Last updated: September 23, 2021
SmartBreast Corporation (collectively with its affiliates and subsidiaries shall be referred to as “SmartBreast”, “we”, “us”, or “our”) is committed to your right to privacy. Protecting our users' privacy is a core value of SmartBreast, and we take precautions to ensure the protection of our users' personal data as well as to comply with applicable privacy and data protection legislation.
In the event you are a California resident and the CCPA applies to you – please also review our CCPA Privacy Notice.
- You are not required by law to provide us with any Personal Data. Sharing Personal Data with us is entirely voluntary. However, some of the Company's operations may depend on your providing us with certain Personal Data, as specified below.
- In general we use Personal Data (1) where we have a legitimate interest to do so (for example for website’s security purposes); (2) to perform a contract (for example, to provide you with the support you have requested or respond to your inquiry); (3) where there is a legal obligation imposed on us or to protect our legal rights; and (4) otherwise with your consent to do so.
- Children under the age of 18 are not permitted to use the Website or provide us with any Personal Data.
- You may be entitled under applicable law to request to review, amend, erase or restrict the use of your Personal Data, all as detailed under this Policy.
- We do not sell, trade, or rent users’ Personal Data to third parties. We only share Personal Data for limited circumstances as specified herein.
If you have any comments, questions, or requests regarding the processing of your Personal Data please send us an email to: [email protected].
POLICY CHANGES AND UPDATES
We may update or revise this Policy from time to time. Modifications to this Policy will be posted on the website, and shall be effective as of the date reflected under the “Last Updated” header above. We encourage you to periodically review this Policy to stay informed about our practices related to the collection and use of Personal Data.
Note to California Residents: Notwithstanding the above, as required under the, this Policy will be reviewed and updated at least every 12 months, as required under the CCPA.
WHAT DATA IS COLLECTED AND FOR WHAT PURPOSES?
In the event you access or interact with our website, we collect both Personal and Non-personal data, as follows:
“Personal Data”, means information that identifies or may with reasonable effort identify an individual, including online identifiers, as detailed below.
“Non-Personal Data”, means non-identifiable aggregated data, such as technical data transmitted by the user’s device and aggregated use of the website. This data is not used to identify individuals.
Non-Personal Data Used by Us We collect Non-Personal Data regarding use of the website and the operation of the Company, such as technical and aggregated data about you, such as: type of browsers; type of operation system; type of device; time and date you access the website; users’ navigation and actions in the website; language preference; country level location. Non-Personal Data is used mainly for click stream analysis to provide, maintain, develop and enhance our Website, including among others, to measure and understand the level of engagement with our Website, for general business analytics, for ensuring the technical functioning of our network, to help prevent fraudulent use of the Website, etc.
Personal Data Processed by Us We collect the following Personal Data, and process it in accordance with the purposes and legal basis specified in the table below:
|Type of Personal Data||Purposes of Data Use||For EU Individuals - Legal Basis under the GDPR|
|Contact Details & Contact History If you voluntarily contact us through any means of communication (for example, through a “Contact Us” page in the website, by sending us an email, or any other request or notification) you may be required to provide us with certain information such as your name, organization name and email address||Your contact details and contact history with us will be used to provide you with the support you have requested or to respond to your inquiry.||Performance of a contract and necessity of use for the purposes of our legitimate interests.|
|Online Identifiers We will collect your Internet Protocol (“IP”) addresses. This data might be collected by us, or by our service providers or business partners.||We use this data to maintain, protect and manage the website; improve our Website, as well as enhance your experience while you use our Website; for analytic and statistical purposes regarding traffic flow and users’ interaction with our website; to audit our affiliates, calculate payments and detect fraud, as well as detect and resolve security or technical issues.||Necessity of use for the purposes of our legitimate interests, and your consent, where required under applicable law.|
HOW PERSONAL DATA IS COLLECTED
Certain Personal Data is collected automatically by using cookies and other similar tracking technologies, while you provide other Personal Data voluntarily and actively, for example, when you contact us.
COOKIES & TRACKING TECHNOLOGIES
We may send our Partners an email or other messages about us. We may also send our updates or newsletter to individuals who have registered for the newsletter or are engaged with the Company's operations. You can remove your Personal Data from our mailing list and stop receiving promotional communications from us by emailing us at [email protected]. Please note that in the event you are our Customer, even if you unsubscribe, we reserve the right to send you service-related communications, including service announcements and administrative messages, relating either to your account or to your transactions, without offering you the opportunity to opt out of receiving them unless you terminate and delete your account. If you wish to delete your account, please contact us at: [email protected]. Note that even if we will delete your account, we will not delete certain information required under applicable law or otherwise required for the legitimate purposes of our business. For example, we will not delete any invoices sent to you, as we need them for the purpose of managing our finances.
SHARING DATA WITH THIRD PARTIES
We will not share any Personal Data collected from you with third parties or any of our partners except in the following events:
- Authorized Disclosures. We may disclose your Personal Data to third parties when you consent to a particular disclosure. Please note that once we share your information with a third party, that information becomes subject to the third party’s privacy practices.
- Compelled Disclosures. We will share your information, solely to the extent needed to comply with any applicable law or permitted by it, regulation, legal process or governmental request (e.g., pursuant to law enforcement inquiries, subpoenas or court orders), or when we believe, in good faith, it is required to enforce our policies and agreements, including investigations of potential violations thereof or to detect, prevent, or take action regarding illegal activities or other wrongdoing, suspected fraud, or security issues. In addition, we will share your information solely to the extent needed to establish or exercise our rights to defend against legal claims or to prevent harm to the rights, property, or safety of us, our users, yourself, or any third party, for the purpose of collaborating with law enforcement agencies, or in case we find it necessary to enforce intellectual property or other legal rights.
- Agents / Service Providers. We may disclose Personal Data to our trusted agents and service providers so that they can perform requested services on our behalf (among others, as detailed in the “Cookies and other technologies” Section above). For example, we may share your email address with a third-party service provider in order to assist us with email marketing. These entities are prohibited from using your personal information for any purposes other than providing us with requested services.
- Online Identifiers. We may share Online Identifiers collected by us (as detailed above), for the purpose of operating our business and providing the Website, as well as to calculate payments and detect fraud, security or technical issues in connection with the operation of the Company.
Regarding Non-Personal Data, we may share or aggregate Non-Personal Data with Business Partners and other third parties in accordance with the terms of this Policy. We may store Non-Personal Data and Personal Data on our servers or our cloud servers, use or share Non-Personal Data in any of the above circumstances, as well as for the purpose of providing and improving our Website as detailed above. Furthermore, we reserve the right to use, disclose or transfer (for business purposes or otherwise) aggregated and processed data to third parties, including, inter alia, affiliates, for various purposes including commercial use. This information may be collected, processed and analyzed by us and transferred in a combined, collective, and aggregated manner (i.e., your information is immediately aggregated with other users and no longer identifiable) to third parties.
We acknowledge that people have different privacy concerns and preferences. Our goal is to be clear about what information we collect, so that you can make meaningful choices about how it is used. We provide you with the ability to exercise certain choices, rights and controls in connection with your information, including (and depending on your jurisdiction):
- The right to access your Personal Data that we use;
- The right to ensure your Personal Data is accurate, complete and up to date;
- The right to have your Personal Data amended (by correcting, deleting or adding information);
- The right to object to the use of your Personal Data, to the extent applicable;
- The right to send or “port” your Personal Data;
- The right to file a complaint with a supervisory authority in your jurisdiction;
- The right to withdraw consent, subject to legal or contractual restrictions and reasonable notice;
- Right to Non-Discrimination; and
- Rights to submit a “Do not sell” request, where applicable.
Please review our Privacy Rights Policy regarding your rights under applicable law. You may exercise any or all of your above rights in relation to your Personal Data by filling out the Data Subject Request (“DSR”) form.
Where we are not able to provide you with the information for which you have asked, we will endeavor to explain the reasoning for this and inform you of your rights. We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any such information in accordance with applicable law.
We retain the information we collect solely for as long as required to fulfill the purposes for which it was collected, and as detailed below:
|Data Sets||Retention Period|
|Online Identifiers||Deleted following the completion of use and not later than following 60 days.|
|Contact Details||Deleted Immediately following the completion of a request.|
|Partners Data||According to applicable laws.|
|Technical Information||For as long as needed to provide with the Website|
Notwithstanding the above, in some circumstances we may retain the information we collect for longer periods, for example, when we are required to do so in accordance with legal, tax and accounting requirements. In addition, we may also retain your Personal Data for longer periods if we reasonably believe, at our discretion, that we need to obtain an accurate record of your correspondence or any dealing with using the event of any complaints, all, in compliance with applicable laws as well as our Partners’ data.
SECURITY OF THE DATA
We make best efforts keep our website and the data we secure. We employ industry standard and implemented technical and administrative security measures to ensure the safety of our users’ Personal Data and prevent unauthorized access or use of such Data. In spite of all our efforts, it is not guaranteed that the protection is hermetic and that data transmission over the Internet or any wireless network is 100% secure and we cannot be responsible for the acts of those who gain unauthorized access or abuse our website, and we make no warranty, express, implied or otherwise, that we will be able to prevent such access. If you feel that your privacy was violated, or it suffered from an attempt to abuse our website or to act in an inappropriate manner, please contact us directly at: [email protected].
CHILDREN PRIVACY AND DATA
The Website is not intended for individuals under the age of eighteen (18). Accordingly, we do not use the website to knowingly solicit data from or market to children as defined under applicable law (e.g. thirteen (13) regarding US individuals and sixteen (16) regarding European Economic Area ("EEA") individuals). We request that such individuals do not provide Personal Data.
If you have any questions or concerns regarding privacy issues, or if you wish to be provided with any other information related to our privacy practices, please contact us at: [email protected].