We at Adam-Milo Tech 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 create an account, purchase subscriptions, assessment packages, bundles, credits or individual assessments, or otherwise provide us with personal data. Our website, web-platform and related services are intended for business, professional, workplace, recruitment, hiring, organizational or similar commercial purposes, and not for personal, family or household consumer purposes.
We are headquartered at 1 David Ben Gurion St., Bnei Brak, LYFE Tower Israel 5120149.
You may only use the website, web-platform and related services where we make them available, subject to any excluded jurisdictions, sanctions restrictions, legal or regulatory limitations, and service availability limitations that we may designate from time to time.
We serve as the data controller of your personal data if and when you use our website, and for limited administrative, security, compliance and marketing activities relating to the website and our business operations. We generally serve as the data processor of your personal data if and when it is processed through our web-platform on behalf of our customers. When you use our web-platform, our customers are your data controllers. Where a user opens an account on our web-platform to order, manage, administer or purchase assessments for candidates, that user and/or the organization on whose behalf that user acts is the data controller of candidate personal data processed through the web-platform, and our role is to process such personal data on that customer’s behalf. If you create, access or use an account on behalf of an employer, recruiter or other organization, personal data associated with that account, the account administrator’s instructions, and related use of the services may be processed in connection with that organization’s account and business relationship with us.
Our customers usually are employers, recruiters, hiring managers, existing or potential ones, and other persons or organizations 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 employers’ recruitment processes may be automated, our assessments alone are not used for automatic recruitment decisions, only to augment our 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.
If you have any questions, please contact us at [email protected] or call us at +972 3-645-0000
Personal Data that We Collect
When you browse through our website, subscribe to our newsletter, create an account, log in to our web-platform, purchase services, use any of our web services, or otherwise interact with us, we may collect, process or store personal data including, without limitation and where applicable, your name, phone number, mobile number, physical or billing address, email address, company or organization name, government ID or identification number, IP address, device information, payment-related transaction information from our payment processors, and your browsing history. When you schedule, administer 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 a candidate’s fit to the role and organization to which such candidate is being recruited or promoted, as the case may be. Accordingly, personal data may also include usernames and passwords, job descriptions, candidate identifiers, candidate personal data and available information associated with such assessments.
Depending on the applicable workflow and jurisdiction, this may include information that may be considered sensitive personal data, sensitive personal information, special category data, or data subject to similar heightened protection under applicable law, such as government-issued identification data, accessibility or accommodation-related information, demographic information, and audio, video or similar recordings.
We may also process personal data in connection with algorithmic, statistical or AI-assisted assessment tools that help generate reports, scores, benchmarks, insights and suitability indicators, as further described below.
Some of the assessments may require additional personal data, which may include one or more of the following: educational history, employment and professional background, accessibility or accommodation needs, and additional information a candidate or user might provide concerning personal work experiences and work ethics. While users or candidates may be requested to provide demographic information too, please note that providing such information may be voluntary in some cases; however, in certain assessments or workflows, failure to provide some requested information may prevent completion of the relevant assessment and may require alternative measures and/or coordination by the applicable customer.
In some assessments, candidates may be requested to answer several open questions verbally and to video-record their responses by using a device’s or computer’s microphone and camera, as the case may be. Similarly, in other assessments, candidates or users may be requested to consent to the use of a device’s camera and other identity verification tools, which may be used to verify identity during the assessment or in connection with account activation and security. In those cases, image, voice and related verification data may be collected and processed and such information may constitute sensitive personal data, the collection and processing of which may require explicit consent or another valid legal basis under applicable law. In certain jurisdictions, voiceprints, facial geometry, video recordings, photographs or similar technical measurements may also be regulated as biometric data or biometric identifiers, and where we collect or process such data we will do so only as permitted by applicable law and, where required, based on an appropriate notice, consent or other valid legal basis. When videos are recorded and submitted, we may also collect and retain images, video, voice and audio information and a transcript of audio information in such videos. In some cases, providing such information may be voluntary, but if it is not provided, the candidate may be unable to complete a particular assessment and alternative measures and/or coordination may then be required.
We do not use personal data submitted through the web-platform to train general-purpose generative AI models for unrelated third-party use. Where we make available AI-assisted support or drafting tools that are designed not to process personal data, users should nevertheless avoid entering personal data into such tools unless we expressly indicate otherwise in the relevant interface or documentation.
AI-assisted tools made available through our services may include, for example, support tools that help explain how to read reports and tools that help prepare job descriptions or suggest relevant assessments. Such tools are intended to assist users and are not intended to make decisions about any identified individual.
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.
If you create an account, purchase services, contact us by email or through support channels, or otherwise communicate with us, we may keep a record of the correspondence and we may also record any telephone call we have with you, where applicable and lawful. Support for self-serve users may be provided primarily by email and on a reasonable efforts basis, unless expressly agreed otherwise in writing.
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.
We collect this information by using cookies in accordance with our Cookie Policy described below and we use the information we collect to improve our website, the services we provide, and for analytical and research purposes.
Marketing Communications
It is necessary for our legitimate interests, and in some cases based on your consent where required by applicable law, to use your personal data to send you marketing communications, which may include newsletters, blog posts, surveys and information about new products and services. Where applicable law treats certain advertising cookies or similar technologies as a sale, sharing, targeted advertising or cross-context behavioral advertising activity, we will provide the rights and choices required by such law, including opt-out mechanisms where applicable.
You can choose to no longer receive marketing communications by contacting us at [email protected] or by 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 have purchased, where applicable, including to create and maintain your account, process orders and payments, verify your identity and contact details, provide access to subscriptions, bundles, credits and assessments, 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, recruiter or other customer, then we process your personal data on behalf of that customer to assess your fit to the specific role and/or organization. Our computerized assessments may use algorithms, AI tools and other analytical tools to process personal data and generate reports, scores, benchmarks, insights and suitability indicators concerning 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 are intended as decision support tools only and are not used by us to make solely automated decisions producing legal or similarly significant effects concerning a candidate. The applicable customer remains responsible for determining whether and how to use such outputs in a lawful manner, including compliance with applicable employment, anti-discrimination, privacy, accommodation and AI-related laws.
Where AI-assisted functionality is used, it is intended to support human review and not to replace human judgment or serve as the sole basis for an employment-related decision unless and only to the extent permitted by applicable law.
We may also use personal data for our legitimate interests, including dealing with customer service and support requests, enforcing the terms of any agreement between us, administering accounts, maintaining backups, conducting audits, preventing fraud and misuse, maintaining platform and information security, meeting legal and regulatory obligations, and contacting you about changes to this policy, our services or our terms, if necessary.
Where required by applicable law, individuals may have rights to receive additional information regarding the use of automated processing, to request human review, to contest a decision, to express their point of view, or to request an alternative process or accommodation. Where we act as processor on behalf of a customer, we may direct such requests to the applicable customer, although we may assist the customer as required by law or contract.
Individuals may also have rights, under applicable law, to receive information about the logic involved in certain automated processing, the significance and envisaged consequences of such processing, and the measures available to obtain human intervention or review.
Additional U.S. State Privacy Disclosures
Residents of certain U.S. states, including California and other states with applicable privacy laws, may have the right, subject to applicable exceptions and verification, to request access to, confirmation of, correction of, deletion of, or a copy of certain personal data, to opt out of certain sales, sharing, targeted advertising or profiling activities, to limit certain uses of sensitive personal information where such right is provided by law, and to appeal our denial of a privacy request where applicable law provides such right. Authorized agents may submit requests on behalf of individuals where permitted by applicable law.
We will not discriminate against you for exercising any privacy rights available under applicable law. To exercise applicable privacy rights, please contact us at [email protected]. If applicable law provides a right to appeal our decision regarding your request, you may submit an appeal by replying to our response or by contacting us at the same email address with the subject line Privacy Rights Appeal. We may need to verify your identity and authority before processing your request. Where we process personal data solely on behalf of one of our customers, you may need to direct your request to that customer as the relevant controller or business.
Additional Information About AI-Assisted Tools.
Depending on the relevant service configuration, our services may include algorithmic, statistical or AI-assisted tools used to support assessment administration, report generation, explanatory support, job description preparation, and assessment selection assistance. These tools are intended to support human users, may produce outputs that require verification, and should not be understood as guaranteeing any particular hiring, recruitment or business outcome.
No Personal Data Training for Certain AI Support Features.
Where we make available customer support AI tools, report explanation tools, or job description and assessment-selection assistance tools that are designed not to process personal data, we intend those tools to operate without using personal data inputs and without using personal data to train the underlying model, except to the extent we expressly disclose otherwise in the relevant interface, documentation or supplemental notice.
Sharing Personal Data
We will never sell, rent or trade your personal data. We will share your personal data with third parties only as permitted in this Privacy Policy.
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 providers in the following categories: cloud hosting and infrastructure providers, analytics providers, email and communications providers, payment processors, customer support and helpdesk providers, identity verification providers, video and audio processing providers, security and fraud prevention providers, CRM and marketing automation providers, and data storage and backup providers, as well as accountants, auditors and lawyers. Under certain circumstances we may have to disclose 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. Depending on the applicable jurisdiction, some disclosures involving advertising, analytics or similar third-party technologies may be considered a sale, sharing, targeted advertising or cross-context behavioral advertising under applicable privacy law, even where no money is exchanged.
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.
We do not knowingly sell personal data for money. We also do not knowingly use sensitive personal data or sensitive personal information to infer characteristics about individuals except as necessary to provide the services requested, comply with law, protect security, or as otherwise permitted by applicable law.
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 the personal data was provided, supporting the platform, maintaining security, processing payments and communications, and performing related business operations, even to countries that might not offer a level of protection for personal data that is equivalent to the one offered in your country of residence or in similar countries found to provide adequate safeguards to personal data. Where required by applicable law, we will implement appropriate safeguards and/or obtain the necessary consent or rely on another valid transfer mechanism before transferring personal data internationally. We may also decline to make services available in or from particular jurisdictions or may limit transfers, access or use where required for sanctions, export control, legal, regulatory or risk-management reasons.
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 welcome email and/or verification messages to verify password, username, email address and account details. After you register with our website and/or web-platform and, where required, have provided consent to receiving marketing emails, we may send you on a regular basis 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 opt out from receiving these types of non-essential communications.
We may also send you service, transactional, operational, billing, security, legal and account-related notifications regarding updates to our website and/or web-platform and our services. Where required by applicable law, we will obtain any necessary consent before sending non-essential updates or marketing messages. We may also communicate with you to provide requested services and with respect to issues relating to your account via email or phone.
Security
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.
Links
Our website and/or web-platform may contain links to other sites. Once you have used these links to leave our website and/or web-platform, you should note that we do not have any control over that other site. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this policy. You should exercise caution and look at the privacy policy applicable to the site in question.
Retention
If you register with us, we shall retain your personal data for as long as required to provide the services and for one (1) year thereafter, unless a longer retention period is required or permitted by applicable law, needed for the establishment, exercise or defense of legal claims, or required for security, fraud prevention, backup or compliance purposes. If you receive marketing communications from us, we shall retain the personal data used for such communications until you opt out, subject to lawful suppression and recordkeeping requirements. Where required by applicable law, we may also apply more specific retention periods to particular categories of personal data, including account information, transaction records, assessment records, recordings, support communications, security logs and cookie-related data, based on the nature of the data and the purposes for which it was collected and used.
If you have otherwise used our services or contacted us with a question or comment, we shall retain your personal data for as long as required to provide the services and for one (1) year thereafter in order to respond to follow-up queries, maintain records, support the services and comply with applicable obligations. Users may request deletion of their account or use self-service deletion functionality where available at any time; however, deleted data may remain in backups and archival systems for a limited period and will remain subject to applicable restrictions until removed in the ordinary course.
General
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 18, we will take steps to delete the information as soon as reasonably possible, subject to applicable law. Please immediately contact us by sending an email to [email protected] if you become aware that an individual under 18 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 England and Wales, provided that mandatory laws of your jurisdiction may apply to the extent they cannot lawfully be excluded. To the extent permitted by applicable law, the courts of England and Wales shall have exclusive jurisdiction over disputes arising out of or relating to this policy.
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.
Cookies
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.
Our website and/or web-platform uses cookies so that we can recognize you when you return and personalize your settings and preferences. Most browsers are initially set up to accept cookies. You can change your browser settings to either notify you when you have received a cookie, or to refuse to accept cookies. Please note that our website and/or web services may not operate efficiently if you refuse to accept cookies.
We might use cookies from third-party partners such as analytics, advertising and marketing providers for marketing purposes. These cookies allow us to display promotional materials to you on other sites you visit across the Internet. If and where applicable, we may also share information about your behavior on our website with third parties, including operators of third-party websites and/or social networking sites, in order to target advertisements and other content, subject to applicable law and consent requirements. Where required by applicable law, we will obtain consent before placing non-essential cookies or similar technologies, and we will provide cookie settings or other legally required mechanisms to manage your preferences and opt-out choices.
In some cases, we use cookies to associate user activity with the third party website that referred the user to our website, or to associate user activity that we referred to a third party website. We do not share any personal data or information about individual user activities with these partner entities. We also use cookies to associate user activity with the email campaign that referred the user to our website.
We use cookies to limit certain types of cyber-attacks. We also use cookies during fraud reviews and investigations. Some of our cookie/device tracking happens through third-party vendors, other times we use our own indexes to identify activity related to specific cookies.
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 analytics tools, including Google Analytics or similar services, to monitor how the website and/or web-platform is used. Such tools may collect information and generate 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. These tools may place persistent cookies on your device. If you do not agree to this use you can disable persistent cookies in your browser and, where applicable, manage your cookie preferences through our cookie settings tools. In some jurisdictions, you may also have the right to opt out of certain analytics or advertising-related data sharing through legally required opt-out preference signals or similar mechanisms that we recognize where required by law.
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 as controller, and to require us to correct errors in personal data if it is inaccurate or incomplete or to limit or object to its processing, partially or entirely. You may also have the right at any time to require that we delete your personal data or transfer it to a third party, subject to applicable law. Depending on your jurisdiction, you may also have rights relating to automated decision-making, profiling, targeted advertising, sale or sharing of personal data, use of sensitive personal information, and appeal of denied privacy requests, subject in each case to applicable law. Where we process personal data on behalf of one of our customers as processor, we may direct your request to the applicable customer, or require that you submit your request to that controller, although we may assist that controller as required. 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, where permitted by applicable law.
Additionally, rights of rectification, objection, restriction, access, portability and deletion are subject to certain limitations, as provided for by applicable laws. Individual requests will be addressed as soon as reasonably possible following their receipt and verification and in any event within the timeframe required by applicable law. Where applicable law provides a right to appeal a decision concerning a privacy request, you may exercise that right using the appeal process described in this policy.
You may also have the right to make a complaint to the relevant supervisory authority or other competent privacy regulator. 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, backup integrity, or because processing is necessary to deliver the services you or our customer have requested. Where this is the case, we will inform you of relevant details in response to your request, as appropriate.
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.