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Privacy Policy Website

At Cnoga Medical Ltd., its subsidiaries or affiliated companies (Cnoga” or “we” or “us”), we recognize that privacy is important. This privacy policy (“Privacy Policy”) applies to all access to Cnoga’s website (the “Website”), the purchasing of products and/or services via the Website, and the use of the services available through the Website (collectively, the “Services”).

‘Personally Identifiable Information’ (“PII“) is information that can be used on its own or with other information to identify, contact, or locate a single person, or to identify an individual in context. When you, the user (the “User“) uses the Services, your PII will be processed subject to the terms of this Privacy Policy. Please read our Privacy Policy carefully to get a clear understanding of how we organize, collect, use, protect or otherwise handle your PII in accordance with our Website.

You are not legally required to provide PII, however in order to enable you to access and use the Services we require that you provide PII pursuant to this Privacy Policy. By using the Services you consent to this Privacy Policy, inclusive of the terms described herein. Please read this Privacy Policy in full before submitting any PII to us.

If you have any questions about this Privacy Policy, please feel free to contact us at: legal@cnoga.com.

You can visit our website without giving any personal information.

In the case of merely informative use of our website, i.e. if you do not register or otherwise provide us with information, we collect data that your browser transmits to our server (so-called “server log files”). When you visit our website, we collect data that is technically necessary for us to ensure trouble-free operation of the site. These data do not allow us to draw conclusions about your person.

  1. Information and How We Use It

The Website may collect, process and use the data which includes PII, the legal basis of which is your consent (Art. 6 (1) (a) GDPR (as defined below), which you give when you use the Services. Types of PII that may be used include the following, without limitation:

  • We may process data about your use of our Website and Services (“User Data“). User Data may include your IP address, location, type of browser and version, operating system, referral source, visit length, page views and website navigation paths, as well as information about the frequency and timing of your use of the Services. We may use cookies as a source of User Data (see our cookie policy in Section ‎8 below). User Data may be processed in the manner set forth in this Privacy Policy for the purposes of analyzing the use of the Website and Services, operating our Website, improving and customizing the Services, ensuring the security of our Services, maintaining back-ups of our databases and communicating with you.
  • When ordering or registering on our Website you may be asked to enter your name, I.D. number, email address, mailing address, telephone number, or other details. You are the source of such data, and such data may be processed for the purposes of operating the Website, providing the Services, ensuring the security of the Website and Services, and communicating with you.
  • We may process information that you provide to use for the purpose of subscribing to our email notifications (“Notification Data“) provided that you have specifically consented to receive the same. The Notification Data may be processed for the purposes of sending you relevant data .
  • We may process information contained in or relating to any communication that you send to us (“Correspondence Data“), for example, when sign up for our newsletter or respond to a survey or marketing communication. The Correspondence Data may include communication content and/or metadata associated with such communication. The Correspondence Data may be processed for communicating with you and record-keeping.
  • We may collect and retain metadata and statistical information concerning the use of the Services which are not subject to the deletion procedures in this Privacy Policy and may be retained by us for no more than required to conduct our business. Some data may be retained also on our third-party service providers’ servers in accordance with their retention policies. You will not be identifiable from this retained metadata or statistical information.
  • We may process any of the types of data described in this Section 1 if we are required to do so by court-order, any legal obligation to which we are subject, or when necessary, for the establishment, exercise or defense of legal claims. The legal basis for this processing is our legitimate interests, namely of Cnoga’s legal rights, your legal rights and the legal rights of others.
  • Please do not supply any other person’s PII to us without the specific and explicit consent of all parties, including the owner of such PII.
  1. Providing Your PII to Others
    • We may disclose your PII to any member of our group of companies, including subsidiaries, holding companies and all of their respective subsidiaries (if any), insofar as reasonably necessary for the purposes set out in this Privacy Policy. Such member group companies, including subsidiaries, holding companies and all of their respective subsidiaries will only use the PII to the extent necessary to allow them to perform the Services they provide to Cnoga.
    • We may disclose your PII to professional advisers insofar as reasonably necessary for the purposes of obtaining and maintaining insurance coverage, managing risks, obtaining professional advice and managing legal disputes. Such professional advisers will only use the PII to the extent necessary to allow them to perform the Services they provide to Cnoga.
    • We may disclose your PII to third-party service providers, vendors and subcontractors reasonably necessary to provide the Services. Such third-party provider’s vendors and subcontractors will only use the PII to the extent necessary to allow them to perform the Services they provide to Cnoga.
    • We will only disclose your PII to third parties who provide sufficient guarantees that they implement appropriate technical and organizational measures in such a manner that their processing of your PII will meet the requirements of Data Protection Regulation (as defined below) and ensure the protection of your rights and with whom we have written contracts that conform to our legal obligations under Data Protection Regulation.
  2. International Transfers of Your PII
    • In this Section ‎3, we provide information about the circumstances in which your PII may be transferred to countries worldwide including inside and outside the European Economic Area (“EEA“).
    • To the best of our knowledge there is no obligation under the GDPR (as defined below) for data to be stored in the EEA and the rules regarding transfer of personal data outside the EEA remain largely unchanged. The GDPR permits transfers of personal data outside of the EEA subject to certain conditions.
    • We and our other group companies have facilities in Israel, China, Brazil and . “Adequacy decisions” of the European Commission have been made with respect to the data protection laws of Israel.
    • Transfers to countries inside and outside the EEA will be protected by appropriate safeguards, namely the provisions of applicable law which relate to the protection of individuals with regards to the processing of personal data to which a party may be subject including, without limitation, the General Data Protection Regulation (EU) 2016/679 (the “GDPR”), the Data Protection Act 1998, the Regulation of Investigatory Powers Act 2000, the Telecommunications (Lawful Business Practice) (Interception of Communications) Regulation 2000, the Electronic Communications Data Protection Directive 2002/58/EC, the Privacy and Electronic Communications (EC Directive) Regulations 2003 and, where applicable, the guidance and code of practice issued by the Information Commissioner’s Office from time to time, directions of any competent regulatory authority, relevant regulatory guidance and codes of practice (collectively “Data Protection Regulation”) or to the extent transfers will cross borders to outside the EEA, such transfer shall be carried out in accordance with standard contractual clauses annexed to the EU Commission Decision 2010/87/EU of 5 February 2010 for the Transfer of Personal Data to Processors established in Third Countries under the Directive .
    • The hosting facilities for our Website are situated in within the region of service.
    • You acknowledge that PII submitted by you for transmission through the Services may be transmitted around the world via the internet for the purpose of performing the Services and subject to the terms of this Privacy Policy and your agreement with us to purchase the Services.
  3. Retaining and Deleting PII
    • This Section 4 sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of PII.
    • We will retain and delete your PII as follows:
    • PII will be retained for up to a period of three (3) years or as required by applicable law, following the end of the Services after which period it will be deleted from our systems, unless otherwise required under applicable law, additional fee may apply.
    • Notwithstanding the other provisions of this Privacy Policy, we may retain your PII where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
  4. Your Rights
    • In this Section 5, we have done our best to summarize the rights that you may have under applicable data protection law. These are complex, and not all of the details have been included herein. In light of this, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
    • Your principal rights under data protection law are:

(a)      the right to access;

(b)     the right to rectification;

(c)      the right to erasure;

(d)     the right to restrict processing;

(e)      the right to object to processing;

(f)      the right to data portability;

(g)     the right to complain to a supervisory authority; and

(h)     the right to withdraw consent.

  • Right of access according to Art. 15 GDPR: you have the right to confirmation as to whether or not we process your PII and, where we do, access to the PII, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of PII concerned and the recipients of the PII. Providing the rights and freedoms of others are not affected, and as requested or approved by you, we will supply to you a copy of your PII. The first copy will be provided free of charge, but additional copies and other related analytics may be subject to a reasonable fee. You can request to access your PII by requesting an e-mail summary from: support@cnoga.com.  
  • Right to correction pursuant to Art. 16 GDPR:  you have the right to ask for any inaccurate PII about you to be rectified and, taking into account the purposes of the processing, to have any incomplete PII about you completed.
  • Right to cancellation pursuant to Art. 17 GDPR: in some circumstances you have the right to erasure of your PII , by providing adequate evidence attesting to your identity, without undue delay. Those circumstances include: the PII is no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; and the PII have been unlawfully processed. There are certain general exclusions of the right to erasure. Those general exclusions include where processing is necessary: for compliance with a legal obligation or applicable law; or for the establishment, exercise or defense of legal claims.
  • Right to restriction of the processing according to Art. 18 GDPR: in some circumstances you might have the right to restrict the processing of your PII. Those circumstances are (to the extent applicable under applicable Data Protection Regulation): you contest the accuracy of the PII; processing is unlawful but you oppose erasure; we no longer need the PII for the purposes of our processing, but you require PII for the establishment, exercise or defense of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your PII. However, we will only otherwise process it: with your consent; for the establishment, exercise or defense of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
  • Right to information in accordance with Article 19 GDPR: If you have asserted the right to rectify, delete or limit the processing to the person responsible, he/she is obliged to rectify or delete the data to all recipients to whom the personal data relating to you have been disclosed or limitation of processing, unless proving to be impossible or disproportionate. You have the right to be informed about these recipients. [to check with Yael – Goldfarb]
  • Right of objection according to Art. 21 GDPR: you might have the right to object to our processing of your PII on grounds relating to your particular situation (to the extent applicable under applicable Data Protection Regulation). If you make such an objection, we will cease to process the PII unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defense of legal claims.
  • Right to data portability according to Art. 20 GDPR: to the extent that the legal basis for our processing of your PII is consent, and such processing is carried out by automated means, you have the right to receive your PII from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
  • Right to complain under Art. 77 GDPR: If you consider that our processing of your PII infringes Data Protection Regulation, you have a legal right to file a complaint with a supervisory authority responsible for data protection.
  • Right of revocation of granted consent pursuant to Art. 7 (3) GDPR: To the extent that the legal basis for our processing of your PII is consent you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
  • You may exercise any of your rights in relation to your PII by written notice to us in addition to the other methods specified in this Section 5.
  1. Opt-in

When you provide us with PII for a secondary reason, like marketing or other secondary reasons which we will convey to you from time to time if applicable, we will ask for your consent. After you opt-in, you may withdraw your consent at any time, by contacting us at Support@cnoga.com.   

  1. Information Security
    • We follow generally accepted industry standards to protect against unauthorized access to or unauthorized use, alteration, disclosure or destruction of PII. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect PII, we cannot guarantee its absolute security.
    • The PII is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required by contract to keep the information confidential.
    • We implement a variety of security measures when a user places an order, enters, submits, or accesses their information to maintain the safety of the PII.
  2. Cookies
    • Cookies are small files that a site or its service provider transfers to your computer’s hard drive through your web browser (if you allow) that enables the site’s or service provider’s systems to recognize your browser and capture and remember certain information. They are also used to help us understand your preferences based on previous or current site activity, which enables us to provide you with improved Services. We also use cookies to help us compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future.
    • Among other purposes, we use cookies to understand and save user’s preferences for future visits.
    • You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser settings. Since each browser is a little different, look at your browser’s Help Menu to learn the correct way to modify your cookies.
    • If you turn cookies off, some of the features that make your site experience more efficient may not function properly.
    • We use the following types of cookies: session cookies, persistent cookies and third party cookies.
    • We solely control the access the cookie-related information.
    • Cookies will not be used for any purpose other than stated in this Privacy Policy.
    • Legal basis for the use of cookies and similar technologies are your consent to the cookie banner when you visit the Website for the processing of PII via cookies and similar technologies (Art. 6 (1) (a) GDPR), the processing is required for the fulfillment of the contractual relationship in the context of the provision of our Website and the services requested (Art. 6 (1) (b) GDPR) and the processing is necessary to safeguard our legitimate interests described above (Art. 6 (1) (f) GDPR).
  3. Third-party Direct Collectors
    • In general, the third-party providers used by us will only collect, use and disclose your information to the extent necessary to allow them to perform the Services they provide to us. However, certain third-party service providers, have their own privacy policies in respect to the information we are required to provide to them for your purchase-related transactions.
    • For these providers, we recommend that you read their privacy policies so you can understand the manner in which your PII will be handled by these providers. In particular, remember that certain providers may be located in or have facilities that are located a different jurisdiction than either you or us. So if you elect to proceed with a transaction and\or other action that involves the services of a third-party service provider, then your information may become subject to the laws of the jurisdiction(s) in which that service provider or its facilities are located.
    • Once you leave our Website or are redirected to a third-party app or website or application, you are no longer governed by this Privacy Policy or our Terms and Conditions.
  4. Third-party Links

Occasionally, at our discretion, we may include or offer third-party products or services on our Website (including without limitation, embedded YouTube videos). These third-party sites have separate and independent privacy policies. We therefore have no responsibility or liability for the content and activities of these linked sites and you should note that when you leave the Website you also leave the scope of this Privacy Policy. Nonetheless, we seek to protect the integrity of our site and welcome any feedback about these sites.

  1. Age of Consent

By using our Website, you represent that you are at least the age of majority in your state, province or country of residence, and you have given us your consent to allow any of your minor dependents to use this site.

  1. Law and Jurisdiction
    • The law that applies to activity on the Website and the Privacy Policy is the law of the State of Israel alone.
    • Exclusive jurisdiction to hear any dispute regarding the Website and/or the Privacy Policy and anything deriving thereunder is conferred to the competent court in the district of Tel Aviv-Jaffa, Israel.
  2. Changes to the Privacy Policy
    • We reserve the right to modify this Privacy Policy at any time, so please review it frequently. Changes and clarifications will take effect immediately upon their posting on the Website. If we make material changes to this Privacy Policy, we will notify you on the Website and/or in an email that it has been updated.
    • If we are acquired or merged with another company, your information may be transferred to the new owners so that we may continue to provide our Services to you.
  3. Contacting Us

If there are any questions regarding this Privacy Policy, you may contact us by using the information below: legal@cnoga.com.

  1. Last updated: October, 2019
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