PRIVACY POLICY

4.        PERIOD OF STORAGE OF COLLECTED INFORMATION

4.1     Personal Data. Your Personal Data (as described above) will be stored until we no longer need the information and proactively delete it or you send a valid deletion request. Please note that we will retain it for a longer or shorter period in accordance with data retention laws. We have an internal data retention policy to ensure that we do not retain your Personal Data perpetually.

4.2   Cookies. This depends on the cookie in question. Some cookies (e.g. essential cookies) cannot be disabled. You may also control and delete these cookies through your browser settings.

5.        HOW WE PROTECT AND STORE YOUR INFORMATION

5.1   Security. We have implemented appropriate technical, organizational and security measures designed to reduce the risk of accidental destruction or loss, or the unauthorized disclosure or access to such information appropriate to the nature of the information concerned. However, please note that we cannot guarantee that the information will not be exposed as a result of unauthorized penetration to our servers. As the security of information depends in part on the security of the computer, device or network you use to communicate with us and the security you use to protect your user IDs and passwords, please make sure to take appropriate measures to protect this information.

5.2   Retention of your Personal Data. In addition to the retention periods mentioned in Section 1 above, in some circumstances we may store your Personal Data for longer periods of time, for example (i) where we are required to do so in accordance with legal, regulatory, tax or accounting requirements, or (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, or (iii) if we reasonably believe there is a prospect of litigation relating to your Personal Data or dealings.

6.        HOW WE SHARE YOUR PERSONAL DATA

6.1    We do not sell, rent or lease personal data to third parties. We may share your personal information among the corporate affiliates within our group of companies for the purposes described herein.  We will take steps to ensure that the personal information is accessed only by employees of such companies that have a need to do so for the purposes described in this Statement.

6.2    In addition, We may share data with trusted suppliers and service provides outside our corporate group for some or all of the purposes described herein, including without limitation to help us advertise and market our products and services, perform statistical analysis, surveys, campaigns, send email or postal mail, provide customer support, host databases, provide contact platforms, provide project management tools, process payments, supply goods or services that you can purchase through the use of our services, or arrange for deliveries and provide financial and legal advice and services.

6.3    In addition, We may refer questions posted in our Website to third parties such as local distributors or such suppliers or service providers, for response. We will endeavor that such third parties be contractually prohibited from using your personal information except to provide these services to We and required to maintain the confidentiality of your information. We note that such third parties may independently collect personal data as part of and/or in order to perform their services.

6.4    We may also share data with business partners and independent distributors of our products in the relevant territories, to be controlled and used by them in connection with their own business as far as it pertains to our services, including for marketing purposes (electronically or otherwise), it being clarified that, once lawfully transferred to them, they will be responsible for the lawful processing of such data, and the processing of such data by them shall be subject to their own privacy notices and policies. 

6.5    In addition to the above, we may share your information as follows:
     6.5.1     To the extent necessary, with regulators, to comply with all applicable laws, regulations and rules, and requests of law enforcement, regulatory and other governmental agencies or if required to do so by court order.
     6.5.2     If, in the future, we sell or transfer some or all of our business or assets to a third party, we will (to the minimum extent required) disclose information to a potential or actual third party purchaser of our business or assets (including its financial and legal advisors). 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 or assign Personal Data in connection with the foregoing events.
     6.5.3     Where you have provided your consent to us sharing the Personal Data (e.g., where you provide us with marketing consents or opt-in to optional additional services or functionality)

6.6      Where we receive requests for information from law enforcement or regulators, we carefully validate these requests before any Personal Data is disclosed.

If you want to receive the list of recipients of your Personal Data, please make your request by contacting us at info@EitanMedical.com.

7.       ADDITIONAL INFORMATION REGARDING TRANSFERS OF PERSONAL DATA

7.1     Storage: Azure – EU.

7.2    Access from Israel: Access from Israel is covered by the European Commission’s Adequacy Decision regarding Israel.

7.3    External transfers: Where we transfer your Personal Data outside of EU/EEA, for example to third parties who help provide our products and services, we will obtain contractual commitments from them to protect your Personal Data. Some of these assurances are well recognized certification schemes like the EU – US Privacy Shield for the protection of Personal Data transferred from within the EU to the United States.

7.4    Where we receive requests for information from law enforcement or regulators, we carefully validate these requests before any Personal Data is disclosed.

8.        YOUR RIGHTS

The following rights (which may be subject to certain exemptions or derogations) shall apply to certain individuals (some of which only apply to individuals protected by the GDPR):

8.1    You have the right to request that we rectify any Personal Data we hold that it is inaccurate or misleading

8.2    You have a right to access information held about you. Your right of access may normally be exercised free of charge, however we reserve the right to charge an appropriate administrative fee where permitted by applicable law

8.3    You have the right to request the erasure of the Personal Data that relates to you. Please note that there may be circumstances in which we are required to retain your data, for example for the establishment, exercise or defense of legal claims

8.4    You have the right to object, to or to request restriction, of the processing. However, there may be circumstances in which we are legally entitled to refuse your request

8.5    You have the right to data portability. This means that you may have the right to receive your Personal Data in a structured, commonly used and machine-readable format, and that you have the right to transmit that data to another controller

8.6    You have the right to object to profiling

8.7     You have a right to lodge a complaint with your local data protection supervisory authority (i.e., your place of habitual residence, place or work or place of alleged infringement) at any time. We ask that you please attempt to resolve any issues with us before you contact your local supervisory authority

8.8    You have the right to withdraw your consent. Please note that there may be circumstances in which we are entitled to continue processing your data, in particular if the processing is required to meet our legal and regulatory obligations.

8.9    You also have a right to request details of the basis on which your Personal Data is transferred outside the European Economic Area, but you acknowledge that data transfer agreements may need to be partially redacted for reasons of commercial confidentiality.

8.10    You can exercise your rights by contacting us at info@EitanMedical.com. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly or inform you if we require further information in order to fulfil your request.         

8.11    When processing your request, we may ask you for additional information to confirm your identity and for security purposes, before disclosing the Personal Data requested to you. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive.

8.12    In the event that your request would adversely affect the rights and freedoms of others (for example, would impact the duty of confidentiality we owe to others) or if we are legally entitled to deal with your request in a different way than initial requested, we will address your request to the maximum extent possible, all in accordance with applicable law.

9.        USE BY CHILDREN

9.1    We do not offer our products or services for use by children. If you are under 18, you shall not use our services or the Website, or provide any information to the services or Website without involvement of a parent or a guardian. We do not knowingly collect information from, and/or about children.

10.        PUBLIC INFORMATION ABOUT YOUR ACTIVITY ON THE SERVICES

10.1    Some of your activity on and through the Services is public by default. This will include, but not limited to, content you have posted publicly on the Website or otherwise through the Services.

10.2    Registered users can have some of this information associated with their Accounts. Unregistered users will not have this association, but information concerning their use of the Services (such as what pages they have visited) can be tracked anonymously through the use of cookies and stored by us.

10.3    Please also remember that if you choose to provide Personal Data using certain public features of the Services, then that information is governed by the privacy settings of those particular features and can be publicly available. Individuals reading such information may use or disclose it to other individuals or entities without our control and without your knowledge, and search engines may index that information. We therefore urge you to think carefully about including any specific information you may deem private in content that you create or information that you submit through the Services.

11.        LINKS TO AND INTERACTION WITH THIRD PARTY PRODUCTS

11.1    The Website enables you to interact with or contain links to other third party websites, mobile software applications and services that are not owned or controlled by us (each a “Third Party Service”). We are not responsible for the privacy practices or the content of such Third Party Services. Please be aware that Third Party Services can collect Personal Data from you. Accordingly, we encourage you to read the terms and conditions and privacy policy of each Third Party Service that you choose to use or interact with.

12.        LOG FILES

12.1   We make use of log files. The information inside the log files includes internet protocol (IP) addresses, type of browser, Internet Service Provider (ISP), date/time stamp, referring/exit pages, clicked pages and any other information your browser may send to us. We use such information to analyze trends, administer the Website, track users’ movement around the Website, and gather demographic information.

13.    COOKIES AND OTHER TRACKING TECHNOLOGIES

13.1   Our Website utilizes “cookies”, anonymous identifiers and other tracking technologies in order to for us to provide our Website and present you with information that is customized for you. A “cookie” is a small text file that may be used, for example, to collect information about activity on the Website. Certain cookies and other technologies may serve to recall Personal Data, such as an IP address, previously indicated by a user. Most browsers allow you to control cookies, including whether or not to accept them and how to remove them. You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser.

14.    ANALYTIC TOOLS

This Website uses the following analytic tools:

14.1    Google Analytics –  The Website uses a tool called “Google Analytics” to collect information about use of the Website. Google Analytics collects information such as how often users visit this Website, what pages they visit when they do so, and what other websites they used prior to coming to this Website. We use the information we get from Google Analytics to maintain and improve the Website and our products. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Google’s ability to use and share information collected by Google Analytics about your visits to this Website is restricted by the Google Analytics Terms of Service, available at https://www.google.com/analytics/terms/us.html/, and the Google Privacy Policy, available at https://www.google.com/policies/privacy/. You may learn more about how Google collects and processes data specifically in connection with Google Analytics at https://www.google.com/policies/privacy/partners/ . You may prevent your data from being used by Google Analytics by downloading and installing the Google Analytics Opt-out Browser Add-on, available at https://tools.google.com/dlpage/gaoptout/.

14.2   Hotjar web analytics– This Website uses Hotjar web analytics service. Hotjar may record mouse clicks, mouse movements and scrolling activity where we use this information to improve user experience. Hotjar collects information regarding pages visited, actions which are taken, country, device used, operating system, and browser used. Hotjar does not collect personal information that you do not voluntarily enter in this Website. Hotjar does not track your browsing habits across web sites which do not use Hotjar services. For more information about cookies used by Hotjar you may visit:https://www.hotjar.com/legal/policies/cookie-information.If you do not want to be tracked by Hotjar on websites, you can turn it off with a “do not track” header or visit   https://www.hotjar.com/legal/compliance/opt-out.

14.3     Hubspot– This Website uses Hubspot cookies for certain functional purposes as well as for tracking visitors’ identity, sessions and activity on the Website and authentication. For information on Hubspot cookies you may visit:   https://knowledge.hubspot.com/articles/kcs_article/reports/what-cookies-does-hubspot-set-in-a-visitor-s-browser . We use some but not all of the cookies listed in the above link. Note that we do not use the Hubspot feature that gives users the choice to  opt out of cookies. We also note that we manually place the social media websites’ pixel codes on our pages (see below), and not through the use of Hubspot’s ads tool, and therefore Hubspot will not be able to control the placement of social media sites’ cookies on your browsers. Hubspot is using Cloudflare to detect malicious visitors to our website and minimizes blocking legitimate users. Cloudfare cookies may be placed on our visitors’ devices to identify individual users behind a shared IP address and apply security settings on a per-user basis. They are necessary for supporting Cloudflare’s security features. See https://www.cloudflare.com/privacypolicy/

We reserve the right to use other analytic tools.

15.    CALIFORNIA PRIVACY RIGHTS

Subject to certain exceptions, California residents have the right to make the following requests, at no charge:

15.1       Request to Delete: California residents have the right to request deletion of their personal information that we have collected about them and to have such personal information deleted, except where an exemption applies.  

15.2       Request to Know: California residents have the right to request and, subject to certain exemptions, receive a copy of the specific pieces of personal information that we have collected about them in the prior 12 months and to have this delivered, free of charge, either (a) by mail or (b) electronically in a portable and, to the extent technically feasible, readily useable format that allows the individual to transmit this information to another entity without hindrance.  California residents also have the right to request that we provide them certain information about how we have handled their personal information in the prior 12 months, including the: 
·         categories of personal information collected;

·         categories of sources of personal information;

·         business and/or commercial purposes for collecting and selling their personal information;

·         categories of third parties/with whom we have disclosed or shared their personal information;

·         categories of personal information that we have disclosed or shared with a third party for a business purpose;

·         categories of personal information collected; and

·         categories of third parties to whom the residents’ personal information has been sold and the specific categories of personal information sold to each category of third party.

California residents may make Requests to Know up to twice every 12 months. 

15.3       Submitting Requests. California residents’ rights requests may be submitted by sending your questions or comments to info@EitanMedical.com.   Upon receipt of your request, we may ask for information to verify your identity or that you are a current resident of CA.  We will respond to verifiable requests received from California consumers as required by law.

15.4       Right to Non-Discrimination. The CCPA prohibits discrimination against California residents for exercising their rights under the CCPA. Discrimination may exist where a business denies or provides a different level or quality of goods or services, or charges (or suggests that it will charge) different prices, rates, or penalties on residents who exercise their CCPA rights, unless doing so is reasonably related to the value provided to the business by the residents’ data.  A business may offer financial incentives for the collection, sale or deletion of California residents’ personal information, provided the incentive is not unjust, unreasonable, coercive or usurious and is made available in compliance with applicable transparency, informed consent, and opt-out requirements. 

15.5        California Privacy Rights under California’s Shine-the-Light Law. Under California’s “Shine the Light” law (Cal. Civ. Code § 1798.83), California residents who provide us certain personal information are entitled to request and obtain from us, free of charge, information about the personal information (if any) we have shared with third parties for their own direct marketing use.  Such requests may be made once per calendar year for information about any relevant third party sharing in the prior calendar year. California residents who would like to make such a request may submit a request in writing to CCPA Manager at either  DPO@eitanmedical.com. The request should attest to the fact that the requester is a California resident, and provide a current California address.

Last updated November 8, 2021