Effective Date: July 2020

Luminera Derm Ltd. (the “Company”) values your privacy. In this Privacy Policy (“Policy”), we describe how we collect, use, and disclose information that we obtain about visitors and users of the Company’s websites (collectively, the “Site”). 
This policy forms an integral part of the Company’s Terms of Use (the “Terms”). By visiting the Site, you agree and confirm that you have read and that you agree to be bound by the Terms and this Policy and further agree and confirm that your personal information will be handled as described in this Policy. Your use of the Site and any dispute over privacy are subject to this Policy. If you do not agree to the Terms and this Policy, do not connect to, access or use the Site in any manner whatsoever.

 What Information Do We Collect About You?

You are not required to provide us with any information in order to access our Site, however, in order to use all features provided in the Site, you may be required to provide us with certain information as further detailed in this privacy policy. Each type of information will be provided by you based on your consent hereof.

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?

Like most online services, we may use cookies and other technologies, such as web beacons, web storage, and unique advertising identifiers , to collect information when you interact with services we offer through the Site or one of our partners, such as advertising and commerce features. These technologies are used to maintain, deliver and improve our services on an ongoing basis and to provide Users with a better experience, as well as to allow us to examine User preferences, better secure the Services, identify technical issues, and monitor and improve the overall performance of the Services.

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.

  • Google Analytics.This Site uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies, which are text files placed on your device, to help the website analyze how users use the site. The information generated by the cookie about your use of the Site (including your IP address) will be transmitted to and stored by Google on servers in the United States. In case of activation of the IP anonymization, Google will truncate/anonymize the last octet of the IP address for Member States of the European Union, as well as for other parties to the Agreement on the European Economic Area. Only in exceptional cases, the full IP address is sent to and shortened by Google servers in the USA. On behalf of the website provider, Google will use this information for the purpose of evaluating your use of the Site, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage to the website provider. Google will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser. However, please note that if you do this, you may not be able to use the full functionality of this Site.

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).

  • Google Tag Manager. GTM is a tag management system to manage JavaScript and HTML tags used for tracking and analytics on websites and allowing marketed website tags to be managed using an interface. Tags are small code elements that, among other things, are used to measure traffic and visitor behavior: to understand the effect of online advertising and social channels; to set up remarketing and orientation towards target groups; and to test and optimize websites. GTM makes it easier for us to integrate and manage our tags.

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.

Further information concerning GTM’s privacy practices can be found at: https://policies.google.com/privacy and https://developers.google.com/tag-manager.

  • Facebook Pixel and Facebook Advertising. This Site uses cookies placed by Facebook to enables it to measure, optimize and build audiences for advertising campaigns served on Facebook and for additional for statistical and market research purposes. In particular it enables us to see how our users move between devices when accessing our Site and Facebook, to ensure that our Facebook advertising is seen by our users most likely to be interested in such advertising by analyzing which content a user has viewed and interacted with on the Site.

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.

You can opt-out of Facebook’s use of cookies through settings on your Facebook Account. To opt-out please see https://www.facebook.com/ads/preferences.

Further information concerning the terms and conditions of use and data privacy can be found at: https://www.facebook.com/about/privacy/.

These entities may use cookies and other tracking technologies to perform their services.

 

 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?

Our Site may contain links to third-party websites. Any access to and use of such linked websites is not governed by this Policy, but instead is governed by the privacy policies of those third-party websites. We do not exercise control over such third-party websites and are not responsible for the information practices of such third-party websites. You access such third-party websites or content at your own risk. You should always read the privacy policy of a third-party website before providing any information to the website.

 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.

 European Citizens

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: privacy@luminera.com

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.