation, or until you will express your preference to opt out, where applicable.

    The criteria used by us to determine our retention periods are as follows:
    • We retain Personal Data for the periods needed in order to achieve the purpose for which Personal Data was collected.
    • We retain Personal Data for the periods needed in order to comply with our obligations under applicable laws.
    • If you have a dispute with us, we may retain certain types of Personal Data as necessary and applicable to your claims, including any legal proceedings between us, until such dispute is resolved, and following, if we find it necessary, in accordance with applicable statutory limitation periods. In addition, in the event you request to exercise your rights, we will maintain the relevant correspondence for as long as needed to demonstrate compliance.

    At our sole discretion, we may rectify or erase information from our systems without prior notice to you, once we deem it no longer necessary for such purposes.
  10. SECURITY
    We implement extensive security measures to reduce the risks of damage, loss of information and unauthorized access or misuse of Personal Data. We implement appropriate data collection, storage, and processing practices and security tools to protect personal data against unauthorized access, alteration, disclosure or destruction. You should be aware that no security measures are completely fail-proof, and it is impossible to prevent any and all threats to the security of data and systems. Therefore, you should be aware that any digital personal data processing holds certain inherent risks, and we cannot guarantee that our services and databases will be immune to any wrongdoings, malfunctions, unauthorized interceptions or access, malware attacks or other kinds of abuse and misuse.
  11. CHILDREN
    Our website is not directed nor is it intended for use by children under the age of sixteen (18) and we do not knowingly process a child’s information. We will immediately discard any information we receive from a visitor considered a child upon our discovery that such a visitor shared information with us. If you are under eighteen (18), please read the terms of this Policy carefully with your parents or other legal guardians. Please contact us through the above means of contact if you believe a child has shared any information with us.