Last Updated on September 1, 2020
We at Adam-Milo Ltd. (“AM,” “we,” “our,” or “us”) respect your privacy.
This policy, therefore, describes how we collect, process and hold your personal data if and when you visit our website (www.adam-milo.com, www.adam-milo.co.il) (collectively, the “website”), use our services made available through our web-platform (ama.veritas-hr.com, ama.vce-hr.com, amr.veritas-hr.com) (“web-platform”), or if you otherwise provide us with personal data.
We are headquartered at 3 Tvuot Haaretz St., Tel-Aviv, Israel 6954627.
We serve as the data controller of your personal data, if and when you use our website, and as the data processor of your personal data, if and when you use our web-platform. When you use our web-platform our customers are your data controllers.
Our customers usually are employers, existing or potential ones, which use our web-platform to schedule and conduct computerized assessments of individual candidates who applied for a specific role or job. Our assessments serve as decision support tools in connection with recruitment processes of such candidates. While parts of the employers’ recruitment processes may be automated, our assessments alone are not used for automatic recruitment decisions, only to augment the customers’ human decision-making processes. A more detailed description of our assessments can be found on our website.
This policy affects your legal rights and obligations so please read it carefully.
Personal Data that We Collect
When you browse through our website, subscribe to our newsletter, log-in to our web-platform (with or without a username and password), or otherwise use any of our web services, we may collect, process or store your personal data including, without limitation and where applicable, your name, phone number, mobile number, physical address, email address, company name, IP address, device info, and your browsing history
When you schedule or take assessments on our web-platform, such assessments may include personality assessments, ethics and compliance assessments, skills and aptitude assessments, among others, all of which are designed to assess your fit to the role and organization to which you are recruited or promoted, as the case may be. Accordingly, personal data may also include your username and password (where and when applicable), your personal identification code, and available information associated with such assessments.
Some of the assessments may require additional personal data, which may include one or more of the following: educational history, employment and professional background, the need to accessibility accommodations, and additional information you might provide concerning your personal work experiences and work ethics. While you may be requested to provide your demographic information too, please note that providing such information will always be voluntary and your refusal to provide such information, shall not negatively impact your scores in such assessments.
In some assessments, you may be requested to answer several open questions verbally and to vide-record your responses by using your device’s or computer’s microphone and camera, as the case may be. Similarly, in other assessments, you may be requested to consent to the use of your device’s camera, which will be used to verify your identity during the assessment. In those cases, your image and/or voice may be collected and processed and such information constitutes “sensitive” personal data, the collection and processing of which requires your explicit consent. When you record and submit videos, we may also collect and retain images, video, voice and audio information and a transcript of your audio information in such videos. Please note that providing such information will always be voluntary and your refusal to provide such information, shall not negatively impact your scores in such assessments.
Personal data, however, does not include information that has been irreversibly anonymized or aggregated so that it can no longer enable anyone, whether in combination with other information or otherwise, to identify you.
AM’s assessments serve as decision support tools to the recruiting organizations together with other information collected independently by such employers, which may include interviews, your curriculum vitae (CV), references, and other information.
All personal data that you provide to us must be true, complete and accurate. If you provide us with inaccurate or false data, and we suspect or identify fraud, we will record this.
Please keep in mind that you do not need to provide us with any personal data to browse through our website. However, we may still automatically collect certain information as described below.
When you contact us by email, we may keep a record of the correspondence and we may also record any telephone call we have with you.
Data that We Automatically Collect
When you visit our website or web-platform, we, or third parties on our behalf, automatically collect and store information about your device and your activities. This information could include (a) your computer or other device’s unique ID number; (b) technical information about your device such as type of device, web browser or operating system; (c) your preferences and settings such as time zone and language; and (d) statistical data about your browsing actions and patterns.
It is necessary for our legitimate interests to use your personal data to send you marketing communications, which may include newsletters, blog posts, surveys and information about new products and services.
You can choose to no longer receive marketing communications by contacting us at [email protected] or clicking unsubscribe or “opt-out” from a marketing email.
If you do unsubscribe to marketing communications, it may take up to 5 business days for your new preferences to take effect. We shall therefore retain your personal data in our records for marketing purposes until you notify us that you no longer wish to receive marketing emails from us.
Why We Process Personal Data
We will use your personal data in order to comply with our contractual obligations, to supply to you the products or services that you had purchased, where applicable, including to contact you with any information relating to the delivery of the products or services to you in accordance with any requests you make and that we agree to, and to deal with any requests, questions, comments or complaints you have with respect to the same, if any.
If you were directed to our web-platform to take an assessment in connection with a recruiting process for a specific employer (or your current employer), then we process your personal data to assess your fit to the specific role and/or organization. Our computerized assessments may use algorithms and other analytical tools to process your personal data and rate or predict the best fit, risk or performance of a specific individual, personality trait or skill in relation to a specific role, organization and/or applicant pool. Such assessments have been professionally validated and such validity is periodically monitored and verified.
We may also use your personal data for our legitimate interests, including dealing with any customer services you require, enforcing the terms of any other agreement between us, for regulatory and legal purposes, for audit purposes and to contact you about changes to this policy, if necessary.
Sharing Personal Data
We may share your personal data with our customers, the data controllers, if we collected such information on their behalf. Specifically, if you are a job candidate, we may share your personal data and the results of any assessments you have completed on our web-platform, with the employers, the controllers of such information, who are also our customers.
We may also share personal data with our employees, service providers, sub-contractors and agents that we may appoint to perform functions on our behalf and in accordance with our instructions, including marketing services providers (e.g., Google Analytics), email communication providers, IT service providers, accountants, auditors and lawyers.
Under certain circumstances we may have to disclose your personal data under applicable laws and/or regulations, for example, as part of anti-money laundering processes or to protect a third party’s rights, property or safety.
We may also share your personal data in connection with, or during negotiations of, any merger, sale of assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or into another company.
Cross-border Transfer of Personal Data
We may share personal data with our employees, consultants and third party service providers outside your country but only for purposes of performing the services for which you provided your personal data, even to countries that might not offer a level of protection for your personal data that is equivalent to the one offered in your country of residence or in similar countries found to provide adequate safeguards to your personal data. We will obtain your consent, however, before using your personal data for any purposes other than performing the services for which you provided the personal data.
For additional information on the legal basis for processing of personal data of European Economic Area (EEA) residents and the GDPR please follow this link.
Notifications and Updates
Our website and/or web-platform may send new registered users a welcoming email to verify password and username. After you register with our website and/or web-platform and have provided consent to receiving marketing emails, we may send you on a regular basis via emails information on other services or products that we believe may be of interest to you. We give you the option at all times to unsubscribe or to opt-out from receiving these types of communications.
We may also send you notifications regarding updates to our website and/or web-platform and our services only if you have provided consent to receiving updates about our opportunities, services and products. We may also communicate with you to provide requested services and with respect to issues relating to your account via email or phone.
We shall process your personal data in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organizational measures.
All information you provide to us is stored on our secure servers. Where applicable, any payment transactions are encrypted using SSL technology. Where we have given, or you have chosen a password, you are responsible for keeping this password confidential.
You acknowledge, however, that no system can be completely secure. Therefore, although we take these steps to secure your personal data seriously, we do not and cannot promise that your personal data will always remain completely secure.
If you register with us, we shall retain your personal data until you close your account or until we no longer need it for the purposes it was provided to us. If you receive marketing communications from us, we shall retain your personal data until you opt-out of receiving such communications.
If you have otherwise used our services or contacted us with a question or comment, we shall retain your personal data for at least 6 months following completion of such service or contact in order to respond to any further queries you might have. Please keep in mind that you can always request that we suspend or remove your personal data at any time.
If any provision of this policy is held by a court of competent jurisdiction to be invalid or unenforceable, then such provision shall be construed, as nearly as possible, to reflect the intentions of the parties and all other provisions shall remain in full force and effect.
The website and services are intended to be used by individuals over the age of 18. If we become aware that we have collected the personal data of an individual under 16, we will take steps to delete the information as soon as possible. Please immediately contact us by sending an email to [email protected] if you become aware that an individual under 16 has provided us with personal data.
Unless specifically stated otherwise herein, this policy shall be governed by and construed in accordance with the laws of the State of Israel and you agree to submit to the exclusive jurisdiction of the Israeli Courts.
We may change the terms of this policy from time to time. You are responsible for regularly reviewing this policy so that you are aware of any changes to it. If you continue to use our website and/or web-platform after the time we state the changes will take effect, you will have accepted the changes.
A cookie is a small text file containing a unique identification number that is transferred (through your browser) from a website to the hard drive of your computer.
The cookie identifies your browser but will not let a website know any personal data about you, such as your name and/or address. These files are then used by websites to identify when users revisit that website.
Session Cookies are temporary cookies that remain in the cookie file of your browser until you leave our website. Persistent Cookies, on the other hand, commonly remain in the cookie file of your browser for longer periods depending on the lifetime of the specific cookie. When we use session cookies to track the total number of visitors to our Site, for example, this is done on an anonymous aggregate basis.
We also use Google Analytics to monitor how the website and/or web-platform is used. Google Analytics collects information anonymously and generates reports detailing information such as the number of visits to the website and/or web-platform, where visitors generally came from, how long they stayed, and which pages they visited. Google Analytics places several persistent cookies on your computer’s hard drive. These do not collect any personal data. If you do not agree to this use you can disable persistent cookies in your browser. This will prevent Google Analytics from logging your visits.
Legal Basis for Processing of Personal Data of EEA Residents & the GDPR
If you reside within the European Economic Area (EEA), our processing of your personal data is subject to the General Data Protection Regulation (EU) 2016/679 (“GDPR”), notwithstanding anything to the contrary herein, and therefore will be legitimized as follows:
Whenever we require your consent for the processing of your personal data such processing will be justified pursuant to Article 6(1) lit. (a) of the GDPR.
If the processing of your personal data is necessary for the performance of a contract between you and us or for taking any pre-contractual steps upon your request, such processing will be based on GDPR Article 6(1) lit. (b).
Where the processing is necessary for us to comply with a legal obligation, we will process your information on basis of GDPR Article 6(1) lit. (c), and where the processing is necessary for the purposes of our legitimate interests, such processing will be made in accordance with GDPR Article 6(1) lit. (f).
Your rights Under GDPR
You have the right to obtain from us a copy of the personal data that we hold, and to require us to correct errors in the personal data if it is inaccurate or incomplete or to limit or object to its processing, partially or entirely. You also have the right at any time to require that we delete your personal data or transfer it to a third-party. To exercise these rights, or any other rights you may have under applicable laws, please contact us at [email protected].
Please note, however, that we reserve the right to charge an administrative fee if your request is manifestly unfounded or excessive.
Additionally, such rights of rectification, objection, restriction, access, portability and deletion are subject to certain limitations, as provided for by applicable laws. Individual requests will be completed as soon as possible following their receipt and in any event within thirty (30) days from our confirmation of such receipt.
You may also have the right to make a GDPR complaint to the relevant Supervisory Authority. A list of Supervisory Authorities is available here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
If you need further assistance regarding your rights, please contact us using the contact information provided below and we will consider your request in accordance with applicable law. In some cases our ability to uphold these rights for you may depend upon our obligations to process personal data for security, safety, fraud prevention reasons, compliance with regulatory or legal requirements, or because processing is necessary to deliver the services you have requested. Where this is the case, we will inform you of specific details in response to your request.
For more information on the GDPR, please refer to:
Cross-border Transfer of Personal Data
We may share personal data with our employees, consultants and third party service providers outside your country but only for purposes of performing the services for which you provided your personal data, even to countries that might not offer a level of protection for your personal data that is equivalent to the one offered in your country of residence or in similar countries found to provide adequate safeguards to your personal data. We will obtain your express consent, however, before using your personal data for any purposes other than performing the services for which you provided the personal data.
For EU and Swiss users only – Transferring your information outside the European Economic Area.
As part of the services offered to you through this website or web-platform, as applicable, the information which you provide to us may be transferred to countries outside the European Economic Area (“EEA”) and Switzerland. This may happen if any of our servers are from time to time located in a country outside of the EEA or Switzerland. These countries may not have similar data protection laws to the EEA or Switzerland
In such circumstances, we will enter into model contractual clauses as adopted by the European Commission, or rely on alternative legal bases such as the EU-US Privacy Shield and Swiss-US Privacy Shield Frameworks (described below), where applicable, or binding corporate rules where our affiliates, consultants or service providers have adopted such internal policies approved by European data protection authorities.
If you use our services while you are outside the EEA or Switzerland, your information may be transferred outside the EEA or Switzerland in order to provide you with those services.