We at Growth Space Ltd. (“Growth Space“, “us“, “we“, or “our“) recognize and respect the importance of maintaining individual’s privacy rights. We have developed a platform (“Platform“) throu,gh which our customers (“Customers“) and their personnel or service providers (“Customer Personnel“) can receiving services from qualified experts, coaches, mentors, lecturers, trainers, or consultants (“Experts“). We also maintain a website, https://www.growthspace.com/, (“Site“) where visitors (“Website Visitors“) can receive information about our Platform and Experts can apply to provide services through our Platform.
As part of these activities, we handle Personal Data of a number of different types of people – the person with whom we are in contact or who represents the Customer (“Customer Representative“), the Customer Personnel who are using the Platform, Experts, and Website Visitors.
This Privacy Notice describes the types of information we collect from all of these individuals, how we process, transfer, store and disclose the information collected, as well as how these individuals can control certain uses of the collected information. “You” means any adult who is a Customer Representative, Customer Personnel, Website Visitor, or Expert.
“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.
If you are an individual located in the European Union, some additional terms and rights may apply to you, as detailed in this Privacy Notice.
Controllers and Processors of Personal Data Collected
Growth Space is the data controller in respect of the processing of Personal Data of Website Visitors, Experts, and Customer Representatives. Our registered office is at Yehuda HaLevi 3, Tel Aviv – Yafo, Israel and our registration number is 515998052. We determine what Personal Data should be collected from these individuals how it will be used and for what purpose(s). You can contact our representative in the European Union at: Maetzler Rechtsanwalts GmbH & Co KG, Attorneys at Law, c/o GrowthSpace, Schellinggasse 3/10, 1010 Vienna, Austria. Please include the subject “GDPR-REP ID: 14358136” on all correspondence. In addition, if you want to want to exercise your rights as a data subject, as described below, you can visit https://gdpr-rep.eu/q/14358136.
When we process Personal Data of Customer Personnel, we do so solely on behalf of the applicable Customer and at such Customer’s direction. If you are using the Platform as Customer Personnel, the Customer serves as a controller of your Personal Data and Growth Space serves as a processor on its behalf.
Privacy Notice Key Points
The key points listed below are presented in further detail throughout this Privacy Notice. You can click on the headers in this section in order to find out more information about any topic. These key points do not substitute the full Privacy Notice.
- Personal Data We Collect, Uses, and Legal Basis
- Additional Uses
- Sharing Personal Data
- International Transfer
- Your Rights – How to Access and Limit Our Use of Certain Personal Data
- Data Retention
- Cookies and Similar Technologies
- Third-Party Applications and Services
- Changes to the Privacy Notice
- Comments and Questions
1. PERSONAL DATA WE COLLECT, USES, AND LEGAL BASIS
Depending on your usage, we collect different types of data and we and our third-party subcontractors and service providers use the data we collect for different purposes, as specified below. It is your decision whether to provide us with certain Personal Data, but if you refuse to provide such Personal Data we may not be able to provide you with the Site or Platform or part thereof.
1.1 Website Visitors
1.1.1 Contact Information. When you request information from us or contact us for any other reason, we will collect any data you provide, such as your email address and the content of your inquiry.
How we use this data. To respond to your request or inquiry.
Legal Basis. We process this Personal Data based on the performance of a contract when we respond to your inquiry.
1.1.2 Automatically Collected Data
When you visit the Site, we automatically collect information about your computer or mobile device, including non-Personal Data such as your operating system, and Personal Data such as your IP address and device ID. For more information about the cookies and similar technologies we use and how to adjust your preferences, see the section “Cookies and Similar Technologies” below.
How we use this data. (1) To review usage and operations, including in an aggregated non-specific analytical manner, develop new products or services and improve current content, products, and services; and (2) to prevent fraud, protect the security of our Site and address any problems with the Site.
Legal Basis. We process this Personal Data for our legitimate interests to develop and improve our products and services, review usage, perform analytics, prevent fraud, for our recordkeeping, and protection of our legal rights.
1.2.1 Application Information
When you apply to be an Expert on our Platform, you will be required to provide your full name, email address, phone number, a link to your resume or LinkedIn profile, country, languages spoken, and details of your professional experience, the company for which you work, start date, educational history, expertise, a biographical summary, whether or not you have coaching certification, whether or not you have professional development certification, and the services you would like to provide. You will also be required to create a password. In addition, we monitor your usage of the Platform and collect information regarding your viewing and usage history on the Platform.
How we use this data. (1) to assess whether to engage you as an Expert; (2) to provide services to our Customers through the Platform; and (3) to fulfill our obligations under our contract with you, such as our payment obligations.
Legal Basis. We process this Personal Data for our legitimate interests to manage our business and services, for the performance of our contract with you, and for our recordkeeping and protection of our legal rights.
1.3 Customer Representative
1.3.1 Contact Information. If you are a Customer Representative, we will collect your name, email address, and any additional details you provide, such as your phone number or position within the Customer’s organization.
How we use this data – To engage the Customer for the provision of services through the Platform.
Legal Basis – We process this Personal Data based on the performance of a contract with the relevant Customer.
1.4 Customer Personnel
1.4.1 If you are Customer Personnel, we process your Personal Data as a processor on behalf of the Customer and the Customer serves as the controller. We collect, process, and transfer this data solely for the purpose of providing services to our Customers, at their instruction, and on their behalf. Certain types of data listed below will be shared with the Customer or an Expert assigned to you, all at the direction of the Customer. For more information about these processing activities or to exercise any rights you may have as a data subject, please contact the applicable Customer directly.
- Administrator. If you use the Platform as an administrator (“Administrator“), you will be required to register and provide your name, email address, and a password you create.
- Direct Manager of Employee. If you use the Platform as the direct manager of an employee receiving services from an Expert in connection with the Platform (“Direct Manager“), you will be required to register and provide your name, email address, and a password you create.
- Employee. If you use the Platform to participate in coaching, training, mentoring, or similar sessions as an employee of our Customer (“Employee“), we will collect the following Personal Data: (i) data provided by the Administrator such as your name, email address, level of seniority, identity of your Direct Manager, geographical location, and language; (ii) data provided by your Direct Manager including relevant background and your Direct Manager’s assessment of your strengths and weaknesses, challenges, and, in some cases, specific business goals; and (iii) information that you provide including your job function, years of experience within the organization, number of employees you manage, your phone number (optional), details about your personality (based on a list of questions), any additional information about your goals. In addition, we will collect the password you create and any answers you, your Direct Manager, or the applicable Expert provide on feedback forms.
2. ADDITIONAL USES
2.1. Statistical Information. By analyzing the information we receive, including all information concerning users of the Platform we may compile statistical information across a variety of platforms and users (“Statistical Information“). Statistical Information helps us understand trends and customer needs so that new products and services can be considered and so that existing products and services can be tailored to customer desires. Statistical Information is anonymous and aggregated and we will not link Statistical Information to any Personal Data. We may share such Statistical Information with our partners, without restriction, on commercial terms that we can determine at our sole discretion.
2.2 Analytics. We and/or our service providers or subcontractors, use analytics tools (“Tools“) to collect information about the use of the Site. Such Tools collect information such as how often users visit the Site, what pages they visit when they do so, and what other sites and mobile applications they used prior to visiting the Site. We use the information we get from the Tools to improve our Site and Platform.
3. SHARING PERSONAL DATA
We may share information for which we’re a controller, including Personal Data, as follows:
3.1. 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 have agreed to confidentiality restrictions and who use such information solely on our behalf in order to: (1) help us provide you with the Site and/or Platform; and (2) aid in their understanding of how users are using our Site and/or Platform.
Such service providers and subcontractors provide us with website hosting, IT and system administration services, data backup, security, and storage services, and data analysis.
3.2. Experts. If you are Customer Personnel, we share certain Personal Data with Experts to allow them to provide you with services. Experts serve as sub-processors on our behalf and are subject to strict undertakings relating to their use of your Personal Data, including undertakings not to use your Personal Data for any purpose other than providing their services and not to disclose your Personal Data to external third parties.
3.3. Controllers. If you are Customer Personnel, we share your Personal Data at the direction of the Customer, who serves as a controller. We will share certain Personal Data with the Customer or other Customer Personnel. For example, if you are an Employee, we may share details of the number of coaching sessions in which you have participated with your Direct Manager or with the Administrator. For more information regarding these controllers processing activities, please contact the relevant controller.
3.4. 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.
3.5. 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 this Privacy Notice); (ii) when required by law, regulation subpoena, court order or other law enforcement related issues, agencies and/or authorities; or (iii) as is necessary to comply with any legal and/or regulatory obligation.
3.6. 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.
4. INTERNATIONAL TRANSFER
We use subcontractors and service providers, including Experts, who are located in countries other than your own, such as Israel, and send them information we receive (including Personal Data). We conduct such international transfers for the purposes described above. We will ensure that these third parties will be subject to written agreements ensuring the same level of privacy and data protection as set forth in this Privacy Notice, including appropriate remedies in the event of the violation of your data protection rights in such a third country. Whenever we transfer your Personal Data to third parties based outside of the European Economic Area (“EEA“), we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
4.1. We will only transfer your Personal Data to countries that have been deemed to provide an adequate level of protection for Personal Data by the European Commission.
4.2. Where we use certain service providers not located in countries with an adequate level of protection as determined by the European Commission, we may use specific contracts approved by the European Commission which give Personal Data the same protection it has in the EEA.
Please contact us at [email protected] if you would like further information on the specific mechanism used by us when transferring your Personal Data out of the EEA.
We have implemented and maintained appropriate technical and organizational security measures, policies, and procedures designed to reduce the risk of accidental destruction or loss, or the unauthorized disclosure or access to Personal Data appropriate to the nature of such data. The measures we take include:
5.1. Safeguards – The physical, electronic, and procedural safeguards we employ to protect your Personal Data include secure servers, firewalls, antivirus, and SSL encryption of data.
5.2. Access Control – We dedicate efforts to proper management of system entries and limit access only to authorized personnel on a need-to-know basis of least privilege rules, review permissions quarterly, and revoke access immediately after employee termination.
5.3. Internal Policies – We maintain and regularly review and update our privacy-related and information security policies.
5.4. Personnel – We require new employees to sign non-disclosure agreements according to applicable law and industry customary practice.
5.5. Encryption – We encrypt the data in transit using secure HTTPS protocols.
5.6. Database Backup – Our databases are backed up on a periodic basis for certain data and are verified regularly. Backups are encrypted and stored within the production environment to preserve their confidentiality and integrity, are tested regularly to ensure availability, and are accessible only by authorized personnel. 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.
6. YOUR RIGHTS – HOW TO ACCESS AND LIMIT OUR USE OF CERTAIN PERSONAL DATA
Subject to certain exemptions, and in some cases dependent upon the processing activity we are undertaking, you have certain rights in relation to the Personal Data that we hold about you, as detailed below. We will investigate and attempt to resolve complaints and disputes and make every reasonable effort to honor your wish to exercise your rights as quickly as possible and, in any event, within the timescales provided by applicable data protection laws. We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any information and/or comply with any of your requests, as detailed below. If you are one of the Customer Personnel, any requests to exercise such rights with respect to information held by the Customer, who serves as a controller of your Personal Data, please contact the applicable Customer directly.
6.1. Right of Access – You have a right to know what Personal Data we collect about you and, in some cases, to have such Personal Data communicated to you. Subject to applicable law, we may charge a fee. Please note that we may not be able to provide you with all the information you request, and, in such case, we will endeavor to explain to you why.
6.2. Right to Data Portability
If the processing is based on your consent or performance of a contract with you and processing is being carried out by automated means, you may be entitled to (request that we) provide you or another party with a copy of the Personal Data you provided to us in a structured, commonly used, and machine-readable format.
6.3. Right to Correct Personal Data – Subject to the limitations in applicable law, you may request that we update, complete, correct, or delete inaccurate, incomplete, or outdated Personal Data.
6.4. Deletion of Personal Data (“Right to Be Forgotten”) – You have a right to request that we delete your Personal Data if either: (i) it is no longer needed for the purpose for which it was collected, (ii) our processing was based on your consent and you have withdrawn your consent, (iii) you have successfully exercised your Right to Object (see below), (iv) processing was unlawful, or (iv) we are required to erase it for compliance with a legal obligation. We cannot restore information once it has been deleted. Please note that to ensure that we do not collect any further Personal Data, you should clear our cookies from any device where you have visited our Site. We may retain certain Personal Data (including following your request to delete) for audit and record-keeping purposes, or as otherwise permitted and/or required under applicable law.
6.5. Right to Restrict Processing – You can ask us to limit the processing of your Personal Data if either: (i) you have contested its accuracy and wish us to limit processing until this is verified; (ii) the processing is unlawful, but you do not wish us to erase the Personal Data; (iii) it is no longer needed for the purposes for which it was collected, but we still need it to establish, exercise, or defend of a legal claim; (iv) you have exercised your Right to Object (below) and we are in the process of verifying our legitimate grounds for processing. We may continue to use your Personal Data after a restriction request under certain circumstances.
6.6. Right to Object – You can object to any processing of your Personal Data with our legitimate interests as its legal basis if you believe your fundamental rights and freedoms outweigh our legitimate interests. If you raise an objection, we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms.
6.7. Withdrawal of Consent – You may withdraw your consent in connection with any processing of your Personal Data based on a previously granted consent. This will not affect the lawfulness of any processing prior to such withdrawal.
6.8. Right to Lodge a Complaint with Your Local Supervisory Authority – You may have the right to submit a complaint to the relevant supervisory data protection authority if you have any concerns about how we are processing your Personal Data, though we ask that as a courtesy you please attempt to resolve any issues with us first.
7. DATA RETENTION
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. Retention by any of our processors may vary in accordance with the processor’s retention policy. 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, and 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. To determine the appropriate retention period, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data, and whether those purposes can be achieved through other means, as well as applicable legal requirements.
Please contact us at [email protected] if you would like details regarding the retention periods for different types of your Personal Data.
8. COOKIES AND SIMILAR TECHNOLOGIES
8.1. 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 Site.
- 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”.
Type of Cookies
These cookies are necessary in order to allow the Site to work correctly. They enable you to access the Site, 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.
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.
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.
These cookies can help us collect information to help us understand how you use our Site, 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 Site.
These cookies collect information regarding your activity on our Site to help us learn more about which features are popular with our users and how our Site can be improved.
8.3. How to Adjust Your Preferences. Most 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 Site may not function properly when cookies are disabled or removed.
9. 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 sixteen (16). In the event that you become aware that an individual under the age of sixteen (16) has enrolled without parental permission, please advise us immediately.
12. 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 return to this page every now and then to ensure 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 Site or per email.
13. 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: August 2021