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Cnoga Privacy Policy

Last Revised: [1.10.17]

Cnoga Medical Ltd. and its affiliates (“Cnoga“, “Company“, “we” or “us“) respect the privacy of the users (“User(s)” or “you”) of its mobile application for the retrieval and transmission of information collected by our Devices (the “App“) which is compatible with our TensorTip®CoG Combo Glucometers, TensorTip® MTX Matrix, TensorTip® VSM Vital Sign Monitor devices, as well as any other devices offered by us from time to time (collectively referred to herein as the “Device“), and portal (the “Portal“) (collectively, the “Services”, as further detailed in the Terms of Use). We are committed to protect the information you submit through our Services. We believe that you have a right to know our practices regarding the information we may collect and use when you use our App, Portal and/or Services.

  1. Capitalized terms which are not defined herein, shall have the meaning ascribed to them in Cnoga’s Terms of Use available at [https://cnogacare.co/cnoga-medical-terms-of-use/] (“TOU“) to which this Privacy Policy is incorporated.

1.        Your Consent (important, please read carefully!)

BY (A) INSTALLING AND/OR DOWNLOADING THE APP ON YOUR MOBILE DEVICE, (B) ENTERING INTO, CONNECTING TO, ACTIVATING, USING AND/OR ACCESSING THE APP, THE PORTAL, THE DEVICES AND/OR THE SERVICES, AND/OR (C) CLICKING THE “I AGREE” BUTTON WHEN SETTING YOUR PASSWORD FOR THE APP AND/OR PORTAL, YOU AGREE TO THE TERMS AND CONDITIONS SET FORTH IN THIS PRIVACY POLICY, INCLUDING TO THE POSSIBLE COLLECTION AND PROCESSING, MONITORING, STORING AND SHARING OF THE INFORMATION SPECIFIED HEREIN. IF YOU DO NOT AGREE TO THE TERMS OF THIS PRIVACY POLICY, PLEASE DO NOT USE THE SERVICES, THE DEVICES AND DO NOT INSTALL THE APP, DO NOT CONNECT TO, ACCESS OR USE THE APP OR PORTAL, AND PROMPTLY ERASE THE APP FROM YOUR MOBILE DEVICE.

2.        Which information we may collect on our Users?

We may collect two types of data and information from our Users:

  1. The first type of information is un-identified and anonymous information (“Non-personal Information“). We are not aware of the identity of the User from whom we have collected the Non-personal Information. Non-Personal Information is any unconcealed information which does not enable identification of an individual User, and which is available to us when such User installs the App and when he/she uses the App or Portal. Non-personal Information which is being gathered consists of technical information, behavioral information and aggregated information, and may contain, among other things, browser type, the type of the User’s mobile device and its operating system and version, device language, device storage, screen resolution and other modes (e.g. vibration mode, Bluetooth), User’s ‘click-stream’ in the App or Portal, time spent on various screens of the App and/or Portal, date and time stamps, Internet connectivity, etc.
  2. The second type of information is personally identifiable information, namely information that identifies, or may with reasonable effort identify an individual, or may be of a private and/or sensitive nature (“Personal Information“):

·       Users of the App automatically provide (a) their mobile device ID, or in connection with the use of computers, the IP address (or Mac Address, as applicable) mainly for enhancing the User’s experience and for geo-location and security purposes as further detailed below and (b) pages viewed by each individual User.

·       Users who are interested in opening an Account are required to provide the following details: full name, e-mail address and a password, gender, date of birth, weight, height. Users may also choose to provide the following information in connection with setting up their account: photo, middle name, place of birth, home phone number, mobile phone number, full address (including country, city, and zip code) and a local identification number. This information is stored on our servers.

·       This information will also be collected by us and stored on our servers.

·       The App makes specific access requests to use the camera on your device.

·       When you purchase our Devices, you will be asked to provide credit card and/or billing information. We will use the credit card and/or billing information provided in connection with a User’s purchase to process your order and for no other purpose.

·

For avoidance of doubt, any Non-Personal Information connected or linked to any Personal Information shall be deemed as Personal Information as long as such connection or linkage exists.

We do not collect any Personal Information from you or related to you without your approval, which is obtained, inter alia, through your acceptance of the TOU and this Privacy Policy.

3.        How Do We Collect Information on Our Users and/or their Patients?

There are a few methods that we use:

  1. We collect information through your installation and use of the App and/or Portal. In other words, when you are using the App and/or Portal we are aware of it and may gather, collect and store the information relating to such usage, either independently or through the help of our authorized third-party service providers as detailed below. Non-personal Information is collected from your mobile device automatically (i) through your use of the App, once your mobile device is on and as long as the App is running on your mobile device, and (ii) during your use of the Portal.
  2. We collect information which you may, at your discretion, provide us voluntarily. We collect Personal Information when you, at your discretion, decide to provide us (e.g. your name, email and phone number). We may gather, collect and store the Personal Information either independently or through the help of our authorized third-party service providers as detailed below.
  3. We collect medical information that you transmit from the Device(s) to our servers. We make no use of your medical Personal Information other than storing it in connection with the provision of the Services and the purposes set forth below. We may, however, anonymize Personal Information we collect and use it for the purposes stated below with respect to Non-Personal-Information and share such anonymized information with third parties in an aggregated manner which will not enable such third parties to deduct any Personal Information about a particular User.

4.        What are the Purposes of the Collection of Information?

We collect Non-personal Information and Personal Information in order to provide the Services.

We collect Non-personal Information in order to:

  • Use it for statistical and research purposes and for customization and improvement of our Services.
  • Improve our metrics and the quality of the Services and gather statistics for commercial purposes and in order to enhance the User’s experience.
  • Engage with third parties for commercial or research purposes.

We collect Personal Information in order to:

  • Allow you to export it to your Account for your own purposes.
  • Verify the User’s identity when he/she signs into the Services.
  • Be able to reply to the User’s support requests or other question concerning the Services.
  • Allow you to communicate with your health care provider or other third parties you authorize to receive your Personal Information (if you choose to do so).
  • Determine geo-location information from which the User’s mobile device or computer is connected to the Internet in order to render the Services, for statistical purposes as well as in order to safeguard our Services.

5.        Sharing Information with Third Parties

We may share Personal Information only in the following cases: (a) to satisfy any applicable law, regulation, legal process, subpoena or governmental request; (b) to enforce this Privacy Policy, the TOU, including investigation of potential violations thereof or dishonest or fraudulent activities; (c) to detect, prevent, or otherwise address fraud, security or technical issues; (d) to respond to User’s support requests; (e) to respond to claims of violations of any right of a third-party through the App, Portal and Services; (f) to protect the rights, property or personal safety of Cnoga, its users or the general public; (g) when Cnoga  is undergoing any change in control, including by means of merger, acquisition or purchase of all or substantially all of the assets of Cnoga (in which event your Personal Information may be transferred to a third party located in a country that does not have the same data protection laws as your jurisdiction); (h) to collect, hold and/or manage the Personal and Non-personal Information collected within the App and/or Portal through our authorized third party service providers, as reasonable for business purposes, which may be located in a country that does not have the same data protection laws as your jurisdiction; (i) to cooperate with third parties for the purpose of enhancing the User’s App or Portal experience; and/or (j) pursuant to your explicit approval prior to the disclosure.

For avoidance of doubt, Cnoga may transfer and disclose Non-personal Information, including anonymized aggregated information as described above, to third parties at its sole discretion and without restriction. 

6.               Security

We take reasonable measures to maintain the security and integrity of our App and Portal as well as our User’s information, and prevent unauthorized access to it or use thereof through generally accepted industry standard technologies and internal procedures.

The information which is gathered from the App and/or Portal is sent to our servers over a secure channel using HTTPS protocols We also encrypt certain information in our database in order to effectively anonymize any User information. We also limit access of third parties to the Services by requiring the use of a password and by determining different access levels to Users

If we learn of a security breach, we may attempt to notify you electronically so that you can take appropriate protective steps. We may post a notice on the App and/or Portal if a security breach occurs.

Please note, however, that there are inherent risks in transmission of information over the Internet or other methods of electronic storage and we cannot guarantee that unauthorized access or use will never occur. WE WILL NOT BE RESPONSIBLE OR LIABLE FOR UNAUTHORIZED ACCESS, HACKING, OR OTHER SECURITY INTRUSIONS OR THE THEFT, DELETION, CORRUPTION, DESTRUCTION, DAMAGE, OR LOSS OF ANY DATA OR INFORMATION.

7.               Your Compliance with Privacy and Health-Related-Information Laws

BY UPLOADING OR SUBMITTING INFORMATION, INCLUDING, WITHOUT LIMITING THE GENERALITY OF THE FOREGOING, MEDICAL PERSONAL INFORMATION, YOU REPRESENT AND WARRANT THAT YOU CAN UPLOAD OR SUBMIT SUCH INFORMATION IN FULL COMPLIANCE WITH ANY APPLICABLE PRIVACY LAWS AND REGULATIONS. WE WILL NOT ASSUME ANY LIABILITY IN THIS RESPECT.

8.               Deletion or Modification of Personal Information

If for any reason you wish to update or modify the Personal Information you may do so by log-in to the Services, and use the user information menu. If you wish to remove your Account, you may do so by sending us an e-mail request to support@cnoga.com and we will make reasonable efforts to do so pursuant to any applicable privacy laws.

We may retain and use your Personal Information for a reasonable time after termination as necessary to comply with our legal or business requirements or obligations (including as required by applicable law), to resolve disputes and/or to enforce our TOU, all as permitted under any applicable privacy laws. Aggregated and/or anonymous data derived from your Account may remain on our servers indefinitely. Cnoga cannot ensure that third parties to which you chose to transfer Personal Information deleted it and cannot monitor their use of such information.

Please note: Cancelling your Account may cause inability to access your Account and/or the loss of certain information (including, without limitation, the Reading results and/or any other Personal Information). You will have a thirty (30) day period from the cancellation date to copy or extract any information which was uploaded by you to our Services. We do not and will not accept any liability for information loss which occurs after this thirty (30) day period.

9.        Third Party Software/Service

In order to provide you with the Services via the App and/or Portal, we may use third party service providers who may collect, store and/or process the information detailed herein, such as Google Analytics and Microsoft [*], which respective privacy policies can be found at www.google.com/policies/privacy/partners/ and http://www.google.com/intl/en/analytics/privacyoverview.html; and: https://azure.microsoft.com/en-us/support/trust- center/privacy/ and https://www.microsoft.com/privacystatement/en-us/OnlineServices/Default.aspx

We use commercially reasonable efforts to engage with third parties that post a privacy policy governing their collection, retention, processing and use of non-personal and Personal Information. We do not control such third party service providers. Please read their terms of use and privacy policies to better understand their privacy practices.

10.      International Data Transfer

We may transfer information collected about you, including Personal Information, to affiliated entities, or to other third party service provides (as provided herein) across borders and from your country or jurisdiction to other countries or jurisdictions around the world. Please note that we may transfer such information to a country and jurisdiction that does not have the same data protection laws as your jurisdiction, and you consent to such transfer of information. If you do not consent to the terms of this policy, please do not use the Services and /or the Devices. Please note that under the laws of jurisdictions in which your Personal  Information may be held or processed , that Personal Information may be accessed by the relevant authorities or the relevant courts.

 

Cookies & Local Storage

When you access or use the App and/or Portal, we and/or our third party service providers may use industry-wide technologies such as “cookies” and local storage (or other similar technologies), which store certain local information on your mobile device and/or computer (e.g. geo-location information and Internet connectivity) (“Local Storage“) which may enable, inter alia, automatic activation of certain features and make the User’s App or Portal experience and usage simpler, more relevant, convenient and effortless. Such information is locally stored in the User’s mobile device or computer. Cnoga and/or our authorized third party service providers may access such information. Cnoga and/or our authorized third party service providers may use both session cookies (which expire once you exit the App or Portal) and persistent cookies (which stay on the User’s mobile device and/or computer until he/she deletes them) for the purpose of confirming the user’s validity and for analytic purposes. Such Local Storage used by the App and/or Portal may store non-personal information (such as the different pages viewed by a User within the App or Portal or Internet connectivity) as well as geo-location data, which will be collected in accordance with the terms specified herein. It is easy to prohibit and/or delete the Local Storage, inter alia, via uninstalling the App from your mobile device and/or through the Settings option of your device or browser. Most platforms and browsers will allow you to erase cookies from a device, block acceptance of cookies, or receive a warning before a cookie is stored. In order to erase or disable the Local Storage option you may use the settings option of your browser or device or according to the specific instructions provided by the third party service provider’s privacy policy and terms of use. However, if you block or erase cookies, or change the settings of your device or browser, your App and/or Portal experience may be affected and may be limited.

11.      Changes to the Privacy Policy

The terms of this Privacy Policy will govern the use of the App, the Portal, the Devices and the Services and any information collected therein. Cnoga may change the terms of this Privacy Policy at any time and at its sole discretion, so please re-visit this page frequently. In case of any material changes, we will make reasonable efforts to post a clear notice on the App and/or Portal (if applicable) and/or send you an e-mail (to the extent that you provided us with such e-mail address) regarding such change. Such material changes will take effect seven (7) days after such notice was provided on our App and/or Portal or sent via e-mail, whichever is earlier. Otherwise, all other changes to this Privacy Policy are effective as of the stated “Last Revised” date, and your continued use of the App, the Portal and/or the Services on or after the Last Revised date will constitute your acceptance of, and agreement to be bound by, those changes. In the event that the TOU or this Privacy Policy should be amended to comply with any legal requirements, the amendments may take effect immediately, or as required by the law and without any prior notice.

 

12.      Any Questions?

If you have any questions (or comments) concerning this Privacy Policy, you are most welcome to send us an e-mail to the following address, and we will make an effort to reply within a reasonable timeframe: SingularSupport@cnoga.com

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