Privacy Policy

18 Feb 2022

PRIVACY POLICY – MEDISAFE PROJECT

UPDATED February 18, 2022

We have the highest regard for your privacy and personal information and realize that the success of our services depends on the trust that you have in the way we handle your personal information. By entrusting us with your information, we would like to assure you of our commitment to keep such information private. We have taken considerable steps to protect the confidentiality, security and integrity of this information. We encourage you to review the following information carefully.

This Privacy Policy applies to your use of the Medisafe mobile device applications (including the Medisafe App and Medisafe Maestro Link; collectively the “Apps”) and related websites located at www.medisafe.com and www.medisafeapp.com (including their mobile-optimized versions, collectively the “Site”) owned by Medisafe Project Ltd. (“we” or “us”). The Apps and the Site are referred to together as the “Service”. “You” refers to any user of the Service.

This policy sets out our commitments and explains the rights that you have with respect to your personal information. We may update this Privacy Policy from time to time. Any changes will be effective immediately upon the posting of the revised Privacy Policy. We encourage you to periodically review this Privacy Policy for the latest information on our privacy practices. If you do not agree to the terms of this Privacy Policy, please do not use the Service.

GROUNDS FOR DATA COLLECTION

When you use our Service, you consent to the collection, storage, use, disclosure and other uses of your personal information as described in this Privacy Policy.

Processing of your Personal Information (meaning, any information which may potentially allow your identification with reasonable means; hereinafter “Personal Information”) is necessary for the performance of our contractual obligations towards you and providing you with our Service, to protect our legitimate interests, to ensure compliance with legal and financial regulatory obligations, or otherwise, subject to your consent.

HOW DO WE RECEIVE INFORMATION ABOUT YOU

While you may use some of the functionality of the Service without creating a profile or registration, certain tools of the Service require registration and provision of your information, including Personal Information.

  • If you use the Service without creating a profile or registering – we will only collect information through the use of cookies, web beacons, device data, and navigational data collection, as well as any voluntary information you provide us, including Health Information (as defined below). While we cannot directly identify you through such data, in some jurisdictions, this information is still subject to applicable data protection laws and requires your consent as described below.
  • If you choose to create a profile or register with us – you will be asked to provide Personal Information which will be associated with your Health information.
  • Whenever you submit information via our Service – including, but not limited to, by telephone or email with customer service, we may collect Health Information and other Personal Information you provide us, in order to provide you with our Service.
  • Third parties – we may receive information about you from our partners, such as pharmaceutical companies and medical providers as needed in order to provide you with our Service, and from other third parties in the context of our marketing activities, as further described in this policy.

It is your voluntary decision whether to provide us with any Personal Information or Health Information, however if you do not provide this information you may not be able to create a profile or register with the Service and your use of the Service may be limited.

WHAT TYPES OF INFORMATION DO WE COLLECT

Personal Information

We may collect the following Personal Information about you:

Contact Information – your name, gender, birth date, email address, home address and/or office address, phone number and optionally, zip code.

Caregiver or Medfriend Information – If you opt to use the Caregiver or Medfriend features of the Apps, we will also receive the contact information (such as name, phone number, address and email) of the Caregiver or Medfriend that you chose to appoint and provide us with their information.

Additional information – while you are using our Apps, subject to your permission, we may obtain access to your contact list and to your calendar. In addition, if you choose to make use of the skin tracker, you will be required to grant us access to your camera and to the photos saved on your device.

If you are a healthcare provider – you may be asked to provide information regarding your professional qualifications as well as additional Personal Information.

Voluntary information – when you communicate with us (for example when you send us an email or use a “contact us” form) we collect your email address, and the Personal Information you provided us with within such communication.

Technical information – we collect certain technical information that is automatically recorded when you use our Service, such as your IP address and device geo-location.

Background geo-location – please note that certain features of our Apps (such as medication reminders you have set to display upon your arrival home) requires you to enable background location access on your device.

Personal Health Information – you may choose to use certain features of the Service that will allow you to input other Personal Information with respect to your health, such as the medications you take, the date of your prescriptions, the number of refills you have made, how often you take your medication, dosage, physical measurements your doctor’s name, information related to your health insurance, and the name of your pharmacy (collectively your “Health Information”).

Non-Personal Information

Site:

Site usage data – We collect information about your use of the Site, including but not limited to: type of computing or mobile device you use, language of your operating system, the Internet browser you are using, geo-location and use of the Site.

Health Information – We may also collect your non-identifiable Health Information if you choose to provide it (in case of non-registered users)

Apps:

Installation ID – When you download and install our App onto a mobile device, we assign a random number to your App installation. We do not use this number to identify you personally unless you choose to become a registered user of the App. We use this random number in a manner similar to our use of cookies as described in this Privacy Policy. Because the random number is assigned to your installation of the App itself, it cannot be removed through the settings of your App or your device. If you do not want us to use the random number for the purposes for which we use cookies, please do not install our App.

Technical information – The App automatically collects certain information about you when you use the App, this includes, but not limited to: details of the Wi-Fi you use and accelerometer used on your device, type of computing or mobile device you use, advertiser ID, your device’s operating system, the language of your operating system and the Internet browser you are using. The App may also access a list of installed apps on your device. This is done only to ensure proper quality of service, as some apps might interfere with the App functionality.

TRACKING TECHNOLOGIES – COOKIES

A cookie is a small piece of text that is sent to a visitor’s browser. The browser provides this piece of text to the device of the originating visitor when this visitor returns. We use cookies to help personalize your Medisafe experience. You are free to delete any existing cookies at any time. If you delete or disable cookies from our Site, some parts or functions of the Site may not work properly for you.

A “persistent” cookie may be used to help save your settings and customizations. Also, if you log in to the Site, such a cookie will be used to recognize you as a valid user so you will not need to log in each time you use the Site.

Most Web browsers automatically accept cookies however allow you to modify security settings so you can approve or reject cookies on a case-by-case basis or reject all cookies. You can configure your web browser to remove cookies by following the directions provided in your Internet browser’s “help” section.

We also use “Google Analytics” to collect information about the use of the Service. Google Analytics collects information such as how often users visit the Service, what pages they visit when they do so, and what other sites they used prior to coming to the Service. Google Analytics collects only the IP address assigned to you on the date you use the Service, as well as information regarding your operating system, language and information regarding your use of the Service, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with Personal Information. We use the information we get from Google Analytics only to improve the Service. Google’s ability to use and share information collected by Google Analytics about your use of the Service is restricted by the Google Analytics Terms of Use located here and the Google Privacy Policy located here.

HOW DO WE USE THE INFORMATION WE COLLECT

  • Provision of service – we use the Personal Information you provide us for the provision and improvement of our Service to you, operate our business, and provide information that you request form us. For example, data collected automatically on the Service may be used to help diagnose problems with our servers, to make our Service more useful, to customize it and personalize its content for you (for example, we will use your Health information to send you reminders to take your medications).
  • General communication – we also use your Personal Information to send you texts, emails or other communications regarding general adherence information, Service maintenance and other technical support, updates, or changes to this Privacy Policy or any other relevant agreements, and to respond to your inquiries.
  • Marketing purposes – subject to your marketing preferences, we may use your Personal Information (such as your email address or phone number) to communicate with you. We may also send you promotional material concerning our services or our partners’ services (which we believe may interest you), including but not limited to, by building an automated profile based on your Personal Information, for marketing purposes.
    • Opt-out of receiving marketing materials – If you do not want us to use or share your Personal Information for marketing purposes, you may opt-out by contacting us in accordance with this Privacy Policy, by clicking the “unsubscribe” button included in every marketing communication you receive from us, or with respect to tracking technologies, by using the cookie preferences menu displayed on our Site. Please note that even if you opt-out, we may still use and share your Personal Information with third parties for non-marketing purposes (for example to fulfill your requests, communicate with you and respond to your inquiries, etc.).
  • Analytics, surveys and research – we are always trying to improve our services and think of new and exciting features for our users. From time to time, we may conduct surveys or test features, and analyze the information we have to develop, evaluate and improve these features.
  • Protecting our interests – we may use your Personal Information when we believe it’s necessary in order to take precautions against liabilities, investigate and defend ourselves against any third party claims or allegations, investigate and protect ourselves from fraud, protect the security or integrity of our Service and protect the rights and property of Medisafe, its users and/or partners.
  • Enforcing of policies – we may use your Personal Information in order to enforce our policies, including but limited to this Privacy Policy, the Terms and Conditions and/or any applicable Program terms and policies.
  • Compliance with legal and regulatory requirements – we also use your Personal Information as required by law, regulation or other governmental authority, or to comply with a subpoena or similar legal process.

WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION

  • Research partners – we may share your Personal Information with third parties, such as research institutes, healthcare systems and healthcare providers. They may associate it with other information that they have about you, for improved healthcare, research purposes and the improvement of our Service.
  • Providers of personalized third party content – from time to time, we may also ask whether you would like us to share your Personal Information with another company that may want to send you information about their products or services. If you consent to such transfer by us of your Personal Information to another company, please note that the information provided will be subject to such company’s privacy practices and shall not be within our control.
  • Content providers – we may also use your Personal Information in order to provide you with personalized third party content or links to third party sites that might interest you. We provide this third party content and/or links to third party sites for information purposes only and are not liable for such content or sites. For more information see the “Links to other Websites or Apps” section below.
  • Third Party Health Apps – we participate in Apple HealthKit, Samsung S-Health and Google Fit frameworks. We will use information that you consent that we receive from those third party health apps for medical research purposes, internally in order to improve our products and services and in the form of aggregated and/or analytical data as described in the Use of Aggregated Data section of the Privacy Policy, and may transfer this data to third parties for such purposes. We may provide users with the ability to share their Medisafe data with other authorized services on their device after receiving their consent for the same. We will not sell any Personal Information nor will we use this data for advertising purposes. Please note that when you share information with third party apps, such information will be subject to their privacy policy, over which we have no control. In order to learn more, please visit each of AppleSamsung, or Google’s relevant pages and their respective privacy policies.
  • Service providers – we may share your Personal Information, as is reasonably necessary, with our service providers, including vendors and suppliers that provide us with development services, technology (such as AWS), services, or content for the operation, development and maintenance of our Service or data and analysis on Service use, who are bound by an obligation of confidentiality, provided that we will only share Personal Information to the extent necessary with such service providers.
  • Law authorities – we may share your personal data with law enforcement authorities, courts and tribunals, including with legal advisors and consultants, in case we need to respond to law enforcement requests or other legal requests or pursuant to a requirement imposed by law, order, judgment or decree, or courts in order to protect and defend our rights and property or those of Service users.
  • Merger, acquisition or sale – we may transfer your Personal Information in the event of a merger, acquisition or sale of all or a portion of our assets.

Medisafe may offer you, from time to time and at our sole discretion, participation in customized programs, based on specified criteria (“Programs”). Participation in Programs may require sharing of Personal Information from and with additional third parties. If you choose to participate, you will be provided with additional information and  consent requests for such sharing. Review the Programs terms and conditions for additional information.

Your Personal Information will not be combined with other information and will not be used for other purposes, except as explained in this Privacy policy. Please note that we are not subject to medical secrecy obligations.

  • Personal Information you may share through our Service
    • Medfriend and Caregivers –
      • If you use the Services on your own behalf: You may send family members or friends an invitation to be your “Medfriend” or “Caregiver” by means of the Service, so that such person will receive alerts regarding your compliance with your medication regime. At your decision, your chosen Caregivers may also receive permissions to edit your information on the Services. By sending such invitation and granting such permissions, you represent that you have the right to appoint and provide the information of such person; that you consent to our disclosure of Personal Information about your medications and your compliance with your medication regime to such person; and, as applicable, that you allow your Caregiver to make changes to the Services including to your personal information, on your behalf. Sharing of your Personal Information and providing the editing permissions in this manner are solely at your responsibility.
      • If you use the Services on behalf of your child or an incapacitated person, you shall be considered such person’s “Medfriend” or “Caregiver”, as applicable. In such event, you represent and warrant that you have the legal authority to act on behalf of that person; that you will keep confidential and only use the Personal Information made available to you through the Services for the purpose for which it was made available to you; that any permission and personal information provided to you through the Services will be used with due care and only for that person’s own good and best interests.
    • Medical professionals and Doctors – You may use the Service in order to share your Personal Information or other information with your doctor or healthcare providers. Such sharing may be enabled by inviting your healthcare provider to monitor your Personal Information, by accepting an invitation from your healthcare provider to download and use the Service, or otherwise using the Service settings to share your information with your healthcare provider; in these cases you consent to our sending Personal Information about your medications and your compliance with your medication regime with your healthcare providers. Confirm with your healthcare provider that they have sent you an invitation to use the Service. Such sharing of your information is at your discretion and is solely your responsibility.
    • Pharmacies and coupon companies – you may choose to share your Personal Information with pharmacies with which we partner or third party coupon companies, so that we may send you coupons or provide you with reminders to get your prescription refilled. If you choose to share your Personal Information in this manner, please note that such information may be disclosed to the coupon companies or pharmacies and will be subject to their privacy practices.

While we take great care to keep your Personal Information confidential and secure, when you share your health or medication information with others or provide feedback regarding health matters, medications and otherwise, including by means of social media sites, or when you participate in a forum on the Service, any information disclosed by you in such way is solely your responsibility. You should exercise caution when disclosing any information (including Personal Information) in such ways, as you do not know who will access or use such information and for what purposes.

USE OF AGGREGATED DATA

We may de-identify and aggregate Personal Information; aggregated data will not contain any information that could be used to contact or identify you. We may analyze and/or combine all information we receive, including Health Information and information regarding your use of the Service, with information from other users to create aggregated data that may be disclosed to and utilized by us, our partners and by third parties without restriction, on commercial terms that we can determine in our sole discretion, for purposes such as: content marketing, research purposes, in order to understand behavior patterns, in order to increase adherence to medication regimens, marketing strategies and for entering into commercial contracts in order to provide our users with the Service. As an exception to the above, we will not include data received via Apple HealthKit in the aggregated data we share with and/or sell to third parties or for marketing purposes.

INTERNATIONAL TRANSFERS

Personal Information may be transferred to and maintained on computers and servers located outside of your state, province, country, or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you are located outside of the United States, please note that data we collect about you may be transferred to, processed and stored in the United States unless otherwise noted. If you reside in the UK or the EU, please note that some of our service providers may be located outside the European Economic Area (the “EEA”). In such cases we will transfer your data only to such countries as approved by the European Commission as providing adequate level of data protection, or enter into legal agreements ensuring an adequate level of data protection in accordance with the instructions of the EU commission as updated from time to time.

We may transfer our databases containing your Personal Information in connection with the transfer or sale of all (or substantially all) of our business assets, or in the event of a merger, consolidation or similar transaction.

USER RIGHTS

Data protection laws in certain jurisdictions provide individuals with certain statutory rights with respect to their Personal Information.

For example, if you reside in the UK or the EU, you may have the right to request to: (a) receive confirmation as to whether or not Personal Information concerning you is being processed, and access your stored Personal Information, together with supplementary information; (b) receive a copy of Personal Information you directly volunteer to us in a structured, commonly used and machine-readable format; (c) request rectification of your Personal Information that is in our control; (d) request erasure of your Personal Information; (e) object to the processing of Personal Information by us; (f) request to restrict processing of your Personal Information by us; and (g) lodge a complaint with a supervisory authority if you believe your privacy rights have been prejudiced by us.

Data subjects residing in other jurisdictions may also be afforded with certain rights with respect to their personal data, as determined by such jurisdictions’ applicable laws. Such rights maybe similar or may differ from those set out above with respect to EU residents.

We comply with applicable laws and respect the privacy rights of our users. If you wish to exercise any of your rights, or ask us a question, please contact us by using the contact details provided below.

However, please note that these rights are not absolute, and may be subject to our own legitimate interests and regulatory requirements.

RETENTION

We will retain your Personal Information for as long as necessary to provide the Services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our policies. Retention periods will be determined taking into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation.

LINKS TO OTHER WEBSITES OR APPS

Our Service may link to or refer to third party websites or services that we do not own or control. Any Personal Information you provide is provided directly to such third party and is subject to such third party’s provider’s privacy policy. This Privacy Policy does not apply to such other websites or services, and we are not responsible for the privacy practices or content of any websites or services not controlled by us, nor are we responsible for such third party’s use or misuse of your Personal Information. If you have any concerns, we urge you to review the terms of those other websites or services for more information about their applicable policies.

HOW WE PROTECT YOUR INFORMATION

We have implemented administrative, technical, and physical safeguards to help prevent unauthorized access, use, or disclosure of your Personal Information. Your information is stored on secure servers and isn’t publicly available. We limit access of your information only to those employees or partners that need to know the information in order to enable the carrying out of the agreement between us.

While we seek to protect your information to ensure that it is kept confidential, no security system is infallible and impervious, and we cannot absolutely guarantee its security. You should be aware that there is always some risk involved in transmitting information over the internet. While we strive to protect your Personal Information, we cannot ensure or warrant the security and privacy of your Personal Information or other content you transmit using the Service, and you do so at your own risk.

You need to help us prevent unauthorized access to your account by protecting your password appropriately and limiting access to your account (for example, by signing off after you have finished accessing your account). You will be solely responsible for keeping your password confidential and for all use of your password and your account, including any unauthorized use.

CHILDREN

Our Service is intended for use by persons over the age of majority (as determined by applicable laws where such persons reside in: “Age of Majority”), unless we are provided with a valid parental or guardianship approval and consent, in accordance with the requirements of applicable laws. Under no circumstances should the Service be used by persons under the Age of Majority. We will not knowingly collect Personal Information from any person under the Age of Majority unless as described herein, and at our sole discretion. If you discover that a child has been using the Service without your consent, or that someone has been using the Service for or on behalf of your child without your consent, please contact us using the information below under “How to Contact Us” and we will take reasonable steps to delete the child’s information from our active databases. Medisafe reserves the right to check its user base from time to time and remove users whom Medisafe has grounds to believe they are in fact minors, including without limitation, restricting those user accounts, or deleting them, as Medisafe may deem appropriate.

HOW TO CONTACT US

If you have any questions, comments, requests, or concerns related to this Privacy Policy or the privacy practices of our Service, please contact us at:

 

MEDISAFE

info@Medisafe.com
117 Kendrick St. ,Suite 300, Needham, MA 02494

ATTN: Medisafe Project Ltd.
Building #41, Ha’atzmaut, Haifa 3303321, Israel

 

MEDISAFE UK
115 Mare St., London E8 4RU, UK
EU-info@Medisafe.com

You may also contact our Data Protection Officer: DPO@medisafe.com

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