Privacy Policy – "Kibbutz Ulpan" Program
1. Introduction and Purpose
This Privacy Policy details how Habonim Dror (hereinafter: "The Association" or "We"), operating in Israel under the Netaim Organization and running the "Kibbutz Ulpan" program, collects, uses, retains, discloses, and protects the personal data of its participants and website visitors. This is done in accordance with the requirements of the EU General Data Protection Regulation (GDPR) and the Israeli Protection of Privacy Law.
- Data Controller: The Association determines the purposes and means of processing personal data.
- Target Audience: The program is intended for people from the diaspora who immigrate to Israel to volunteer in a Kibbutz.
2. Types of Data Collected
We collect two types of information: Information collected via the website and information collected during the registration process for the program.
2.1. Information Collected via the Website
- Technical Usage Details: IP address, data regarding site usage, browser type (via cookies and tracking technologies).
- Voluntary Inquiries: Free text (via "Contact Us" forms) arriving at the Association's systems.
2.2. Information Collected via the "Kibbutz Ulpan" Program
- Identification Information: Full name, date of birth (to verify ages 18-35), gender, marital status.
- Documentation and Status: Passport details and photocopy, citizenship, and status in Israel (Tourist / New Immigrant - Oleh Hadash).
- Contact Details: Email address, phone numbers, permanent residential address, and emergency contact details.
- Special Categories of Personal Data (Sensitive Data - Art. 9):
- Medical Information: Relevant medical data, for insurance purposes.
- Origin: Information regarding a person's origin.
- Education and Employment Information: Educational background (degrees, diplomas), spoken languages, and employment experience (for placement in various work branches in the Kibbutz).
3. Purposes of Processing and Legal Basis
Data processing by the Association is performed based on one or more of the grounds detailed in the GDPR regulations:
| Legal Basis (GDPR Art. 6) | Purpose |
|---|---|
| Contract Performance: Processing is necessary for the performance of the agreement between us to provide camp/program services. | Participation in the Program: Registration and placement in a Kibbutz. |
| Consent: At the registration stage, we request separate and explicit consent for these actions. | Marketing and Photography: Sending newsletters and publishing photos. |
| Legal Obligation: Compliance with laws and regulations in Israel. | Legal Compliance: Keeping documents for insurance and taxes. |
| Legitimate Interest: The Association and Netaim Organization have a legitimate interest in maintaining contact with alumni and offering relevant continuation activities. | Ongoing Operations and Future Programs: Site security, reporting to donors, offering Netaim continuation programs. |
4. Sharing Data with Third Parties
We share your information solely with parties required for operating the program and meeting legal requirements:
| Purpose of Sharing | Recipient |
|---|---|
| Data Processors: Used for document storage and registration management (CRM). These entities act on behalf of the Association. | SaaS Service Providers (e.g., Monday.com) |
| Sharing application details for scholarship eligibility checks and participation coordination. | "Masa" Organization |
| For matching a Kibbutz and placement for residence and work. | Various Kibbutzim |
| Your medical information is transferred to our insurance provider for issuing a mandatory medical insurance policy and confirming coverage. | Insurance Companies |
| Ministry of Interior (visas) and relevant embassies. | State Authorities |
5. International Data Transfers
The Association operates in Israel (outside the European Union). Data is collected on Data Subjects (participants) who voluntarily come to Israel or participate in international programs.
- Transfer to Israel: The Association relies on the fact that Data Subjects voluntarily contact and choose to transfer the information to Israel.
- Legal Basis (Art. 49(1)): Explicit Consent and Contract Performance with the Data Subjects.
- Cloud Services: Providers (Monday) may store data on servers in the USA.
- For users in the EEA: The European Commission has determined that Israel provides an adequate level of protection for personal data (Adequacy Decision).
6. Data Retention
We retain your personal data only for as long as necessary for the purposes for which it was collected:
- Medical Information: Retained for 7 years from the end of the program to comply with legal requirements.
- Contact Details: Kept in the Netaim Organization's databases to offer participants and alumni continuation programs.
- General Participation: Retained as long as you are an active participant or candidate.
- Marketing: Retained until you unsubscribe or request deletion.
7. Your Rights as Data Subjects (GDPR Rights)
Data subjects have the following rights:
- Withdraw Consent: Regarding medical information (note: insurance is mandatory for participation).
- Access, Rectification & Erasure: To receive a copy, correct, or request deletion of data.
- Object: To object to processing for marketing or continuation programs.
- Other Rights: Right to restriction and data portability.
8. Data Security
The Association implements technical and organizational security measures to protect information against unauthorized access, alteration, or exposure. Access is limited to authorized employees only.
9. Cookies and Tracking Technologies
Our site uses Cookies for proper operation and traffic analysis. Use of marketing cookies (such as Facebook Pixel) is subject to your consent via the Cookie Banner.
10. Contact Information
For questions regarding this policy or to exercise your rights, please contact us:
Organization: Netaim Organization, Habonim Dror Association – "Kibbutz Ulpan"
Address: HaYasmin 1, Ramat Gan
Email: media@netaimolami.org
11. Updates to the Policy
We reserve the right to update this policy. Material changes will be published on the website.
