Privacy and Cookie Policy

Last updated: May 10, 2020

 

Preface

PulmOne Advanced Medical Devices Ltd. (“PulmOne”,”us”, “we”, or “our”) operates the www.pulm-one.com website and any service included therein (hereinafter referred to as the “Website”).

This Privacy and Cookie Policy (the “Policy”) covers the Website and informs you of our policies regarding the collection, use and disclosure of personal data when you use our Website.

Information about the responsible party, the data controller (referred to as the “controller” in the GDPR):
PulmOne Advanced Medical Devices Ltd., having its registered office address at 14 Hamelacha St., Ra’ananna 4366107 Israel
Email: [email protected]

By accessing and using the Website, you agree to the collection and use of information in accordance with this policy.

For the purpose of this Policy, Personal Data means any information that can be used to identify, locate or contact an individual.

 

General

PulmOne is the data controller, as these term is defined under the EU General Data Protection Regulation (“GDPR”), of the Personal Data collected via the Website.

 

Personal Data Collection

We collect via the Website the following types of Personal Data:

    • Contact details you voluntarily provide to us via the “contact us” page or via the customer portal: such data may include full name, email address, phone number, location (address) and the message filled-in by you via the “contact us” page.
    • Details you provide to us via the “customer portal” page: if you wish to order any product or services via the customer portal, you will provide via the portal, your (or your business) payment details for the transaction and your (or your business) address and contact details the for delivery of the purchased product.
    • Data collected via automated means – we may collect via cookies and automated means, details of your use of the Website and visits to the Website including traffic data, location data, IP and log-in information, language, communication data, and the resources of user’s access from. For further details please read the cookie clause below.
    • Data minimizationwe request our Customers and Users to use the Website only for the intended purpose, and to avoid uploading excessive Personal Data to the Website.
      • We may also collect non-personal data which consists of technical information and aggregated usage information, and may contain, among other things, the user’s operating system, type of browser, screen resolution, browser and keyboard language, etc. Non-Personal Information may be gathered by us in order to examine the users’ interactions with the Website. For the avoidance of doubt, any non-personal data connected or linked to any Personal Data shall be deemed as Personal Data as long as such connection or linkage exists.

 

Use of Personal Data

We may use your Personal Data in the following ways:

    • To interact with our Users and provide customer service – if you approach us via the “contact us” page, we will use your contact details to reply to your message or to contact you by a sales representative.
    • To allow log-in to our customer portal.
    • To take and handle your orders, deliver products and services, process payments, and communicate with you about orders, products and services.
    • To gather analysis or valuable information collected automatically so that we can improve our Website, monitor the usage of our Website, and detect, prevent and address technical issues and fraudulent or illegal activity.
    • To provide you with personalized advertising and marketing communications.
    • Subject to your consent, we may send you newsletters, marketing or promotional materials, sales offer, product updates and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or the instructions provided in any email we send or by contacting us: [email protected].

 

Legal Basis for Processing

If you are from the European Economic Area (EEA), PulmOne’s legal basis for collecting and using personal data under the GDPR, are as follows:

    • Consent;
    • Performing a contract with our customer (Accessing the Customer Portal, providing customer’s orders)
    • Where we have a legitimate interest, e.g. managing our business, or defending ourselves from claims, subject to such processing not overriding your own rights and freedoms.

 

Disclosure of Personal Data

We may disclose Personal Data to third parties only in the following cases:

    • When we use a cloud computing service provider for the storage of data;
    • When we use third party service providers that are required for the performance of our business, and who are bound by law or contract to protect the Personal Data and only use it in accordance with our instructions; for example – third party provider of products you ordered; service providers for delivering your orders to your address; service provider for sending email notifications, for analytics purposes etc.;
    • If we are under a duty to disclose or share Personal Data in order to comply with any legal obligation, such as in response to a subpoena, including to law enforcement agencies and courts;
    • We may also disclose Personal Data where needed to affect the sale or transfer of business assets, to enforce our rights, protect our property, or protect the rights, property or safety of others, or as needed to support external auditing, compliance and corporate governance functions.

 

Cookie Policy

Cookies are small data files that are stored on an Internet user’s computer by a web server. Cookies contain user information such as login ID and allow us to recognize your browser preferences. Cookies help us to deliver certain functionalities to you and to guarantee the best user experience possible.

When you visit our Website, we may use cookies and similar technologies for the following purposes:

    • To help us recognize you as a unique visitor (just a number) when you return to our Website.
    • To compile anonymous, aggregated statistics that allow us to understand how users interact with our Website.
    • To help us improve the structure of our Website.
    • To protect the security of our Website.

We also use 3rd party remarketing cookies, Google Analytics cookies and Facebook pixel. To see an overview of privacy at Google and how this applies to Google Analytics, visit https://www.google.com/policies/privacy/. You may opt out of tracking by Google Analytics by installing the Google Analytics opt-out browser add-on at https://tools.google.com/dlpage/gaoptout. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing information with Google Analytics about visits activity.

Similarly, you can opt out of Google’s use of cookies by visiting Google’s Ads Settings. You can use your browser settings to withdraw your consent to our use of cookies at any time and delete cookies that have already been set.

The website www.allaboutcookies.org contains comprehensive information about the process of opting out on different browsers.

Note that by disabling certain categories of cookies you may be prevented from accessing some features of our website, or certain content or functionality may not be available.

 

Retention of Data

PulmOne will retain your Personal Data only for as long as is necessary for the purposes set out in this Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes and enforce our legal agreements and policies.

PulmOne will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer periods.

 

Transfer of Data

Your Personal Data, may be transferred to — and maintained on — computers located outside of your country, where the data protection laws may differ from those of your jurisdiction.

If you are located outside Israel and choose to provide information to us, please note that we may transfer the data, including Personal Data, to Israel and/or to the US, and process it there.

PulmOne will take all the steps reasonably necessary to ensure that your data is treated in accordance with this Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data, including through adequate contractual means.

 

Security of Data

The security of your data is important to us but remember that no method of transmission over the Internet is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

 

Our Policy on “Do Not Track” Signals under the California Online Protection Act (COPPA)

We do not support Do Not Track (“DNT”). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.

You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

 

Your Data Protection Rights under the General Data Protection Regulation (GDPR)

If you are a resident of the European Economic Area (EEA), you have certain data protection rights. These rights may include the following, depending on the circumstances: right to access data, right to rectify data, right to object to processing, right to erase data, right to data portability. In addition, you have the right to lodge a complaint with a supervisory authority.

You also have the right to withdraw consent from receiving promotional and other newsletters at any time.

If you wish to exercise any of your rights, please contact us: [email protected].

Please note that we may ask you to verify your identity before responding to such requests.

 

Service Providers

We may employ third party service providers to facilitate our Website and Service. These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

 

Analytics

We may use third-party Service Providers to monitor and analyze the use of our Service.

Google Analytics

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network. For more information on Google Analytics and opting-out, see “Cookie Policy” above.

For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en.

 

Behavioral Remarketing

PulmOne uses remarketing services to advertise on third party websites to you after you visited our Service. We and our third-party vendors use cookies to inform, optimize and serve ads based on your past visits to our Service.

 

Links to Other Sites

Our Website may contain links to other sites that are not operated by us. If you click a third party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy and Cookie Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

 

Children’s Privacy

Our Service does not address anyone under the age of 18 (“Children”).

We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.

 

Changes to This Policy

We may update our Privacy and Cookie Policy from time to time. We will notify you of any changes by posting the new Privacy and Cookie Policy on this page.

We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the “effective date” at the top of this Privacy and Cookie Policy.

You are advised to review this Privacy and Cookie Policy periodically for any changes. Changes to this Privacy and Cookie Policy are effective when they are posted on this page.

 

Contact Us

If you have any questions about this Privacy and Cookie Policy, please email us at [email protected].