Privacy Policy

Last Revised: December 14, 2020

Introduction

Kahun Medical Ltd. (“Kahun”, “we”, “us” or “our”) respects the privacy of its users (“User(s)”, “your” or “you”), and is committed to protecting the information that you share with us in connection with use of the Kahun Medical web and mobile applications (the “App”), and our main website, available at www.kahun.com or any other related website (the “Website” or “Site”, and together with the App, the “Services”).

Your use of the Site is not involving any submission of personal information, unless you voluntarily choose to contact us and to provide us with such information. The use of the App is available to all users, and certain functionalities may require registration and submission of certain personal information, as described in this Privacy Policy.

To ease your navigation into this Privacy Policy, you may use the following headlines:

About our Privacy Policy

This Privacy Policy (the “Privacy Policy” or “Policy”) applies when you visit or use our Services, and is intended to describe our practices regarding the information we may collect from you when you use the Service, the manners in which we may use such information, and the options and rights available to you.

This Policy supplements and shall be read in conjunction with our Terms of Use at www.kahun.com/TOU (the “TOU”), and may be supplemented by additional privacy statements, terms or notices provided to you, as dependency of your jurisdiction of residency. Capitalized terms which are not defined herein, shall have the meaning ascribed to them in our TOU.

Your Consent

2.1. Please read carefully this Privacy Policy before accessing and using the

Services, whether you are a Site visitor, or an App user. By entering, connecting to, accessing and/or using our Services, you agree to be bound by the terms and conditions set forth in this Policy, including to the collection and processing of your Personal Information (as defined below), when such data is provided by you.

2.2. Certain information we collect, such as general usage information, device information, analytics, statistics, or any other data that enable us to provide the services, is collected as part of our legitimate interest. You can find further explanation below, under the “Legal Basis” section.

2.3. Third-party Information

When you use certain functionalities of the Services, you may do so by submitting certain information to us, that when referred to an actual person, may be classified as personal information. Although we do not take any action to validate any information you submit to us as true or hypothetical, you hereby acknowledge and agree that in case where the information relates to any third-party data subject, you will do so based on their lawful consent, contract or any other lawful basis applicable to your jurisdiction and/or profession.
You hereby undertake to not submit or otherwise transmit to us any personal identifiable information of third parties, such as patients or other individuals. The App and related Services are designed to serve you, when examining a medical case, whether a real or hypothetical one, and shall be used as a research tool to support your diagnosis and decision making processes.
If you are submitting to the Services any personal information pertaining to any third party, you hereby represent and warrant and have received all the necessary legal consents or approvals and have the actual authority and legal right to upload, submit, disclose or otherwise share the Non-personal Information and/or Personal Information and/or any other form of sensitive information, on the third party’s behalf.

Please note: you are not obligated by law to provide us with any Personal Information. you hereby acknowledge and agree that you are providing us with Personal Information at your own free will, for the purposes described in this Policy, and that we may retain such information in accordance with this Policy and any applicable laws and regulations.

We do not collect any Personal Information from you or related to you without your approval, which is obtained, inter alia, through your active acceptance of the TOU and this Privacy Policy.

Information we collect

3.1. General: We may collect two types of data and information from you. In this section, we describe the categories of information which we may collect, and the applicable circumstances under which such collection is performed.

3.2. What is personal information? The exact definition may be different as dependency of your country of residence. Below is the generally acceptable definition, and at the end of this Policy, you may revisit the EU General Data Protection Regulation (GDPR) definitions.

“Personal information” is individually identifiable information, namely information that identifies an individual or may with reasonable efforts or together with additional information we have access to, enable the identification of an individual, or may be of private or sensitive nature information relating to an identified or identifiable natural person. Identification of an individual also includes association of such individual with a persistent identifier such as a name, an identification number etc.

Personal information does not include information that has been aggregated or otherwise processed so that it can no longer be used to identify or be associated with a specific natural person.

3.3. When we collect Personal Information?

We collect Personal Information from you when you use or interact with our Services
We collect Personal Information from you and the devices you use when you register an account with us, submit information to our App, or otherwise using the Services

3.4. Categories of Personal Information: more specifically we collect and use the following categories and types of information in the following respective circumstances:

Personal Information you provide us actively and voluntarily when you use or interact with our Services: including by submitting a contact form, registering with the App and/or, any other data submission option provided to you via the Services.
If you partner with us as a peer, client or any other business-to-business form, we may retain CRM information about you, such as User name, company number, signing person name and position, email and physical addresses, and telephone number, all when such User fills our online form or register for an account with us or when they update their account details.
The contents of Users’ interaction with our customer support which may include text/video/audio recording and transcripts of such communications.
Information we are required or authorized by applicable national laws to require Users to provide us in order to authenticate or identify them or to verify the information we have collected or otherwise provide them with our Services.

Personal Information we automatically obtain when you use or interact with our Services, such as IP address, cookies and tags, via which we may get certain analytics and performance information: Keep in mind that most devices and browsers allow you to control or disable the use of certain collectable information including location services, in the device’s settings menu. We perform such automatic collection through: (i) use of cookies, web beacons, online identifiers, and similar technologies, with respect to Users; and (ii) Technical Identifiers (as defined below), with respect to devices via which Users use the Services. Such means of collection allow us to collect information about the pages and screens Users view, the links you click, engagement within the App, and other actions you take when using the Services.

We generally classify this type of automatically collected personal information under the following categories:

“Usage Information”: this refers to information relating to the Users’ interaction with our Services, such as clicks when using the App and other use of the App’s features.
“Technical Information”: this refers to various unique identifiers that generally only identify a computer, device, browser or Application. For example, IP address (which may also provide general location information), user agent.
“Device Information”: this refers to technical information related to a device, such as: browser type, device type and model, operating system (iOS/Android etc.), system language, memory, OS version, time stamp and zone.

Our legal basis for use of your information

We collect, process and use your information for the purposes described in this Privacy Policy, based at least on one of the following legal grounds:

With your consent upon accessing and registering to the Services: We ask for your agreement to process your information for specific purposes and you have the right to withdraw your consent at any time.
When Performing our Services and providing them to you under the TOU: We collect and process your Personal Information in order to provide you with the Services, following your acceptance of the Terms; to maintain and improve our Services; to develop new services and features for our Users; and to personalize the Services in order to ensure a better user experience.
Legitimate interests: We process certain information such as cookies and other online necessities for our legitimate interests while applying appropriate safeguards that protect your privacy. This means that we process your information for things like detecting, preventing, or otherwise addressing fraud, abuse, security, usability, functionality or technical issues with our Services, protecting against harm to the rights, property or safety of our online properties, our Users, or the public as required or permitted by law; enforcing legal claims, including investigation of potential violations of this Privacy Policy; and in order to comply and/or fulfil our obligations under applicable laws, regulations, guidelines, industry standards, contractual requirements, legal process, subpoena or governmental request, as well as our Terms of Use.

Purpose for processing your information

We may use information that we collect about you for the following purposes:

To provide, operate and improve our Services and manage our operation;

To generate analysis and insights for our Users and to better understand how they use our Services;

To send you updates, notices, notifications, announcements, and additional information related to the Services;

To be able to manage your account and provide you with customer support;

To create cumulative statistical data and other cumulative information that is non-personal, in which we and/or our business partners might make use of in order to operate and improve our Services;

To perform functions or services as otherwise described to you at the time of collection;

To prevent, detect, mitigate, and investigate fraud, security breaches or other potentially prohibited or illegal activities;
To comply with any applicable rule or regulation and/or respond to or defend against legal proceedings brought against us or our affiliates.

Any information you submit to us via the Services is used respectively to the purposes indicated in the relevant form or webpage.

Sharing information with third parties

We keep the information processed by us in strict confidence and only share your information with third parties in very limited circumstances and for very specific purposes, as described below:

Third Party Services: We are partnering with a number of selected service providers, whose services and solutions complement, facilitate and enhance our own. These include hosting, database and server co-location services (e.g., Amazon (AWS)), data analytics services (e.g. Google Analytics) and session replay records for analytic purposes such as crashes, functionality and usability (e.g. MixPanel) and our business, legal and financial advisors (collectively, “Third Party Service Providers”).

Such Third Party Service Providers may receive or otherwise have access to certain of your Personal Information, depending on each of their particular roles and purposes in facilitating and enhancing the Services, and may only use your Personal Information for such purposes. Disclosures of Personal Information is subject to the respective third party’s undertaking of confidentiality obligations, and the prevention of any independent right to use this data except as required to help us provide you with the Services.

Law enforcement, legal proceedings, and as authorized by law: We may disclose or otherwise allow access to Personal Information pursuant to a legal requirement or request, such as a subpoena, search warrant or court order, or in compliance with applicable laws and regulations. Such disclosure or access may occur with or without notice to you, if we have a good faith belief that we are legally required to do so, or that disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing.
Protecting Rights and Safety: We may share your Personal Information with others, with or without notice to you, in cases of emergency or if we believe in good faith that this will help protect the rights, property or personal safety of our company, any of our Users, or any members of the general public.

Our Staff: We may share Personal Information internally with our staff at Kahun, for the purposes described in this Privacy Policy. Should we undergo any change in control, including by means of merger, acquisition or purchase of substantially all of its assets, your Personal Information may be shared with the parties involved in such an event. If we believe that such change in control might materially affect your Personal Information then stored with us, we will notify you of this event and the choices you may have via e-mail and/or prominent notice on our Website, App or Services.
Change of control: In the event that Kahun is acquired by or merged with a third party entity, we reserve the right to transfer or assign the information we collected as part of such merger, acquisition, sale, or other change of control.
In the unlikely event of our bankruptcy, insolvency, reorganization, receivership, or assignment for the benefit of creditors, or the application of laws or equitable principles affecting creditors’ rights generally, we may not be able to control how your information is treated, transferred, or used.

For the avoidance of doubt, we may share your Personal Information in additional manners, pursuant to your explicit approval, or if we are legally obligated to do so. Additionally, we may transfer, share or otherwise use Non-personal (including anonymized, statistical or aggregated) Information in our sole discretion and without the need for further approval.

Where we store your personal information

Your information will be maintained, processed and stored by us and our authorized affiliates (as applicable) in secure cloud storage, provided by our Third Party Service Providers based in the United States.

While the data protection laws in jurisdictions where the information is physically stored may be different than the laws of your residence or location, please know that we, our affiliates and our service providers that store or process your Personal Information on our behalf are each committed to keeping it protected and secured, pursuant to this Privacy Policy and best industry standards, regardless of any lesser legal requirements that may apply in a particular jurisdiction. You hereby accept the place of storage and the transfer of information as described in this Privacy Policy.

Data retention

We retain the Personal Information we collect or receive from you only for as long as your registered account exists in our system and as needed in order to provide you with the Services and as otherwise necessary to comply with applicable laws and regulations. If you withdraw your consent to us processing your Personal Information, including by deleting your account, we will delete your Personal Information from our systems, except to the extent such data in whole or in part is required to comply with any applicable rule or regulation and/or to respond to or defend against legal proceeding brought against us or our affiliates.

Using cookies and other tracking technologies

We may use cookies and similar web technologies to help us with better understanding how you use our Services, including those offered by Third Party Service Providers. These technologies are used in order to maintain, provide and improve our Services on an ongoing basis, and in order to provide a better experience to our Users. For example, these technologies enable us to: (i) keep track of and “remember” our Users’ preferences and authenticated sessions, (ii) secure our Services by detecting abnormal behaviors, (iii) identify technical issues and improve the overall performance of our Services, (iv) and create and monitor analytics.

Minors and third-party information provided by you

Direct User

To access or use the Services, you must be over the age of sixteen (16), and in any case, not an undersage according to the legislation inyour country of residence. Kahun does not knowingly collect Personal Information from children under the age of sixteen (16) and does not wish to do so. We reserve the right to request proof of age at any stage so that we can verify that minors under the age of sixteen (16) are not using the Services.

In the event that it comes to our attention that a person under the age of sixteen(16) is using the Services, we may prohibit and block such User from using the Services and will make all efforts to promptly delete any Personal Information with respect to such User.

Third Party Data

If you are submitting to the Services any personal information pertaining to any minor child, you hereby represent and warrant that you have received all the necessary legal consents or approvals or that you are the parent or legal guardian and have the actual authority and legal right to upload, submit, disclose or otherwise share the Non-personal Information and/or Personal Information and/or any other form of sensitive information, on the minor’s behalf.

Data security

We take great care in implementing and maintaining the security of the Services and of your Personal Information. We employ industry standard procedures and policies to ensure the safety of your information, reduce the risks stemming from loss of information and prevent unauthorized use of any such information. However, we do not and cannot guarantee that unauthorized access will never occur and reiterate that no measure can provide absolute information security.

Updating, obtaining a copy of or deleting your information

If the law applicable to you grants you such rights, you may ask to access, correct, or delete your Personal Information that is stored in our systems. You may also ask for our confirmation as to whether or not we process your Personal Information. Subject to the limitations in law, you may request that we update, correct, inaccurate or outdated information, or delete Personal Information we retain about you. You may also request that we suspend the use of any Personal Information whose accuracy you contest while we verify the status of that data. Subject to the applicable law’s limitations, you may also be entitled to obtain the Personal Information you directly provided us (excluding data we obtained from other sources) in a structured, commonly used, and machine-readable format and may have the right to transmit such data to another party.

If you wish to exercise any of these rights, contact us with an explicit request at: privacy@kahun.com. When handling these requests, we may ask for additional information to confirm your identity and your request. Please note, upon request to delete your Personal Information, we may retain such data in whole or in part to comply with any applicable rule or regulation and/or to respond to or defend against legal proceedings brought against us or our affiliates.

To find out whether these rights apply to you and for any other privacy-related matters, you can contact your local data protection authority if you have concerns regarding your rights under local law.

If you are resident of the European Union (EU), the European Economic Area (EEA), or United Kingdom (UK), you have the right to lodge a complaint with the responsible supervisory authority, if you believe that your personal data are processed in a way that does not comply with the GDPR.

Changes to the Privacy Policy

The terms of this Privacy Policy will govern the use of the Services and any information collected therein. Kahun reserves the right to change this Privacy Policy at any time, so please re-visit this page frequently. We will provide notice of substantial changes of this Privacy Policy on the homepage of the Website and/or we will send you an e-mail regarding such changes to the e-mail address that you may have provided to us. Such substantial changes will take effect seven (7) days after such notice was provided on our Website or sent by email. Otherwise, all other changes to this Privacy Policy are effective as of the stated “Last Revised” date and your continued use of the Website after the Last Revised date will constitute acceptance of, and agreement to be bound by, those changes.

General

This Privacy Policy, its interpretation, and any claims and disputes related hereto, shall be governed by the laws of the State of Israel, without respect to its criminal law principles. Any and all such claims and disputes shall be brought in, and you hereby consent to them being litigated in and decided exclusively by a court of competent jurisdiction located in Tel Aviv, Israel.

This Privacy Policy was written in English and may be translated into other languages for your convenience. If a translated (non-English) version of this Privacy Policy conflicts in any way with the English version, the provisions of the English version shall prevail.

Have any questions?

If you have any questions (or comments) concerning this Privacy Policy, you are welcome to send us an email at: support@kahun.com and we will make an effort to reply within a reasonable timeframe.

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