UVTAL Health Ltd. (“YuviTal”, “Us” or “We”), respects its users’ privacy and is committed to protecting the personal information that you share with Us. We need your personal information to provide the services that you request (the “Services”). This policy describes how we collect, store, process, disclose, transfer and use your personal information and for what purposes.
We are required by applicable data protection Law to: make sure that Personal Identifiable Information (PII) and electronic Protected Health Information (ePHI) that identify you is kept private; give you this notice of our legal duties and privacy practices with respect to PII and ePHI about You; follow the terms of the notice that is currently in effect and notify You following a breach of unsecured ePHI and PII.
The Information We Collect and How We Collect and Use Information
Personal Data that we might collect, store, process, disclose transfer and use are: any information that may be used to identify an individual, including, but not limited to, full name, a company or other entity to which you are affiliated, occupation and industry, contact information, physical addresses, birth date, title, reviews, feedbacks, activity record, steps record, sleep records, etc. and any information provided by you via your use of the Services or when you interact with Us, and other information when needed for the purpose of providing the Services, for our internal records and analysis purposes and for research and developments, excluding any publicly available information lawfully made available from government records, de identified or aggregated consumer information, or information excluded from the California Consumer Privacy Act (the “CCPA”).
What Personal Information We Collect, How We Collect It and Why
The purposes of Our collection and processing of information in the context of the YuviTal’s website are:
- To offer Our services and/or products to users of the YuviTal’s website and any potential customers.
- To provide Our services and/or products to Our customers.
- To address users’ applications, inquiries, questions, requests, comments, responses, etc.
- For development and Customer Service. For example, to provide customer service and support or assist in protecting and securing our systems and services our development and customer service team may require access to Personal Information. In such cases, our personnel must abide by our data privacy and security requirements and policy and are not allowed to use Personal Information for any other purpose.
- To discuss and consider business interactions and proposals of any kind.
- To study the users’ interaction with the YuviTal’s website and/or to study the behavior of users in the context of such use, for the purpose of assessing the YuviTal’s website performance and/or effectiveness.
- To provide the Services and operate our business, We may use the Personal Data for processing and analyzing purposes.
- To protect the security of the Site and Services, to detect and prevent cyberattacks, fraud, phishing, identity theft, and data leaks, to verify genuine software licenses, to resolve disputes, and to enforce our agreements.
- To, for example, respond to a subpoena or request from law enforcement, a court or a government agency (including in response to public authorities to meet national security or law enforcement requirements), or in the good faith belief that such action is necessary to (a) comply with a legal obligation, (b) protect or defend our rights, interests or property or that of third parties, (c) prevent or investigate possible wrongdoing in connection with the Services, (d) act in urgent circumstances to protect the personal safety of users of the Site and Services or the public, or (e) protect against legal liability.
Legal Basis for Processing
Our collection and processing of personal information is based on the following:
- Need to carry out the above processing of information, which is in anticipation of entering into engagements or as part of the performance of existing engagements with you or the organization you work for, for example for providing the Services or for the purpose of customer support and inquiries.
- To the extent that we use personal information for analyzing statistics, the basis for collection of data is our legitimate interest to conduct such improvements and analysis.
Information Sharing and Disclosure
We may share your personal information with other companies or people under any of the following circumstances:
- When we have your consent to share the information;
- We need to send the information to third parties who work on behalf of YuviTal or with YuviTal to provide a product or service (we will only provide those companies the information they need to for the Services, and they are prohibited from using that information for any other purpose);
- In the event of sale or transfer of all or substantially all of YuviTal or any YuviTal affiliate’s shares or assets, in cases of mergers or in case of negotiations with respect to the foregoing;
- Where needed for corporate audits or to investigate or respond to a complaint or security threat, to prevent illegal uses of our services, to defend ourselves against third party claims and assist in fraud prevention or investigation; and/or
- We will also disclose your personal information if required to do so by law, or in urgent circumstances, to protect personal safety, the public or our website.
- In order to provide the Services and operate our business, We may use the Personal Data for processing and analyzing purposes.
- If you provide Personal Data for a specific purpose, We may use said Personal Information in connection with the purpose for which it was provided. For instance, if you contact Us by email, we will use the Personal Information you provide to answer your question or resolve your problem and will respond to the email address used to contact Us.
- We may use any Personal Information you provide us with to generate statistical reports containing aggregated information.
- We may need to share Personal Information with our cloud service. For example, to assist in protecting and securing the website or Services the cloud service admin may need access to Personal Information to provide those functions. In such cases, the cloud service provider must abide by our data privacy and security requirements and is not allowed to use Personal Information they receive from us for any other purpose.
YuviTal will use and transfer information received from Google APIs to any other app in accordance with Google API Services User Data Policy, which includes the obligations of Limited Use. This will happen only if explicit consent is provided to utilize the information for marketing purposes.
IF YOU RECEIVE DIRECT MARKETING BY MISTAKE OR WITHOUT YOUR SPECIFIC CONSENT AND/OR YOU WISH TO OPT-OUT, YOU ARE REQUIRED TO CONTACT US AT [email protected].
We will not sell or otherwise transfer the personally identifiable information you provide to Us at our Websites to any third parties for their own direct marketing use unless we provide clear notice to you and obtain your explicit consent for your data to be shared in this manner.
For the above purposes, personal information may be transferred to recipients in countries around the world (which may be located outside the EU/EEA, European Economic Area) which in some cases may have a lower level of protection than that within the EU/EEA. When transferring personal data to countries outside the EU/EEA, to jurisdictions that did not receive an adequacy decision by the European Commission, we use standard contractual clauses approved by the European Commission to ensure a sufficient level of protection for your personal information. The standard contractual clauses can be found via the following link: http://ec.europa.eu/justice/data-protection/international-transfers/transfer/index_en.htm.
We do not knowingly collect Personal Data from children under 14 without the specific written consent of a parent/legal guardian. If your child is under the age of 14, and you become aware that your child has provided Us with Personal Data, without your consent, then please contact us using the details below so that we can take steps to remove such information and terminate any account your child has created with Us. As the child’s parent/legal guardian, please be advised that:
o We will not require a child to disclose more information than is reasonably necessary to participate in an activity;
o You can review your child’s Personal Data, direct Us to delete it, and refuse to allow any further
collection or use of the child’s information;
o You can agree to the collection and use of your child’s information, but still not allow disclosure to third parties that are not part of the service providers; and
o If you wish to exercise any of your rights, please contact us at: [email protected] .
YuviTal stores the personal information as long as it is necessary to fulfill the purpose for which the data has been collected. This means that YuviTal deletes your personal information when such information is no longer necessary, unless we have a legitimate interest to retain such data for longer periods or are required to do so by any applicable law. Statistics which have been anonymised may be saved thereafter.
Data Subject Rights
In some circumstances, the user has the right to obtain (i) confirmation of whether, and where, we are processing your Personal Data; (ii) information about the categories of Personal Data we are processing, the purposes for which we process your Personal Data and information as to how we determine retention periods; (iii) information about the categories of recipients with whom we may share your Personal Data; and (iv) a copy of the Personal Data we hold about you.
You may at any time request the rectification or erasure of your personal information. Please note however that deletion could mean that YuviTal cannot provide you any requested services. You have the right to request a copy of your personal information from our record. You have the right to request a limitation of the use of your personal information (for example if you deem the information to be incorrect) or the termination of use of your personal information (for example as regards the use of the information to improve our services).
You have the right, in certain circumstances, to receive a copy of the Personal Data in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of your Personal Data to another person.
If you wish to do so, you can send Us an email with your request to: [email protected] and We will make reasonable efforts to fulfill your request within a reasonable period of time and no more than 30 days of its receipt, and pursuant to any applicable privacy laws If we require more time, we will inform you of the reason and extension period in writing. We will deliver our written response via email. The response we provide will also explain the reasons we cannot comply with a request, if applicable.
Note that unless you instruct Us otherwise, We may retain and use your Personal Information for as long as reasonably required for the purposes of which such Personal Information was collected, including without limitation, for future analytics and analysis, comply with Our legal or business requirements or obligations, to resolve disputes, to enforce Our Terms of Service, all as permitted under any applicable privacy laws. Notwithstanding the foregoing, Personal Information may be kept by Us for a period exceeding that if it is required to do so to satisfy any applicable law, regulation, legal process, subpoena or governmental request.
Rights of California Residents
Right to Access Personal Information Collected, Disclosed or Sold:
You have the right to ask Us to disclose to you certain information regarding our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (as described below), we will disclose to you:
- The categories of personal information we sold about you;
- The categories of personal information we disclosed about you;
- The categories of sources for the personal information we collected about you;
- Our business or commercial purpose for collecting or selling that personal information;
- The categories of third parties with whom we shared that personal information;
- The specific pieces of personal information we collected about you; and/or
- If we sold or disclosed your personal information for a “business or commercial purpose”, as defined in the CCPA, lists of sales, identifying the categories of personal information that each category of recipient purchased or obtained.
Right to Request Deletion of Personal Information
You have the right to request that we delete any of your Personal Information that we collected from you, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete, and direct our service providers to delete, your Personal Information from our records, unless an exception applies.
We may deny your request to delete your Personal Information if retaining the information is necessary for Us or our service providers to:
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;
- Debug or identify and repair errors that impair existing intended functionality;
- Exercise free speech, ensure the right of another consumer to exercise that consumer’s right of free speech, or exercise another right provided for by law;
- Comply with the California Electronic Communications Privacy Act;
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, if you have provided informed consent;
- Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with Us;
- Comply with a legal obligation; and/or
- Make other internal and lawful uses of the Personal Information that are compatible with the context in which you provided such information
Right to Non-Discrimination
We will not discriminate against you for exercising any of your rights under the CCPA. Unless permitted by the CCPA, we will not:
- Deny you goods or services;
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
- Provide you a different level or quality of goods or services; or
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
Right to Opt-out of the Sale of Personal Data
You have the right to opt-out of the sale of personal data we have collected about you.
Within the past 12 months, we have disclosed to the following third parties your personal information:
- Service providers; and/or
- Third parties to which you authorized Us to disclose personal information in connection with products or services provided to you.
California Shine the Light Law
California Civil Code Section 1798.83 permits our visitors who are California residents to request certain information regarding our disclosure of personal data to third parties for their direct marketing purposes. To make such a request, please contact [email protected].
Your Rights Regarding PHI
THIS POLICY DESCRIBES HOW PHI MAY BE USED AND DISCLOSED AND HOW YOU CAN EXERCISE YOUR RIGHTS REGARDING THIS INFORMATION. PLEASE REVIEW IT CAREFULLY::
You have the following rights regarding the PHI we maintain about you:
Right to Amend
If you feel that PHI, we have about you is incorrect or incomplete, you may ask us to amend the information. You have the right to request an amendment for as long as the information is kept by or for YuviTal. To request an amendment, your request must be made in writing and submitted to Noah Mozes St 1, Rishon LeTsiyon, Israel. In addition, you must provide a reason that supports your request. We may deny your request for an amendment if it is not in writing or does not include a reason to support the request. In addition, we may deny your request if you ask us to amend information that: (a) was not created by Us, unless the person or entity that created the information is no longer available to make the amendment; (b) is not part of the PHI kept by or for Us; (c) is not part of the information which you would be permitted to inspect and copy; (d) is accurate and complete or (e) You are not the owner or its legal authorized representative of the information .
Right to Request Restrictions
You have the right to request a restriction or limitation on our use or disclosure of information about you for treatment, payment or healthcare operations. You also have the right to request a limit on the information we disclose about you to someone who is involved in your care or the payment for your care, like a family member or friend.
Right to Request Confidential Communications
We will communicate with you only through your contact details that you provided us with the registration process, e.g., your provided email address.
Right to a Paper Copy of This Notice
You have the right to a paper copy of this notice. You may obtain a copy of this notice at our website, yuvital.com/ , or download this document.
If you believe your privacy rights have been violated, you may file a complaint with Us or with the Secretary of the U.S. Department of Health and Human Services. To file a complaint with Us, contact [email protected] . All complaints must be submitted in writing. You will not be penalized for filing a complaint.
OTHER USES OF PHI
Other uses and disclosures of information not covered by this policy or the laws that apply to Us will be made only with your written permission.. If you provide Us permission to use or disclose information about you, you may revoke that permission, in writing, at any time. If you revoke your permission, we will no longer use or disclose information about you for the reasons covered by your written authorization. You understand that we are unable to take back any disclosures we have already made with your permission, and that we are required to retain our records of the Services that we provided to you.
YuviTal safeguards the security of the data you send Us with physical, electronic, and managerial procedures, taking into consideration the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of processing your personal information. YuviTal complies with the GDPR and HIPAA and is ISO 27001, 27799 certified. While we strive to protect your personal information, we cannot ensure the security of the information you transmit to Us, and so we urge you to take every precaution to protect your personal data when you are on the Internet.
Once you print, download, or save to file any portion of your personal information from our Platform, YuviTal is no longer able to protect that information from further uses and/or disclosures and is not liable for any further uses and/or disclosures of that information. You understand and agree that you are responsible for all further actions or omissions related to the security and privacy of that information.
Please keep in mind that whenever you voluntarily disclose information about yourself in the public domain, for example, through social media, bulletin boards, chat rooms or e-mails, it is likely to be collected and used by third parties. These third parties may use your information to contact you or for unauthorized purposes. Also, please remember that no one can guarantee the absolute security of information transmitted electronically.
If you have any questions about security on the Services, you can contact us at [email protected] .
YuviTal will amend this policy from time to time. If we make any substantial changes in the way we use your personal information we will make that information available by posting a notice on this site. Revised copies of this notice will be provided upon request.
At all times, you may choose whether to provide or disclose Personal Information. If you choose not to provide mandatory by law and/or necessary data to provide the services, you will not be able to use the Services. Privacy Inquiries
YuviTal is responsible for the processing of your personal data, and requests to exercise your rights as stated above shall be addressed to [email protected]
If you are a resident of the EU/EEA and have a complaint regarding the processing of your personal data by YuviTal you are entitled to report such dissatisfaction to the applicable supervisory authority in your country of residence.
Our representative in the European Union is AI Tech&Reg. You may contact our representative at:
Address: Sofia City 1463, Triaditza district, 66 Vitosha blvd. floor 4.
Email: [email protected]
LAST UPDATE: January 2023