Last Updated: September 2023

Privacy Policy

Spiral Solutions Ltd. (the “Company“, “we“, “us” and “our“) respects your privacy. This Privacy Policy explains our privacy practices for this website (the “Website”) and/or as part of our activities, as well as our business relationships with partners and/or contractors (collectively “Partner(s)”) and/or Candidates (as defined below). This Privacy Policy describes the ways your personal information is collected and used.


This Privacy Policy covers our treatment of Personal Data. Our gathering of data is limited to you as the Website’s user and/or visitor (herein “User(s)”; “you”) while using our Website and/or as a candidate who submits his/her candidacy for a position in the Company and/or in its affiliated companies (herein “Candidate”; “you”).

We may gather various types of Personal Data from our User(s) and/or Candidate (s), as explained in more detail below, and we use this Personal Data internally to personalize, provide, and improve our Services. For example, we may use data to allow you to set up a User account and/or Candidate profile and to contact you.


Device and analytical data. We collect basic information about the personal computer or mobile device you use to access the Website, including its model, its operating system, browser type, the Internet Protocol (IP) address through which you accessed the Website and the approximate city from which you accessed the Website.

Inquiries. If you contact us for questions or inquiries, or submit an inquiry using one of our “contact us” forms, we will collect the information related to your inquiry. This may include your name, email address and other contact information, depending on the nature of your inquiry.

Applying for available positions at Spiral Solutions. As a Candidate, you may apply for career opportunities at Spiral Solutions through the Website and/or through data processors to whom we have instructed to collect, store and process personal information on our behalf for the purposes of providing our services, for example, Comeet, as a recruiting and applicant tracking platform (“Platform”) in order to handle your personal data as a candidate. To do so, you will be asked to provide information such as your name, email address, phone number and a copy of your résumé (curriculum vitae – CV). The CV you submit will typically include your personal information. Note that your application does not obligate us to consider your candidacy, contact you regarding your application or hire you.

We receive personal data about you as a Candidate for positions at the Company, such as: contact information, address, Curriculum Vitae (resumé) information (including information such as skills, work experience, education), notes submitted with the application, URL of your LinkedIn and other online profiles, the position for which you have been or are being considered, the source who submitted your candidacy (e.g., recruiting agency, referral), email correspondences between you, the Company and between the Company and other sources (such as recruiting agency and referrals) about your candidacy, information from references, events in the lifecycle of your candidacy, your responses to questionnaires sent to you by us, information about your candidacy and employment options (such as availability to be hired and salary expectations), evaluations of your candidacy, internal discussions within the Company about your candidacy, materials you or other parties (such as evaluators or background check providers) submitted in relation to your candidacy. If you submit your candidacy by email, or online, then you are the main source of the personal data. Your personal data can also originate from other sources, such as LinkedIn profiles, recruitment agencies, headhunters and referrals.

In certain cases, we may also share some Personal Data with third parties, such as the Platform, and as described below.


We may use the information outlined above for the following purposes:

  • To facilitate access to and use of the Website, and to manage the operational and administrative aspects of the Website;
  • If you provided your contact details or submitted an inquiry, we may use your personal information to contact you, either directly or through others on our behalf, including via the Platform and/or by e-mail messages;
  • To improve and enhance the content offered on the Website;
  • To enforce this Privacy Policy, and prevent misuse of the Website and our services;
  • To comply with any applicable law and assist law enforcement agencies and authorities, if we believe it is necessary or justified; and
  • Take any action in any case of a dispute involving you with respect to the Website.

We will use your personal data in accordance with this Privacy Policy, including to evaluate and consider you as a Candidate for positions, in accordance with its processes and policies for evaluating employment candidates, to contact you for your candidacy status and interviews, to schedule meetings and interviews, amongst others.

The lawful bases we rely on for processing personal information are (if applicable to us under privacy law):

  • You gave us your consent to the processing of your personal data (for one or more specific purposes);
  • Processing is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract;
  • Processing is necessary for the purposes of the legitimate interest; and/or
  • Processing is necessary for compliance with a legal obligation to which the controller is subject.

If you have questions about these uses, please contact us. Please note that the legal basis is provided for General Data Protection Regulation (the “GDPR”) purposes only (if applicable).

Sharing collected information.

We may share personal information outlined in this Privacy Policy, with others, in any of the following instances:

  • With our service providers – in order to operate, maintain and enhance the Website and facilitate our email communications with you;
  • Personal information pertaining to your application for open positions at Spiral Solutions (including your CV) may be shared with service providers we engage with to evaluate candidates, including, Comeet (who provide us with the Platform) in the context of your candidacy. These service providers are authorized to use your personal data as necessary to provide these services or as otherwise authorized by us. Comeet’s privacy policy is available here;
  • If your details are submitted to the Company by a third party (such as an employee of the Company or a recruiting agency), the Company can give the third party access to your name, photo and some of the general recruitment status.
  • If you apply to a job opening using a unique referral link that was provided to you by an employee of the Company to which you are applying, the Company may share some of your general recruitment status, without identifying you by name, with the person that provided you the referral link.
  • The purpose of sharing the above information is to operate incentive programs (i.e., employee referral bonus programs) of the Company and to provide feedback to third parties who submit Candidates to the Company regarding their submission.
  • If, in the future, we sell or transfer, or we consider selling or transferring, some or all of our business, shares or assets to a third party, we will disclose your personal data to such third party (whether actual or potential) in connection with the foregoing events.
  • In the event that we are acquired by, or merged with, a third party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer, disclose or assign your personal data in connection with the foregoing events, including, in connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or to another company.
  • If you abused your rights to use the Website, or violated any applicable law – your information may be shared with authorities or other third parties, if we believe it is necessary or justified;
  • With attorneys, courts and relevant third parties, in any case of dispute, or legal proceeding of any kind involving you with respect to the Website;
  • If the operation of the Website is organized within a different framework, or through another legal structure or entity (such as due to a merger or acquisition), provided that those entities agree to be bound by the provisions of this Privacy Policy, with reasonably necessary changes taken into consideration; and
  • We may share personal information with our corporate group entities (companies that we control, control us, or are under common control with us – whether directly or indirectly), but their use of such information must comply with the Privacy Policy.

In any case other than above, your personal information will be shared with others only if you provide your explicit prior consent.


If the law grants you such rights, you may ask to access the personal information about you that is stored in our systems. You may also ask for our confirmation as to whether or not we process personal data concerning you.

Subject to the limitations in law, you may request that we update, correct or delete inaccurate or outdated information, and have us suspend the use of personal data whose accuracy you contest while we verify the status of that data.

If you wish to exercise any of these rights, contact us at:  When handling these requests, we may ask for additional information to confirm your identity and your request.

Cookies and other trackers

We use various types of cookies and other types of web trackers, which help us to administer and operate the Website.

These trackers are used mainly to collect statistical information about your use of the Website;.

We use cookies for Website analytics purposes, as explained above.

If you wish to block cookies, you may do so through your browser’s settings. You can delete cookies that are already on your computer and you can set your browser to prevent them from being placed going forward. Please refer to the browser’s help menu for further information.

For information about opting-out of Google Analytics cookies, click here. Please also bear in mind that disabling cookies may adversely affect your user experience on the website.

Third parties

When you use our Website, other parties, such as Google, may collect personally identifiable information about your online activities over time and across different websites.

Transfer of data outside your territory

We may store and process information in countries such as the United States and elsewhere. We may also process information using cloud services. In certain cases, the laws in some of these countries may provide a lesser degree of data protection than the laws of your own country.

We may host Candidates’ personal data in connection with our use of the Platform either in the European Economic Area, in the US, in the country where we are located, or in countries deemed as providing an adequate level of data protection. 

Candidates’ data will be accessible in the country where we or our service providers are located, the UK, the US, and countries deemed as providing an adequate level of data protection. 

See here the Platform’s vendors. For more information, please contact us.

You agree to the transfer of your information to such other countries for the purpose of processing as described in this Privacy Policy, including through cloud services.


Your rights may vary, depending on the applicable law. These rights may not be available in certain jurisdictions and/or may be subject to certain derogations or limitations. You may have the following rights:

  • To ask us to receive a copy of your personal data that is stored on our servers, including the Platform;
  • to update, correct and/or delete your personal data;
  • to request the restriction of processing concerning your personal data or to object the processing of your personal data;
  • to request to obtain a copy of your personal data in a structured, commonly used and machine-readable format;
  • If we rely on consent, please note that you have the right to withdraw consent at any time; and/or
  • to lodge a complaint with a supervisory authority.

If you wish to exercise any of these rights, please contact us. If you choose to exercise any of your rights, we will handle these requests in accordance with applicable law but please note that exercise of some of those rights may have some consequences in your application as a candidate.

In the context of the Platform, we do not use any automated decision-making related to your personal data.


In order to provide our Services to our Partners, we may collect or obtain certain types of personal information and/or data from them. This section will describe how these types of data are collected and used by us, as well as the geographical differences that affect this Privacy Policy.

Collection of data

During a Partner’s use of our Services, it may provide us with its and/or its customers’ information such as name, email, address, telephone, financial information (if required or applicable) and other relevant data. This information is used by us to identify the Partner and provide it with Services, support, mailings, sales and marketing actions, billing (if required or applicable) and to meet our contractual obligations with the relevant Partner.

Collection and Processing of Personal Data

We rely on the Partner’s consent to process personal information and/or on Partner’s representations and statements that such Partner has obtained the required consent from its customers and/or users. On other occasions, We may process personal information when we need to do this to fulfill a contractual obligation with you as a Partner or where it is required to do so by law.

We may also process personal information when it is in our or our Partners' legitimate interests to do so and when these interests are not overridden by the individual’s data protection rights (which may vary based on an individual’s jurisdiction).


We may process personal information both as a Processor and/or as a Controller, as defined in the GDPR, if applicable:

  • For User’s data, provided by the User to us, we will be the Controller in accordance with the GDPR.
  • For Partner’s data and/or Partner’s customers’ data, provided by the Partner to us, we will be the Processor in accordance with the GDPR.
  • All data collected by us will be stored exclusively in secure hosting facilities. All hosting is performed in accordance with the highest security regulations. We contract with such hosting providers to ensure that all hosting is performed in accordance with the highest security regulations.


  • Retention. We will retain your personal data for as long as we need it to assess you as a candidate or as long as we have a valid legal basis. In accordance with our internal data retention policies and practices, we can decide whether to keep your personal data, delete it or pseudonymize/anonymize it.
  • Security. We implement industry-standard measures to reduce the risks of damage, loss, unauthorized access, or use, of your personal data. However, these measures do not provide absolute information security.
  • Technical and Organizational Safeguards. We have adopted reasonable physical, technical and organizational safeguards against accidental, unauthorized or unlawful destruction, loss, alteration, disclosure, access, use or processing of the Partner’s data and/or Partner’s customers’ data and/or the Personal Data in its possession. We will promptly notify Partner in the event of any known unauthorized access to, or use of, the Partner’s data and/or Partner’s customers’ data and/or the Personal Data. Please note however that when transmitting information over the internet, this can never be guaranteed to be 100% secure.


We do not intentionally or knowingly collect personal information regarding children who are under 13 years of age.


We do not respond to browsers’ “Do Not Track” requests.

You may have a right to submit a complaint to the relevant supervisory data protection authority, pursuant to the law.

Changes to this Privacy Policy.

We may change this Privacy Policy from time to time by posting the modified policy on the website.

Contact Us.

You may contact us with any questions or comments, at:; If, as per the GDPR (if applicable), your question relates to our data protection officer (DPO) or representative in the EU, we will forward the request accordingly.