Last Revised: March 24, 2021
The Kleros Project, a project of the History School in Tel Aviv University d/b/a the Kleros Project (“The Kleros Project”, “we” or “us”), respects the privacy of the users, visitors and nominees on its website at https://www.klerosproject.org/ (the “Site” and “User” or “you”, respectively), and is committed to protect the personal information that its Users share with it. We believe that you have a right to know our practices regarding the information we may collect and use when you use the Site.
Please read the following carefully to understand the Kleros Project's views and practices regarding your personal information and how the Kleros Project will treat it.
Table of Content
- Who we are
- Your acknowledgment of this policy
- What are the Purposes of the Collection of Information?
- How Do We Collect Information on Our Users?
- What are the Purposes of the Collection of Information?
- Sharing Information with Third Parties
- Your Rights
- Location of Your Data
- Third Party Service Providers
- Links to Third Party Websites
- Data Retention
- Got any Questions?
2. Who we are
In this policy, references to the Kleros Project, or to "we" or "us" are to the Kleros Project, Tel Aviv University, Tel Aviv 6997801. If you wish to contact us about data protection issues you may do so by writing to us at the above address or by emailing us at [email protected].
3. Your acknowledgment of this policy
4. Which information we may collect on our Users?
We collect two types of data and information from Users of our Site:
4.1. Non-Personal Information. The first type is non-identifiable and anonymous information. Non-personal information, which we may collect, consists of technical information and behavioral information that does not pertain to a specific individual (“Non-Personal Information”).
You may access and browse the Site without disclosing personal information, although, like most websites and online services, we passively collect certain Non-Personal Information from your devices when you access and browse the Site , including: (i) technical information such as the type and version of your device and its operating system, the type of browser, screen resolution, device browser and keyboard language, Wi-Fi connectivity and the type and name of your device and/or browser, etc.; and (ii) behavioral information which may include the User’s click-stream on the Site, the activities of the User on the Site and additional information of a similar nature (collectively, “Technical and Behavioral Information”). We may also use third-party service providers such as Google Analytics to obtain detailed analytics on the device and the User's behavior on the Site.
4.2. Personal Information. The other type of information we collect is individually identifiable information. Put simply, this information identifies an individual or is of a private and/or sensitive nature, such as your contact information (“Personal Information”), including:
4.2.1. Personal Information which is provided voluntarily:
- Communications with the Kleros Project: Personal Information you provide as part of any communications with the Kleros Project, by any means, including when enquiring about our scholarships and prizes by phone or by email.
- Contact Details: when you enquire about the Kleros Project's services via the Site (e.g. by filling out the “Contact Us“ form on the Site), we will ask you to provide us with some or all of the following details: full name, phone number, e-mail address, address, the name of your organization and a free text message.
- Newsletter: when subscribing to our newsletter, you will be required to provide us with your name and e-mail address.
- Search Tab: when using the “Search” tab, we will record any keywords included in your searches.
4.2.2. Personal Information relating to nominees and scholarship applicants:
You may use the "Nominations" and/or "Scholarship Applications" pages available on our Site to submit nominees for the Kleros Project or to apply for a scholarship, and in such case the following applies:
- As part of the submission of an application or a nominee, you will be required to provide certain Personal Information, as detailed in the applicable form available on the Site, including the nominee's/applicant's title, full name, full curriculum vitae, a list of publications, letters of recommendation, etc.
- The Personal Information collected as part of the application process, including any Personal Information included in any attached document (such as CVs and letters of recommendation) may be accessed by the Kleros Project staff managers and stakeholders worldwide, solely for the purposes of evaluation and to enable us to contact you.
- Please note that if you have received a prize, grant or scholarship from the Kleros Project, any Personal Information collected as part of the application process will be retained by the Kleros Project as long as we are comfortable that it is accurate and can be relied upon.
4.2.3. Personal Information collected via technology:
- Geolocation data: while using the Site we will access, collect, process, monitor and/or remotely store "geolocation data", including through the collection of IP addresses and other similar information to determine your location for analytics and security purposes.
- Technical and Behavioral Information: to the extent that the Technical and Behavioral Information detailed above under Section 4.1 will be linked to or associated with a specific individual then such information will be considered Personal Information.
4.3. Please note:
- We may cross-reference Personal Information with other Personal Information we have about you and any Non-personal Information connected or linked to or associated with any Personal Information shall be deemed as Personal Information as long as such connection, linkage or association exists.
5. How Do We Collect Information on Our Users?
There are two main methods we use:
a) We collect information through your entry, connection, access and/or use of the Site. In other words, when you are using the Site we are aware of it and may gather, collect and store the information relating to such usage (such as the Non-Personal Information detailed above and your IP address).
b) We collect information which you provide us voluntarily. For example, we collect Personal Information when you apply for a scholarship or when you contact us via the Site. We may gather, collect and store such information either independently or through the help of our authorized third-party service providers as detailed below.
6. What are the Purposes of the Collection of Information?
We collect Non-personal Information and Personal Information in connection with use of our Site.
Non-personal Information is processed in order to:
- Use it for statistical and research purposes and for customization and improvement of our services;
- Improve the quality of our service by formulating, customizing and enhancing the User's experience on the Site; and
- Keep the Site safe and secure and for prevention of fraud.
Personal Information is processed in order to:
- Enable the operation of the Site;
- To process, examine and evaluate application for scholarships and nominations for our prize;
- Your contact details are processed to contact you by email, SMS, phone, through web-browser notification or through the post and provide you with updates, notices, announcements, and additional information relating to the Kleros Project or other services you enquired about via the Site;
- Add your email address to our database for the purposes of sending you information about the Kleros Project. You have the right to opt-out of marketing messages at any time by following the instructions in such message or by contacting us at: [email protected]. For email marketing to an individual subscriber (that is, a non-corporate email address) with whom we have not previously engaged as a client, we may need your consent to send you unsolicited email marketing;
- Ensure that content on the Site is presented in an optimal way for you and for your device (e.g. tablet, mobile phone);
- Conduct internal operations, including troubleshooting, data analysis, testing, research and statistical purposes;
- Keep the Site safe and secure and for prevention of fraud and crime;
- Comply with our legal obligations and in order to be able to protect our rights and legitimate interests, including in order to improve the Site;
- Maintain our data processing records and general administrative purposes;
- Email tracking – we may use tracking technology within the email we may send you in order to improve interactions with you and to better understand whether our emails were opened and read, and such tracking may include capturing the time and date in which you opened our email messages and the type of device you use to open such emails.
Note to our Users in the EU:
In order for the Kleros Project to process your Personal Information, as detailed herein, such processing must be justified by a "basis" for processing. Please note that the Personal Information processing activities detailed herein may be justified on the basis that:
- the processing is necessary to comply with a legal obligation - we may process your Personal Information for disclosure of information to authorities; and
- the processing is in our legitimate commercial interests - subject to your interests and fundamental rights, under our legitimate interest in marketing our services and offering the public comfortable and safe access to our Site, we shall perform the Personal Information processing activities described herein, such as the processing of your Personal Information in order to prevent crime and fraud, manage our internal operations, maintaining records and email tracking. We may also use the information contained in certain cookies and other such files or tags based on such ground for our legitimate interests in a safe and user-friendly presentation of our Site. Where we rely on legitimate interests as a lawful basis, we will carry out a balancing test to ensure that your interests, rights and freedoms do not override our legitimate interests.
Note to non-EU Users:
BY ENTERING, CONNECTING TO, ACCESSING OR USING THE SITE, YOU CONSENT TO THE COLLECTION AND PROCESSING OF YOUR PERSONAL INFORMATION AS SPECIFIED HEREIN.
7. Sharing Information with Third Parties
7.2. In addition to using the information collected by us for the purposes described under Section 6 above, we may also share your information in the following cases:
The Kleros Project Personnel: Personal Information that we collect and process may be transferred to or accessed by personnel of the Kleros Project for the sole purpose of enabling the operation of the Site and to contact you (as detailed in Section 6 above). Please note that all Kleros Project personnel that will have access to your Personal Information are under an obligation of strict confidentiality with respect to such Personal Information.
Service Providers: we share Personal Information with vendors, commercial software providers, consultants and data processers who perform services on our behalf, including without limitation, companies that provide analysis, messaging services and services which host the Site. Please note that we collect, hold and manage your Personal Information through a third party's cloud based services, as reasonable for business purposes, which may be located in countries outside of your jurisdiction. For more information regarding our Service Providers, please refer to Section 11 below.
7.3. For avoidance of doubt, the Kleros Project may transfer and disclose Non-personal Information to third parties at its discretion including without limitation for statistical, analytical and research purposes and for customization, developing and improvement of our Site.
8. Your Rights
The Kleros Project acknowledges you have the right to access and change the Personal Information we collect and process. If you wish to access or to correct, amend, or delete Personal Information, please send us an email to: [email protected] and we will respond within a reasonable timeframe, but in any event no later than permitted by applicable law.
Note to our Users in the EU:
We hereby inform you of the following rights (by virtue of EU law), in respect of your Personal Information:
- Right to access: you may have the right to request a review of your Personal Information held by the Kleros Project. We may refuse to comply with your access request if the request is manifestly unfounded, excessive or repetitive in nature.
- Right to erasure: under certain conditions, you may be entitled to require that the Kleros Project will delete or "block" your Personal Information (e.g. if the continued processing of those data is not justified).
- Right to portability: you may have the right to transfer your Personal Information between data controllers (i.e. to transfer your Personal Information to another entity). The right to data portability only applies where your Personal Information is processed by us with your consent or for the performance of a contract and when processing is carried out by automated means.
- Right to object to or withdraw consent: where that lawful basis for processing your Personal Information is either "public interest" or "legitimate interests", those lawful bases are not absolute, and you may have a right to object to such processing. Where you object on grounds of legitimate interest, we shall no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims. If the processing of your Personal Information is based on your consent, you have the right to withdraw your consent to such processing at any time.
- The right to restrict processing – under certain circumstances, you may have the right to object to the processing of your Personal Information due to your particular situation.
- Right to lodge a complaint: you have the right to lodge a complaint before the relevant data protection authority or supervisory authority of your jurisdiction.
To exercise these rights, where applicable, please contact us by sending an email to: [email protected]
9. Location of Your Data
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.
In order to keep your Personal Information safe, we apply strict safeguards when transferring it outside of the EEA, 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.
Note to non-EU Users:
BY SUBMITTING YOUR PERSONAL INFORMATION THROUGH THE SITE, YOU ACKNOWLEDGE, AND AGREE, IN JURISDICTION WHERE SUCH CONSENT IS REQUIRED, TO SUCH TRANSFER, STORING AND/OR PROCESSING OF PERSONAL INFORMATION.
The Site is intended for Users over the age of sixteen (16). Therefore, the Kleros Project does not intend and does not knowingly collect Personal Information from minors under the age of sixteen (16) and does not wish to do so. 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 we learn that we collected Personal Information from minors under the age of sixteen (16) we will delete that information as quickly as possible.
11. Third Party Service Providers
11.2. Note, that we collect, hold and/or manage your Personal Information through the Kleros Project's authorized third party vendors of certain products or services (such as hosting cloud services) (including, as applicable, their affiliates) solely and limited to providing us with such requested services, and not for any other purposes.
11.3. Such vendors may be located in a country that does not have the same data protection laws as your jurisdiction.
11.4. Such third parties service providers include without limitation the following categories of service providers:
- Hosting services, including our service provider Tel Aviv University;
12. Links to Third Party Websites
13.1. We take appropriate measures to maintain the security and integrity of our Site and prevent unauthorized access to it or use thereof through generally accepted industry standard technologies and internal procedures.
13.2. Your Personal Information is hosted on Tel Aviv University servers, which provide advanced strict security standards (both physical and logical).
13.3. Some of the security measures that we employ include, without limitation: highly secure services design and implementation using state of the art encryption and architectures mechanisms, restriction of access to your Personal Information to individuals who need access to it in order to process it on the Kleros Project's behalf and implementation of a secured permission management and auditing system using specific and proprietary firewall and network access filtering as well as security group mechanisms.
Please note, however, that there are inherent risks in transmission of information over the Internet or other methods of electronic storage and we cannot guarantee that unauthorized access or use will never occur.
13.4. The Kleros Project will comply with applicable law in the event of any breach of the security, confidentiality, or integrity of your Personal Information and will inform you of such breach if required by applicable law.
13.5. TO THE EXTENT THAT THE Kleros Project IMPLEMENTED THE REQUIRED SECURITY MEASURES UNDER APPLICABLE LAW, THE Kleros Project SHALL NOT BE RESPONSIBLE OR LIABLE FOR UNAUTHORIZED ACCESS, HACKING, OR OTHER SECURITY INTRUSIONS OR FAILURE TO STORE OR THE THEFT, DELETION, CORRUPTION, DESTRUCTION, DAMAGE, OR LOSS OF ANY DATA OR INFORMATION INCLUDED IN THE PERSONAL INFORMATION.
14. Data Retention
The Kleros Project will retain the Personal Information for as long as we are comfortable that it is accurate and can be relied upon. Personal Information which is no longer required for the purpose for which is was initially collected will be deleted unless we have a valid justification to retain it which is permitted under applicable law, such as to resolve disputes or comply with our legal obligations.
16. Got any Questions?