DermaDetect

DERMADETECT PRIVACY POLICY
[Last Updated: February 2, 2023]

This Privacy Policy ("Privacy Policy") is an integral part of our Terms of Use (“Terms”) and governs the processing of information by DermaDetect Ltd. and its affiliates (“DermaDetect”, “Company”, “we”, “us”, or “our”) while you (“you” or “user”) access, use or interact with our website, available at: https://www.dermadetect.com/index.aspx (“Website”) and the Demo System provided to some of our potential customers, partners and other relevant third-parties (“Demo System") and services provided therein (collectively, the “Services”).
Any capitalized terms not defined herein shall have the meaning ascribed to them in the Terms.
DermaDetect may update or revise this Privacy Policy from time to time. Modifications to this Policy will be posted on the Website or addressed directly to where DermaDetect, upon its sole discretion, finds it required.
This Privacy Policy explains how the data is collected, used, or shared with others, how it is safeguarded, and how an individual may exercise their lawful rights related, among others, and where applicable, as required according to the EU General Data Protection Regulation (“GDPR”).
Please note that you are not required by law to provide us with Personal Data (as defined below). Providing Personal Data to us is entirely voluntary, provided however, that we will not be able to provide you with certain services or information without obtaining your Personal Data (for example, we will not be able to contact you in response to your inquiry if we will not have your contact details).
DermaDetect shall be entitled to (however not obligated), to retain and store Personal Data in its databases, as detailed under this Privacy Policy, and subject to applicable law.

CONTACT DETAILS

DermaDetect Ltd., incorporated under the laws of the state of Israel, is the Controller (as such term is defined under the GDPR or equivalent privacy legislation) of the Personal Data we collect from you in our Website and Demo System.
For any question, inquiry or concern related to this Privacy Policy or the processing of your Personal Data, you may contact as follows:
DPO Contact Information: [email protected].
By Mail: 4 Oppenheimer St., Rehovot, Israel 7670104.

WHICH DATA DO WE COLLECT AND FOR WHAT PURPOSE?

“Non-Personal Data”: means non-identifiable, aggregated data, that is mainly technical data which is transmitted to us by your device when you access and interact with our Services, such as the type of browser, type of operating system, type of device used, the time and date you access the Website, navigation, language preference, etc. Non-Personal data is used mainly for click stream analysis to provide, maintain, develop and enhance our Website and the Services provided therein (if applicable) and is not used to identify individuals.
“Personal Data”: means individually identifiable information which identifies or may identify, with reasonable effort, an individual, including online identifiers, such as your name, address, phone number, and online identifiers (such as IP address).
Please see below the table which specifies the Personal Data we collect and how we use it.

DATA SET			PURPOSE AND OPERATIONS		LAWFUL BASIS UNDER THE GDPR
VISITORS
Online Identifiers We use third-party cookies on the Website. As further detailed below, these cookies provide us with analytics and marketing services. The Personal Data processed is an online identifier, a cookie agent, the IP address, etc.			We will use such data through our or third parties’ cookies and tracking technologies for analytic, marketing and advertising purposes. In addition, we process such data for operation, security and fraud prevention purposes.		Strictly necessary cookies, such as technical and security purposes, which are required for the proper and basic operation of the Website will be processed in our legitimate interest. Other cookies data, including any targeting, advertising and marketing cookies, will be processed subject to your consent, provided through the cookie notice and Consent Management Platform ("CMP"). You may withdraw consent at any time by using the cookie preference settings as detailed in the "Cookie Usage" section below.
Contact Us If you voluntarily contact us in order to ask for information regarding our Services or any other inquiry, you may be required to provide us with certain information such as your name, email address, phone number, the company which on its behalf you are contacting us, the industry you are related to, and additional information you decide to share with us. If you are contacting us on behalf of another person, we value your assistance and care for others, please note that it is your responsibility to make sure that any person whose Personal Data you provide is aware of the principles of this statement and agrees that you will provide Personal Data to us on this basis.			We will use this data to provide you with the information you requested, respond to your inquiry, or provide our Services. We may process the content of our correspondence with you to improve customer service, and in the event we believe it is required in order to provide you with any further assistance (if applicable). The correspondence and its contents with you may be processed and stored by us in order to improve our customer service and in the event, we believe it is required to continue to store it, for example, in the event of any claims or in order to provide you with any further assistance (if applicable).		We process such data and retain any inquiry history subject to our legitimate interests.
Recruitment Data In the event you apply for a job, we will collect your CVs as uploaded by you, including your name, email address, phone number, information regarding your education and skills, employment history and your photo (to the extent provided by you). Also, where allowed or required by law, we may process diversity and inclusion data regarding your candidacy, such as ethnicity, gender data or any disability. In addition, we may collect further information from public and online sources, referees and former employers and combine such data with your other data.			We will use such data as part of our recruitment and screening efforts to decide whether you can suit a position in the Company. Also, sometimes we will process your data to enable us to comply with corporate governance and legal and regulatory requirements. After the completion of the recruitment process, we will retain the data as part of our internal record keeping, including for legal defense from any future claim. If you are hired by us, your Recruitment Data may be used in connection with your employment and our corporate management. We will keep your data, analyze it, store it in our systems, use the data or contacting you or for further recruitment steps (e.g., interview) and keep records of our interaction with you.		We process such data subject to our legitimate interest. In some cases, for example where we will ask you to provide health related data or diversity and inclusion data, we will process your data based upon your consent. You may always withdraw consent at any time by contacting us. We will retain your data for record keeping and future defense from legal claims under our legitimate interest. *** In case you will be hired and become part of our workforce, your recruitment data may be kept as part of your employee record.
Demo System
Login Data: When you contact us and request to use our Demo System, we will need to request certain information during the registration to the Demo System or log-in will include your name, email address, password and username (“Login Data”). You represent and warrant that you will not provide us with inaccurate, misleading or false information.			We will use this data in order to create you an account, provide you access to our Demo System in order to have the ability to examine our services and see how our product works. We may also use the information in order to verify your identity.		We process such data under our legitimate interest as part of our marketing and business development efforts.
	Health Data: In order to provide you with our Services, we will need to request clinical and demographic information such as birth year (approximate age), gender, picture of the infected area and some de-identified clinical data (“Health Data”).		We will use this data to analyze your photo and provide you with a demo of our services and products.		Usually, Health Data will be processed by us only after being de-identified, meaning it will not allow, by reasonable means, to identify you. Where we will process Health Data as identified, meaning it will be deemed as Personal Data, we will only do so provided your consent for such use.
Usage Data When you use our Services, information and data gets automatically generated and collected that can help us to understand how you are using our Services, and how to better provide the Services to you(“Usage Data”). Most Usage Data is not personal The information includes the click stream within the Website, page viewed, the use of the Services (i.e., accessed or used by end user) and the time spent on those pages or features, crash data and analytics, etc. To the extent Usage Data contains Personal Data, it will be treated as personal data and is covered under this Privacy Policy.		We use Usage Data to improve our Services.		We process such information subject to our legitimate interest.

Please note that the actual processing operation per each purpose of use and lawful basis detailed in the table above may differ. Such processing operation usually includes a set of operations, made by automated means, such as collection, storage, use, disclosure by transmission, erasure, or destruction. Transfer of personal data to third-party countries, as further detailed in the "Data Transfer" section, is based on the same lawful basis as stipulated in the table above.
In addition, we may use certain Personal Data to prevent potentially prohibited or illegal activities, fraud, misappropriation, infringements, identity thefts, and any other misuse of the Website and to enforce the Terms, as well as to protect the security or integrity of our databases, Website and to take precautions against legal liability. Such processing is based on our legitimate interest.

COOKIES USAGE

We use cookies to improve your experience while you interact with our Website and use the Services provided therein. We may use various types of cookies:

Essential Cookies – which are necessary for the Website to work properly;
Functional Cookies – designated to save your settings on the Website - your language preference or other view preferences;
Session Cookies – used to support the Website's functionality – such cookies are stored only temporarily during a browsing session and are deleted from your device when you close the browser;
Targeting Cookies - these cookies are used to collect information from you to help us improve our Services and provide you with targeted advertisements that we believe will be relevant to you (e.g., Google's Cookies).
Analytics Cookies - give us aggregated and statistical information to improve the Services and further developing it (e.g., Google analytics, etc.).

Please note that the data collected by the use of cookies may be linked to and combined with any other data, including Personal Data.
In addition, cookie's data is usually collected through the use of third-party services, like Google, Facebook, LinkedIn, etc. In those cases, your Personal Data might be transferred to those third parties, which might link it and use it together with other information they have on you from other sources. Such data is "owned" and processed separately by those third-parties under their terms and conditions and the direct accounts or subscriptions you have with those third parties.
The specific cookies we currently use and your choices with regard to such use are as followed:
Our Site may use cookies to enhance user experience. User’s web browser places cookies on their hard drive for record-keeping purposes and sometimes to track information about them. Users may choose to set their web browser to refuse cookies, or to alert you when cookies are being sent..

HOW WE COLLECT INFORMATION

According to the nature of your interaction with the Website, we may collect information as follows:

Automatically – we may use cookies and similar tracking technologies (as elaborated in the Cookies Section below) to gather some information automatically when you interact with our Website.
Provided by you voluntarily – we will collect information if and when you choose to provide us with information, such as when you contact us in case of an inquiry or planning a trip with us as part of the Services.
Provided by third parties – we may receive certain data, such as KYC/AML data or information regarding any money transfer from third parties involved in such transfer (such as the sending financial institution).

DATA SHARING– CATEGORIES OF RECIPIENTS WE SHARE PERSONAL DATA WITH

We share your data with third parties, including trusted partners or service providers that help us provide our Services and improve the Website:

Legal Requirement: We will share your information in this situation only if we are required to do so to comply with any applicable law, regulation, legal process, or governmental request (e.g., to comply with a court injunction, comply with tax authorities, AML/KYC processes, etc.);
Policy Enforcement: We will share your information, solely to the extent required to (i) enforce our policies and agreements; or (ii) to investigate any potential violations thereof, including without limitations, detect, prevent, or take action regarding illegal activities or other wrongdoings, suspected fraud or security issues;
Company's Rights: We will share your information to establish or exercise our rights, to prevent harm to our rights, property, or safety, and to defend ourselves against legal claims, when necessary, subject to applicable law;
Third Party Rights: We will share your information, solely to the extent required to prevent harm to the rights of our customers, yourself, or any third party's rights, property, or safety;
Service Providers: we share your information with third parties that perform services on our behalf (e.g., tracking cookies, servers, marketing, and support, etc.) these third parties may be located in different jurisdictions.
Corporate Transaction: we may share your information in the event of a corporate transaction (e.g., sale of a substantial part of our business, merger, consolidation or asset sale). In the event of the above, our affiliated companies or acquiring Company will assume the rights and obligations as described in this Privacy Policy;
Authorized Disclosures: we may disclose your information to third parties when you consent to a particular disclosure. Please note that once we share your information with another company, that information becomes subject to the other Company's privacy practices.

Where we share information with service providers and partners, we ensure they only have access to such information that is strictly necessary in order for us to provide the Services. These parties are required to secure the data they receive and to use the data for pre-agreed purposes only, while ensuring compliance with all applicable data protection regulations.

DATA TRANSFER

Any information you provide us may be transferred to and processed in countries other than the country from which you accessed the Website. If you are a resident of the European Economic Area ("EEA") we will take appropriate measures to ensure that your Personal Data receives an adequate level of data protection upon its transfer outside of the EEA. If you are a resident of a jurisdiction where the transferring of your Personal Data requires your consent, then your consent to this Privacy Policy includes your express consent for such data transfer.

USER RIGHTS

We acknowledge that different people have different privacy concerns and preferences. Our goal is to be clear about what information we collect so that you can make meaningful choices about how it is used. We provide you with the ability to exercise certain choices, rights, and controls in connection with your information. Depending on your relationship with DermaDetect, data protection and privacy laws provide you with some of the following principal rights regarding your Personal Data, including (and depending on your jurisdiction): The right to access your Personal Data that we process; The right to ensure your Personal Data is accurate, complete and up to date; The right to have your Personal Data amended (by correcting, deleting or adding information); The right to object to the processing of your Personal Data, to the extent applicable; The right to send or "port" your Personal Data; The right to file a complaint with a supervisory authority in your jurisdiction; The right to withdraw consent, subject to legal or contractual restrictions and reasonable notice; etc.
You may exercise any or all of your above rights in relation to your Personal Data by contacting us at: [email protected].
Where we are not able to provide you with the information for which you have asked, we will endeavor to explain the reasoning for this and inform you of your rights, including the right to complain to the supervisor authority (in the event you are an EEA resident). We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any such information in accordance with applicable law.

RETENTION

We retain Personal Data we collect as long as it remains necessary for the purposes set forth above, all in accordance with applicable laws, or until an individual expresses a preference to opt-out.
Other circumstances in which we will retain your Personal Data for longer periods of time include: (i) where we are required to do so in accordance with legal, regulatory, tax, or accounting requirements; (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. Please note that except as required by applicable law, we may at our sole discretion, delete or amend information from our systems, without notice to you, once we deem it is no longer necessary for such purposes.

SECURITY

We implement extensive security measures to reduce the risks of damage, loss of information, and unauthorized access or misuse of Personal Data. We implement appropriate data collection, storage, and processing practices and security tools to protect Personal Data against unauthorized access, alteration, disclosure, or destruction. You should be aware that no security measures are completely fail-proof, and it is impossible to prevent any and all threats to the security of data and systems. Therefore, you should be aware that any processing of digital Personal Data holds certain inherent risks, and we cannot guarantee that our services and databases will be immune to any wrongdoings, malfunctions, unauthorized interceptions or access, malware attacks or other kinds of abuse and misuse.

CHILDREN

Our Services are not intended for use by children and we do not knowingly collect or maintain information about anyone under the age of 16. Please contact us at: [email protected] f you have reason to believe that a child has shared any information with us.

Last Updated: February 02, 2023