Last updated: December 12, 2018
Kramer Electronics Ltd. and its affiliated corporations (“Kramer” or “we”) develops, manufactures and markets video, audio and control products, solutions and services (the “Products”). Kramer also creates and operates various websites (the “Websites”).
Data that we use, receive, collect, process or store and how we use it:
Using, receiving, collecting, processing or storing Personal Data is not our primary purpose. Kramer uses, receives, collects, processes or stores only Personal Data necessary to provide the Products and operate its business.
However, in the course of running our business, we might use, receive, collect, process or store Personal Data relating to potential and actual customers, service providers, suppliers, employees, users of the Websites and others.
This Personal Data may include:
- names, telephone numbers, email addresses, addresses, contact details, financial information (i.e. billing information, bank account information, credit card information), social network contact accounts, employee’s health information, employee and candidate CVs and other information.
- information as to how the Products and the Websites are accessed and used including information such as computer IP addresses, browser types or versions, the pages of the Website that a user visits, the times and dates of visits, the time spent on each page, unique device identifiers and other diagnostic data.
- Session cookies – for operating our Products.
- Preference cookies – for remembering your preferences and various settings.
- Security cookies – for security purposes.
We may use Personal Data as follows:
- Training and certification: To provide relevant and topical training and education on key industry concepts, technologies and techniques that provide students with the comprehensive knowledge base necessary to succeed in the AV marketplace.
- Certain purposes: if you provide Personal Data for a certain purpose, Kramer may use the Personal Data in connection with the purpose for which it was provided. For instance, if you contact Kramer by e-mail, we will use the Personal Data you provide to answer your question or resolve your problem and will respond to the email address from which the contact came.
- Marketing purposes: Personal Data provided to us by you may be used by us to contact you in the future for our marketing and advertising purposes, including informing you about new Products we believe might be of interest to you and developing and delivering promotional or marketing materials. If by mistake you receive direct marketing without your specific consent or wish to opt-out, please contact us at DPO@KramerAV.com.
- Training and certification: We may use Personal Data to provide relevant and topical training and education on key industry concepts, technologies and techniques that provide students with the comprehensive knowledge base necessary to succeed in the AV marketplace.
- Statistics: Personal Data provided to us by you may be used by us for statistical reports containing aggregated information.
- Security and dispute resolution: we may use Personal Data to protect the security of our Websites and Products, to detect and prevent cyber-attacks, fraud, phishing, identity theft, data leakage, to confirm the validity of software licenses, to resolve disputes and to enforce our agreements.
- We may disclose your Personal Data if required to do so by law in order to (for example) respond to a subpoena or request from law enforcement, a court or a government agency (including in response to public authorities to meet national security or law enforcement requirements), or in the good faith belief that such action is necessary to (a) comply with a legal obligation, (b) protect or defend our rights, interests or property or that of third parties, (c) prevent or investigate possible wrongdoing in connection with the Products, (d) act in urgent circumstances to protect the personal safety of users of the Websites and Products or the public, or (e) protect against legal liability.
- Non-Personal Data: Since Non-Personal Data cannot be used to identify you, we may use such data in any way permitted by law.
How we store information and transfer it.
- We use third parties' cloud services such as:
- Microsoft office 365
- Salesforce cloud services which will comply with the GDPR in the delivery of their services, certify compliance with the EU-U.S. Privacy Shield Framework and is ISO 27001, 27017,27018 certified (for Salesforce full statement see https://www.salesforce.com/eu/campaign/gdpr/).
- Docebo LMS: we use Docebo Learning Management System (LMS) for our e-learning platform. For Docebo’s statement on how it complies with the GDPR please refer to https://www.docebo.com/blog/how-docebo-lms-is-gdpr-compliant/ .
- Personal Data may be processed by third party service providers. We transfer to such providers only the minimum data that is necessary for conducting our services. The data is transferred only to suppliers approved by us that allow compliance with the GDPR.
- Personal Data may be transferred stored and processed in countries outside the EU or European Economic Area (EEA). Such transfer to third countries may include countries that do ensure the same level of data protection laws as required by EU privacy laws. In such cases, we implement information security techniques and technical measures or third parties' contractual obligations to maintain such Personal Data at the same security level as other Personal Data that Kramer administers.
- We may transfer Personal Data to Israel and maintain it there. Kramer's headquarters are in Israel. Israel's data protection law is considered by the EU as adequate.
Security of Personal Data
- We are strongly committed to the protection of your Personal Data, and we will take commercially reasonable technical steps, of the sort commonly accepted in our industry, to keep your Personal Data secure and to protect it from loss, misuse or alteration. However, no network, server, database, Internet or e-mail transmission is ever fully secure or error free. Therefore, you should take special care in deciding what information you disclose.
- If you notice a risk or any security violations, we please report to us on DPO@KramerAV.com, so that we can attempt to resolve it as soon as possible.
- We recommend that you use, disclose and share your Personal Data with caution and don’t give out Personal Data unless it is necessary, as we cannot guarantee the security of data over the Internet and cannot control actions of other users of the Products with whom you choose to share Personal Data.
- Kramer implements legal, technical and organizational information security measures, based on the ISO certification mechanism method of ISO 27001:2013 - Information Security Management System and ISO 27017:2015 -Information security controls for cloud services and ISO 27018:2014- - Code of practice for protection of personally identifiable information (PII) in public clouds acting as PII processors.
Access, updates, corrections, deletions, restrictions. Complaints with supervisory authority.
- You may have the right to request access to some of your Personal Data being stored by us; you can also ask to correct, update or delete any inaccurate Personal Data that we process about you – all are subject to our policies and to applicable law and regulations. In order to exercise these rights, please contact us at: DPO@KramerAV.com.
- We may retain your Personal Data for any period permitted or required under applicable laws. Even if we delete your Personal Data it may persist on backup or archival media for an additional period of time due to technical issues or for legal, tax or regulatory reasons or for legitimate and lawful business purposes.
- You may have the right to restriction of processing if one of the following apply:
- The accuracy of the Personal Data is contested by you;
- Unlawful processing has occurred and you object to deletion of the Personal Data and requests restriction of its use instead;
- Your service provider no longer needs the Personal Data for the purposes of the original processing, but the data is required by you for the establishment, exercise or defense of legal claims;
- You have objected to processing pending verification whether the legitimate grounds of your service provider override yours.
If you wish to object to processing, please contact us at DPO@KramerAV.com.
- If you have the right to lodge complaints with supervisory authorities, we would appreciate your contacting us first in order to solve the issue for the benefit of all parties. Please contact us by email to DPO@KramerAV.com. Our supervisory authorities are the Israeli, German and French data protection authorities.
- You provide Personal Data to us consensually either on a case by case basis or in a broader contractual context.
Changes in terms
- If you have a complaint about Kramer’s privacy practices, please write to us at: DPO@KramerAV.com. We will work with you to attempt to resolve your complaint.