The Kabbalah Center (“Center”, “we” or “us”) respect the privacy of the users of our website (the “Site”) and our Services (together with the Site – Services) and are committed to protect the personal information that users may share with us in connection with the use of the Services.

This Privacy Policy (the “Privacy Policy”) is intended to describe how we collect personal information from you (the “User” or “you”), how we use, maintain and disclose such information when you use our Services (or any part thereof).

Capitalized terms which are not defined herein, shall have the meaning ascribed to them in our Terms of Use available at https://kabbalaheurope.com/terms-n-conditions/  which this Privacy Policy is incorporated thereto by reference.

By entering, connecting to, accessing or using the Services (or any part thereof), you agree and accept the terms and conditions set forth in this privacy policy, including the collection and processing of your personal data (as defined below). If you disagree to any term provided herein, you may not access and/or use the service in any manner whatsoever.


1. Legal Basis for Collection and Use of Personal Information

Personal Data”- Any information relating to an identified or identifiable natural person (“data subject”); and identifiable natural person is one who can be identified directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, psychological, genetic, mental, economic, cultural or social identity of that natural person.

“Non-Personal Information”- Which is non-identifying and non-identifiable information, without particular reference to the identity of the User from which such information was collected.

By using the Services, you fully understand and unambiguously consent to the terms of this Privacy Policy including the collection, use, and processing of such information according to the terms of this Privacy Policy.

We collect, process and use your information for the purposes described in this Privacy Policy, based at least on one of the following legal grounds:

  • With your consent – You are not legally obligated to provide us with any Personal Information (and you acknowledge that providing us with Personal Information is done freely). Nor are you required to use the Services in the first place. By accessing or using any of the Services you consent to this Privacy Policy and to our information practices described herein. If you do not agree to this Privacy Policy, please do not access or otherwise use the Services. You have the right to withdraw your consent at any time. However, the withdrawal of consent shall not affect the lawfulness of processing based on your consent before its withdrawal.
    Some of the services on the Center’s site require registration, where you will be required to convey with an information such as: name, address and contact information including your email address.

    The Center shall not collect an information of you enabling it personal identification, unless such information is delivered by you, at your own free will. Notice that, if you decide not to deliver an information enabling personal identification, which will be requested by the site, there will be a possibility not to receive a certain information on the site.
    The Center retains itself the right to request additional details after the registration/ the first step of collecting the data.
  • When Performing this Agreement: We collect and process your personal information in order to provide you with the Services, following your acceptance of this Privacy Policy; to maintain and improve our Services; to develop new Services and features for our Users; and to personalize the Services in order for you to get a better user experience. As the User enters and/or uses the Service, he/she may automatically provide us with his/her IP address which is used mainly for enhancing the User’s experience and for geolocation, personalization and security purposes, as further detailed below.

Legitimate interests: We process your information for our legitimate interests while applying appropriate safeguards that protect your privacy. This means that we process your information for things like detecting, preventing, or otherwise addressing fraud, abuse, security, usability, functionality or technical issues with our Services, protecting against harm to the rights, property or safety of our properties, or our users, or the public as required or permitted by law; Enforcing legal claims, including investigation of potential violations of this Privacy Policy; in order to comply and/or fulfil our obligation under applicable laws, regulation, guidelines, industry standards and contractual requirements, legal process, subpoena or governmental request, as well as our Terms of Use.

2. What are the Purposes of the Collection of Information?

We collect the above mentioned information, using advanced technics, in order to provide and operate the Services, and to give our Users information to use as applicable; to study the Information, for personalized services, notifications; to use on an aggregated, statistical basis to discover patterns and anomalies; to enable us to further develop, customize and improve the Service based on Users’ common preferences, uses, attributes and anonymized data; to enable us to provide our Users with a better user experience, with more relevant and accurate information, services, third party services, features and functionalities, statistical and research purposes, and to deliver advertising and other commercial or sponsored content from the Center’s authorized partners which may be valuable to our Users, etc.

We may share aggregated data (such as statistics about common metastasizes) with third parties for research purposes and to discover patterns and anomalies regarding such things as complications and treatment issues to help to develop better treatments and potentially manage complications. We will not share any identifying information regarding any particular user without such user prior consent.

3. What We Do with The Information Collect

We use your collected data for operating the Services and for the purposes of providing you with the Services, as described in this Privacy Policy and Terms of Use.

We retain your personal information “as is” and we may process it for operating the Services and/or for statistics and research purpose, as describe as follows, in order to improve our Services. We use this information to refine our Services to better tailor them to your needs and to communicate with you about our Services. Our Services do not entail any automated decision making which have legal influence.

We may use your personal data for statistics or research purposes while you are using our Services. By doing so, we shall use non-personal data and we shall not disclose your identified data. In case which we may need to use your identified data, we shall use appropriate safeguards to ensure that technical and organizational measures are in place, in particular, in order to ensure respect for the principle of data minimization. 

We may also use your personal data for statistics or research purposes after the termination of the Services. However, by doing so we will retain your data as non-personal information in our data base and it will be impersonalized.

We shall not use and process your personal information in order to target advertisement to you without your explicit consent.

We will not share any Personal Information with any third party, except without limitation, to the following cases: (a) to provide the Services at your request and choice (b) to satisfy any applicable law, regulation, legal process, subpoena or governmental request; (c) to detect, prevent, or otherwise address fraud, security or technical issues; (d) to respond your support requests; (e) to protect the rights, property, or personal safety of Kabbalah, any of its customers, or the general public; (f) when Kabbalah is undergoing any change in control, including by means of merger, acquisition or purchase of all or substantially all of its assets; (g) to collect, hold use and/or manage your Personal Information through our authorized third party service providers, as reasonable for business purposes (including for purposes of providing and promoting the Services); (h) to provide advertising and other commercial or sponsored content from our authorized partners which may be valuable to you or (i) pursuant to your explicit approval prior to the disclosure.

For avoidance of doubt, we may transfer and disclose to third parties or otherwise use Non-Personal Information at our own discretion, including without limitation for statistical, analytical and research purposes and for customization, developing and improvement of our Services.

4. Where Do We Store Personal Information?

4.1) The Center does not host the Services in its independent infrastructure – All hosting is done by third parties hosting providers that we engage. This means that data you provide us or that we or third parties collect from you (including any Personal Information) is hosted with such third parties service providers on servers that they own or control. Regardless of where such third parties service providers themselves are based, their servers may be located anywhere in the world. Your data may even be replicated across multiple servers located in multiple countries. So please be aware that you are consenting to your data being transferred to various third parties service providers around the world. It means that the servers which store and process the data may be located in countries outside of your jurisdiction. However, we are committed to protect your Personal Information and to take appropriate steps to ensure that your Personal Information is processed and stored securely and in accordance with applicable privacy laws, as detailed in this Privacy and Cookie Policy. Such steps include putting in place data transfer agreements or ensuring our third-party service providers comply with the Center’s data transfer protection measures.

4.2) Third parties that are maintaining your personal data and the type of information maintains are as follows:

♦ Salesforce. Comprehensive personal data includes but not limited to: birth of date, family connections, occupation, interests, purchases, invoices, courses and events. We rely on Salesforce Inc. security and privacy regarding to the infrastructure. (hereby Salesforce Inc’s Privacy Policy https://www.salesforce.com/company/privacy/).   

♦ Microsoft. Comprehensive personal data includes but not limited to: birth of date, family connections, occupation, interests, courses and events except of purchases, invoices. We rely on Microsoft security and privacy regarding to the infrastructure (hereby Microsoft Privacy Policy https://privacy.microsoft.com/en-gb/privacystatement).

♦ Netsuite. Basic personal data such as name, phone number, e-mail, address, ID number, purchases and invoices.

Cloud accounting system. Basic personal data such as name, phone number, e-mail, address, ID number, purchases and invoices.

Note to our users in Israel:

We are committed to maintaining the same level of protection as required in Israel, in a case that the hosting will occur outside Israel.

Note to our users in the EU:

If you are located in the EU, you have a right to request further information regarding the data transfer mechanisms used by us with respect to data transfers to third countries and to international organizations.

In case that your data will be stored outside the EU, we will apply strict safeguards which may include the following:

♦ Transferring your personal information to countries approved by the European Commission as having adequate data protection laws, such as Israel;

♦ Entering into standard contracts that have been approved by the European Commission and which provide an adequate level of high quality protection, with the recipients of your Personal Information;

♦ Transferring your Personal Information to organizations that are Privacy Shield Scheme certified, as approved by the European Commission.

4.3) while making purchases on our Site you are being transfer to a PCI complaint’s defrayal page. In addition, while providing us credit card details in any other way, your credit card details will be transfer only to PCI-DSS 3.2 compliant companies. We do not maintain your credit card details in our systems and infrastructure, and at the most we maintain only the credit card token.

5. Minors

To use the Service, you must be over the age of sixteen (16). The Kabbalah Center does not knowingly collect Personal Information from children under the age of sixteen (16), unless such Personal Information was provided by the User’s family member who is over the age of sixteen (16) and has all of the required consents, approvals, and rights to upload Personal Information on the minor’s behalf. We reserve the right to request proof of age at any stage so that we can verify that minors under the age of sixteen (16) are not using the Service. If it comes to our knowledge that a person under the age of sixteen (16) is using the Services, we reserve the right to prohibit and block such User from accessing the Service.

6. Cookie Policy

Like many websites we use “Cookies” to collect information.

What is a cookie? A cookie is a small file sent from a website which is then stored by your web browser. Cookies are widely used for record-keeping purposes in order to make a website work, or work more efficiently, as well as to provide information to the owners of the website

How do we use cookies? When you use a widget, or any other tool offered by us, whether on a system, device, site, or third-party site, we may record data related to that activity, the layout of the widget, or any other account-related data.

We use Google Analytics – An analytics service provided by Google, Inc. (“Google”) on the Site, to assist in analyzing the use of the site. For this purpose, Google Analytics uses cookies (text files located on your computer).

The information generated by cookies regarding the use of the Site, standard web log information (including the IP address) and anonymous visitor behavior is transmitted and stored by Google, including on US servers, we upload your IP address before sending it to Google.

In accordance with its Privacy Shield Certification, Google declares that it complies with the EU-US Privacy Shield Framework. Google may transfer the information collected by Google Analytics to third parties when required by law or when such third parties process the information on Google’s behalf.

The usage of the data collected on behalf of a third-party will be according to Google Analytics Terms of Service. (Please see the link attached:  https://www.google.com/analytics/terms/us.html.).

According to Google Analytics terms of service, Google will not associate the IP address data with any other data held by Goggle. 

You may refuse the use of Google Analytics cookies by downloading and installing Google Analytics Opt-out Browser Add-on. https://tools.google.com/dlpage/gaoptout?hl=en

Cookies are also used to record if the data subject has agreed (or not) to the use of cookies on the site, so you will not be asked the question each time you visit the site.

What can you do if you don’t want cookies on your computer? You can change your internet browser settings by following the instructions provided by your browser provider to stop accepting cookies or notify you before receiving a cookie from the site you’re visiting if you do not accept cookies. However, you may not be able to use all parts of the site or any functionality of the relevant services.

7. Direct Marketing

We will ask your explicit consent to use your contact details for the purpose of informing you regarding our products and services (which may interest you, and to send to you other marketing material, including news, updates and relevant medical data) transmitted to the e-mail address or phone number you have provided or in any other way. If you already received from us marketing information in the past and you did not ask to unsubscribe, we may continue send you marketing information.  

You may withdraw your consent at any time by clicking the “unsubscribe” link in the bottom of the message you received from us or by sending us a written notice by email to the following address: care@kabbalaheurope.com

Please note that the Center may also contact you with important information regarding our Services. For example, we may notify you (through any of the means available to us) of changes or updates to our Services, payment issues, service maintenance, etc. You will not be able to opt-out of receive such service messages. 

8. Third Parties Websites

This Privacy Notice applies only to Services provided on the System or a Device under your control, or on the Site. The Site may include links and references to the websites of others or third party advertises. These other sites may place their own cookies or other files on your computer, collect data or solicit personal information from you. Other websites follow different rules regarding the use or disclosure of the Personal Information that you submit. We encourage you to read the privacy policies and other terms of the other websites. We do not review, approve, monitor, endorse, warrant, or make any representations with respect to such websites. In no event will we be responsible or liable, directly or indirectly, to anyone for any loss or damage arising from such sites, including without limitation for your use of such website and for any information submitted by you, or otherwise collected by such websites.

9. Changes to the Privacy Policy

The Kabbalah Center reserves the right to change this Privacy Policy at any time so please re-visit this page frequently. We will provide notice of substantial changes of this Privacy Policy on the Service and/or we will send you an e-mail regarding such changes to the e-mail address that is registered with your Account. Such substantial changes will take effect seven (7) days after such notice was provided on any of the above-mentioned methods. Otherwise, all other changes to this Privacy Policy are effective as of the stated “Last Revised” date, and your continued use of the Service after the Last Revised date will constitute acceptance of, and agreement to be bound by, those changes.

10. Retention Period

Any personal information collected will be retained by us as long as you are using our services. After termination of the Services we will retain your information according to the circumstances in which it was shared and on a need basis in order to comply with regulations and legitimate interests.

Beyond that, if you will not use our Services for one (1) year (without asking explicitly to terminate the Services) we will erase some of your personal information which is not necessary on a need basis in order to comply with regulations.

Either way, we will not retain unnecessary personal data, nor keep it beyond regulatory and legitimate interests required periods.

11. Rights

You have several rights regarding to your personal information, such as access and change of your personal information. If you wish to implement any of your rights, please contact us at care@kabbalaheurope.com.

Note to our users in Israel:

The Israeli law provides you certain rights as described as follows:

(a)    You have the right to inspection – You are entitled to inspect your personal information which is being held in our data bases, by yourself or by your legal representative. In order to do so, please contact us by email (enter email address). We will reply to your request as soon as possible and if applicable we will allow you to inspect your personal information no more than 30 days after submitting the request.

(b)    You have the right to rectify incorrect or incomplete personal information – After you inspect your personal information and find it incorrect or incomplete, you are entitled to contact us by email (enter email address) in order to rectify or delete this information. We will reply to your request as soon as possible and no longer than 30 days after submitting the request.

 

Note to our users in the EU:

The European Union’s General Data Protection Regulation (GDPR) provides you certain rights as described as follows:

(a)    You have a right to withdraw your consent at any time. However, the withdrawal of consent shall not affect the lawfulness of processing based on your consent before its withdrawal.

(b)    You have the right to access your personal data and supplementary information, rectify your data and data portability. By using our site, you have a direct access to all your personal information that you provide to us. In that way, you can rectify inaccurate personal data concerning to you. In case which there are personal information which you can’t rectify, you can contact us, and we will rectify your information without undue delay. If you’d like, we can give you this information in a structured, commonly used and machine-readable format.

(c)    You have the right to erase your information (“The right to be forgotten”). However, such a decision may result in the need to terminate the Services provided to you. This right applies in certain circumstances and as long there is not a legal requirement or duty which determine otherwise. Note that we may retain your Personal Information for a minimum period required to provide the Services, or pursuant to any applicable law and legitimate interests. Please note, upon request to delete your account, the Center may depersonalize (and un-identifiable) your personal information and/or your service activity history for the purpose of enhancing and improving our Services. 

(d)   If you consider that your rights under the GDPR are infringed, you have the right to lodge a complaint with a supervisory authority.

For more information regarding to your rights according to the GDPR you can visit the United Kingdom’s Information Commissioner’s Office website:

  https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr

 

12. Contact us

If you have any questions (or comments) concerning this Privacy Policy, you are welcome to send us an email at care@kabbalaheurope.com and we will try to reply within a reasonable timeframe.

By contacting us, you acknowledge the fact that, if the information delivered by you is not enough for the Center to make a definite identification of you, the Center may request the provision of additional data necessary to confirm the identity of the data subject.