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.

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

WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION

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.

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

[email protected]
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
[email protected]

You may also contact our Data Protection Officer: [email protected]