CorNeat Vision Ltd. (“Company,” “We,” “Our” or “Us”) is committed to protect your privacy and the Personal Data (as defined below) you provide us.
Because We care about you and your privacy, We want you to understand how We collect, use and disclose your information and what We do to protect your personal information.
You are aware that your Personal Data may be stored on Company’s database and that providing the Personal Data is subject to your wish and your consent. However, if you do not provide Us with the Personal Data that We request, or prohibit Us from collecting such Personal Data, We may not be able to provide you with the services.
Collection of Personal Data
1. The information We collect may include individually identifiable information that identifies you as an individual or relates to an identifiable individual or may – with reasonable effort – identify an individual (“Personal Data”). Such Personal Data may include, without limitation, your name, gender and organization or corporation in which you are employed or associated, if relevant; contact information such as email address, phone number, country of residence, and address; online identifiers (i.e. online data collected from the user’s devices and protocols such as the Internet Protocol address related to the electronic device from which the request is sent); professional interests; health-related information such as medical indications and your interest in our clinical trials; and a record of the correspondence between us.
2. By analyzing the information We receive, including all information concerning users, We may compile statistical information ("Statistical Information"). Statistical Information is anonymous and aggregated and We will not link Statistical Information to any Personal Data.
How We Use the Personal Data
6. We use and process the Personal Data and other information We collect for the following purposes, among others:
6.1. Data Analysis – to better understand your needs and interests, so that We can personalize Our interactions with you and provide you with information, content and/or offers that We believe will be relevant to you.
6.2. Development & Improvements – to enhance, improve or modify the Website, Our products and services and to facilitate the development of new products and services.
6.3. Services and Pre-Sale Information – to provide you information, services and products.
6.4. Marketing – to send you marketing communications, updates and newsletters and present personalized content. Please note that We may contact you by email, post, telephone, SMS and through other communication channels such as social media platforms.
6.6. Audits & Security – to meet legal, security, processing, and regulatory requirements.
7. In addition, where allowed by applicable law, We may use and disclose information that is not in personally identifiable form for any purpose.
Bases to Use Your Personal Data
8. We rely on a number of legal bases to use your Personal Data in these ways. These legal bases include where:
8.1. Necessary to perform the contractual obligations in Our Terms and Conditions;
8.2. Necessary in order to provide services to you;
8.3. You have consented to the processing;
8.4. Necessary to comply with a legal obligation, a court order, or to exercise or defend legal claims;
8.5. Necessary for the purposes of Our or a third party's legitimate interests, such as those of other visitors or Our vendors;
8.6. Necessary to protect your interests, or those of others.
9. We share your information, including Personal Data, with third parties including, but not limited to, the following:
9.1. Service providers and suppliers who assist Us in providing services. Examples of such service providers and suppliers are: Our manufacturers, Our distributors, IT service providers, legal advisers, accountants, suppliers of payment services, data analysis, social media services, etc.
9.2. Our marketing and advertising partners, in order to provide you with more relevant advertising on Our Website and to encourage you to return to Our Website.
9.3. We may disclose and transfer your Personal Data to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of the Company’s business and assets.
11. If you reside in the European Union, you have certain rights under European Data Protection Law with regard to your Personal Data. You have the right to:
11.1. Request access to your Personal Data (commonly known as a “data subject access request”). This enables you to receive a copy of the Personal Data We hold about you and to check that We are processing it lawfully.
11.2. Request correction of the Personal Data that We hold about you. This enables you to have any incomplete or inaccurate data We hold about you corrected, though We may need to verify the accuracy of the new data you provide to Us.
11.3. Request erasure of your Personal Data. This enables you to ask Us to delete or remove Personal Data where there is no good reason for Us continuing to keep and/or process it. You also have the right to ask Us to delete or remove your Personal Data where you have successfully exercised your right to object to processing (see below), where We may have processed your information unlawfully or where We are required to erase your Personal Data to comply with local law. Note, however, that We may not always be able to comply with your request of erasure for specific legal reasons which, if applicable, will be notified to you at the time of your request.
11.4. Object to the processing of your Personal Data where We are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you wish to object to processing on this ground, as you believe that it impacts on your fundamental rights. You also have the right to object where We are processing your Personal Data for direct marketing purposes. In some cases, We may demonstrate that We have compelling legitimate grounds to process your information which override your rights.
11.5. Request restriction of the processing of your Personal Data. This enables you to ask Us to suspend the processing of your Personal Data in the following scenarios: (a) if you want Us to establish the Personal Data’s accuracy; (b) where Our use of the Personal Data is unlawful but you do not want Us to erase it; (c) where you need Us to hold the Personal Data even if We no longer require it, as you need it to establish, exercise or defend legal claims; or (d) you have objected to Our use of your Personal Data but We need to verify whether We have overriding legitimate grounds to use it.
11.6. Request the transfer of your Personal Data to you or to a third party. We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for Us to use or where We used the information to perform a contract with you.
11.7. Withdraw consent at any time where We are relying on consent to process your Personal Data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, We may not be able to provide certain products or services to you.
11.8. To lodge a complaint to a supervisory authority.
Please note that We have appointed Prighter as Our privacy representative and your point of contact. Prighter gives you an easy way to exercise your privacy-related rights (e.g. requests to access or erase personal data). If you want to contact Us via our representative Prighter or make use of your data subject rights, please visit: https://prighter.com/q/15760271166.
12. If you reside anywhere outside the European Union (including Israel) your rights to review, edit or amend Personal Data held on Our Databases will be in accordance with applicable Israeli law, including the provisions of the Protection of Privacy Law, 5741-1981. If you want to review, correct, update, submit a complaint, opt-out from Our mailing lists or if you just have questions, please contact Us in accordance with the “Contact Us” section below.
13. You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, We may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, We may refuse to comply with your request in these circumstances.
14. We may need to request specific information from you to help Us confirm your identity and to ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request.
15. The security and confidentiality of your information is important to Us. We implement reasonable administrative, organizational and technical safeguards and security measures to protect Personal Data from unauthorized access, disclosure, destruction or alteration, accidental loss, misuse or damage. We regularly review and monitor such safeguards and security measures.
16. Please keep in mind that no method of transmission over the Internet, or method of electronic storage, is 100% secure. As a result, although We strive to protect your Personal Data, We cannot promise or guarantee that such information will be immune from any wrongdoing, malfunction, unlawful interception or access, or other kinds of abuse and misuse.
17. If you have reason to believe that your interaction with Us is no longer secure, please immediately notify Us in accordance with the “Contact Us” section, below.
18. To the extent permitted by applicable law, We will retain your Personal Data for such period as is necessary to satisfy or to fulfill the following:
18.1. The purposes for which that Personal Data was provided;
18.2. An identifiable and ongoing business need, including record keeping;
18.3. A requirement to retain records that may be relevant to any notified regulatory investigations or active legal proceedings;
18.4. To comply with any applicable law, regulation or legal process, including, without limitation, court orders and/or compulsory disclosures required by governmental authorities.
19. We may store your Personal Data for longer periods of time, for instance where We are required to do so in accordance with legal and/or regulatory requirements and in order that We will have an accurate record of your dealings with Us in the event of any complaints or challenges, or if We believe that We need to store your Personal Data in order to fulfill the legitimate interests of the Company and third parties, such as, to provide a defense in the case of legal procedures, etc.
20. Unless specifically requested, We ask you not to disclose any sensitive personal data (e.g., health information, national identification number, data related to racial or ethnic origin, political opinions, religion, ideological or other beliefs, biometrics or genetic characteristics, criminal background, trade union membership, or administrative or criminal proceedings and sanctions).
Use By Minors
21. The Website is not directed at children under 18. We do not knowingly collect information from anyone under 18 years of age. In the event that you become aware of Our collection of Personal Data of an individual under the age of 18 who has used our Website without parental permission, please update Us immediately.
25. Alternatively, letters may be sent to the following address: CorNeat Vision Ltd., 4 HaSheizaf St., Ra’anana, Israel, 4366411.
Last updated on: July 22, 2020