Afimilk Website Privacy Policy

Last updated Nov 1, 2022

We, at Afimilk Agricultural Cooperative Ltd. (“Afimilk”, “we”, “our”, or “us”), put great efforts in making sure that we secure the Personal Data related to you and use it properly. Afimilk provides advanced dairy management and milking solutions for farmers including cow monitoring, farm management software and cloud-based services provided through our mobile and web applications, and milking parlor automation (the “Service”). Afimilk’s website is located at https://www.afimilk.com (the “Website”).

This policy explains our privacy practices for processing Personal Data related to you. The term “Personal Data” refers to information that identifies you as an individual or relates to an identifiable individual. For example, Personal Data is your name, email address, telephone or mobile number, and other contact details which you submit to us.

The summary of this policy will give you a quick and clear view of our practices. Please take the time to read our full policy.

A Summary of The Policy

Personal Data You Provide Us –We receive and store any information you enter on our Website or give us in any other way. If you subscribe to the Service we will need your name, your company name and email address for subscription and notice purposes, we will collect the information you provide. Read More.

Personal Data That We Collect – We automatically log ‘traffic/session’ information including IP addresses and user agent. We collect session durations and additional activity information. Read More.

What Do We Do with Personal Data? – We maintain the Service, make it better and continue developing it, communicate with you, provide maintenance and support to our Services, provide you with newsletters or promotional materials, and protect us and the Service from misuse and law violations. Read More.

Sharing Personal Data Related to You with Others – We use service providers, for example, to process payments and send email messages. We will transfer information when we change our corporate structure, and we will share the information with our affiliated entities. Read More.

Disclosure of Personal Data to Authorities – We will obey orders and other lawful requirements by authorities to disclose information. Read More.

Aggregated and Analytical Information – Aggregated data is not identifiable. We use it for legitimate business purposes and for standard analytical tools. Read More.

Your Choice – You may opt-out of our mailing lists and terminate your use of the Service. Our Service does not respond to Do Not Track (DNT) signals. Read More.

Accessing Personal Data related to you – At any time you can request access to Personal Data related to you. Read More.

Your EU Data Subject Rights – If we process personal data related to you when you are in the EU, further terms apply to our processing in relation to your rights as a data subject under EU data protection laws. Read More.

Specific Provisions for California Residents If you reside in the State of California, further terms apply to our processing in relation to your rights as a data subject under the California Consumer Privacy Act of 2018 (CCPA).  Read More.

Your Canadian Privacy Law Rights – If you are from Canada, further terms apply to our processing in relation to your rights as a data subject under Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA). Read More.

Your Privacy Rights Under Israeli Law – If you are from Israel, further terms apply to our processing in relation to your rights as a data subject under the Israeli Protection of Privacy Law, 5741-1981 (PPL). Read More.

Personal Data retention – We retain Personal Data to provide the Service and for legitimate and lawful purposes, as further explained in the data retention section of the policy. Read More.

Transfer of Data Outside Your Territory – We keep Personal Data related to you in the Israel and in western Europe and will store them at additional sites, at our discretion. These service providers provide us adequate security and confidentiality commitments. Read More.

Cookies – We use cookies to make it easier for you to log-in and to facilitate Service activities. Read More.

Information Security – We implement systems, applications, and procedures to secure Personal Data related to you, to minimize the risks of theft, damage, loss of information, or unauthorized access or use of information. Read More.

Dispute Resolution – Contact us at: dpo@afimilk.com or write us for every request and complaint. We will make good-faith efforts to resolve any existing or potential dispute with you. Read More.

Changes to this Privacy Policy – We will update our policy from time to time after giving proper notice. Read More.

Incorporation to the Terms of Use – This policy is an integral part of the Website’s Terms of Use or, if applicable, of any other Service and/or license agreement entered into between you (or the entity that you are acting on its behalf) and us. Read More.

Contact Us – Please contact us at: dpo@afimilk.com for further information. Read More.

The Afimilk Privacy Policy

Personal Data That You Provide Us

We receive and store any information you enter on our Website or give us in any other way, for example, when you: (i) enter your information via the “Contact Us” page and submit it to us; (ii) order products and/or services from us; (iii) request information from us; (iv) provide us your business card or provide us your contact details by filling-in a paper forms  during trade shoes etc.; (v) participate in a conference or in public forums on the Website; (vi) opt in or subscribe to our newsletter or participate in a campaign; (vii) respond to our customer surveys; (viii) accept the terms of our End-user license agreement (EULA); or (ix) subscribe to any of our mobile or web applications or cloud-based services.

Personal Data That We Collect

Like many websites, we use “cookies” (for further information about cookies, please see our Cookies and Similar Tracking Technologies Policy), and we obtain information when your browser accesses our Website or web applications. [This should link to the cookie policy]

Examples of the information we collect and analyze include the Internet Protocol (IP) address used to connect your access device to the Internet; login; physical and e-mail address; location; access device and connection information such as browser type and device ID, version, and time zone setting, browser plug-in types and versions, operating system, and platform.

When you use the Service, we collect information about your Service activity, for example your log-in and log-out time, the duration of Service sessions, the content uploaded and downloaded, viewed web-pages or specific content on web-pages, activity measures and geo-location.

Information from Third-Party Platforms: You may allow us to interact with one or more third-party social networks or platforms (such as Facebook), which will provide data about you to us (“Social Network”). The information you allow us to access varies by Social Network, and it is affected by the privacy settings you and those that you are connected with establish while using such Social Networks. Social Networks are operated, controlled, and maintained by third parties that are not operated, controlled, or maintained by us. We recommend that you read the terms of use or service and privacy policies of those Social Networks to understand how they collect and treat your data and what data they might share with us or other third parties.

What Do We Do With Personal Data?

We use Personal Data related to you to provide the Service to you, to provide you with notifications related to your use of the Service and/or our products, such as electronic newsletters or promotional e-mails, to provide support, to maintain the Service, to communicate with you from time to time in response to your requests for information, to customize the information we deliver to you and to improve and to continue developing our products and the Service.

We obey the law and expect you to do the same. If necessary, we will use Personal Data related to you to enforce our terms, policies, and legal agreements, to comply with court orders and warrants, and assist law enforcement agencies, to collect debts, prevent fraud, misappropriation, infringements, identity thefts and any other misuse of our products or the Service, and to take any action in any legal dispute and proceeding.

We commit to process Personal Data related to you solely for the purposes described in this policy.

Sharing Personal Data related to you with Others

Your personal information may be shared with certain members of our staff, as well as external consultants. We may also share your personal information with our affiliates worldwide, who are all governed by this Privacy Policy. We may also share your personal information with our distributors, dealers and agents worldwide and with third-party service providers which process your information on our behalf; however, such distributors, dealers, agents and service providers will be contractually bound to keep your personal data confidential and appropriately secure.

A merger, acquisition or any other structural change will require us to transfer Personal Data related to you to another entity, as part of the structural change, provided that the receiving entity will comply with this policy.

We will share Personal Data related to you only subject to the terms of this policy, or subject to your prior consent.

Disclosure of Personal Data to Authorities

We will need to disclose Personal Data related to you in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Aggregated and Analytical Information

We use standard analytics tools. The privacy practices of these tools are subject to their own privacy policies, and they use their own cookies to provide their service (for further information about cookies, please see the ‘Cookies’ section in this policy).

We use the standard analytics tools of Google Analytics, and we will use additional or other analytics tools, from time to time, to learn about how you and other users use the Service, in support of our Service-related activities and operations.

The privacy practices of these tools are subject to their own privacy policies. See Google Analytics Privacy Policy at: http://www.google.com/analytics/learn/privacy.html.

We use anonymous, statistical, or aggregated information and will share it with our partners for legitimate business purposes. It has no effect on your privacy, because there is no reasonable way to extract data from the aggregated information that we or others can associate specifically to you.

Your Choice

If you wish to exercise any of your rights in relation to Personal Data related to you, including accessing, modifying, deleting or exercising your opt-out rights, please send us an email to dpo@afimilk.com.

We may send newsletters or promotional communications to our users. To unsubscribe to these communications, you will be required to click an “Unsubscribe” link in these emails and confirm the email address for which you would like to unsubscribe.

We may send you Service-related announcements (such as, but not limited to, a notice that we have changed our Service, our Terms of Service, or Privacy Policy) when we believe it is necessary to do so.

You may request that your subscription to any of the Services be terminated, and that Personal Data related to you be deleted by sending an email to dpo@afimilk.com. Any termination of your subscription may involve deletion of your Personal Data from our live databases and all the information and data stored for such account in the Service. Afimilk will not have any liability whatsoever to you for any termination of your subscription or the related deletion of your information. We are not obliged to delete Personal Data if we can show that the processing is required under applicable law or regulation, or necessary for a legitimate interest, for example, for the establishment, exercise, or defense of a legal claim or for collection or securing of any amounts you might owe to us.

You may request a copy of the Personal Data related to you that we store about you by sending an email to dpo@afimilk.com. You may also request that Afimilk transfer Personal Data related to you or provide you with copies of such Personal Data to enable its transfer to a third party.

When we delete Personal Data related to you that we have collected from or about you, it will be deleted from our active databases but may remain in our archives. Although Afimilk may deactivate a user’s software license or subscription pursuant to his/her request, it may continue to retain the user’s information for legitimate business purposes as set forth above.

Web browsers offer a “Do Not Track” (“DNT”) signal. A DNT signal is a HTTP header field indicating your preference for tracking your activities on a service or through cross-site user tracking. Our Service does not respond to DNT signals.

If you find that the information on your account is not accurate, complete or up-to-date, please provide us the necessary information to correct it.

At any time, you can contact us at: dpo@afimilk.com and request to access the Personal Data related to you that we keep about you. We will ask you to provide us certain credentials to make sure that you are who you claim to be and to the extent required under the applicable law, will make good-faith efforts to locate the Personal Data related to you that you request to access.

If you are eligible for the right of access under the applicable law, you can obtain confirmation from us of whether we are processing Personal Data related to you, and receive a copy of that data, so that you could –

  • verify its accuracy and the lawfulness of its processing;
  • request the correction, amendment or deletion of the Personal Data related to you if it is inaccurate or if you believe that the processing of the Personal Data related to you is in violation of the applicable law.

We will use judgement and due care to redact from the Personal Data which we will make available to you, Personal Data related to others.

Your EU Data Subject Rights

If EU data protection laws apply to the processing of the Personal Data related to you by Afimilk, then the following terms apply:

For the purpose of the Service:

  • We are the data controller with respect to Personal Data related to you that you provide us as a Subscriber.

Where we process personal data related to you as a data controller, the processing is based on the following lawful grounds:

  • All processing of personal data related to you which are not based on the lawful grounds indicated below, are based on your consent.
  • We process your account and payment details to perform the contract with you.
  • We will process personal data related to you to comply with a legal obligation and to protect your and others’ vital interests.
  • We will further rely on our legitimate interests, which we believe are not overridden by your fundamental rights and freedoms, including, without limitation, for the following purposes:
    • Communications with you, including direct marketing where you are our client or a user of our client, or where you make contact with us through our website and other digital assets.
    • Cyber security
    • Support, customer relations, service operations
    • Enhancements and improvements to yours and other users’ experience with our services.
    • Fraud detection and misuse of the Service.

In addition to your rights under other sections in this policy, you have the following rights:

  • AT ANY TIME, CONTACT US IF YOU WANT TO WITHDRAW YOUR CONSENT TO THE PROCESSING OF PERSONAL DATA RELATED TO YOU. EXERCISING THIS RIGHT WILL NOT AFFECT THE LAWFULNESS OF PROCESSING BASED ON CONSENT BEFORE ITS WITHDRAWAL.
  • Request to delete or restrict access to personal data related to you. We will review your request and use our judgment, pursuant to the provisions of the applicable law, to reach a decision about your request.
  • If you exercise one (or more) of the above-mentioned rights, in accordance with the provisions of applicable law, you may request to be informed that third parties that hold personal data related to you, in accordance with this policy, will act accordingly.
  • You may ask to transfer personal data related to you in accordance with your right to data portability.
  • You may object to the processing of personal data related to you for direct marketing purposes. Additional information about this right is available under the Choice section in this policy.
  • You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affecting you.
  • You have a right to lodge a complaint with a data protection supervisory authority of your habitual residence, place of work or of an alleged infringement of the GDPR.

A summary and further details about your rights under EU data protection laws, is available on the EU Commission’s website at: https://ec.europa.eu/info/law/law-topic/data-protection/reform/rights-citizens_en.

Note that when you send us a request to exercise your rights, we will need to reasonably authenticate your identity and location. We will ask you to provide us credentials to make sure that you are who you claim to be and will further ask you questions to understand the nature and scope of your request.

If we need to delete personal data related to you following your request, it will take some time until we completely delete residual copies of personal data related to you from our active servers and from our backup systems.

If you have any concerns about the way we process personal data related to you, you are welcome to contact our privacy team at: dpo@afimilk.com. We will look into your inquiry and make good-faith efforts to respond promptly.

Specific Provisions for California Residents

This section applies solely to all visitors, users and others who reside in the State of California. We adopted this section to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this section.

We have collected the Personal Data related to you which is described above under the section “The Personal Data that We Collect and Store” of this Policy. Such Information may consist of the following categories:

Identifiers and Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a your interaction with the Website.

Commercial information, including products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

Geolocation data, namely your physical location or movements.

Inferences drawn from any of the above-mentioned information.

We obtain the categories of Personal Data related to you listed above from the following categories of sources:

  1. Directly and indirectly from you and your activity on the Website and/or Services.
  2. Third parties such as reliable service providers and social networks.

We use the Personal Data related to you that we collect or receive for the purposes mentioned under the section “How We Use Your Personal Information?” of this Policy.

We disclose Personal Data related to you to third parties for Business Purposes as described above under the section titled “Information Sharing and Disclosure?”.

We will not sell Personal Data related to you.

Your rights as a California Resident

In addition to your rights under the section titled “Our Retention of Your Information”, if you are a California resident, you are entitled also to the following specific rights under the CCPA regarding Personal Data related to you:

Access to specific Personal Data and data portability rights – you have the right to request that we will disclose certain information to you about our collection and use of Personal Data related to you over the past 12 months. Upon verification of your request, we will disclose to you:

The categories of Personal Data we collected about you;

The categories of sources for the Personal Data we collected about you;

Our Business or Commercial Purpose for collecting that Personal Data;

The categories of Personal Data that we disclosed for a Business purpose, and the categories of third parties with whom we disclosed that particular category of Personal Data;

The specific pieces of Personal Data that we collected about you;

If we disclosed Personal Data related to you for a Business Purpose, we will provide you with a list which will identify the Personal Data categories that each category of recipient obtained.

Deletion rights – you have the right to request that we delete any of Personal Data related to you. Upon confirmation of your request, we will delete Personal Data related to you from our records, unless an exception applies.

Non-discrimination – you also have a right not to be discriminated against for exercising your rights under the CCPA.

Exercising Your Rights

To exercise the access, data portability, and deletion rights described above, please submit your request to us by sending an email message to: dpo@afimilk.com.

Only you or a person authorized to act on your behalf, may make a request related to Personal Data related to you.

A request for access can be made by you only twice within a 12-month period.

The verifiable consumer request must:

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Data or an authorized representative.

Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with the requested Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Data related to you.  We will only use the Personal Data provided in your request to verify your identity or authority to make the request.

We will do our best to respond to your request within 30 days of its receipt. If we require more time (up to additional 30 days), we will inform you of the reason and extension period in writing. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

We do not charge a fee to process or respond to your request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will inform you of the reasons for such decision and provide you with a cost estimate before completing your request.

Your Canadian Privacy Law Rights

If you are from Canada, we collect, use disclose and otherwise process the personal information described above with prior notice in the applicable situations or as authorized by Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA). If you do not wish to provide us with any personal information which is indicated as compulsory, we may not be able to communicate with you or provide certain services or features to you. Further, if you provide us with details of any other individual, you must give a copy of this Privacy Policy to, (and obtain consent from, that individual if such individual is resident in the Province of Québec) before giving their personal information to us where consent is required by applicable laws (for example, with respect to individuals resident within the Province of Québec).

This section applies if your information is collected from within Canada.

Access and correction.  You may access the personal information we hold about you, by making a request.  We will respond to your request within a reasonable period, and in any event within 30 days.  We may charge you a reasonable fee for processing your request (but not for making the request for access).  We may decline a request for access to personal information in circumstances prescribed by the Personal Information Protection and Electronic Documents Act (Canada PIPEDA), and if we do, we will give you a written notice that sets out the reasons for the refusal (unless it would be unreasonable to provide those reasons), including details of the mechanisms available to you to make a complaint.

If, upon receiving access to your personal information or at any other time, you believe the personal information we hold about you is inaccurate, incomplete or out of date, please notify us immediately.  We will take reasonable steps to correct the information so that it is accurate, complete and up to date.  If we refuse to correct your personal information, we will give you a written notice that sets out our reasons for our refusal (unless it would be unreasonable to provide those reasons), including details of the mechanisms available to you to make a complaint.

Complaints and feedback.  If you wish to make a complaint about a breach of Canada PIPEDA, please contact us using the details below and we will take reasonable steps to investigate the complaint and respond to you.

If after this process you are not satisfied with our response, you can submit a complaint to the Office of the Privacy Commissioner of Canada.

If you have any queries or concerns about our privacy policy or the way we handle your personal information, please contact our privacy officer using the Contact Information set out below.

Your Privacy Rights Under Israeli Law

This section of our Privacy Policy provides information for Israeli data subjects, as required by the Israeli Protection of Privacy Law, 5741-1981 (PPL).

If you are from Israel, we collect, use, disclose and otherwise process the personal information described above with your consent where required by applicable law. If you do not wish to provide us with any personal information which is indicated as compulsory, however not required by law, we may not be able to communicate with you or provide certain services or features to you. Further, if you provide us with details of any other individual, you must give a copy of this Privacy Policy to, and obtain consent from, that individual before giving their personal information to us where consent is required by applicable laws.

Rights of the Data Subjects in Israel. The PPL grants you the following rights with respect to your personal information:

Right of access. At any time you can contact us and request to access the personal information that we keep about you. We will ask you to provide certain credentials to verify your identity. If required under the PPL, and no exemption applies, we will make good-faith efforts to locate and provide you with a copy (which may be a digital copy) of personal information related to you that you request and that resides on our information systems. In responding to your request, we will apply limitations available under applicable law, for example to protect our trade secrets and confidential information and to protect the privacy of others.

Right of rectification, update or delete. If you find that personal information related to you is inaccurate, incomplete or not up to date, please provide us the necessary information to correct it. In such case, you are also entitled to request the deletion of said personal information.

Opt out of mailing lists. At any time you may opt out of our mailing lists, or request that personal information related to you will not be shared with our affiliates or with our third-party providers. It may take time for your opt-out request to take effect.

Complaints. If your exercise of these rights is denied or not fulfilled within the deadlines for reasons not justified in accordance with the PPL, you have the right to lodge a complaint with the Privacy Protection Authority or to appeal against such decision in a court.

Data Retention

We retain different types of Personal Data related to you for different periods, depending on the purposes for processing the information, our legitimate business purposes as well as pursuant to legal requirements under the applicable law.

We will maintain your contact details, to help us stay in contact with you. At any time you can contact our privacy team at: dpo@afimilk.com and request to delete your contact details. Note that we may keep your details without using them unless necessary, and for the necessary period of time, for legal requirements and proceedings.

We may retain Personal Data related to you after you have terminated your use of the Service, if retention is reasonably necessary to collect any debts or secure any liabilities incurred during the term of your subscription and/or use of the Services, to resolve disputes between our users, to prevent fraud and abuse, or to enforce this Privacy Policy and our Terms of Use. We will keep aggregated non-identifiable information without limitation, and to the extent reasonable we will delete or de-identify potentially identifiable information, when we no longer need to process the information.

In any case, as long as you use the Service, we will keep information about you, unless the law requires us to delete it, or if we decide to remove it at our discretion, according to the terms of this policy.

Transfer of Data Outside Your Territory

The Service is a web-based service. We store and process information, including Personal Data, either directly or using third parties, such as data hosting service providers, in Israel, and West Europe. The laws of these territories may differ from the laws of the jurisdiction in which you live.

We make sure that our third-party service providers, provide us with adequate confidentiality and security commitments and we will take all steps reasonably necessary to ensure that Personal Data related to you is treated securely and in accordance with this privacy policy.

If you are a resident in a jurisdiction where transfer of Personal Data related to you to another jurisdiction requires your consent, then you provide us your express and unambiguous consent to such transfer.

If you are located in the European Economic Area (EEA), note that we will transfer personal data related to you to other jurisdictions, which are not deemed to provide an adequate level of data protection. In such case, we will use appropriate safeguards, in particular, by way of entering into the European Union (EU) Standard Contractual Clauses as amended from time to time with the relevant recipients, or by adhering to equivalent data transfer regulations to protect the security and confidentiality of such personal data. You can obtain a copy of the suitable safeguards that we use when transferring personal data as described above or receive further information about data transfer by contacting us at: dpo@afimilk.com.

Cookies

We use cookies and similar tracking technologies to make sure that our Service is continuously improved and meets your needs.

Please view our Cookies and Similar Tracking Technologies Policy for more information on our use of cookies.

Information Security

We and our hosting services implement systems, applications, and procedures to secure Personal Data related to you, to minimize the risks of theft, damage, loss of information, or unauthorized access or use of information.

These measures provide sound industry standard security. However, although we make efforts to protect your privacy, we cannot guarantee that the Service will be immune from any wrongdoings, malfunctions, unlawful interceptions or access, or other kinds of abuse and misuse.

Dispute Resolution

We do periodical assessments of our data processing and privacy practices, to make sure that we comply with this policy, to update the policy when we believe that we need to, and to verify that we display the policy properly and in an accessible manner. If you have any concerns about the way we process Personal Data related to you, you are welcome to contact our privacy team at: dpo@afimilk.com, or write to us. Our address is published on our website at: https://www.afimilk.com.

We will look into your query and make good-faith efforts to resolve any existing or potential dispute with you.

Changes to this Privacy Policy

From time to time, we will update this policy. If the updates have minor if any consequences, they will take effect 14 days after we post a notice on the Website. Substantial changes will be effective 30 days after we initially posted the notice.

Until the new policy takes effect, if it materially reduces the protection of your privacy right under the then-existing policy you can choose not to accept it and terminate your use of the Service. Continuing to use the Service after the new policy takes effect means that you agree to the new policy. Note that if we need to adapt the policy to legal requirements, the new policy will become effective immediately or as required by law.

Incorporation to the Terms of Use

This policy is an integral part of the Website’s Terms of Use or, if applicable, of any Service subscription agreement entered into between you (or the entity that you are acting on its behalf) and us, including but not limited to any software end user license agreement and the terms of use of the Website and of any of our mobile or web applications.

Contact Us

Please contact dpo@afimilk.com  for further information.

Last Updated: November 1, 2022