Privacy Policy
1. Introduction
For K Dictionaries Ltd (referred to herewith as “KD”) the protection of our customers’ personal data is a matter of the greatest importance. We are committed to ensuring that you (“You” or “Your“) can rely on the protection of Your personal data by KD at all times, and know how KD both uses Your data and ensures its protection.
This privacy policy document informs You about the processing of personal data (the “Data”) by KD when You visit the Lexicala API Website (the “Website”) or make use of the services offered by the Website, i.e. when registering to access and use the Lexicala API (severally and jointly, the “Services”).
2. Responsible Party
K Dictionaries Ltd
8 Nahum Hanavi Street
6350310 Tel Aviv, Israel
Tel.: +972-3-5468012
e-mail: lexicala@kdictionaries.com
References to “KD”, “We”, “Us” and “Our” may be construed as references to K Dictionaries Ltd or divisions.
The Data is mainly processed in the State of Israel. The European Commission has decided in its adequacy decision 2011/61/EU that there is an adequate level of Data protection in the State of Israel.
3. Contact Info of our Data Protection Officer
You can contact our data protection officer by email (lexicala@kdictionaries.com) or by letter to the above address with the addition “Data Protection Officer”.
4. Processing of Personal Data
Your Data is processed and used in compliance with the applicable statutory regulations, in particular the EU’s General Data Protection Regulation (referred to below as the “GDPR”).
4.1. Making Contact
Any Data You enter on our contact form or communicate to Us by email or otherwise will be processed so that We can deal with and reply to Your enquiry.
In accordance with Art. 6 Section 1 a) GDPR, We can process the Data You have entered on our contact form, provided that You have given Your consent to this by clicking on the “Send” button. If You enter sensitive information in the “Message” field which contains specific categories of Data (e.g. Your origins, political opinions, religion, medical data), You also give Your consent to the processing of such Data. If You send Us the Data by email or in some other form, the legal basis will be Art. 6 Section 1 f) and if relevant 1 b) GDPR. We have a legitimate interest in answering your questions as quickly as possible.
There is no legal or contractual requirement for You to provide Your Data by our contact form or email. However, We would not be able to respond to Your request without receiving Your email address.
The Data concerned will be deleted at the latest 24 months after the receipt of Your enquiry, unless We are entitled or obliged to save it for a longer period on the basis of legal requirements in conjunction with Art. 6 Section 1 c) GDPR. This may lead to a maximum retention period of seven years.
4.2. Visitors to the Website
4.2.1 Creation of Log Files
When You visit the Website, the following details are saved in a log file:
- the IP address and if relevant the MAC address of Your computer or mobile device,
- the date and time of Your access,
- the names of the files You access and the Data volume which is transmitted,
- the type of operating system and Web browser used, including the language settings,
- the website from which You reach the Website (referrer URL),
- the websites which are accessed from our Website by the user’s system.
It is necessary for a large part of this Data to be saved for technical reasons, so that the Website can be displayed on Your device, as well as to ensure system security. In addition, the above Data is evaluated in anonymized form for statistical purposes and for the purpose of optimizing the Website.
The Data is processed on the basis of Art. 6 Section 1 f) GDPR. If the Google Analytics service is involved, 4.2.3 will also apply. We have a legitimate interest in ensuring that the Website is displayed to You correctly, in identifying and remedying the cause quickly in the event of a breakdown or hacker attack, and in evaluating the Data in anonymized form for statistical purposes. The provision of such Data is not mandatory in legal or contractual terms, but for technical reasons use of the Website is not possible without the processing of a large volume of this Data.
4.2.1 Cookies
We also set session cookies in relation to Your visit to the Website.
Cookies are small files which contain an identification number provided by Us. When You access the Website, cookies are saved on Your computer or mobile device. If You access the Website again later, Your computer or mobile device can be recognized on the basis of this ID number.
Session cookies help You to navigate the pages of the Website. They ensure that You do not have to re-enter Data that You have entered in fields, for example, if You have visited another website in the meantime and that as a registered customer You remain logged in, even if You have accessed different websites in succession.
We have the right to set session cookies in accordance with Art. 6 Section 1 f) GDPR. Session cookies are deleted when You close Your browser. We have an interest in optimizing the Website and adapting it to the requirements of visitors. The following cookies may be applied for the purposes described below and for the indicated retention period:
(a) Range Measurement
Cookie |
Purpose |
Saved for |
Google Analytics |
See 4.2.3 below |
26 months |
(b) User-friendliness (cookies set by KD)
Cookie |
Purpose |
Saved for |
sessionId (1 parameter) |
Stores whether user is logged in or not |
Renews every 5 minutes for the duration of the session |
localStorage (multiple parameters) |
Stores data on the user’s browser to authenticate user and enable access |
the duration of the session |
You can also visit the Website without the setting of cookies on Our part, but in this case it may not be possible for You to use all the available functions. There is no obligation for cookies to be set. Most browsers automatically accept cookies. In order to prevent this, You have to change the relevant setting in Your browser. The settings have to be applied separately for every browser and every device You use.
4.2.3 Web Analysis by Google Analytics
On the Website We use the Google Analytics service. This is an analytical service provided by Google LLC, 1600 Amphitheatre Parkway Mountain View, CA 94043, USA (“Google”). Google uses cookies (see 4.2.2 above). The information generated by the cookie about Your use of the Website is as a rule transmitted to Google in the USA, and processed there. The same applies to Your anonymized IP address. In addition, Google Analytics analyses the Data contained in the log files, the Internet address of the website which You accessed before Your visit to the Website (referrer URL), and the search term with which You found the Website via a search engine.
Google processes the Data on Our behalf in order to evaluate the use of the Website and compile reports on the activities on the Website. Google uses the Data contained in the log files, for example, in order to compile statistics on the frequency with which the Website is accessed. In this process pseudonymised user profiles of visitors can be created on the basis of the processed Data.
We only apply Google Analytics with activated IP anonymization. This means that within Israel Your IP address is truncated by Google. Only in exceptional cases will the full IP address be transmitted to Google in the USA and then truncated there.
You can prevent the storage of cookies by setting Your browser as described above. You can also prevent the processing of Data generated by the cookie by downloading and installing the plugin available at the following link: http://tools.google.com/dlpage/gaoptout?hl. With effect for the Website an opt-out cookie is set in the browser which You are currently using. If You delete the cookies in this browser, You will need to click on this link again. If You use several devices or browsers, You must click on this link for each individual device in each individual browser.
For the exceptional cases in which Google transmits Data to the USA, Google has subjected itself to the “EU-US Privacy Shield”. The European Commission has decided in its adequacy decision (EU) 2016/1250 that this will ensure an adequate level of data protection.
The Data is processed on the basis of Art. 6 Section 1 f) GDPR. We have a legitimate economic interest in using the evaluation of the above statistics to adapt the Website to the needs of visitors and to use these statistics for internal market research. The provision of this Data is not mandatory and is not necessary for the purpose of concluding a contract with Us.
For further information about Google Analytics please see the following Google website: https://support.google.com/analytics/ansWer/6004245?hl=en.
4.3. Users of the Lexicala API
We request Your personal information in order to provide the Lexicala API services and personalize Your experience with the Services, to ensure the security of the Website and the Services, and to run our business.
4.3.1 Creation of Log Files
When You register for a user account, the following Data is recorded:
- the username You have selected for Your user account during the registration process,
- the email address You have entered during the registration process,
- the first name You have entered during the registration process (if You have entered one),
- the last name You have entered during the registration process (if You have entered one).
We process Your data pursuant to Art. 6 Section 1 b) GDPR insofar as this is necessary for the fulfilment of a contract between You and Us or for pre-contractual measures taken at Your request. In this respect, We process Your data in particular
- to provide the Lexicala API services and personalize Your experience with the Services,
- for contract management and to run our business,
- for communication with You.
If You have entered data in voluntary fields, your legal basis is Your consent (Art. 6 Section 1 a) GDPR). By clicking “Register” You give Your consent to providing Us with these personal details.
We process Your data pursuant to Art. 6 Section 1 f) GDPR insofar as this is necessary to ensure the security of the Website and the Services.
We use Your Data to the extent permitted to send email advertising for Our Services. The legal basis is Art. 6 Section 1 f) GDPR. We have a legitimate interest in the sending of direct advertising.
KD will save anonymous logs of Your account’s user history for technical and development purposes, which will include Your usage history. The legal basis is Art. 6 Section 1 f) GDPR. We have a legitimate interest in the continuous development and improvement of our Services.
There is no legal or contractual requirement for You to provide Your Data. However, to sign up for Lexicala API, You need to register for a user account. During the registration process, when We ask for Your personal information (email address and preferred username), it is because it is required to authenticate Your account and provide You with the Services. If You do not provide this information, We will not be able to grant You access to the Services. All other information is voluntary.
Your personal Data in the context of Your user account will be deleted as soon as you request it or after 5 years after Your last login. We may process this Data for the above-mentioned purposes until the final processing of the respective contract and, if applicable, also within the statutory regular limitation periods of 3 years or, if applicable, warranty periods. If the storage of Data is necessary for compliance with our legal obligations in accordance with Art. 6 Section 1 c) GDPR, We have the right to save such data until the expiry of the retention periods which the applicable laws and regulations stipulate. This can lead to a retention period of up to 7 years.
5. What is the Source of the Data?
As a rule, We receive the Data from You or Your Internet browser.
6. Is Data passed on to Other Parties?
We pass on Data, at least in part, to the following external processors and other recipients for the purposes described below:
Recipient |
Purpose |
Google LLC, 1600 Amphitheater Parkway, Mountainview, CA 94043, USA |
Google Analytics |
Mailgun Technologies, Inc., 548 Market St. #43099, San Francisco, CA 94104, USA |
Automated mail services |
In order to fulfill legal obligations (Art. 6 Section 1 c) GDPR) or to defend and enforce legal claims (Art. 6 Section 1 f) GDPR), We may also be entitled to disclose the Data to authorities, courts, auditors, insurance companies or lawyers if this is necessary.
7. Rights of Data Subjects
If Your Data is processed by Us, You are a ‘Data subject’ as defined by the GDPR, and You have the following rights in relation to the responsible party. You can assert all of these rights by sending an email to lexicala@kdictionaries.com or to one of the addresses indicated in Sections 2 and 3. If You wish to withdraw Your consent or remove personally identifying information, please contact Us at the email stated above.
7.1. The Right to Information and Data Transferability
In accordance with Art. 15 GDPR You have the right to require Us to provide You with information:
- about whether We have saved Your Data and, if so, what Data and for what purpose;
- about the source of the Data;
- to what recipients or categories of recipients Your Data may have been passed on.
In accordance with Art. 20 GDPR You have the right to receive the Data You have transmitted to Us on the basis of Your consent or a contract, provided that the processing of the Data was automated. If You wish and if it is technically possible, We will also transmit this Data to a third party at Your request.
7.2. The Right to Correction
If the Data relating to You is incorrect or incomplete, You have the right to demand that Your Data should be corrected and if relevant completed by the responsible party (Art. 16 GDPR). You may update Your personal information stored in Your user account at any time.
7.3. The Right to the Deletion or Blocking of Data
You have the right to demand that We delete Your Data in accordance with Art. 17 GDP or block it in accordance with Art. 18 GDPR. If You delete Your user account with KD We will delete Your personally identifying Data, i.e. Your first and last names and email address, unless We have the right to save it for the fulfilment of contracts which have not yet been completed, for the assertion of legal claims, or in compliance with statutory obligations. Be advised that by removing some personal information, such as email address, without providing a valid alternative, You may lose Your access to the Services.
7.4. The Right of Objection
To the extent that We process data exclusively for the purpose of safeguarding Our interests on the basis of Art. 6 Section 1 f) GDPR You have the right to object to the processing of Your Data for reasons arising from Your individual situation. If You make such an objection, We will no longer process the relevant Data, unless We can prove that such processing is essential for the protection of those of our interests which take precedence over Your interests, rights and freedoms, or if the processing is for the purpose of asserting legal claims.
In addition, You can at any time object to the processing of Your Data for advertising purposes without incurring any other charges than the transmission cost at basic rates.
7.5. The Right to Withdraw Consent
If You have given Your consent to the processing/use of Your Data, You can withdraw this consent at any time. Such withdrawal will not affect the legality of the processing of Your Data prior to the withdrawal of Your consent. We will then delete Your Data, unless We have the statutory right or obligation to retain and process it.
7.6. The Right to Complain to the Regulatory Authorities
You have the right to register a complaint with the competent regulatory authorities.
Last updated on July 25, 2019.