Privacy Policy

1Introduction

1.1This Privacy Policy (the “Policy”) explains how Mine Marketing LTD (“Mine Marketing”) collects, uses, discloses, keeps and protects Personal Data in the circumstances described in Section 4, and the rights that individuals have over that Personal Data.

1.2It is the notice that Mine Marketing gives under the Data Protection Laws, including Arts. 13 and 14 of the GDPR and the UK GDPR. Where a clause applies only under a particular law, it says so. It is to be read with the Cookie Policy and the Terms & Conditions.

2Controller and contact details

2.1Mine Marketing is the controller of the Personal Data described in this Policy and, under the Israeli Privacy Law, the controller of the databases in which it is held:

Controller

Mine Marketing LTD, a company incorporated in Israel

Registered address

28 HaArba'a St., Tel Aviv-Yafo 6473925, Israel

Email

team@mine-marketing.com, with “Privacy” in the subject line

Website

https://mine-marketing.com

2.2Where the Data Protection Laws require Mine Marketing to appoint a data protection officer, or to designate a representative under Art. 27 of the GDPR or the UK GDPR or under the Swiss Federal Act on Data Protection, it will do so and name them in this Policy. Individuals and supervisory authorities in every jurisdiction may contact Mine Marketing directly at the details above.

3Definitions

3.1In this Policy, “including” means “including without limitation”, and:

Applicant

An individual who applies, or asks about applying, for a role at Mine Marketing.

Business Contact

An individual who works for or represents a Client, prospective client, supplier, advertising platform, feed partner or other organisation with which Mine Marketing does or may do business.

CCPA

The California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020, and its regulations.

Client

A business that has signed a written agreement for services with Mine Marketing (an “Agreement”, which includes any document made under it).

Content Hosts

Google Fonts (fonts.googleapis.com and fonts.gstatic.com) and the jsDelivr content delivery network, from which the Site loads its fonts and animation libraries (GSAP, Lenis and Three.js).

Data Protection Laws

The Israeli Privacy Law; the GDPR; the UK GDPR and the Data Protection Act 2018; the Swiss Federal Act on Data Protection (“FADP”); the EU ePrivacy Directive and the laws implementing it, and the UK Privacy and Electronic Communications Regulations (“PECR”); the CCPA and other US state consumer privacy laws; and any other data-protection law that applies to the processing concerned.

Enquiry

Any message or information sent to Mine Marketing through the Site’s contact form, or by email to an address published on the Site, including a job application.

Form Service

FormSubmit (formsubmit.co), the service that receives submissions of the Site’s contact form and delivers them to Mine Marketing by email.

GDPR

Regulation (EU) 2016/679, the General Data Protection Regulation; the “UK GDPR” is the GDPR as it forms part of UK law.

Israeli Privacy Law

The Protection of Privacy Law, 5741-1981, as amended (including by Amendment No. 13), and its regulations, including the Protection of Privacy (Data Security) Regulations, 5777-2017 (the “Data Security Regulations”).

Personal Data

Any information relating to an identified or identifiable individual, including “personal information” as defined in the Data Protection Laws.

Request Data

The technical data that a browser sends with every request for a page or file: the IP address, the date and time, the page or file requested, the browser type and version, the operating system, the language and the referring page. A general location may be inferable from the IP address (Section 5).

Site

The website at https://mine-marketing.com, including all of its pages and the policies published on it.

Visitor

Any individual who accesses or uses the Site or makes an Enquiry.

4Scope

4.1This Policy applies to Personal Data that Mine Marketing processes as a controller about:

1. Visitors, when they use the Site;
2. individuals who make an Enquiry or otherwise correspond with Mine Marketing;
3. Business Contacts;
4. Applicants, including those who follow the Site’s “Careers” link to the contact section and apply by email; and
5. individuals who visit, follow or interact with Mine Marketing’s company page on LinkedIn (Section 8).

4.2This Policy does not apply to:

1. Client data. Personal Data that Mine Marketing processes for a Client in providing services, such as advertising-account, audience and conversion data, which it processes as the Client’s processor or service provider, only on the Client’s instructions and under the Agreement. The Client’s privacy notice applies, and requests should go to the Client, whom Mine Marketing will assist.
2. Owned properties and AdsBuzz. The websites that Mine Marketing operates in search arbitrage, and AdsBuzz at ads.buzz, which have their own privacy notices.
3. Third-party websites, including those linked from the Site (Section 22).
4. Personnel data of Mine Marketing’s employees and contractors, covered by separate notices.

5Personal Data collected and its sources

5.1Mine Marketing collects the following Personal Data, from the sources shown:

5.2The contact form contains a hidden field that people are not expected to complete; a submission in which it is completed is treated as spam, and the field has no other use.

5.3The Site sets no cookies of its own and runs no analytics or advertising tags, tracking pixels, fingerprinting or session recording. It keeps one item in the browser’s sessionStorage, under the key “hl-ov”, recording that the opening animation has been shown. That item holds no Personal Data, is not sent anywhere and is cleared when the tab is closed; if storage is blocked, the full animation plays each time. The Cookie Policy describes it.

5.4Mine Marketing asks individuals not to send special categories of Personal Data or other sensitive information, such as health information, identification numbers or financial account details. Any that an Applicant includes is used only where necessary and lawful, and otherwise deleted.

5.5Whether Personal Data must be provided. No law or contract requires anyone to provide Personal Data to Mine Marketing; doing so depends on the individual’s choice and consent. Every field of the contact form is needed to answer an Enquiry, and the form cannot be sent without them; the individual may write by email instead. Without the necessary details an Agreement cannot be performed or an application considered. Request Data is sent by every browser and is needed to deliver the Site.

5.6Where Mine Marketing receives Personal Data about an individual from someone else, it gives that individual the information in this Policy within one month, or at its first communication with them if earlier, unless they already have it or the law provides otherwise.

6Purposes and legal bases

6.1Mine Marketing processes Personal Data for the purposes below. Where the GDPR or the UK GDPR applies, the legal basis for each, and any legitimate interest relied on, is as shown. Where the FADP applies and a justification is required, Mine Marketing relies on the same grounds:

6.2Where Mine Marketing relies on legitimate interests, it has balanced them against the interests, rights and freedoms of the individuals concerned, and will describe that balance on request. Individuals may object at any time (Section 15).

6.3Ticking the box “I agree to the Privacy Policy” confirms that the Visitor has been given this Policy and, under the Israeli Privacy Law, records their informed consent to the processing of Enquiry data as this Policy describes. Where the GDPR or the UK GDPR applies, Mine Marketing relies on the bases above, not on that box. It is never consent to marketing.

6.4Mine Marketing uses Personal Data only for the purposes in this Policy or as the law otherwise permits, and will not use it for a new, incompatible purpose without first informing the individuals concerned and, where required, obtaining their consent.

7Marketing communications

7.1Mine Marketing sends marketing emails only to Business Contacts who have consented, or, where the law on electronic marketing permits (including the laws implementing the ePrivacy Directive, PECR and the Israeli Communications (Telecommunications and Broadcasting) Law, 5742-1982), to existing Business Contacts about similar services, if they were offered a simple way to refuse when their details were collected.

7.2Every marketing email identifies Mine Marketing and gives a free and simple way to opt out; individuals may also write to team@mine-marketing.com with “Unsubscribe” in the subject line. Mine Marketing gives effect to an opt-out within 10 business days and records it so that it is respected. Opting out does not affect service or contractual messages.

7.3Mine Marketing does not use Personal Data collected under this Policy for targeted or cross-context behavioural advertising, and does not upload it to advertising platforms to build audiences.

8The LinkedIn page

8.1Mine Marketing operates a company page at linkedin.com/company/mine-marketing. LinkedIn gives page administrators “Page Insights”, statistics that it derives from members’ activity on the page.

8.2For the processing that produces Page Insights, Mine Marketing and LinkedIn are joint controllers under the GDPR and the UK GDPR, on the terms of LinkedIn’s Page Insights Joint Controller Addendum, under which LinkedIn takes primary responsibility for that processing, for informing members about it and for answering their requests. Mine Marketing receives only aggregated statistics and cannot identify members from them. Individuals may exercise their rights with LinkedIn directly, or through Mine Marketing, which will pass the request on.

8.3Messages and comments sent to the page are handled as correspondence under this Policy. All other processing by LinkedIn is governed by LinkedIn’s privacy policy.

9Recipients of Personal Data

9.1Mine Marketing discloses Personal Data only to the following recipients, and only as needed for the purposes in Section 6:

9.2If the contact form cannot be submitted, the Visitor’s own email application opens with the message prepared, and nothing is sent until the Visitor sends it.

9.3Mine Marketing engages processors only under written terms that require them to act on its instructions, keep Personal Data confidential and secure, bind any sub-processor to the same terms, assist with requests and incidents, and delete or return the data at the end of the service. Within Mine Marketing, access is limited to staff who need it.

9.4Mine Marketing does not sell, rent or trade Personal Data, does not share it for cross-context behavioural or targeted advertising, and does not disclose it to data brokers or to third parties for their own direct marketing.

10International transfers

10.1Mine Marketing is established in Israel. The European Commission has recognised Israel as ensuring an adequate level of protection, as have the United Kingdom and Switzerland, so Personal Data may be transferred from the EEA, the United Kingdom and Switzerland to Mine Marketing on that basis (Art. 45 of the GDPR and the UK GDPR).

10.2Some recipients process Personal Data outside Israel, including in the United States. Transfers from Israel comply with the Israeli Privacy Law’s rules on transfers abroad. Where the GDPR, the UK GDPR or the FADP applies, Mine Marketing transfers Personal Data only to countries recognised as adequate or under an Art. 46 safeguard, as follows:

10.3A copy of the safeguard for a transfer may be requested under Section 24; commercially sensitive terms may be redacted.

11Retention

11.1Mine Marketing keeps Personal Data only as long as needed for the purposes in Section 6, as follows:

11.2At the end of the period, Mine Marketing deletes the Personal Data or anonymises it so that no one can be identified, unless a legal hold or claim requires it to be kept longer, and then only while that lasts. Deleted data may remain in secure backups until they are overwritten in the normal cycle, and is not used meanwhile. The Content Hosts and LinkedIn keep data under their own retention policies.

12Security

12.1Mine Marketing protects Personal Data with technical and organisational measures appropriate to the risk, in accordance with the Data Protection Laws and, for its databases, the Data Security Regulations, including:

1. transmission of contact-form submissions over an encrypted (TLS) connection, and encryption of other Personal Data in transit wherever the systems involved support it;
2. access limited to authorised staff who need it, with individual accounts, multi-factor authentication where the system supports it, and prompt removal of access when it is no longer needed;
3. written confidentiality obligations and data-protection training for staff and contractors;
4. assessment of service providers before engagement, and written terms requiring them to protect Personal Data;
5. a static Site, with no database, user accounts or server-side code processing Visitors’ data; and
6. periodic review of these measures.

12.2No transmission or storage is completely secure, and email may pass through systems outside Mine Marketing’s control; sensitive information should not be sent by email or through the form.

13Personal Data breaches

13.1Mine Marketing maintains a procedure for detecting, containing, investigating and recording security incidents. Where a Personal Data breach occurs, it will, as the law requires:

1. notify the Privacy Protection Authority where the Data Security Regulations require, and affected individuals where the Authority directs or the law requires;
2. under the GDPR or the UK GDPR, notify the competent supervisory authority without undue delay and, where feasible, within 72 hours of becoming aware of it, unless it is unlikely to result in a risk to individuals (Art. 33), and inform affected individuals without undue delay where it is likely to result in a high risk (Art. 34);
3. under the FADP, notify the Federal Data Protection and Information Commissioner as soon as possible where it is likely to result in a high risk; and
4. notify individuals and authorities under any applicable US state breach-notification law.

14Artificial intelligence and automated decisions

14.1Mine Marketing does not use Personal Data, including Personal Data collected under this Policy, to train, fine-tune or evaluate artificial-intelligence or machine-learning models, and does not permit its processors to do so. Where staff use a language-model tool to help prepare or summarise correspondence, they use only tools whose terms prohibit the provider from training on the input.

14.2Mine Marketing makes no decision about an individual based solely on automated processing, including profiling, that produces legal or similarly significant effects (Art. 22 of the GDPR). Every decision on an Enquiry or application is made by a person; the only automated processing under this Policy is spam filtering of form submissions and incoming email.

14.3The use of artificial intelligence in Client services is described in the Responsible AI Policy.

15Rights of individuals

15.1Subject to the conditions and exceptions in the Data Protection Laws that apply to them, individuals have the right:

1. of access: to confirm whether Mine Marketing processes their Personal Data, and to receive a copy with information about the processing (Art. 15);
2. to correction of inaccurate or incomplete Personal Data (Art. 16);
3. to deletion, including where the data is no longer needed, consent is withdrawn or an objection is upheld (Art. 17);
4. to restriction of processing while accuracy or an objection is considered, or where data is kept only for a legal claim (Art. 18);
5. to portability of data they provided and that is processed by automated means on the basis of consent or contract, in a structured, commonly used, machine-readable format (Art. 20);
6. to object to processing based on legitimate interests, on grounds relating to their situation, in which case Mine Marketing will stop unless it has compelling legitimate grounds or needs the data for a legal claim; and to object to direct marketing at any time, in which case it will stop (Art. 21);
7. to withdraw consent at any time, without affecting processing carried out before withdrawal;
8. not to be subject to solely automated decisions with legal or similarly significant effects (Art. 22; Section 14); and
9. to complain to a supervisory authority (Section 17).

15.2Mine Marketing tells each recipient of the Personal Data about any correction, deletion or restriction, unless this is impossible or disproportionate, and identifies those recipients on request (Art. 19). Additional rights under Israeli law and in the United States are set out in Section 18, Section 19 and Section 20.

16How to exercise rights

16.1Requests may be sent to team@mine-marketing.com with “Privacy request” in the subject line, or by post to the address in Section 2, stating the right exercised and the individual’s relationship with Mine Marketing.

16.2Verification. Mine Marketing verifies the requester’s identity before acting, normally by confirming that the request comes from the email address linked to the Personal Data. It may ask for more information where necessary, which it uses only for verification. No account is required.

16.3Authorised agents. An individual may act through an agent. Mine Marketing may require the individual’s signed permission and may ask the individual to verify their identity directly, unless the agent holds a power of attorney.

16.4Response times. Mine Marketing responds:

1. under the GDPR and the UK GDPR, within one month, extendable by two further months where necessary given the complexity or number of requests, with notice of the extension and its reasons within the first month;
2. under the Israeli Privacy Law and the FADP, within 30 days;
3. under the CCPA, confirming receipt within 10 business days and responding within 45 calendar days, extendable once by 45 calendar days with notice; and
4. under other US state laws, within 45 days, extendable once by 45 days with notice.

16.5Fees and refusals. Requests are free of charge. Where a request is manifestly unfounded or excessive, Mine Marketing may charge a reasonable fee or decline it, as the law permits. When it declines a request in whole or part, it gives its reasons and explains the individual’s rights to complain and, where available, to appeal or apply to a court.

17Complaints

17.1Individuals may raise a concern with Mine Marketing (Section 24) and may complain at any time to a supervisory authority, in particular:

Israel

The Privacy Protection Authority.

EEA

The supervisory authority of the Member State of the individual’s habitual residence or place of work, or of the alleged infringement (Art. 77 of the GDPR).

United Kingdom

The Information Commissioner’s Office.

Switzerland

The Federal Data Protection and Information Commissioner.

United States

For California residents, the California Privacy Protection Agency or the California Attorney General; elsewhere, the Attorney General of the individual’s state.

18Additional information under Israeli law

18.1Under the Israeli Privacy Law, Mine Marketing informs individuals that: there is no legal duty to provide Personal Data, which depends on their will and consent, and the consequences of not providing it are set out in Section 5; the purposes for which it is requested are those in Section 6; the recipients to whom it is passed, and their purposes, are those in Section 9; and it is secured as Section 12 describes.

18.2Every individual may inspect, personally or through a representative authorised in writing, the Personal Data about them held in Mine Marketing’s databases, and may ask for data that is incorrect, incomplete, unclear or out of date to be corrected or deleted. If Mine Marketing refuses, it gives reasons, and the individual may apply to the court as the law provides. An individual may also ask at any time to be removed from any database used for direct mailing (Section 7).

19Information for California residents

19.1This Section is Mine Marketing’s notice at collection and privacy-policy disclosure under the CCPA, to the extent the CCPA applies to it, and covers Business Contacts and Applicants as well as Visitors.

19.2In the preceding 12 months, Mine Marketing has collected the following categories of personal information, for the business purposes in Section 6, and disclosed them for a business purpose as shown:

19.3Mine Marketing does not sell personal information or share it for cross-context behavioural advertising, has not done so in the preceding 12 months, and has no actual knowledge of selling or sharing the personal information of anyone under 16. It does not request sensitive personal information; any that an individual volunteers, for example in an application, is handled as Section 5 describes. It does not use sensitive personal information to infer characteristics, or for any purpose other than those the CCPA permits, so the right to limit does not apply. It offers no financial incentives. The retention period for each category is that of the record in which it is held, as set out in Section 11.

19.4California residents have the rights to know and access the personal information collected about them (including its categories, sources, purposes and recipients), to delete it, to correct it, to opt out of its sale or sharing, and to limit the use of sensitive personal information, and not to be discriminated or retaliated against for exercising them. Requests may be made under Section 16, including through an authorised agent.

19.5Global Privacy Control. Mine Marketing treats a Global Privacy Control signal as a valid request to opt out of sale and sharing for that browser; as it neither sells nor shares personal information, the signal takes effect without further action.

19.6Do Not Track. The Site does not track Visitors over time or across other websites, and no third party collects personal information about Visitors’ online activities through it, other than the Request Data that the Content Hosts receive to deliver content. The Site therefore treats Do Not Track signals like any other visit.

19.7“Shine the Light”. Mine Marketing does not disclose personal information to third parties for their direct-marketing purposes.

20Residents of other US states

20.1Where another US state’s consumer privacy law applies to Mine Marketing and to their Personal Data, residents have rights to confirm and access the processing of their Personal Data, to correct and delete it, to obtain a portable copy, and to opt out of targeted advertising, sale and profiling in furtherance of decisions with legal or similarly significant effects. Mine Marketing engages in none of those three activities.

20.2Requests may be made under Section 16. If Mine Marketing declines to act, the individual may appeal within a reasonable period by writing to team@mine-marketing.com with “Privacy appeal” in the subject line. Mine Marketing decides appeals in writing within 60 days, or any shorter period the law requires; if an appeal is denied, the individual may contact their state Attorney General.

21Children

21.1The Site and Mine Marketing’s services are intended for businesses and are not directed at anyone under 18. Mine Marketing does not knowingly collect Personal Data from anyone under 18, including children under 13 within the meaning of the Children’s Online Privacy Protection Act, and will promptly delete any it learns it has received. A parent or guardian may contact Mine Marketing under Section 24.

22Third-party websites

22.1The Site links to websites operated by others, including LinkedIn, TikTok for Business, AdsBuzz and the advertising platforms. Those operators, and the Content Hosts, handle Personal Data under their own privacy notices, which this Policy does not cover and for which Mine Marketing is not responsible.

23Changes to this Policy

23.1Mine Marketing reviews this Policy at least every 12 months and whenever its processing changes, and publishes the current version on this page with its last-updated date. It identifies a material change at the top of this page for at least 30 days and, where the change affects them and it holds their details, notifies Business Contacts by email. Where a change requires consent, Mine Marketing obtains it first.

23.2If this Policy is translated, the English version prevails to the extent the law permits.

24Contact

24.1Questions and requests about this Policy should be sent to Mine Marketing LTD at team@mine-marketing.com, with “Privacy” in the subject line, or by post to 28 HaArba'a St., Tel Aviv-Yafo 6473925, Israel.