We at Wolf Services Ltd. d/b/a Consiglieri ("Consiglieri", "us", "we", or "our") recognize and respect the importance of maintaining your privacy. This Privacy Notice describes the types of information we collect from you when you visit our website ("Site"), participate in our events, apply for a job, and engage with us as part of our services ("Services"). This Privacy Notice also explains how we process, transfer, store and disclose the information collected, as well as your ability to control certain uses of the collected information. Your use of our Site is governed by the Terms of Service, available at [Please provide URL] ("Terms"). "You" means any individual using the Services.
If you are an individual located in the European Union ("EU Individual"), some additional terms and rights may apply to you, as detailed herein. Consiglieri is the data controller in respect of the processing activities outlined in this Privacy Notice. Our registered office is located at 14 Dan St., Nes Tziona, Israel and our company number is 516185287. [Under the GDPR, companies not established in the EU must retain a representative there so that European data subjects and/or government authorities can easily reach them. Consiglieri may be required to establish an EU rep. We can recommend one to you if you need. If you do so, we will include the contact details here.]
"Personal Data" means any information that refers, is related to, or is associated with an identified or identifiable individual or as otherwise may be defined by applicable law. This Privacy Notice details which Personal Data is collected by us in connection with provision of the Site and/or Services.
Privacy Notice Key Points [Note: We suggest creating a layered privacy notice in which each of the section listed in this key points section is hyperlinked to the full section in the body of the document.]
The key points listed below are presented in further detail throughout this Privacy Notice. You can click on the headers in this section in order to find out more information about any topic. These key points do not substitute the full Privacy Notice.
- Personal Data We Collect, Uses and Legal Basis.
- Website Visitors.
- Consiglieri's Customers.
- Job Applicants.
- Event Participants.
- Sharing the Personal Data We Collect.
- International Transfer.
- Your Rights – How to Access and Limit Our Use of Certain Personal Data.
- Data Retention.
- Cookies and Similar Technologies.
- Third-Party Applications and Services.
- Changes to the Privacy Notice.
- Comments and Questions..
- Personal Data We Collect, Uses and Legal Basis. Depending on your usage, we collect different types of data and we and any of our third-party subcontractors and service providers use the data we collect for different purposes, as specified below. You have no legal obligation to provide us with certain Personal Data, but if you refuse to provide certain Personal Data we may not be able to provide you with the Site, Services, or part thereof.
- Website Visitors. If you visit our Site, we may collect the following Personal Data from or about you:Contact Form Information – If you contact us via the Site's contact form, we collect your email address and phone number and, if you choose to include it, your name and the name of your company.
3.How we use this data: To respond to your request or inquiry.
Legal Basis: We process this Personal Data based on the performance of a contract with you.
4.Automatically Collected Data – When you visit our Site, we automatically collect information about your computer or mobile device, including non-Personal Data such as your operating system, and Personal Data such as your IP address, device ID, approximate age, gender, as well as your browsing history and any information regarding your viewing, use of our Site. For more information about the cookies and similar technologies we use and how to adjust your preferences, please see the section "Cookies and Similar Technologies" below.
How we use this data. (1) to review usage and operations, including in an aggregated, non-specific, analytical manner; (2) to improve current and develop new products and services; (3) to prevent fraud, protect the security of our Site; and/or (4) to address any problems with the Site.
Legal Basis: We process this Personal Data for our legitimate interests to (1) develop and improve our products and services, (2) review the usage of our Site, (3) perform analytics, (4) prevent fraud, and (5) protect our legal rights.
5.Consiglieri's Customers. If you are a customer of Consiglieri's who uses our Services, we collect the following personal data from and about you:
6.Customer Data – In order to use our Services, you will be required to provide us with your name, email address, and job title. We may also ask you to provide your ID number.
How we use this data: To provide you with the Services, to contact you in relation to your use of the Services, and to provide you with promotional materials regarding our Services.
Legal Basis: When we process this Personal Data to provide you with our Services, we do so for the purpose of performance of a contract with you. When we process this Personal Data to provide you with promotional materials, we do so based on our legitimate interests to grow our business.
7.Materials You Provide – We collect the Personal Data contained in any materials you provide to us in the course of using our Services, including in any images and/or documents.
How we use this data. To provide you with the Services.
Legal Basis. We process this Personal Data for the purpose of performance of a contract with you.
7.Investors/Partners – If you are an investor or a third party service provider who partners with Consiglieri in providing services to Consiglieri customers, we collect your name, email, phone number, your LinkedIn profile, company website, and for investors, the investment areas of interest to you, and any other information you provide to us.
How we use this data. To connect you with our customers in the course of providing our Services and to provide you with promotional materials regarding our Services.
Legal Basis. When we process this Personal Data in the course of providing you with our Services, we do so for the purpose of performance of a contract with you. When we process this Personal Data to provide you with promotional materials, we do so based on our legitimate interests to grow our business.
8.Job Applicants – If you apply for a job with us, we collect your Personal Data when we process your job application. This may include your name, contact details, resume, recommendations, and any other information we may request or that you choose to share with us.
How we use this data: We use this data to process your job application, including to contact you for scheduling purposes and to provide you with updates.
Legal Basis: We process this Personal Data based on our legitimate interests to attract and assess candidates for employment.
9.Event Participants – From time to time, we, and/or together with our partners, hold events in which we may invite you to participate. If you receive an invitation, we may collect the following Personal Data from you:
10.Registration Data – when you register for and participate in an event, we collect Personal Data from you, such as your name, contact details, and any other information we may request.
How we use this data: We use this data to: (i) help us plan the event and for other logistical purposes as well as to contact you with reminders and updates about the event; (ii) ask for your feedback regarding the event in order to improve future events or our Services; and (iii) send you marketing information about future events and other Consiglieri updates.
Legal Basis: (i) When we process this Personal Data in the course of planning for and running the event, we do so based on the performance of a contract with you; (ii) when we process this Personal Data to improve our events and Services, we do so based on our legitimate interest to grow our business; (iii) when we process this Personal Data to send you marketing information, we do so based on your consent. You may withdraw your consent at any time by contacting us at email@example.com. [Consiglieri: Please note that you must obtain the participant's consent before using his/her email for marketing purposes. This may be done by having the participant accept this Privacy Notice upon registration for the event.]
11.Event Pictures – We may hire photographers to cover certain events. Event participants may be photographed directly or may appear in the background of event photos.
How we use this data: We may post event pictures, including on social media, to notify or update the public that the event took place. We may tag individuals in specific photos. We may also use them in other marketing materials.
Legal Basis: When we collect event pictures, we do so on the basis of our legitimate interest to market future events and our Services.
12.Sharing the Personal Data We Collect. We share your information, including Personal Data, as follows:
13.Affiliates. We share information, including your Personal Data, with our affiliated company, Yigal Arnon & Co., where this is necessary to provide you with our products and Services, and for the purpose of management of our business.
14.Investors, Partners, and Customers. If you are a Consiglieri customer, we share information, including your Personal Data, with potential investors and partnering service providers to connect you with them as part of the Services we provide. If you are either an investor or a partner, we may share your personal data with relevant customers.
15.Service Providers, and Subcontractors. We disclose information, including Personal Data we collect from and/or about you, to our trusted service providers and subcontractors, who have agreed to confidentiality restrictions and who use such information solely on our behalf in order to: (1) help us provide you with the Services; (2) aid in their understanding of how users are using our Site and Services.
Such service providers and subcontractors provide us with IT and system administration services, data backup, security, and storage services, and data analysis.
16.Business Transfers. Your Personal Data may be disclosed as part of, or during negotiations of, any merger, sale of company assets or acquisition (including in cases of liquidation). In such case, your Personal Data shall continue being subject to the provisions of this Privacy Notice.
17.Law Enforcement Related Disclosure. We may share your Personal Data with third parties: (i) if we believe in good faith that disclosure is appropriate to protect our or a third party's rights, property or safety (including the enforcement of the Terms and this Privacy Notice); (ii) when required by law, regulation subpoena, court order or other law enforcement related issues, agencies and/or authorities; or (iii) as is necessary to comply with any legal and/or regulatory obligation.
18.Legal Uses. We may use your Personal Data as required or permitted by any applicable law, for example, to comply with audit and other legal requirements.
20.We use subcontractors and service providers and have affiliates who are located in countries other than your own, such as Germany, and send them information we receive (including Personal Data). We conduct such international transfers for the purposes described above. We will ensure that these third parties will be subject to written agreements ensuring the same level of privacy and data protection as set forth in this Privacy Notice, including appropriate remedies in the event of the violation of your data protection rights in such third country.
21..Whenever we transfer your Personal Data to third parties based outside of the European Economic Area ("EEA") and when required under applicable law, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
22.We will only transfer your Personal Data to countries that have been deemed to provide an adequate level of protection for Personal Data by the European Commission.
23.Where we use certain service providers not located in countries with an adequate level of protection as determined by the European Commission, we may use specific contracts approved by the European Commission which give Personal Data the same protection it has in the EEA.
24.Please contact us at firstname.lastname@example.org if you would like further information on the specific mechanism used by us when transferring your Personal Data out of the EEA.
25.Security. We have implemented and maintain appropriate technical and organization security measures, policies and procedures designed to reduce the risk of accidental destruction or loss, or the unauthorized disclosure or access to Personal Data appropriate to the nature of such data. The measures we take include:
26.Safeguards – The physical, electronic, and procedural safeguards we employ to protect your Personal Data include secure servers, firewalls, antivirus, and SSL encryption of data. [Consiglieri to confirm]
27.Personnel – We require new employees to sign non-disclosure agreements according to applicable law and industry customary practice.
28.Database Backup – Our databases are backed up on a periodic basis for certain data and are verified regularly. Backups are encrypted and stored within the production environment to preserve their confidentiality and integrity, are tested regularly to ensure availability, and are accessible only by authorized personnel. [Consiglieri to be confirm]
29.However, no method of transmission over the Internet or method of electronic storage is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.
30.As the security of information depends in part on the security of the computer you use to communicate with us and the security you use to protect user IDs and passwords, please take appropriate measures to protect this information.
31.Your Rights – How to Access and Limit Our Use of Certain Personal Data. Subject to applicable law and certain exemptions, and in some cases dependent upon the processing activity we are undertaking, you have certain rights in relation to the Personal Data that we hold about you, as detailed below. We will investigate and attempt to resolve complaints and disputes and make every reasonable effort to honor your wish to exercise your rights as quickly as possible and, in any event, within the timescales provided by applicable data protection laws. We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any information and/or comply with any of your requests, as detailed below:
32.Right of Access. You have a right to know what Personal Data we collect about you and, in some cases, to have such Personal Data communicated to you. Subject to applicable law, we may charge you with a fee. Please note that we may not be able to provide you with all the information you request, and, in such case, we will endeavor to explain to you why.
33.Right to Data Portability. If the processing is based on your consent or performance of a contract with you and processing is being carried out by automated means, you may be entitled to (request that we) provide you or another party with a copy of the Personal Data you provided to us in a structured, commonly-used, and machine-readable format.
34.Right to Correct Personal Data. Subject to the limitations in applicable law, you may request that we update, complete, correct or delete inaccurate, incomplete, or outdated Personal Data.
35.Deletion of Personal Data ("Right to Be Forgotten"). If you are an EU Individual, you have a right to request that we delete your Personal Data if either: (i) it is no longer needed for the purpose for which it was collected, (ii) our processing was based on your consent and you have withdrawn your consent, (iii) you have successfully exercised your Right to Object (see below), (iv) processing was unlawful, or (iv) we are required to erase it for compliance with a legal obligation. We cannot restore information once it has been deleted. We may retain certain Personal Data (including following your request to delete) for audit and record-keeping purposes, or as otherwise permitted and/or required under applicable law.
36.Right to Restrict Processing. If you are an EU Individual, you can ask us to limit the processing of your Personal Data if either: (i) you have contested its accuracy and wish us to limit processing until this is verified; (ii) the processing is unlawful, but you do not wish us to erase the Personal Data; (iii) it is no longer needed for the purposes for which it was collected, but we still need it to establish, exercise, or defend of a legal claim; (iv) you have exercised your Right to Object (below) and we are in the process of verifying our legitimate grounds for processing. We may continue to use your Personal Data after a restriction request under certain circumstances.
37.Right to Object. If you are an EU Individual, you can object to any processing of your Personal Data which has our legitimate interests as its legal basis, if you believe your fundamental rights and freedoms outweigh our legitimate interests. If you raise an objection, we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms.
38.Right to Lodge a Complaint with Your Local Supervisory Authority. If you are an EU Individual, you may have the right to submit a complaint to the relevant supervisory data protection authority if you have any concerns about how we are processing your Personal Data, though we ask that as a courtesy you please attempt to resolve any issues with us first.
39.Data Retention [Consiglieri: Under the GDPR, you are not permitted to retain data indefinitely for no specific purpose. You may only retain personal data for as long as it's needed and then must delete it.]
40.Subject to applicable law, we retain Personal Data as necessary for the purposes set forth above. We may delete information from our systems without notice to you once we deem it is no longer necessary for these purposes. Retention by any of our processors may vary in accordance with the processor's retention policy.
41.In some circumstances, we may store your Personal Data for longer periods of time, for instance where we are required to do so in accordance with legal, regulatory, tax, audit, accounting requirements and so that we have an accurate record of your dealings with us in the event of any complaints or challenges, or if we reasonably believe there is a prospect of litigation relating to your Personal Data or dealings. To determine the appropriate retention period, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data, and whether those purposes can be achieved through other means, as well as applicable legal requirements.
42.Please contact us at email@example.com if you would like details regarding the retention periods for different types of your Personal Data.
44.What are Cookies? A cookie is a small piece of text that is sent to a user's browser or device. The browser provides this piece of text to the device of the originating user when this user returns. We may use the terms "cookies" to refer to all technologies that we may use to store data in your browser or device or that collect information or help us identify you in the manner described above, such as web beacons or "pixel tags".
The specific names and types of the cookies, web beacons, and other similar technologies we use may change from time to time. However, the cookies we use generally fall into the following category:
Type of Cookie
Why We Use These Cookies
These cookies are necessary in order to allow the Site to work correctly. They enable you to access the Site, move around, and access different services, features, and tools. Examples include remembering previous actions (e.g. entered text) when navigating back to a page in the same session. These cookies cannot be disabled.
46.Third-Party Applications and Services. All use of third-party applications or services is at your own risk and subject to such third party's terms and privacy policies.
47.Communications. We reserve the right to send you service-related communications, including service announcements and administrative messages, without offering you the opportunity to opt out of receiving them. Should you not wish to receive such communications, you may request to terminate your customer agreement.
48.Children. We do not knowingly collect Personal Data from children under the age of sixteen (16). In the event that you become aware that an individual under the age of sixteen (16) has provided us with Personal Data without parental permission, please advise us immediately.
49.Changes to the Privacy Notice. We may update this Privacy Notice from time to time to keep it up to date with legal requirements and the way we operate our business, and we will place any updates on this webpage. Please come back to this page every now and then to make sure you are familiar with the latest version. If we make material changes to this Privacy Notice, we will seek to inform you by notice on our Site or via email.
50.Comments and Questions. If you have any comments or questions about this Privacy Notice or if you wish to exercise any of your legal rights as set out herein, please contact us at firstname.lastname@example.org.