We at CyberWell Ltd. (CC) (“CyberWell“, “us“, “we“, or “our“) recognize and respect the importance of maintaining the privacy of our users. CyberWell has developed and maintains a publicly available database platform of online antisemitism, available to you through this website (“Platform“). This Privacy Notice describes the types of information we collect from you when you visit our Platform and/or use our services thereon (such services, together with the Platform, “Services“). This Privacy Notice also explains how we process, transfer, store and disclose the information collected, as well as your ability to control certain uses of the collected information. If not otherwise defined herein, capitalized terms have the meaning given to them in the Terms of Service, available at https://cyberwell.org/terms-of-use/ (“Terms“). “You” means an individual visiting the Platform and/or using the Services as a visitor and/or registered user, as applicable.
“Personal Data” means any information that refers, is related to, or is associated with an identified or identifiable individual or as otherwise may be defined by applicable law. This Privacy Notice details which Personal Data we collect when we provide the Services to you.
Personal Data We Collect.
- Registration. In order to use all of our Services, you will be required to register through a third-party login service, such as Google, Twitter, Facebook or other services, as may be amended from time to time (“Third-Party Login“). We may receive Personal Data about you as provided by such Third-Party Login service. Please check such Third-Party Login’s policies in order to understand what information we receive and/or my collected by such third parties about you.
- Contact Us. We also collect Personal Data when you make use of the Services, request information from us, including to sign-up for our newsletter, request a demo, request to partner with us, request to become a key philanthropic supporter, or contact us for any other reason. Examples of the Personal Data that we collect from you when you engage in any of the activities detailed above, may include your name, e-mail address, name of your organization and a link to its website, and the content of your inquiry.
- Automatic Collection. In addition, when you use the Services, we may gather certain information automatically about your computer or mobile device, such as your operating system, your IP address, device ID, and subject to your consent as may be required under applicable law, (geo) location, as well as your browsing history and any other information regarding your use and viewing on our Services.
- Antisemitic Content. The Services present antisemitic content published by users on social media (“Antisemitic Content“), collected by us and/or trusted third parties. Such Antisemitic Content is publicly available on social media. Without derogating from the disclaimers of warranties in the Terms, CyberWell uses reasonable commercial efforts to assess the Antisemitic Content and analyze whether it constitutes antisemitic content and/or whether it violates the community standards, hate speech and/or other applicable terms or policies of the third-party social media platform on which it was posted, in accordance with our Policy Guidelines, available at https://cyberwell.org/how-it-works/policy-guidelines/. To the extent we have determined the Antisemitic Content is in violation as aforementioned, we will publish on our Platform the content of the Antisemitic Content, user account name and date of publication, and the identity of the social media platform on which the Antisemitic Content was published, all of which may be deemed Personal Data.
- Report. In the future, we may further develop the Services to allow you to report antisemitic content you may encounter on social media (“Report“). Following an assessment (as detailed in Section 1.4 above), we may publish the Report on our Platform, and report the content of the Report to the relevant third-party social media platform, at our discretion. Subject to your consent, we may publish (i) your user-name as the source of the Report, and (ii) a link to your organization’s website (as provided), if applicable.
- You are under no legal obligation to provide us with any Personal Data. It is your voluntary decision whether to provide us with any Personal Data, but if you refuse to provide such information, we may not be able to register you and/or provide you with certain Services.
How We Use Your Personal Data.
- General. We and any of our trusted third-party subcontractors and service providers use the Personal Data we collect from and about you for any of the following purposes: (1) to provide you with the Services; (2) to respond to your inquiries or requests, contact and communicate with you; (3) to develop new products or services and conduct analyses to improve our current content, products, and Services; (4) to contact you with informational newsletters and promotional materials relating to our Services; (5) to review the usage and operations of our Services; (6) to use your data in an aggregated, non-specific format for analytical purposes (as detailed below); (7) to prevent fraud, protect the security of our Services, and address any problems with the Services; and (8) to provide customer support.
- Statistical Information and Analytics. We and/or our service providers use analytics tools to collect and analyze information about the use of the Services, such as how often users visit the Platform, what pages they visit when they do so, and what other sites and mobile applications they used prior to visiting the Platform. By analyzing the information we receive, we may compile statistical information across a variety of platforms and users. This helps us improve our Services by allowing us to identify new trends and customer needs, which in turn allows us to consider new products and services or tailor existing products and services accordingly.
- Research. We and/or our trusted third-party service provider may use all Antisemitic Content, including through Reports, in order to provide the Services and to create an Antisemitic Content database, create reports and analyses and provide additional services, all in furtherance of our mission (as further detailed at – https://cyberwell.org/our-team/our-mission/). We may also grant access to such information to third parties at our discretion, including for commercial purposes.
Sharing the Personal Data We Collect.
- We share your information including Personal Data, as follows:
- Service Providers and Subcontractors. We disclose information, including Personal Data we collect from and/or about you, to our trusted service providers and subcontractors, who use such information to: (1) help us provide you with the Services; and (2) aid in their understanding of how users are using our Services. Such service providers and subcontractors provide us with IT and system administration services, data backup, security, and storage services, data analysis.
- International Transfers. You acknowledge and agree that we may use subcontractors and service providers who are located in countries other than your own and may send them information we receive (including Personal Data). All of our subcontractors and service providers will be subject to non-disclosure and non-use obligations.
- Business Transfers. Your Personal Data may be disclosed as part of, or during negotiations of, any merger, sale of company assets or acquisition (including in cases of liquidation). In such case, your Personal Data shall continue being subject to the provisions of this Privacy Notice.
- Law Enforcement Related Disclosure. We may share your Personal Data with third parties: (i) if we believe in good faith that disclosure is appropriate to protect our or a third party’s rights, property or safety (including the enforcement of the Terms and this Privacy Notice); (ii) as is necessary to comply with any legal and/or regulatory obligation; or (iii) when required by subpoena, court order or the order of another governmental or law enforcement authority.
- Legal Uses. We may use your Personal Data as required or permitted by any applicable law, for example, to comply with audit and other legal requirements.
- Other Uses or Transfer of Your Personal Data. If you use our Services with or through a third-party service (such as a Third-Party Login), site and/or mobile application, we may receive information (including Personal Data) about you from those third parties. Please note that when you use third parties outside of our Services, their own terms and privacy policies will govern your use of those services.
- We make efforts to follow generally accepted industry standards to protect the Personal Data submitted to and collected by us, both during transmission and once we receive it. However, no method of transmission over the Internet or method of electronic storage is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security. As the security of information depends in part on the security of the computer you use to communicate with us and the security you use to protect user IDs and passwords, please take appropriate measures to protect this information,
- Subject to applicable law, you may request to: (i) know the Personal Data and/or type of Personal Data we collected about you and circumstances related to such collection, (ii) rectify such Personal Data in case it is incorrect or not up to date; and/or (iii) delete such Personal Data. You may exercise such rights by emailing us at [email protected], subject to applicable law.
- Subject to applicable law, we retain Personal Data as necessary for the purposes set forth above. We may delete information from our systems without notice to you once we deem it is no longer necessary for these purposes.
- In some circumstances, we may store your Personal Data for longer periods of time, for instance where we are required to do so in accordance with legal, regulatory, tax, audit, accounting requirements and so that we have an accurate record of your dealings with us in the event of any complaints or challenges, or if we reasonably believe there is a prospect of litigation relating to your Personal Data or dealings.
Cookies and Similar Technologies.
- What are cookies? A cookie is a small piece of text that is sent to a user’s browser or device. The browser provides this piece of text to the device of the originating user when this user returns.
- A “session cookie” is temporary and will remain on your device until you leave the Platform.
- A “persistent” cookie may be used to help save your settings and customizations across visits. It will remain on your device until you delete it.
- First-party cookies are placed by us, while third-party cookies may be placed by a third party. We use both first- and third-party cookies.
- We may use the terms “cookies” to refer to all technologies that we may use to store data in your browser or device or that collect information or help us identify you in the manner described above, such as web beacons or “pixel tags”.
The specific names and types of the cookies, web beacons, and other similar technologies we use may change from time to time. However, the cookies we use generally fall into one of the following categories:
Type of Cookie Why We Use These Cookies Necessary These cookies are necessary in order to allow the Services to work correctly. They enable you to access the Services, move around, and access different services, features, and tools. Examples include remembering previous actions (e.g. entered text) when navigating back to a page in the same session. These cookies cannot be disabled. Functionality These cookies remember your settings and preferences and the choices you make (such as language or regional preferences) in order to help us personalize your experience and offer you enhanced functionality and content. Security These cookies can help us identify and prevent security risks. They may be used to store your session information to prevent others from changing your password without your login information. Performance/Analytics These cookies can help us collect information to help us understand how you use our Services, for example whether you have viewed messages or specific pages and how long you spent on each page. This helps us improve the performance of our Services.
Additionally, cookies may be placed in messages we send in order to track your interaction with such emails.
- How to Adjust Your Preferences. Most Web browsers are initially configured to accept cookies, but you can change this setting so your browser either refuses all cookies or informs you when a cookie is being sent. In addition, you are free to delete any existing cookies at any time. Please note that some features of the Services may not function properly when cookies are disabled or removed.
Third-Party Applications and Services.
- All use of third-party applications or services is at your own risk and subject to such third party’s terms and privacy policies.
- We reserve the right to send you service-related communications, including service announcements and administrative messages, without offering you the opportunity to opt out of receiving them. Should you not wish to receive such communications, you may cancel your account.
- We do not knowingly collect Personal Data from children under the age of thirteen (13). In the event that you become aware that an individual under the age of thirteen (13) has registered without parental permission, please advise us immediately.
Changes to the Privacy Notice.
- We may update this Privacy Notice from time to time to keep it up to date with legal requirements and the way we operate our business, and we will place any updates on this webpage. Please come back to this page every now and then to make sure you are familiar with the latest version. If we make material changes to this Privacy Notice, we will seek to inform you by notice on our Platform or via email.
Comments and Questions.
- If you have any comments or questions about this Privacy Notice or if you wish to exercise any of your legal rights as set out herein, please contact us at [email protected].
Last updated: December 2022