There are some legal bases for the processing of your personal data and we count on them to process your personal data. We use the main three bases to process your personal data: consent, and legitimate interest.
Consent - your clear agreement to the processing of your personal data for a specific purpose.
Legitimate Interests - the reason why the processing your data is necessary which is based on the legitimate interests or the legitimate interests of a third party, provided those interests are not outweighed by your rights and interests and those interests have a specific purpose, they are necessary, and they are balanced).
Some applicable laws may indicate other legal grounds for the processing and when applicable we will count on such grounds.
If you have given consent to the processing of your data you can freely withdraw such consent at any time by contacting us.
If you do withdraw your consent, and if we do not have another legal basis for the processing of your data, then we will stop the processing of the personal data and may delete in specific situations, including in case if you request the deletion of your personal data and we are obliged to delete.
If we have another legal basis for the processing of your data, then we may continue to do so, subject to your legal interests and rights.
When we process personal data, we have obligations according to the applicable laws. We act as a data controller when we determine the purposes and means of the processing of your personal data. As a data processor, we process personal data on behalf of the controller.
According to the applicable law, you may become a data controller/processor and it will impose on you additional obligations.
We process personal data when you interact with our website http://smarterflyer.com/ (the “Platform”), especially:
We collect the following types of data:
The recipients of the collected data are the highest management level of our company.
We process the data for:
You may ask us to refrain from using your data for marketing (when you opted-in). You can opt-out from marketing by contacting via the contact form.
You can exercise the following rights by sending us by contacting via the contact form.
You have the right to access information about you, especially:
You have the right to make us correct any inaccurate personal data about you.
You can object to using your personal data for profiling you or making automated decisions about you. We may use your data to determine whether we should let you know information that might be relevant to you (for example, tailoring emails to you based on your behavior).
You have the right to the data portability of your data to another service or website. We will give you a copy of your data in a readable format so that you can provide it to another service. If you ask us and it is technically possible, we will directly transfer the data to the other service for you.
You have the right to be “forgotten”. You may ask erasing any personal data about you if it is no longer necessary for us to store the data for purposes of your use of the Platform.
You have the right to lodge a complaint regarding the use of your data by us. You can address a complaint to your national regulator.
In the context of the right to access information, we shall provide you with the information within one month of your request unless there is a justified requirement to provide such information faster. This term may be extended according to the applicable law.
We have security and organizational measures and procedures to secure the data collected and stored. You acknowledge that no data transmission is guaranteed to be 100% secure and there may be risks. You are responsible for your login information and password. You shall keep them confidential. In case if your privacy has been breached, please contact us immediately.
The personal data is collected by our company incorporated in Israel.
Our servers are provided by hosting provider. We store your personal data on Google Cloud, based out of the United States of America which participates in and has certified their compliance with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List.
There are the following third parties:
We store personal data as long as we need it and the retention practice depends on the type of data we collect, regulatory burden, and how we use the personal data. The retention period is based on criteria that include legally mandated retention periods, pending or potential litigation, intellectual property or ownership rights, contract requirements, operational directives or needs, and historical archiving.
Our usual retention period is 18 months.
We collect certain types of information when you access or use the Platform, including cookies and similar tracking technologies.
Cookies are small data files that are placed on your computer or mobile device when you visit the Platform. Cookies are used by the Platform in order to make the Platform work, or to work more efficiently, as well as to provide reporting information.
We collect essential cookies, functionality cookies, analytics and performance cookies.
In case if you reside in the EU/EEA and we offer our services or goods in your country, we would like to inform you that information we collect from you will be processed in Israel which has got a finding of “adequacy” from the European Union under Article 45 of the GDPR (https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32011D0061). The finding allows us to transfer the information from the EU/EEA to Israel without any derogations.
We store your personal data on Google Cloud, based out of the United States of America which participates in and has certified their compliance with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List.
If you still have any question or need a clarification with regard to our privacy practice, please contact us: