The General Data Protection Regulation (EU) 2016/679 (GDPR)
- What data do we collect?
- How do we collect your data?
- How will we use your data?
- How do we store your data?
- What are your data protection rights?
- What are cookies?
- What types of cookies do we use?
- How to manage your cookies
- Privacy policies of other websites
- How to contact us
- How to contact the appropriate authorities
What data do we collect?
DryGair collects the following data:
- Personal identification information (Name, email address, phone number, etc.).
- Growing data
- Climate data
How do we collect your data?
You directly provide DryGair with most of the data we collect. We collect data and process data when you:
- Register online or place an order for any of our products or services.
- Voluntarily complete a customer survey or provide feedback on any of our message boards or via email
- Use or view our website via your browser’s cookies.
- Smart sensors in some of the units (only when connected to the internet)
How will we use your data?
DryGair collects your data so that we can:
- Process your order, manage your account.
- Email you with special offers on other products and services we think you might like.
How do we store your data?
DryGair securely stores your data at a cloud services company that comply with GDPR regulation.
DryGair would like to send you information about its products and services we think you may be interested in. If you have agreed to receive marketing, you can always opt out any time. You have the right at any time to stop DryGair from contacting you for marketing purposes or giving your data to other members of the DryGair Group. If you no longer want DryGair to contact you for marketing purposes, please click here.
What are your data protection rights?
DryGair is determined to make sure you are fully aware of all of your data protection rights. Every user is entitled to the following:
- The right to access – You have the right to request DryGair for copies of your personal data. We may charge you a small fee for this service.
- The right to rectification – You have the right to request that DryGair corrects any information you believe is inaccurate. You also have the right to request DryGair to complete information you believe is incomplete.
- The right to erasure – You have the right to request DryGair to erase your personal data, under certain conditions.
- The right to restrict processing – You have the right to request DryGair to restrict the processing of your personal data, under certain conditions.
- The right to object to processing – You have the right to object to DryGair ‘s processing of your 3/4 personal data, under certain conditions.
- The right to data portability – You have the right to request DryGair to transfer the data it has collected to another organization, or directly to you, under certain conditions. When you make a request, DryGair has one month to respond to you.
If you would like to exercise any of these rights, please contact us at our email: Call us at: +972-97730980 Or write to us.
What are cookies?
Cookies are text files placed on your computer to collect standard Internet log information and visitor behavior information. When you visit our websites, we may collect information from you automatically through cookies or similar technology. For further information, visit allaboutcookies.org.
- Keeping you signed in
- Understanding how you use our website
What types of cookies do we use?
There are different types of cookies, however, our website uses:
- Functionality – DryGair uses these cookies so that we recognize you on our website and remember your previously selected preferences. These preferences may include your language preference and your location. A mix of first party and third party cookies are used.
- Advertising – DryGair uses these cookies to collect information about your visit to our website, the content you viewed, the links you followed and information about your browser, device, and your IP address. DryGair sometimes shares some limited aspects of this data with third parties for advertising purposes. We may also share online data collected through cookies with our advertising partners. This means that when you visit another website, you may be shown advertising based on your browsing patterns on our website.
How to manage cookies
You can set your browser not to accept cookies, and the above website tells you how to remove cookies from your browser. However, in a few cases, some of our website features may not function as a result.
Privacy policies of other websites
How to contact us
How to contact the appropriate authority
Should you wish to file a complaint or if you feel that DryGair has not addressed your concerns in a satisfactory manner, you may contact the Information Commissioner’s Office. Email: [email protected] Address: Privacy Protection Authority, Government Ministries POB 7360, Tel Aviv, 6107202
GDPR Compliance Statement
The EU General Data Protection Regulation (“GDPR”) comes into force across the European Union on 25th May 2018 and brings with it the most significant changes to data protection law in two decades. Based on privacy by design and taking a risk-based approach, the GDPR has been designed to meet the requirements of the digital age. The 21st Century brings with it broader use of technology, new definitions of what constitutes personal data, and a vast increase in cross-border processing. The new Regulation aims to standardize data protection laws and processing across the EU; affording individuals stronger, more consistent rights to access and control their personal information.
DryGair management is committed to ensuring the security and protection of the personal information that we process, and to provide a compliant and consistent approach to data protection. We have always had a robust and effective data protection program in place which complies with existing law and abides by the data protection principles. However, we recognise our obligations in updating and expanding this program to meet the demands of the GDPR and the country DP law.
DryGair is dedicated to safeguarding the personal information under our remit and in developing a data protection regime that is effective, fit for purpose and demonstrates an understanding of, and appreciation for the new Regulation. Our preparation and objectives for GDPR compliance have been summarised in this statement and include the development and implementation of new data protection rules, policies, procedures, controls and measures to ensure maximum and ongoing compliance.
How We are Preparing for the GDPR
DryGair already has a consistent level of data protection and security across our organisation, however it is our aim to be fully compliant with the GDPR. Our preparation includes:
- Information Audit – carrying out a company-wide information audit to identify and assess what personal information we hold, where it comes from, how and why it is processed and if and to whom it is disclosed.
- Policies & Procedures – implementing new data protection policies and procedures to meet the requirements and standards of the GDPR and any relevant data protection laws, including:
- Data Protection – our main policy and procedure document for data protection has been overhauled to meet the standards and requirements of the GDPR. Accountability and governance measures are in place to ensure that we understand and adequately disseminate and evidence our obligations and responsibilities; with a dedicated focus on privacy by design and the rights of individuals.
- Data Retention & Erasure – we have updated our retention policy and schedule to ensure that we meet the ‘data minimisation’ and ‘storage limitation’ principles and that personal information is stored, archived and destroyed compliantly and ethically. We have dedicated erasure procedures in place to meet the new ‘Right to Erasure’ obligation and are aware of when this and other data subject’s rights apply; along with any exemptions, response timeframes and notification responsibilities.
- Data Breaches – our breach procedures ensure that we have safeguards and measures in place to identify, assess, investigate and report any personal data breach at the earliest possible time. Our procedures are robust and have been disseminated to all employees, making them aware of the reporting lines and steps to follow.
- International Data Transfers & Third-Party Disclosures – DryGair stores or transfers personal information outside the EU, we have robust procedures and safeguarding measures in place to secure, encrypt and maintain the integrity of the data. Our procedures include a continual review of the countries with sufficient adequacy decisions, as well as provisions for binding corporate rules; standard data protection clauses or approved codes of conduct for those countries without. We carry out strict due diligence checks with all recipients of personal data to assess and verify that they have appropriate safeguards in place to protect the information, ensure enforceable data subject rights and have effective legal remedies for data subjects where applicable.
- Subject Access Request (SAR) – we have revised our SAR procedures to accommodate the revised 30-day timeframe for providing the requested information and for making this provision free of charge. Our new procedures detail how to verify the data subject, what steps to take for processing an access request, what exemptions apply and a suite of response templates to ensure that communications with data subjects are compliant, consistent and adequate.
- Legal Basis for Processing – we are reviewing all processing activities to identify the legal basis for processing and ensuring that each basis is appropriate for the activity it relates to. Where applicable, we also maintain records of our processing activities, ensuring that our obligations under Article 30 of the GDPR and Schedule 1 of the Data Protection Bill are met.
- Privacy Notice/Policy – we are revising our Privacy Notice to comply with the GDPR, ensuring that all individuals whose personal information we process have been informed of why we need it, how it is used, what their rights are, who the information is disclosed to and what safeguarding measures are in place to protect their information.
- Obtaining Consent – we are revising our consent mechanisms for obtaining personal data, ensuring that individuals understand what they are providing, why and how we use it and giving clear, defined ways to consent to us processing their information. We have developed stringent processes for recording consent, making sure that we can evidence an affirmative opt-in, along with time and date records; and an easy to see and access way to withdraw consent at any time.
- Direct Marketing – we are revising the wording and processes for direct marketing, including clear opt-in mechanisms for marketing subscriptions; a clear notice and method for opting out and providing unsubscribe features on all subsequent marketing materials.
- Data Protection Impact Assessments (DPIA) – where we process personal information that is considered high risk, involves large scale processing or includes special category/criminal conviction data; we have developed stringent procedures and assessment templates for carrying out impact assessments that comply fully with the GDPR’s Article 35 requirements. We have implemented documentation processes that record each assessment, allow us to rate the risk posed by the processing activity and implement mitigating measures to reduce the risk posed to the data subject(s).
- Processor Agreements – where we use any third-party to process personal information on our behalf (i.e. Payroll, Recruitment, Hosting etc), we have drafted compliant Processor Agreements and due diligence procedures for ensuring that they (as well as we), meet and understand their/our GDPR obligations. These measures include initial and ongoing reviews of the service provided, the necessity of the processing activity, the technical and organizational measures in place and compliance with the GDPR.
- Special Categories Data – where we obtain and process any special category information, we do so in complete compliance with the Article 9 requirements and have high-level encryptions and protections on all such data. Special category data is only processed where necessary and is only processed where we have first identified the appropriate Article 9(2) basis or the Data Protection Bill Schedule 1 condition. Where we rely on consent for processing, this is explicit and is verified by a signature, with the right to modify or remove consent being clearly signposted.
Data Subject Rights
In addition to the policies and procedures mentioned above that ensure individuals can enforce their data protection rights, we provide easy to access information via our office, of an individual’s right to access any personal information that DryGair processes about them and to request information about:
- What personal data we hold about them
- The purposes of the processing
- The categories of personal data concerned
- The recipients to whom the personal data has/will be disclosed
- How long we intend to store your personal data for
- If we did not collect the data directly from them, information about the source
- The right to have incomplete or inaccurate data about them corrected or completed and the process for requesting this
- The right to request erasure of personal data (where applicable) or to restrict processing in accordance with data protection laws, as well as to object to any direct marketing from us and to be informed about any automated decision-making that we use
- The right to lodge a complaint or seek judicial remedy and who to contact in such instances
Information Security & Technical and Organizational Measures
DryGair takes the privacy and security of individuals and their personal information very seriously and takes every reasonable measure and precaution to protect and secure the personal data that we process. We have robust information security policies and procedures in place to protect personal information from unauthorized access, alteration, disclosure or destruction and have several layers of security measures, including:
- access control
- password policy
GDPR Roles and Employees
DryGair has designated the administrative manager as our appointed person and have appointed a data privacy team to develop and implement our roadmap for complying with the new data protection Regulation. The team is responsible for promoting awareness of the GDPR across the organization, assessing our GDPR readiness, identifying any gap areas and implementing the new policies, procedures and measures. DryGair understands that continuous employee awareness and understanding, is vital to the continued compliance of the GDPR and has involved its employees in its preparation plans. We have implemented an employee training program specific to the which will be provided to all employees prior to May 25th, 2020, and forms part of our induction and annual training program. If you have any questions about our preparation for the GDPR, please contact the Appointed Person.
Right to erasure request form
You are entitled to request us to erase any personal data we hold about you under EU General Data Protection Regulation (GDPR). We will do our best to respond promptly and in any event within one month of the following:
- Our receipt of your written request; or
- Our receipt of any further information we may ask you to provide to enable us to comply with your request, whichever happens to be later.
The information you supply in this form will only be used for the purposes of identifying the personal data you are requesting that we erase and responding to your request. You are not obliged to complete this form to make a request, but doing so will make it easier for us to process your request quickly.
We do not sell, trade, or otherwise transfer to outside parties your Personally Identifiable Information.
We do not include or offer third-party products or services on our website.
Google’s advertising requirements can be summed up by Google’s Advertising Principles. They are put in place to provide a positive experience for users. https://support.google.com/adwordspolicy/answer/1316548?hl=en
We have implemented the following:
- Demographics and Interests Reporting
We, along with third-party vendors such as Google use first-party cookies (such as the Google Analytics cookies) and third-party cookies (such as the DoubleClick cookie) or other third-party identifiers together to compile data regarding user interactions with ad impressions and other ad service functions as they relate to our website.
Users can set preferences for how Google advertises to you using the Google Ad Settings page. Alternatively, you can opt out by visiting the Network Advertising Initiative Opt Out page or by using the Google Analytics Opt Out Browser add on.
We use Zoho SalesIQ to collect and analyze visitor’s data:
- Cookie that stores the GDPR consent from the visitor – enable/disable tracking.
- Cookie that identifies unique visitors
- Cookie that is set when the Live Chat feature is disabled by proactive.
Most browsers allow users to control and manage cookies by allowing them to choose their preferences under the Settings or Preferences tab of the respective browsers.
California Online Privacy Protection Act
According to CalOPPA, we agree to the following:
Users can visit our site anonymously.
Can change your personal information:
- By emailing us
- By calling us
How does our site handle Do Not Track signals?
We honor Do Not Track signals and Do Not Track, plant cookies, or use advertising when a Do Not Track (DNT) browser mechanism is in place.
Does our site allow third-party behavioral tracking?
It’s also important to note that we do not allow third-party behavioral tracking
COPPA (Children Online Privacy Protection Act)
When it comes to the collection of personal information from children under the age of 13 years old, the Children’s Online Privacy Protection Act (COPPA) puts parents in control. The Federal Trade Commission, United States’ consumer protection agency, enforces the COPPA Rule, which spells out what operators of websites and online services must do to protect children’s privacy and safety online.
We do not specifically market to children under the age of 13 years old.
Do we let third-parties, including ad networks or plug-ins collect PII from children under 13?
Fair Information Practices
The Fair Information Practices Principles form the backbone of privacy law in the United States and the concepts they include have played a significant role in the development of data protection laws around the globe. Understanding the Fair Information Practice Principles and how they should be implemented is critical to comply with the various privacy laws that protect personal information.
In order to be in line with Fair Information Practices we will take the following responsive action, should a data breach occur:
We will notify you via email
Within 14 business days
We will notify the users via in-site notification
Within 14 business days
We also agree to the Individual Redress Principle which requires that individuals have the right to legally pursue enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data users, but also that individuals have recourse to courts or government agencies to investigate and/or prosecute non-compliance by data processors.
Proposition 65 warnings can be found on many manufacturers’ products and packaging, including ours.
These warnings are a result of a California State Law passed in 1986—the California Safe Drinking Water and Toxic Enforcement Act of 1986, also commonly known as Proposition 65. Read on for more information on Proposition 65 Warnings.
What is proposition 65? The purpose of Prop 65 is to ensure the public is informed about the potential exposure to chemicals known to cause cancer, birth defects, or other reproductive harm.
Proposition 65 requires the State of California to publish a list of these chemicals. This list currently contains over 900 chemicals and continues to expand.
The law also requires companies to provide a warning on their products and/or packaging if they contain these chemicals. Chemicals on this list can be found in many everyday items. A warning must be given if the listed chemical is present in a product unless it can be demonstrated that the chemical poses “no significant risk.” For chemicals that can cause cancer, the ‘no significant risk’ level is defined as the level, which is calculated to result in not more than one excess case of cancer in 100,000 individuals exposed over a 70-year lifetime.
Our products may have traces of various chemicals that are on the list, but they are all a part of the normal manufacturing process.
What does a Proposition 65 warning mean? The warning does not mean our products will inevitably cause cancer or reproductive harm. Proposition 65 may be best defined as a “Right to Know” law and Proposition 65 warnings are not an indication that a product is violating safety standards or regulations.
Why do some products include this warning? Proposition 65 law applies to any company operating, manufacturing, or selling products in the state of California. Our products are sold internationally and it would be difficult or impossible to place warnings only on products shipped to or sold in California. At this time, we have chosen to include this warning on all of our products to ensure compliance with Proposition 65 law, regardless of destination.
Visit the state of California’s Proposition 65 website at: www.p65warnings.ca.gov