Last updated: May 5th , 2019 This privacy policy (“Privacy Policy”) governs how we, Spot-On Therapeutics Ltd., (“Spot-On”, “we”, “our” or “us”) use Personal Information (defined below) that we collect, receive and store pertaining to you (“User”, “you”) in connection with the following use cases:

  1. When you browse or visit our website, http://www.spotonbalance.com and/or http://spoton.s139.upress.link/ (“ Website ”)
  2. When you make use of, or interact with, our Website
    1. When you request clinical information
    2. When you request to set up a consultation meeting
    3. When you review our product
    4. When we process your job application
    5. When you send us your testimonials of our products
    6. When you subscribe to newsletters, email list and/or blog
    7. When you contact us (e.g. customer support, and/or when you leave your contact details for us to contact you)
  3. When you attend to the initial meeting and the adjustment meetings of our services
  4. When you attend a marketing event and provide Personal Information
  5. When you exchange business cards with us
  6. When we acquire your Personal Information from third-party sources (such as lead-generation companies)
  7. When we use the Personal Information of our service providers
  8. When we use the Personal Information of our customers
  9. When you interact with us on social media (e.g., Facebook, Instagram, Twitter, LinkedIn)

The Website is referred to herein as the “ Services ”. We greatly respect your privacy, which is why we make every effort to provide a platform that will live up to the highest of user privacy standards. Please read this Privacy Policy carefully, so you can fully understand our practices in relation to Personal Information. “ Personal Information ” means any information that can be used, alone or together with other Information, to uniquely identify any living human being.

Table of contents:

  1. Introduction
  2. Terms of use
  3. Consent and modification
  4. What information we collect, why we collect it, and how it is used
  5. How we protect and store your personal Information
  6. How we share your personal Information
  7. Additional information regarding transfers of personal Information
  8. Use by children
  9. Links to and interaction with third party product
  10. Log files
  11. Cookies and other tracking technologies
  12. Use of Google Analytics
  13. Access/Accuracy
  14. California privacy rights
  15. Our California do not track notice
  16. Deletion of content from California residents
  17. How to contact us

This Privacy Policy may be updated from time to time and therefore we ask you to check back periodically for the latest version of the Privacy Policy, as indicated below.  If there will be any significant changes made to the use of your Personal Information in a manner different from that stated at the time of collection, we will notify you by posting a notice on our Website or by other means.

1. INTRODUCTION

We have implemented this Privacy Policy because your privacy, and the privacy of other users, is important to us. This Privacy Policy explains our online information practices and the choices you can make about the way your Personal Information is collected and used in connection with the Services. “Personal Information” means any information that may be used, either alone or in combination with other information, to personally identify an individual, including, but not limited to, a first and last name, a personal profile, an email address, a home or other physical address, or other contact information.

2. TERMS OF USE

This Privacy Policy forms part of our Terms of Use which is available at https://www.spotonbalance.com/legal/?lang=en  (“Terms”). Any capitalized but undefined term in this Privacy Policy shall have the meaning given to it in the Terms.

3. CONSENT AND MODIFICATION

You are not legally obligated to provide us Personal Information, and you hereby confirm that providing us Personal Information is at your own free will. By using the Services, you consent to the terms of this Privacy Policy and to our collection, processing and sharing of Personal Information for the purposes set forth herein. If you do not agree to this Privacy Policy, please do not access or otherwise use the Services. We reserve the right, at our discretion, to change this Privacy Policy at any time. Such change will be effective ten (10) days following posting of the revised Privacy Policy on the Website, and your continued use of the Services thereafter means that you accept those changes.

4. WHAT INFORMATION WE COLLECT, WHY WE COLLECT IT, AND HOW IT IS USED

5. PERIOD OF STORAGE OF COLLECTED INFORMATION

a.Personal Information. Your Personal Information (as described above) will be stored until we no longer need the information and proactively delete it or you send a valid deletion request. Please note that we will retain it for a longer or shorter period in accordance with data retention laws. We have an internal data retention policy to ensure that we do not retain your Personal Information perpetually.

6. HOW WE PROTECT AND STORE YOUR INFORMATION

a. Security. We have implemented appropriate technical, organizational and security measures designed to reduce the risk of accidental destruction or loss, or the unauthorized disclosure or access to such information appropriate to the nature of the information concerned. However, please note that we cannot guarantee that the information will not be exposed as a result of unauthorized penetration to our servers. Nevertheless, we make commercially reasonable efforts to make the collection and security of such information consistent with this Privacy Policy and all applicable laws and regulations. As the security of information depends in part on the security of the computer, device or network you use to communicate with us and the security you use to protect your user IDs and passwords, please make sure to take appropriate measures to protect this information. b. Retention of your Personal Information. In addition to the retention periods mentioned in Section ‎0 above, in some circumstances we may store your Personal Information for longer periods of time, for example (i) where we are required to do so in accordance with legal, regulatory, tax or accounting requirements, or (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 Information or dealings.

7. HOW WE SHARE YOUR PERSONAL INFORMATION  

In addition to the recipients described in Section ‎0, we may share your information as follows:

  • To the extent necessary, with regulators, to comply with all applicable laws, regulations and rules, and requests of law enforcement, regulatory and other governmental agencies or if required to do so by court order;
  • If, in the future, we sell or transfer some or all of our business or assets to a third party, we will (to the minimum extent required) disclose information to a potential or actual third party purchaser of our business or assets. In the event that we are acquired by or merged with a third party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer or assign Personal Information in connection with the foregoing events.
  • Where you have provided your consent to us sharing the Personal Information (e.g., where you provide us with marketing consents or opt-in to optional additional Services or functionality); and
  • Where we receive requests for information from law enforcement or regulators, we carefully validate these requests before any Personal Information is disclosed.

8. ADDITIONAL INFORMATION REGARDING TRANSFERS OF PERSONAL INFORMATION

We will use your Personal Information to provide and improve our Site, to send you marketing/advertisement communications that we believe may be of interest to you, to contact you in connection with the Site and certain programs or offerings that you may have registered for, and to identify and authenticate your access to the parts of the Site that you are authorized to access. We may use your designated email address to: (i) send you updates or news regarding the Site and our products; and/or (ii) respond to a “Contact Us” or administrative request (for example, to change your password). We may transfer your Personal Information to our local or foreign subsidiaries or affiliated companies for the purpose of storing or processing such information on our behalf. Such information may be transferred to other countries (including US). We require that these parties agree to process such information in compliance with our Privacy Policy. We may share your Personal Information with our third party service providers and partners, but only to assist us with our business operations and to provide our Site to you and other users. Such information may be transferred to other countries. We use commercially reasonable efforts to only engage or interact with third party service providers and partners that post a privacy policy governing their processing of Personal Information. We may disclose your Personal Information or any information you submitted via the Site if we have a good faith belief that disclosure of such information is helpful or reasonably necessary to: (i) comply with any applicable law, regulation, legal process or governmental request; (ii) enforce our Terms, including investigations of potential violations thereof; (iii) detect, prevent, or otherwise address fraud or security issues; or (iv) protect against harm to the rights, property or safety of Spot-On, our users, yourself or the public.

9. USE BY CHILDREN

If you are under 18, you may not use the Website, or provide any information to the Website without involvement of a parent or a guardian. We do not knowingly collect information from, and/or about children.

10. LINKS TO AND INTERACTION WITH THIRD PARTY PRODUCTS 

The Site may enable you to interact with or contain links to your third party account and other third party websites and Services that are not owned or controlled by us (each a “Third Party Service”). We are not responsible for the privacy practices or the content of such Third Party Services. Please be aware that Third Party Services may collect Personal Information from you. Accordingly, we encourage you to read the terms and conditions and privacy policy of each Third Party Service that you choose to use or interact with.

11. LOG FILES

We make use of log files. The information inside the log files includes internet protocol (IP) addresses, type of browser, Internet Service Provider (ISP), date/time stamp, referring/exit pages, clicked pages and any other information your browser may send to us. We may use such information to analyze trends, administer the Site, track users’ movement around the Site, and gather demographic information.

12. COOKIES AND OTHER TRACKING TECHNOLOGIES

Our Site utilizes “cookies”, anonymous identifiers and other tracking technologies in order for us to provide our Site and present you with information that is customized for you. A “cookie” is a small text file that may be used, for example, to collect information about activity on the Site. Certain cookies and other technologies may serve to recall Personal Information, such as an IP address, previously indicated by a user. Most browsers allow you to control cookies, including whether or not to accept them and how to remove them. You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser.

13. GOOGLE ANALYTICS

  • Google Analytics. The Site may use a tool called “Google Analytics” to collect information about use of the Site. Google Analytics collects information such as how often users visit this site, what pages they visit when they do so, and what other sites they used prior to coming to this Site. We use the information we get from Google Analytics to maintain and improve the Site and our products. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Google’s ability to use and share information collected by Google Analytics about your visits to this Site is restricted by the Google Analytics Terms of Service, available at https://www.google.com/analytics/terms/us.html, and the Google Privacy Policy, available at http://www.google.com/policies/privacy/. You may learn more about how Google collects and processes data specifically in connection with Google Analytics at http://www.google.com/policies/privacy/partners/. You may prevent your data from being used by Google Analytics by downloading and installing the Google Analytics Opt-out Browser Add-on, available at https://tools.google.com/dlpage/gaoptout/.
  • Google Signals. The Site uses a tool called “Google Signals” to collect information about use of the Site. When you activate Google Signals, some existing Google Analytics features are updated to also include aggregated data from Google users who have turned on “Ads Personalization” (Ads Personalization available at https://support.google.com/ads/answer/2662856). Audiences that You create in Google Analytics and publish to Google Ads and other Google Marketing Platform advertising products can serve ads in cross device-eligible remarketing campaigns to Google users who have turned on Ads Personalization. Google Analytics collects additional information about users who have turned on Ads Personalization, base across device types and on aggregated data from users who have turned on Ads Personalization. The data is user based rather than session based. The Cross Device reports include only aggregated data. No data for individual users is ever exposed. You can modify your interests, choose whether your personal information is used to make ads more relevant to you, and turn on or off certain advertising services: https://support.google.com/accounts/answer/2662856
  • Mixpanel. We collect personally identifiable information such as your email address and your user activity through the use of Mixpanel. Mixpanel’s ability to use and share information is governed by the Mixpanel Terms of Use, available at https://mixpanel.com/terms/, and the Mixpanel Privacy Policy, available at https://mixpanel.com/privacy/. You can opt-out of Mixpanel’s services by clicking on the following link: https://mixpanel.com/optout/. If you get a new computer, install a new browser, erase or otherwise alter your browser’s cookie file (including upgrading certain browsers). You may also clear the Mixpanel opt-out cookie.
  • Facebook Pixels, ads and SDKs. We may use Facebook pixels, ads or SDKs, which are tools that provide help to website owners and publishers, developers, advertisers, business partners (and their customers) and others integrate, use and exchange information with Facebook, as such the collection and use of information for ad targeting. Please note that third parties, including Facebook, use cookies, web beacons, and other storage technologies to collect or receive information from your websites and elsewhere on the internet and use that information to provide measurement services and target ads. Facebook’s ability to use and share information is governed by the Facebook Tools Terms, available at: https://www.facebook.com/legal/technology_terms/. You can prevent your data from being used by Facebook Pixels and SDKs by exercising your choice through these mechanisms: http://www.aboutads.info/ choices or http://www.youronlinechoices.eu/.

14. ACCESS/ACCURACY

To the extent that you do provide us with Personal Information, we wish to maintain accurate Personal Information. If you would like to delete or correct any of your other Personal Information that we may be storing, you may submit an access request by sending an email to info@spotonbalance.com.  Your email should include adequate details of your request.

15. CALIFORNIA PRIVACY RIGHTS

California Civil Code Section 1798.83 permits our customers who are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please send an email to tlvcenter@spotonbalance.com. Please note that we are only required to respond to one request per customer each year.

16. OUR CALIFORNIA DO NOT TRACK NOTICE

We do not track consumers over time and across third party websites and therefore do not respond to Do Not Track signals. We do not allow third parties to collect personally identifiable information about an individual consumer’s online activities over time and across different websites when a consumer uses the Services.

17. DELETION OF CONTENT FROM CALIFORNIA RESIDENTS

If you are a California resident under the age of 18 and a registered user, California Business and Professions Code Section 22581 permits you to remove content or Personal Information you have publicly posted. To remove, please send an email to tlvcenter@spotonbalance.com. Please be aware that after removal you will not be able to restore removed content. In addition, such removal does not ensure complete or comprehensive removal of the content or Personal Information you have posted and that there may be circumstances in which the law does not require us to enable removal of content.

18. CONTACT US

If you have any questions, concerns or complaints regarding our compliance with this notice and the Information protection laws, or if you wish to exercise your rights, we encourage you to first contact us at to tlvcenter@spotonbalance.com