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Last Updated: September 9, 2020
Keter Plastic Ltd, Keter UK Ltd, Keter US Inc, Keter Luxembourg Sarl and their affiliates (including wholly and partially owned subsidiaries) ("Keter", "we", "our" or the "Company", and their cognates) respects the privacy of its customers, employees and candidates, and is committed to protecting the personal information you share with us. We also protect the privacy of our website visitors, site visitors, followers, vendors, service providers, consumers, partners and others who come in contact with Keter (these and any others with respect to whom we collect personal data, shall collectively be referred to as "Customers" or "you" or “Data Subjects”).
Please read the following carefully to understand our practices regarding your personal data and how we will process it.
For the purposes of EU’s General Data Protection Regulation (“GDPR”) and other applicable European Economic Area data protection law, (the "Data Protection Law"), Keter will usually be a data controller (the "Controller").
Summary: we collect various categories of personal data in order to meet our contractual obligations, and also to meet various legitimate interests, such as fraud prevention and marketing.
There are several categories of information and data we collect from our Customers. This includes data you provide to enable us to communicate with you, sell you our products, and provide services including on our websites.
One type of Data we process is non-identifiable and anonymous information ("Non-Personal Data"). We also collect several categories of personal data, also called personal information ("Personal Data"). Personal Data which is being gathered consists of any details which are personally identifiable provided consciously and voluntarily by you, or by an organization you represent or are associated with or through your purchases of Keter products, or your use of Keter services, or your provision of services/product to Keter, including use of the Keter’s websites (as described below). This may include personal information, such as: your name (first and last), email address, phone numbers, picture, postal address, birthdate or year of birth, gender, position and organization name, billing details, billing address, login credentials, your Keter account username and password and usage details, and other information you choose to provide to Keter. Additionally, we may obtain location data related to the geographic location of your laptop, mobile device or other digital device on which the Keter website(s) is used. You do not have any legal obligation to provide any information to Keter, however, we require certain information in order to perform contracts, such as sale or purchase, or to provide any services and products. If you choose not to provide us with certain information, we may not be able to provide you with some or all of the services or fulfill your order for products. Keter also collects the email addresses of people who communicate with Keter via email or via messenger services or other social media platforms or create accounts and login credentials. By registering on Keter’s website(s), or submitting requests for support or information via the website(s), Keter will collect details, including also your name, your company name, your phone number and the personal or company email you provided, your address, your birthdate and other such information. Keter uses this information to offer Keter’s services and support, and will share this data across Keter group companies and service providers in order to optimize its services. You may create a Keter account on certain Keter websites. In some cases you may be able to access Keter services through login credentials of a designated third party website or service (each a “Third Party Account”), including but not limited to Google, LinkedIn, Facebook or Twitter. Doing so will enable you to link your Keter account and your Third-Party Account. If you choose this option, then you will be required to approve the connection as well as the provision of information (which may include Personal Information, such as your profile picture, gender, birthdate, headline, summary that appears in the profile, friends’ lists, previous positions and organizations), that we obtain from your Third Party Account. Any data submitted to any Third-Party Account, even on and through Keter services, is managed directly by such third party and is not the responsibility of Keter. Keter also collects Personal Data through the use of CCTV cameras and employee’ site access cards. This consists of video images of you in the public spaces at Keter sites, as well as records of your entrances and exits of the Keter sites, buildings and office floors. It also includes identity verification systems and data. We may not always be aware of the nature of the information collected through our services (for example, through our CCTV systems), and such information may inadvertently include sensitive or special categories of Personal Data, but we do not knowingly collect such data about our Customers, members, site visitors etc. We collect this Personal Data based on our legitimate interest in keeping our premises safe and secure and preventing and responding to crime. Keter also collects data relating to its employees. This is governed by a specific notice we have made available to our employees. Keter also collects data relating to employment candidates. This includes CVs and the data contained therein, notes on meetings, standardized tests, reports, references, interviewer impressions and such industry standard data, as well as collecting data made publicly available or available to us on social networks. We collect such data based on the intention of the candidate to enter into an employment agreement with Keter.
Summary: we collect personal data when you or your organization send it to us, or when a vendor sends it to us so; we collect personal data through our websites and services.
We collect Personal Data through your use of our websites. In other words, when you are using the websites, we are aware of it and will gather, collect and record the information relating to such usage, either independently or through the help of third-party services as detailed below. This may include technical information and behavioral information such as your Internet Protocol (IP) address, your uniform resource locators (URL), the operating system of your browsing device, type of browser, browser plug-in types and versions, screen resolution, Flash version, time zone setting, the User’s ‘clickstream’ on the website, the period of time the User visited the website, methods used to browse away from a page, and any phone number used to call our customer service number. We likewise place cookies on your browsing devices through which you visit our websites (see section 6 below).
We collect Personal Data required to provide services when you register interest, make an order, register for warranty, contact our support centers, contact us for information, sign up for newsletters and updates, or open an account. In most cases, you provide this information to us directly, in other cases your employer or an organization you represent may provide this information, or it may be provided by a vendor with whom you have contracted. We also collect Personal Data through our CCTV recordings and through our card reader software, which automatically collect information about your presence in Keter facilities. We collect Personal Data when you apply for a position at Keter, and throughout the recruiting process – such as through interviews, references, background checks and so on.
Summary: we process personal data to meet our obligations, protect and enforce our rights and manage our business.
We will process Personal Data to provide and improve our services to our customers and others and meet our contractual, ethical and legal obligations, including for example:
In all cases, assembly requires no special DIY skill and involves standard household tools, for quick, easy construction.
Processing which is necessary for the purposes of the legitimate interests pursued by Keter or by a third party of providing an efficient and wide-ranging service to Customers:
Processing which is necessary for compliance with a legal obligation to which Keter is subject:
Summary: we share personal data with our service providers, partners, group companies and authorities where required.
We transfer Personal Data to: Members of our Group: This includes any member of our group, which means our subsidiaries - whether wholly or partially owned by Keter, in the EU, in Israel, in the US, in Canada and elsewhere. Third Parties. We transfer personal data to third parties in a variety of circumstances. We take steps to ensure that these third parties use your information only to the extent necessary to perform their functions, and in particular we have a contract in place with them to govern their processing on our behalf. These third parties include business partners, suppliers, affiliates, agents and sub-contractors for the performance of any contract we enter into with you. They assist us in providing the products we offer, processing transactions, fulfilling requests for information, receiving and sending communications, analysing data, providing IT and other support services or in other tasks, from time to time. These third parties also include analytics and search engine providers that assist us in the improvement and optimisation of our website and our marketing. They also include service providers who may help prevent fraud, protect Keter, its staff and its property, and assert our rights.
We periodically add and remove third party providers. At present, third party providers to whom we transfer personal data include also the following:
Summary: we retain personal data according to our data retention policy, as required to meet our obligations, protect our rights, and manage our business.
Keter will retain Personal Data in accordance with our data retention policy, as long as required to provide the services and as necessary to comply with our legal and other obligations, to resolve disputes and to enforce agreements. We will also retain personal data to meet any audit, compliance and business best-practices.
Our websites may, from time to time, contain links to external sites. We are not responsible for the operation, privacy policies and practices or the content of such sites.
Summary: we take data security very seriously, invest in security systems, and train our staff. In the event of a breach, we will notify the right people as required by law.
We take great care in implementing, enforcing and maintaining the security of Personal Data. Keter implements, enforces and maintains security measures, technologies and policies to prevent the unauthorized or accidental access to or destruction, loss, modification, use or disclosure of personal data. We likewise take steps to monitor compliance of such policies on an ongoing basis. Where we deem it necessary in light of the nature of the data in question and the risks to data subjects, we may encrypt data. Likewise, we take industry standard steps to ensure our websites are safe. Note however, that no data security measures are perfect or impenetrable, and we cannot guarantee that unauthorized access, leaks, viruses and other data security breaches will never occur. Within Keter, we limit access to personal data to those of our personnel who: (i) require access in order for Keter to fulfil its obligations, and (ii) have been appropriately and periodically trained in Personal Data practices, and (iii) are under confidentiality obligations as may be required under applicable law. Keter shall act in accordance with its policies and with applicable law to promptly notify the relevant authorities and data subjects in the event that any personal data processed by Keter is lost, stolen, or where there has been any unauthorized access to it, all in accordance with applicable law and on the instructions of qualified authority. Keter shall promptly take reasonable remedial measures. We store Personal Data on devices and servers which will be owned or controlled by Keter in our various sites, or processed by third parties on behalf of Keter, by reputable cloud-service providers. Personal Data is stored in all Keter group locations, such as USA, Israel, UK, EU, Australia, Brazil and many more.
Summary: we transfer personal data within and to the EEA, UK, USA, Israel and elsewhere, with appropriate safeguards in place. We store your personal data across multiple locations globally.
Summary: depending on the law that applies to your personal data, you may have various data subject rights, such as rights to access, erase, and correct personal data, and information rights. We will respect any lawful request to exercise those rights.
Data subjects with respect to whose data Californian law applies, please see section 11 below. Data subjects with respect to whose data GDPR applies, have rights under GDPR and local laws, including, in different circumstances, rights to: data portability, access data, rectify data, object to processing, and erase data. It is clarified for the removal of doubt, that where personal data is provided by a customer being the data subject's employer, such data subject rights will have to be effected through that customer. In addition, data subject rights cannot be exercised in a manner inconsistent with the rights of Keter employees and staff, with Keter proprietary rights and other Keter rights and legal interests, and third party rights. As such, job references, reviews, internal notes and assessments, documents and notes including proprietary information or forms of intellectual property, cannot generally be accessed or erased, and may not be rectifiable. In addition, these rights may not be exercisable where they relate to data that is not in a structured form, for example emails, or where other exemptions apply. If processing occurs based on consent, data subjects have a right to withdraw their consent. Cookies and any rights associated with cookies may be exercised through our cookie management tool, or your own device and browser settings. If, for any reason, a data subject wishes to exercise these rights and modify, delete or retrieve their Personal Data, they may contact Keter by email (firstname.lastname@example.org). Note that Keter will undertake a process to identify a data subject exercising their rights. Keter may keep details of such rights exercised for its own compliance and audit requirements. Data subjects in the EU have the right to lodge a complaint, with a data protection supervisory authority in the place of their habitual residence. Our lead supervisory authority is the National Commission for Data Protection (‘CNPD’) of the Grand Duchy of Luxembourg (complaints may be lodged at https://cnpd.public.lu/en/particuliers/faire-valoir/formulaire-plainte.html). If the supervisory authority fails to deal with a complaint you may have the right to an effective judicial remedy.
Summary: The California Consumer Privacy Act (“CCPA”) provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights. Access to Specific Information and Data Portability Rights.
You have the right to request that Keter disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Websites that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to email@example.com.
Summary: we do not knowingly collect data of minors aged 16 or under. We may make changes to this policy. Mistakes in translation of this policy may occur. You may contact us with suggestions or complaints regarding personal data.
Keter and Keter’s Data Protection Officer contact details: Keter Plastic Ltd., 1 Sapir Street Herzliya, Israel firstname.lastname@example.org.