Effective Date: July 2020
What Information Do We Collect About You?
The type of information that we collect from you depends on your interaction with our Site, and may include:
- Information that you chose directly to share with us, either by entering it on our Site or provide it to us in any other way (such as when you contact us), including personal information. Such information usually includes your name, email address, phone number and other contact information;
- Information that we collect automatically about you when you use the Site, from different sources and in various ways. Such information usually includes search terms, viewing history, communications, traffic data, IP address of your device, browser type and version, type and version of your operating system, and additional information relating to how you interact with the Site. This information is being collected by using third-party data sources (including analytics and tracking), as well as other third parties who perform functions on our behalf and who also provide services to us, as further elaborated below; and
- information we infer or generate from other data collected in accordance with sub-section (i) and (ii). This type of information will be collected on an aggregate or de-identified basis and will not be considered as “personal information”.
- We may also collect other and additional information, with your permission.
- How Do We Use Third-Party Analytics and Tracking?
Most web browsers are set to accept cookies by defaults. If you prefer, you can usually remove or reject browser cookies through the settings on your browser or device. Keep in mind, though, that removing or rejecting cookies may affect the availability and functionality of our Site.
We use automated devices and applications, as described below, to evaluate our Site and its usage by visitors. We use these tools to help us improve our Site, its overall performance and user experiences.
You can refuse the use of Google Analytics and opt out of having your information used by Google Analytics by visiting https://tools.google.com/dlpage/gaoptout/. An opt-out cookie will be set on the device, which prevents the future collection of your data when visiting this Site.
Further information concerning the terms and conditions of use and data privacy can be found at: http://www.google.com/analytics/terms/gb.html
Please note that on this Site, Google Analytics code is supplemented by Google to ensure an anonymized collection of IP addresses (so called IP-masking).
The GTM is a cookie-less domain and does not register personal data. The tool causes other tags to be activated which may, for their part, register data under certain circumstances. Google Tag Manager does not access this information.
Facebook may link this information to your Facebook account and also use it for its own promotional purposes, in accordance with Facebook’s Data Usage Policy.
Further information concerning the terms and conditions of use and data privacy can be found at: https://www.facebook.com/about/privacy/.
What about Children on our Site?
Our Site is not designed for persons under 18. We do not knowingly collect personal information from children under the age of 18. If we become aware that we have inadvertently received personal information from a child under the age of 18, we will delete such information from our records.
How Do We Use Your Information?
We use the information, including personal information, alone or in combination with other information that we may collect about you, including information from third parties, for the following purposes that we consider in our legitimate interests:
- To provide you with the Site and with our services.
- To communicate with you (via email or other platforms), including responding to your requests or inquiries.
- To better understand how users access and use our Site, both on an aggregated and individualized basis.
- To maintain, support, develop, improve, customize, optimize, implement, operate and modify the Site and our services, to respond to user preferences, to use a de-identified or aggregate copy of information for our analytical, research and development purposes, and for research and analytical purposes.
- To identify and prevent unauthorized or prohibited uses of the Site, viruses, frauds or violation of the Terms, the Policy or any applicable law.
- We may share your information in any case of dispute, or legal proceeding of any kind between you and us concerning the Site or your use thereof.
Your consent serves as the legal basis for processing your information. You may withdraw consent at any time, without affecting the lawfulness of data processing we carried out based on your consent before such withdrawal.
Does the Company Share the Information It Collects About You?
We may share the information that we collect about you, with third parties worldwide, as follows:
- Service Providers/Agents. We may disclose your information to third parties, including service providers, independent contractors, and affiliates that perform functions on our behalf and process the information on our behalf and under our instructions. Examples include: cookies, analyzing data, analytics companies that collect browsing information and profiling information relating to marketing and promotional purposes.
We will only provide these entities with the information necessary for them to perform these services and functions on our behalf. These entities are contractually required to protect your personal information from unauthorized access, use, or disclosure. Prior to engaging with any third party, we will assess the security risks involved in contracting with such third party and define its obligations with respect to the data security and confidentiality. Although efforts are made by us, we are unable to guarantee that each third party with whom we will contract and to whom the information will be transferred, will meet their obligations.
- We may also share personal information with our business partners.
- We may share non personal, aggregate or de-identified information with third parties for our business purposes (such as development and research), including cookies.
- We may share your information in any case of dispute, or legal proceeding of any kind between you and us concerning the Site or your use thereof to third parties, if we believe disclosure is in accordance with or required by, applicable law, regulation or legal process.
- Business Transfers. If we are acquired by or merged with another company, if substantially all of our assets are transferred to another company, or as part of a bankruptcy proceeding, we may transfer the information we have collected from you to the other company. You will have the opportunity to opt-out of any such transfer if, in our discretion, it will result in the handling of your information in a way that differs materially from this Policy.
- We do not share your personal information with third parties for any other purpose.
What About Third-Party Links?
How Secure is My Personal Information?
We have implemented commercially reasonable precautions to protect the information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction, in accordance with industry practice and applicable laws. Please be aware that despite our best efforts, no data security measures can guarantee 100% security. While we strive to protect information transmitted on or through our Site, we cannot and do not guarantee the security of any information you transmit on or through the Site, and you do so at your own risk.
Please note that most mobile devices allow their users with tools to control your data and to secure your information. Please be aware of these tools.
Will You Transfer My Information Outside of My Home Country?
We may transfer certain information outside to other countries, including to the United States, which may not have an equivalent level of data protection as in your home country. However, please rest assured that we implement all the necessary and appropriate legal, organizational and technical measures to protect your personal information. Your data also may be subject to access by law enforcement and other government entities, including courts and tribunals in accordance with the laws applicable in those jurisdictions.
Can I Access, Update, Correct, or Delete My Personal Information?
You have the right to view, correct and delete the personal information that we hold about you.
As permitted by applicable law, we may retain changed or deleted information for archival purposes. If you wish to view, correct or delete your personal information please contact us using the contact information detailed in Section 12 below.
With respect to your Personal Information, you have the right to:
- request access to and be provided with information on the processing of your personal information;
- request corrections of your personal information if such personal information proves inaccurate or incomplete;
- request your personal information to be deleted (i) if it is no longer necessary for the purposes described in this Policy, (ii) should you decide to withdraw your consent where you gave it, (iii) should you identify that it would have been unlawfully processed, (iv) should we be under a legal obligation to erase it to comply with EU law or the law of an EU country and always provided we are not under a legal obligation to keep it;
- restrict the processing of your personal information (i) if you contest its accuracy; (ii) if the processing is unlawful and you oppose the erasure; (iii) if it is no longer needed for the purposes set out in this Policy but you require it for the establishment, exercise or defense of a legal claim, (iv) if you object to profiling; and
- receive personal information which you provided to us in a structured, commonly used and machine-readable format and to transmit it to another provider provided it is processed based on your consent or our contract.
If you wish to exercise any of your above rights, please reach out to us using the contact information detailed in Section 12 below.
How Long Does the Company Retain my Information?
The data is only kept for the time necessary for the purpose for which it was collected as described above, where it is in our legitimate interest, or to comply with our legal obligations. Following such a period, we will delete the personal information from our internal systems. Please note that we may keep copies of de-identified or aggregate information (provided that it does not include any personal information).
You have the right to request deleting the personal information that we hold about you at any time.
The following disclosures are made pursuant to the European General Data Protection Regulation (GDPR): You have the right to withdraw your consent at any time and submit a complaint to the relevant supervisory data protection authority.
How do I get in touch with the Company?
You may contact us with any questions or comments:
Luminera Derm Ltd.
Contact Person: Liat Goldshaid-Zmiri, CEO.
Email address: firstname.lastname@example.org
Address: Bat Sheva 1, Lod, Israel;
Phone: +972-72-2744141; Fax: +972-72-2744145.
Changes to this Policy
This Policy is current as of the Effective Date set forth above. We may change this Policy from time to time, so please be sure to check back periodically. We will post any changes to this Policy on our Site. If we make any changes to this Policy that materially affect our practices with regard to the personal information, we have previously collected from you, we will endeavor to provide you with notice in advance of such change by highlighting the change on our Site.