THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION. PLEASE REVIEW IT CAREFULLY.
We at Hedonia Ltd. ("Hedonia", "us", "we", or "our") recognize and respect the importance of maintaining the privacy of our users. This Privacy Notice describes the types of information we collect from you when you visit our website ("Site"), use our mobile application ("App") and/or use our services ("Services"). This Privacy Notice also explains how we process, transfer, store and disclose the information collected, as well as your ability to control certain uses of the collected information. If not otherwise defined herein, capitalized terms have the meaning given to them in the Terms of Service, available at [www.hedonia.io] ("Terms"). "You" means an individual using the Site, App or Services.
If you are an individual located in the European Union ("EU Individual"), some additional terms and rights may apply to you, as detailed herein. Hedonia Ltd. is the data controller in respect of the processing activities outlined in this Privacy Notice. Our registered office is Magshimim 26, Petah Tikva, Israel 4934835 and our Company number is 516429586.
Note that if you are using the App or Services in the context of treatment and/or clinical trial you are undergoing in a healthcare setting, the applicable healthcare provider and/or clinical trial research personnel or external staff may be serving as an additional, independent controller of your Personal Data.
If you reside or are located in the United States, provision of the Services to you may be subject to the Health Insurance Portability and Accountability Act of 1996, Subtitle D of the Health Information Technology for Economic and Clinical Health Act of 2009 ("HITECH"), and regulations and other guidance promulgated under both laws by the U.S. Department of Health and Human Services (collectively, "HIPAA").
"Personal Data" means any information that refers, is related to, or is associated with an identified or identifiable individual or as otherwise may be defined by applicable law. This Privacy Notice details which Personal Data is collected by us in connection with provision of the Site, App and Services.
"Protected Health Information" or "PHI" means individually identifiable information about your health, such as any information about (i) your health condition, (ii) healthcare services you have received or may receive in the future, or (iii) the payment for the provision of such healthcare when combined with additional information which may identify you (such as your name, phone number or Social Security Number).Privacy Notice Key Points
The key points listed below are presented in further detail throughout this Privacy Notice. You can click on the headers in this section in order to find out more information about any topic. These key points do not substitute the full Privacy Notice.
- Personal Data We Collect, Uses and Legal Basis.
- Additional Uses.
- Sharing the Personal Data We Collect.
- International Transfer.
- Your Rights - How to Access and Limit Our Use of Certain Personal Data.
- Data Retention.
- Cookies and Similar Technologies.
- Third-Party Applications and Services.
- Changes to the Privacy Notice.
- Comments and Questions.
Personal Data We Collect, Uses and Legal Basis. Depending on your usage, we collect different types of data and we and any of our third-party subcontractors and service providers use the data we collect for different purposes, as specified below. You have no legal obligation to provide us with certain Personal Data, but if you refuse to provide such Personal Data we may not be able to register you to the App and/or provide you with the Services or part thereof.
Contact Information - When you request information from us, or contact us for any other reason, including through the Site, we will collect any data you provide, such as your email address and the content of your inquiry. When you sign up for newsletters or email lists, we collect your email address.
How we use this data: To respond to your request or inquiry and to provide you with newsletters.
Legal Basis. We process this Personal Data based on performance of a contract when we respond to your inquiry and provide you with newsletters.
Questionnaires – If you fill out a questionnaire that we make available at a link or through a forum, we will collect the Personal Data you provide on such questionnaire, including data about your feelings and mood. In some jurisdictions, this may be considered health data and subject to additional protections. Note that if you register to use our App after completing a questionnaire, we will associate the data provided by way of the questionnaire with the data provided as part of the registration process.
How we use this data: To assess usage and effectiveness of the App and Services and improve the Services and in some cases in order to provide you with the Services.
Legal Basis: We process this data based on your consent. When we process this Personal Data for the purpose of providing the Services to you, we do so in order to perform our contract with you.
Registration and Form Data - In order to use our App and/or receive related Services, you will be required to register and provide us with the following Personal Data: email address, phone number, gender and age. As part of the registration process and throughout use of the Services, you may be asked to fill out certain forms and provide information such as your diagnosis (if any), your mood, your gender, employment status, marital status, place of residence, and other information. See also the section on Special Categories of Data below.
How we use this data: (1) to provide you with the App and/or Services and to respond to your inquiries and requests and to contact and communicate with you; and (2) to assess usage and effectiveness of the App and Services, to create analytics and improve the Services.
Legal Basis: (1) We process this Personal Data for the purpose of providing the Services to you, which is considered performance of a contract with you, including responding to your inquiries and requests and providing customer support. (2) When we process your Personal Data for the purposes of preventing fraud, protecting the security of and/or addressing problems with the Site and Services and/or for the purpose of providing you with informational newsletters and promotional materials relating to our Services, such processing is based on our legitimate interests.
Automatically Collected Data – When you visit the Site or use the App, we automatically collect information about your computer or mobile device, including non-Personal Data such as your operating system, and Personal Data such as your IP address, device ID, as well as your activities and browsing and usage history, including the times of your usage sessions and your gameplay activity.
How we use this data. We use this data to review usage and operations, including in an aggregated non-specific analytical manner, develop new products or services and improve current products and Services.
Legal Basis: We process this Personal Data for our legitimate interests to develop and improve our Site, App, products and Services, review usage, perform analytics, and prevent fraud.
Materials You Upload – Any materials including User Content you may provide, including via user forums will be collected by us.
How we use this data. To provide you with the Services.
Legal Basis. We process this Personal Data for the purpose of performance of a contract with you.
- Contact Information - When you request information from us, or contact us for any other reason, including through the Site, we will collect any data you provide, such as your email address and the content of your inquiry. When you sign up for newsletters or email lists, we collect your email address.
- Statistical Information and Analytics. We and/or our service providers use analytics tools, including "Google Analytics" to collect and analyze information about the use of the Site, App and/or Services, such as how often users access the Site or App, what pages they visit when they do so, and what other sites and mobile applications they used prior to visiting the Site or App. By analyzing the information we receive, we may compile statistical information across a variety of platforms and users, which helps us improve our Site, App, and Services, understand trends and customer needs and consider new products and services, and tailor existing products and services to customer desires. You can find more information about how Google collects information and how you can control such use at this Link
Direct Marketing. As described above, we may use Personal Data to let you know about our products and Services that we believe will be of interest to you. In all cases, we will respect your preferences for how you would like us to manage marketing activity with respect to you. To protect privacy rights and to ensure you have control over how we manage marketing with you:
- We will take steps to limit direct marketing to a reasonable and proportionate level and only send you communications which we believe may be of interest or relevance to you.
- You can ask us to stop sending email marketing by following the "unsubscribe" link you will find on all the email marketing messages we send you. Alternatively, you can contact us at firstname.lastname@example.org.
- You can change the way your browser manages cookies, which may be used to deliver online advertising, by following the settings on your browser as explained below. If our marketing activities are based upon your consent, you may withdraw this consent at any time.
We recommend you routinely review the privacy notices and preference settings that are available to you on any social media platforms as well as your preferences within your account with us.
Sharing the Personal Data We Collect. We share your information, including Personal Data, as follows:
- Clinical Providers. If you use the App in the context of treatment and/or clinical trial you are undergoing and/or participating in, as applicable, in a healthcare setting, we may share your Personal Data applicable healthcare provider, who serves as an additional, independent controller of your Personal Data.
Service Providers, and Subcontractors. We disclose information, including Personal Data we collect from and/or about you, to our trusted service providers and subcontractors, who have agreed to confidentiality restrictions and who use such information solely on our behalf in order to: (1) help us provide you with the Site, App and/or Services and (2) aid in their understanding of how users are using our Site, App and/or Services.
Such service providers and subcontractors provide us with IT and system administration services, data backup, security, and storage services, data analysis and help us serve advertisements and provide other marketing services.
- Business Transfers. Your Personal Data may be disclosed as part of, or during negotiations of, any merger, sale of Hedonia assets or acquisition (including in cases of liquidation). In such case, your Personal Data shall continue being subject to the provisions of this Privacy Notice.
- Law Enforcement Related Disclosure. We may share your Personal Data with third parties: (i) if we believe in good faith that disclosure is appropriate to protect our or a third party's rights, property or safety (including the enforcement of the Terms and this Privacy Notice); (ii) when required by law, regulation subpoena, court order or other law enforcement related issues, agencies and/or authorities; or (iii) as is necessary to comply with any legal and/or regulatory obligation.
- Legal Uses. We may use your Personal Data as required or permitted by any applicable law, for example, to comply with audit and other legal requirements.
- We use subcontractors and service providers who are located in countries other than your own and send them information we receive (including Personal Data). We conduct such international transfers for the purposes described above. We will ensure that these third parties will be subject to written agreements ensuring the same level of privacy and data protection as set forth in this Privacy Notice, including appropriate remedies in the event of the violation of your data protection rights in such third country.
Whenever we transfer your Personal Data to third parties based outside of the European Economic Area ("EEA") and when required under applicable law, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your Personal Data to countries that have been deemed to provide an adequate level of protection for Personal Data by the European Commission.
- Where we use certain service providers not located in countries with an adequate level of protection as determined by the European Commission, we may use specific contracts approved by the European Commission which give Personal Data the same protection it has in the EEA.
- Please contact us at email@example.com if you would like further information on the specific mechanism used by us when transferring your Personal Data out of the EEA.
Security. We have implemented and maintain appropriate technical and organization security measures, policies and procedures designed to reduce the risk of accidental destruction or loss, or the unauthorized disclosure or access to Personal Data appropriate to the nature of such data. The measures we take include:
- Safeguards – The physical, electronic, and procedural safeguards we employ to protect your Personal Data include secure servers, firewalls, antivirus, and SSL encryption of data.
- Access Control – We dedicate efforts for a proper management of system entries and limit access only to authorized personnel on a need to know basis of least privilege rules, review permissions quarterly, and revoke access immediately after employee termination.
- Internal Policies – We maintain and regularly review and update our privacy related and information security policies.
- Personnel – We require new employees to sign non-disclosure agreements according to applicable law and industry customary practice.
- Database Backup – Our databases are backed up on a periodic basis for certain data and are verified regularly. Backups are encrypted and stored within the production environment to preserve their confidentiality and integrity, are tested regularly to ensure availability, and are accessible only by authorized personnel.
- However, no method of transmission over the Internet or method of electronic storage is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.
- As the security of information depends in part on the security of the computer you use to communicate with us and the security you use to protect user IDs and passwords, please take appropriate measures to protect this information.
Your Rights - How to Access and Limit Our Use of Certain Personal Data. Subject to applicable law and certain exemptions, and in some cases dependent upon the processing activity we are undertaking, you have certain rights in relation to the Personal Data that we or other controllers hold about you, as detailed below. For any requests to exercise such rights with respect to information held by other controllers, please contact the applicable controller directly. If you wish for us to notify all independent controllers, please specify that request when you contact us in order to exercise any of your rights. We will investigate and attempt to resolve complaints and disputes and make every reasonable effort to honor your wish to exercise your rights as quickly as possible and, in any event, within the timescales provided by applicable data protection laws. We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any information and/or comply with any of your requests, as detailed below:
- Right of Access. You have a right to know what Personal Data we collect about you and, in some cases, to have such Personal Data communicated to you. Please note that we may not be able to provide you with all the information you request, and, in such case, we will endeavor to explain to you why.
- Right to Data Portability. If the processing is based on your consent or performance of a contract with you and processing is being carried out by automated means, you may be entitled to (request that we) provide you or another party with a copy of the Personal Data you provided to us in a structured, commonly-used, and machine-readable format.
- Right to Correct Personal Data. Subject to the limitations in applicable law, you may request that we update, complete, correct or delete inaccurate, incomplete, or outdated Personal Data.
- Deletion of Personal Data ("Right to Be Forgotten"). If you are an EU Individual, you have a right to request that we delete your Personal Data if either: (i) it is no longer needed for the purpose for which it was collected, (ii) our processing was based on your consent and you have withdrawn your consent, (iii) you have successfully exercised your Right to Object (see below), (iv) processing was unlawful, or (v) we are required to erase it for compliance with a legal obligation. We cannot restore information once it has been deleted. Please note that to ensure that we do not collect any further Personal Data, you should also delete our App from your mobile devices, terminate your account with us, and clear our cookies from any device where you have used our App or visited our Site. We may retain certain Personal Data (including following your request to delete) for audit and record-keeping purposes, or as otherwise permitted and/or required under applicable law.
- Right to Restrict Processing. If you are an EU Individual, you can ask us to limit the processing of your Personal Data if either: (i) you have contested its accuracy and wish us to limit processing until this is verified; (ii) the processing is unlawful, but you do not wish us to erase the Personal Data; (iii) it is no longer needed for the purposes for which it was collected, but we still need it to establish, exercise, or defend of a legal claim; (iv) you have exercised your Right to Object (below) and we are in the process of verifying our legitimate grounds for processing. We may continue to use your Personal Data after a restriction request under certain circumstances.
- Direct Marketing Opt Out. You can change your mind at any time about your election to receive marketing communications from us and/or having your Personal Data processed for direct marketing purposes. If you do, please notify us by contacting us at firstname.lastname@example.org. We will process your request as soon as reasonably possible, however it may take a few days for us to update our records before any opt out is effective.
- Right to Object. If you are an EU Individual, you can object to any processing of your Personal Data which has our legitimate interests as its legal basis, if you believe your fundamental rights and freedoms outweigh our legitimate interests. If you raise an objection, we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms.
- Withdrawal of Consent. You may withdraw your consent in connection with any processing of your Personal Data based on a previously granted consent. This will not affect the lawfulness of any processing prior to such withdrawal.
- Right to Lodge a Complaint with Your Local Supervisory Authority. If you are an EU Individual, you may have the right to submit a complaint to the relevant supervisory data protection authority if you have any concerns about how we are processing your Personal Data, though we ask that as a courtesy you please attempt to resolve any issues with us first.
Information subject to HIPAA. If you the information we handle about you is subject to HIPAA and constitutes PHI, you may have the following rights with respect to such PHI, all to the extent provided under HIPAA:
- The right to request restrictions on certain uses and disclosures of protected health information. We are not required to agree to a requested restriction, except in case of a disclosure restricted under HIPAA.
- The right to receive confidential communications of PHI.
- The right to inspect and copy PHI;
- The right to amend PHI;
- The right to receive an accounting of disclosures of PHI;
- You may submit complaints directly to us at email@example.com or to the Secretary of Health and Human Services, if you believe your privacy rights have been violated. There will be no retaliation if you file a complaint against us.
- Note that we are required by law to maintain the privacy of PHI and, to provide you with notice of our legal duties and privacy practices with respect to PHI, to notify affected individuals following a breach of unsecured PHI, and to abide by the terms of this Privacy Notice.
- Subject to applicable law, we retain Personal Data as necessary for the purposes set forth above. We may delete information from our systems without notice to you once we deem it is no longer necessary for these purposes. Retention by any of our processors may vary in accordance with the processor's retention policy.
- In some circumstances, we may store your Personal Data for longer periods of time, for instance where we are required to do so in accordance with legal, regulatory, tax, audit, accounting requirements and so that we have an accurate record of your dealings with us in the event of any complaints or challenges, or if we reasonably believe there is a prospect of litigation relating to your Personal Data or dealings. To determine the appropriate retention period, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data, and whether those purposes can be achieved through other means, as well as applicable legal requirements.
- Please contact us at firstname.lastname@example.org if you would like details regarding the retention periods for different types of your Personal Data.
What are Cookies? A cookie is a small piece of text that is sent to a user's browser or device. The browser provides this piece of text to the device of the originating user when this user returns.
- First-party cookies are placed by us, while third-party cookies may be placed by a third party. We use both first- and third-party cookies.
- We may use the terms "cookies" to refer to all technologies that we may use to store data in your browser or device or that collect information or help us identify you in the manner described above, such as web beacons or "pixel tags".
The specific names and types of the cookies, web beacons, and other similar technologies we use may change from time to time. However, the cookies we use generally fall into one of the following categories:
Type of Cookie Why We Use These Cookies Performance / Analytics These cookies can help us collect information to help us understand how you use our Site and App, for example whether you have viewed messages or specific pages and how long you spent on each page. This helps us improve the performance of our Site and App. Advertising These cookies are placed in order to deliver content, including ads relevant and meaningful to you and your interests. They may also be used to deliver targeted advertising or to limit the number of times you see an advertisement. This can help us track how efficient advertising campaigns are, both for our own Services and for other websites. Such cookies may track your browsing habits and activity when visiting our Site and App and those of third parties.
- Third Party Cookies - Google Ads Google Analytics Google Firebase Apple Search Ads Facebook Business Manager Facebook Pixels
- How to Adjust Your Preferences. Most Web browsers are initially configured to accept cookies, but you can change this setting so your browser either refuses all cookies or informs you when a cookie is being sent. In addition, you are free to delete any existing cookies at any time.
- By changing your device settings, you can prevent your device's ad identifier being used for interest-based advertising, or you can reset your device's ad identifier. Typically, you can find the ad identifier settings under "privacy" or "ads" in your device's settings, although settings may vary from device to device. Adjusting your preferences as described in this section herein does not mean you will no longer receive advertisements; it only means the advertisements that you do see will be less relevant to your interests.
- What are Cookies? A cookie is a small piece of text that is sent to a user's browser or device. The browser provides this piece of text to the device of the originating user when this user returns.
- Third-Party Applications and Services. All use of third-party applications or services is at your own risk and subject to such third party's terms and privacy policies.
- Communications. We reserve the right to send you service-related communications, including service announcements and administrative messages, without offering you the opportunity to opt out of receiving them. Should you not wish to receive such communications, you may cancel your account.
- Children. We do not knowingly collect Personal Data from children under the age of eighteen (18). In the event that you become aware that an individual under the age of eighteen (18) has enrolled without parental permission, please advise us immediately.
- Changes to the Privacy Notice. We may update this Privacy Notice from time to time to keep it up to date with legal requirements and the way we operate our business, and we will place any updates on this webpage. Please come back to this page every now and then to make sure you are familiar with the latest version. If we make material changes to this Privacy Notice, we will seek to inform you by notice on our Site or via email.
- Comments and Questions. If you have any comments or questions about this Privacy Notice or if you wish to exercise any of your legal rights as set out herein, please contact us at email@example.com.