Nefesh B’Nefesh Aliyah (“NBN”) is an Israeli non-profit organization whose purpose is to aid and assist new immigrants requiring information and support concerning their immigration and absorption in Israel. To do this we need to collect personal information from you to understand your individual circumstances and needs. The security of your personal data is extremely important to us. Therefore, we want to:
- Ensure that you understand what personal data we collect about you, the reasons why we collect and use it, and with whom we share it;
- Explain the way we use the personal data that you share with us; and
- Explain your rights and choices in relation to the personal data we collect and process about you and how we will protect your privacy.
- About this Policy
From time to time, we may develop new or additional services. Unless stated otherwise, these additional services will also be subject to this Policy.
We hope this helps you to understand our privacy commitments to you. For information on how to contact us if you ever have any questions or concerns, please see the ‘How to Contact Us’ Section 9 below. If you do not agree with the content of this Policy, you may choose not to use NBN Services.
- Information We Collect and How we Collect It
We have set out below the type of personal data we collect, how we collect it, and how we use the information we collect. Unless we have noted otherwise, we use the information we collect in order to provide you with the relevant assistance in your Aliyah process by tailoring it to your specific situation and needs, help you with your absorption in Israel (at whatever stage), and to abide by our reporting requirements to governmental agencies. Most of the information we collect is provided by you. A limited amount of information will be collected from our website when you browse it. We might also collect additional information from other third parties or governmental agencies, in order to process your Aliyah application, or upon a specific request made by you post-Aliyah. You do not have to provide us with your personal information but if you choose not to provide us with that information, this may impact your use of certain features or services that NBN provides, or all of them.
- Registration Data. When you sign up to use Nefesh B’Nefesh’s Services, you provide us with certain personal data such as your name, email address, phone number, birth date, gender, country, Aliyah date, marital status, number of children, and profession, religious affiliation, and other personal information (“Registration Data”). We need this information in order to assist you in your Aliyah process and address your specific needs.
- Call Center Data. When you call our call center, you may provide us with similar types of personal data as well as other personal information such as that listed in the “Post Aliyah” section below. We will retain notes of the information you provide to us on the call, and we may also retain a digital recording of the call. It is entirely your decision as to which information you provide to us in the call. We need this information in order to assist you in the particular issue for which you requested NBN’s assistance.
- Email or Online Requests. When you send us an email or online request, we will retain the content of the message, your email address or any contact information you provide, and our response. We need this information in order to assist you in the particular issue for which you requested NBN’s assistance
- Post-Aliyah. From time to time, you also may provide us with additional personal data or give us your permission to collect additional personal data so that we can help you in your absorption in Israel and provide you with services in Israel. For example, you might request that we help you obtain a discount to which you may be entitled for “arnona” or municipality tax, and you will provide us with the information that you received from the municipality so that we can communicate with the municipality on your behalf. We need the information provided in order to assist you with your particular request.
- Employment Information and Job Board. If you requested NBN’s assistance in finding employment, then you might supply NBN with your resume and other details regarding your employment history. In addition, NBN has a “job board” to help olim find employment after making Aliyah, through which olim can contact potential employers directly. The employment information provided to NBN will be used to help you find employment in Israel and will be shared with potential employers and/or head hunters. We need the information you provide in order to assist you in your search for employment.
- Information collected from Governmental Agencies. We may collect information from governmental agencies in order to assist you in your Aliyah process or your absorption.
- Photographs. We may photograph and/or film you at NBN events and use such photographs for marketing purposes. When taking photographs and/or filming at events, we display notices at the venue to inform participants of this.
- Legal basis for processing
- It is necessary for the performance of the contract between you and NBN (for example, in order to process your Aliyah Application) or to provide you with information prior to filing for Aliyah;
- It is necessary in order for us to comply with a legal or regulatory requirement (for example, in order to update Israeli governmental authorities about your upcoming Aliyah);
- It is necessary for our legitimate interests (for example, to provide you with services relating to your Aliyah, to improve the website and our Services, or for someone’s health and safety);
- Where we have no other valid legal basis to process personal data, it will be processed based on your consent, which may subsequently be withdrawn at any time by emailing our privacy contact at firstname.lastname@example.org. Withdrawal of your consent will not affect the lawfulness of processing based on consent before its withdrawal, or processing that is being done on the basis of other lawful grounds.
- Your rights under local laws
Subject to certain exemptions, and in some cases dependent upon the processing activity we are undertaking, you may have, under certain applicable laws, some or all of the following rights in respect to your Personal Information. We remind you that we are an Israeli organization. We specifically mention the General Data Protection Regulation (“GDPR”), a European Union wide legal framework for the standardization of data protection. If you are an EU resident, you should consult the GDPR for more information on your rights.
- Right of Access: the right to be informed of and request access to the personal data we process about you;
- Right to Rectification: the right to request that we amend or update your personal data where it is inaccurate or incomplete;
- Right to Erasure: the right to request that we delete your personal data where: (i) it is no longer needed for the purposes for which it was collected, or; (ii) you have withdrawn your consent (where the processing of your personal data was based on consent); (iii) you have successfully objected (see right to object below); (iv) it has been processed unlawfully. We are not required to comply with your request to erase personal data if the processing of is it necessary for compliance with a legal obligation or for the establishment, exercise or defense of legal claims.
- Right to Restrict: the right to request that we temporarily or permanently stop processing all or some of your personal data;
- Right to Object: the right to object to your personal data being processed for direct marketing purposes and the right, at any time, to object to us processing 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 freedom;
- Right to Data Portability: the right to request a copy of your personal data in electronic format and the right to transmit that personal data for use in another party’s service; the right to request a copy of your personal data in a structured, commonly used, machine readable format, and the right to request that we transfer it directly to another data controller, but in each case only where: (i) the processing is based on your consent or on the performance of a contract with you; and (ii) the processing is carried out by automated means.
- Right not to be subject to Automated Decision-making: the right to not be subject to a decision based solely on automated decision making, including profiling, where the decision would have a legal effect on you or produce a similarly significant effect.
If you wish to issue a request to exercise your rights where applicable by law, please contact our Privacy Office at email@example.com . Please provide your name and contact information along with the request. When we receive a request to exercise one of these rights, we will indicate what personal information we require from you to validate your identity. We will also provide information on the action we intend to take on the request without undue delay. Please note, these requests are subject to applicable legal or document retention obligations imposed on us
The electronic marketing messages you receive from NBN (e.g. those sent via email) also will include an opt-out mechanism within the message itself. .
- Sharing your personal data
- To contractors, service providers, and other third parties we use to support our activities and who are bound by contractual obligations to keep personal data confidential and use it only for the purposes for which we disclose it to them, such as persons who perform maintenance on our computer systems, companies that assist us in processing transactions, an external call center that answers phone calls at certain off-hours which allows us provide additional coverage. We may also provide your name, contact details, and Aliyah date to public relations companies so that we can encourage others to make Aliyah. We may also provide your contact details and relevant details regarding Aliyah to community volunteers to assist you in your absorption process.
- To Israeli governmental agencies in order fulfill the purpose for which you provide the personal data. For example, if you apply for Aliyah, then your personal information will be transmitted to the relevant government ministries for processing of your Aliyah application (including for example, Ministry of Absorption).
- We may also transfer your information to the municipality where you intend to live upon Aliyah so that, for example, the relevant Aliyah coordinator in that city can also assist you in your absorption process; Likewise, if you request, we will transfer your information to a “Buddy Oleh” in the community in which you intend to live.
- To the Jewish Agency. The Jewish Agency is bound by contractual and other legal obligations to keep personal data confidential and use it only for the purposes for which it is disclosed to them, which may involve providing that information to third parties.
- Law enforcement and data protection authorities, if it is necessary in order to comply with any court order, law, or legal process, including to respond to any government or regulatory request when we in good faith believe it is necessary for us to do so.
- Potential employers and head hunters.
- If you become a soldier, we might provide information to additional sources in order to better provide services for lone soldiers and to liaise on their behalf with the Israel Defense Forces. We might provide information to the Israel Defense Forces or to Garin Tzabar (an organization with whom we collaborate). In addition, we provide information about you and your family members to an organization Friends of the Israeli Defense Forces (which provides grant funding for the Lone Soldiers Program) so that, inter alia, they can raise additional funding for lone soldier programs.
- Further, we might refer you to other organizations, which help Olim, such as Blev Shalem (a social work agency) or Shira Pransky Project (which help Olim navigate the Israeli healthcare system). If you request that we speak to the organization directly in order to serve you better, we will share your personal information with these organizations.
We take proper steps to ensure that recipients of your personal data are bound to duties of confidentiality and we implement data protection contractual clauses between the Parties to ensure that any transferred Personal Data, remains protected and secure. A copy of these clauses and a list of service providers and contractors can be requested by emailing our Privacy Office at firstname.lastname@example.org.
- Data Retention
We keep your personal data electronically only as long as necessary to provide you with NBN Services, and for legitimate business and legal purposes, including a legal obligation imposed by governmental agencies upon NBN to save this data. Since persons often request our assistance post-Aliyah, unless you request otherwise, we will retain your personal data post-Aliyah electronically so that we can assist you and follow up in your absorption process, or if we reasonably believe there are prospects of legal proceedings relating to the information. Our general policy is to retain the documents in your Aliyah Application for a period of ten years after you submitted them to NBN.
NBN’s website is not directed at children. NBN does not knowingly collect personal information directly from children (persons under the age of 13, or another age if required by applicable law). However, we will collect personal data regarding children from their parents or guardians because this information is required to provide the services. If you are a parent or guardian of a child who has provided personal information without your knowledge and consent, you may request we remove this child’s information by emailing our Privacy Office at email@example.com.
- Contact our Privacy Office
If you have any questions about this Policy, please contact us by emailing our Privacy Office at firstname.lastname@example.org. Alternatively, inquiries may be mailed to the following address:
5 Nachum Hefzadi