Cnoga Privacy Policy

Last Revised: February 10, 2019

Cnoga Medical Ltd. and its affiliates (“Cnoga", "Company", “we” or "us") respect the privacy of the users (“User(s)” or “you”) of its mobile application for the retrieval and transmission of information collected by our Devices (the "App") which is compatible with our TensorTip®CoG Combo Glucometers, TensorTip® MTX Matrix, TensorTip® VSM Vital Sign Monitor devices, as well as any other devices offered by us from time to time (collectively referred to herein as the "Device"), and portal (the "Portal") (collectively, the "Services", as further detailed in the Terms of Use). We are committed to protect the information you submit through our Services. We believe that you have a right to know our practices regarding the information we may collect and use when you use our App, Portal and/or Services.

1. Capitalized terms which are not defined herein, shall have the meaning ascribed to them in Cnoga's Terms of Use available at http://cnogacare.co/cnoga-medical-terms-of-use/ ("TOU") to which this Privacy Policy is incorporated.

1. Your Consent

Personal information is collected and processed by Cnoga only upon specific consent of the data subjects, unless another legal basis applies.

2. Which information we may collect on our Users?

We may collect two types of information from our Users:

a. Non-personal Information

We are not aware of the identity of the User from whom we have collected the Non-personal Information. Non-Personal Information is any unconcealed information which does not enable identification of an individual User, and which is available to us when such User installs the App and when he/she uses the App or Portal.

• Non-personal Information consists of technical information, behavioral information and aggregated information, and may contain, among other things, browser type, the type of the User's mobile device and its operating system and version, device language, device storage, screen resolution and other modes (e.g. vibration mode, Bluetooth), User's 'click-stream' in the App or Portal, time spent on various screens of the App and/or Portal, date and time stamps, Internet connectivity, etc.
• Users of the App automatically provide (a) their mobile device ID, or in connection with the use of computers, the IP address (or Mac Address, as applicable) mainly for enhancing the User’s experience and for geo-location and security purposes as further detailed below and (b) pages viewed by each individual User.

b. Personal Information

Personally Identifiable Information (PII) is information that identifies, or may with reasonable effort identify an individual, or may be of a private and/or sensitive nature:

• Users who are interested in opening an Account are required to provide the following details: full name, e-mail address, password, gender, date of birth, weight, height. Users may also choose to provide the following information in connection with setting up their account: photo, middle name, place of birth, home phone number, mobile phone number, full address (including country, city, and zip code) and a local identification number. This information is stored on our servers.
• The app makes specific access requests to use the camera on your device.

For avoidance of doubt, any Non-Personal Information connected or linked to any Personal Information shall be deemed as Personal Information as long as such connection or linkage exists.

We do not collect any Personal Information from you or related to you without your approval, which is obtained, inter alia, through your acceptance of the TOU and this Privacy Policy.

3. How Do We Collect Information on Our Users and/or their Patients?

There are a few methods that we use:

1. We collect information through your installation and use of the App and/or Portal. In other words, when you are using the App and/or Portal we are aware of it and may gather, collect and store the information related to such usage, either independently or through the help of our authorized third-party service providers as detailed below. Non-personal Information is collected from your mobile device automatically (i) through your use of the App, once your mobile device is on and as long as the App is running on your mobile device, and (ii) during your use of the Portal.
2. We collect information which you may, at your discretion, provide us voluntarily. We collect Personal Information when you, at your discretion, decide to provide us (e.g. your name, email and phone number). We may gather, collect and store the Personal Information either independently or through the help of our authorized third-party service providers as detailed below.
3. We collect medical information that you transmit from the Device(s) to our servers. We make no use of your medical Personal Information other than storing it in connection with the provision of the Services and the purposes set forth below. We may, however, anonymize Personal Information we collect and use it for the purposes stated below with respect to Non-Personal-Information and share such anonymized information with third parties in an aggregated manner, which will not enable such third parties to identify a specific User.

4. What are the Purposes of the Collection of Information?

We collect Non-personal Information and Personal Information in order to provide the Services.

We collect Non-personal Information in order to:

• Better understand the behavior and preferences of our customers.
• For statistical and research purposes, customization and improvement of our Services and for commercial purposes.
• Engage with third parties for commercial or research purposes.
• Comply with our legal obligations and resolve any disputes we may have.
• Deliver and enforce our Terms of Service.

We collect Personal Information in order to:

• Allow you to export it to your Account for your own purposes.
• Verify the User's identity when he/she signs into the Services.
• Be able to reply to the User's support requests or other question concerning the Services.
• Allow you to communicate with your health care provider or other third parties you authorize to receive your Personal Information (if you choose to do so).
• Determine geo-location information from which the User's mobile device or computer is connected to the Internet in order to render the Services, for statistical purposes as well as in order to safeguard our Services.

Cnoga will not retain personal data for longer than is necessary for our business purposes or for legal requirements.

In all cases of data access and collection, the information provided will not be disclosed, rented, loaned, leased, sold, or otherwise voluntarily distributed to unaffiliated third parties and will be used solely for the purpose stated herein.

5. Children’s Privacy

Cnoga is committed to protecting the privacy needs of children and encourage parents and guardians to take an active role in their children’s online activities and interests. Cnoga does not knowingly collect information from children under the age of 18 without their parents' or guardians’ consent. Cnoga relies upon the accuracy of information provided by the user or controller to determine age.

6. Sharing Information with Third Parties

We may share Personal Information only in the following cases:

1. to satisfy any applicable law, regulation, legal process, subpoena or governmental request;
2. to enforce this Privacy Policy, the TOU, including investigation of potential violations thereof or dishonest or fraudulent activities;
3. to detect, prevent, or otherwise address fraud, security or technical issues;
4. to respond to User's support requests;
5. to respond to claims of violations of any right of a third-party through the App, Portal and Services;
6. to protect the rights, property or personal safety of Cnoga, its users or the general public;
7. when Cnoga is undergoing any change in control, including by means of merger, acquisition or purchase of all or substantially all of the assets of Cnoga;
8. to collect, hold and/or manage the Personal and Non-personal Information collected within the App and/or Portal through our authorized third party service providers, as reasonable for business purposes;
9. to cooperate with third parties for the purpose of enhancing the User's App or Portal experience;
10. Pursuant to your explicit approval prior to the disclosure.

In order to provide you with the Services via the App and/or Portal, we may use third party service providers who may collect, store and/or process the information detailed herein, such as Google Analytics and Microsoft.

Cnoga does not share personal information with third parties for their direct marketing purposes unless upon specific consent to such disclosure.

Cnoga discloses Personal Information to third parties only if they have satisfactory measures to protect Personal Information.

For avoidance of doubt, Cnoga may transfer and disclose Non-personal Information, including anonymized aggregated information as described above, to third parties at its sole discretion and without restriction.

7. Links to Third Parties’ Sites

Cnoga may include or offer links to third party products or services. Cnoga does not control the content or links that appear on such other sites and is not responsible for the practices they employ. These parties should have separate and independent privacy policies, and Cnoga has no responsibility or liability for the content and activities of these linked sites.

8. Security

We take reasonable measures to maintain the security and integrity of our App and Portal as well as our User's information, and prevent unauthorized access to it or use thereof through generally accepted industry standard technologies and internal procedures in order to protect against unauthorized access, alteration, disclosure or destruction of your personal information, username, password, transaction information, and all other data stored on our Site.

The information which is gathered from the App and/or Portal is sent to our servers over a secure channel using HTTPS protocols. We also encrypt certain information in our database in order to effectively anonymize any User information. We also limit access of third parties to the Services by requiring the use of a password and by determining different access levels to Users.

If we learn of a security breach, we may attempt to notify you electronically so that you can take appropriate protective steps. We may post a notice on the App and/or Portal if a security breach occurs.

9. Your Compliance with Privacy and Health-Related-Information Laws

BY UPLOADING OR SUBMITTING INFORMATION, INCLUDING, WITHOUT LIMITING THE GENERALITY OF THE FOREGOING, MEDICAL PERSONAL INFORMATION, YOU REPRESENT AND WARRANT THAT YOU HAVE THE RIGHT TO UPLOAD OR SUBMIT SUCH INFORMATION IN FULL COMPLIANCE WITH ANY APPLICABLE PRIVACY LAWS AND REGULATIONS. WE WILL NOT ASSUME ANY LIABILITY IN THIS RESPECT.

10. Deletion or Modification of Personal Information

Cnoga maintains accurate customer records. If for any reason, you wish to update or modify the Personal Information you may do so by logging-in to the Services, and using the user information menu.

Cnoga supports the Data subjects' "Right to be forgotten". If you wish to remove your Account, you may do so by sending us an e-mail request to support@cnoga.com and we will make reasonable efforts to do so pursuant to any applicable privacy laws.

We may retain and use your Personal Information for a reasonable time after termination as necessary to comply with our legal requirements or obligations (including as required by applicable law), to resolve disputes and/or to enforce our TOU, as permitted under any applicable privacy laws. Aggregated and/or anonymous data derived from your Account may remain on our servers indefinitely.

Accounts created with Cnoga are considered active until Cnoga receives a user request to delete or deactivate them.

Please note: Cancelling your Account may cause inability to access your Account and/or the loss of certain information (including, without limitation, the reading of results and/or any other Personal Information). You will have a thirty (30) day period from the cancellation date to copy or extract any information which was uploaded by you to our Services. We do not accept any liability for information loss, which occurs after this thirty (30) day period.

11. International Data Transfer

As part of our international operations, we may transfer information collected about you, including Personal Information, to affiliated entities, or to other third party service providers (as provided herein) across borders and from your country or jurisdiction to other countries or jurisdictions around the world.

Cnoga transfers personal data to a third country only if the controller or processor has provided appropriate safeguards, and on condition that enforceable data subject rights and effective legal remedies for data subjects are available.

Personal data collected may also be processed by Cnoga' employees operating outside of the EU or one of its Affiliates or vendors. This staff may be engaged in processing transactions and payment details or provisioning support services. Cnoga vendors are carefully vetted through a vendor assessment procedure and are legally committed to comply with relevant regulations.

12. Cookies & Local Storage

When you access or use the App and/or Portal, we and/or our third party service providers may use industry-wide technologies such as "cookies" and local storage (or other similar technologies), which store certain local information on your device (e.g. geo-location information and Internet connectivity) ("Local Storage") which may enable automatic activation of certain features and make the User’s App or Portal experience and usage simpler, more relevant, convenient and effortless. Such information is locally stored in the User's mobile device or computer.

Cnoga and/or our authorized third party service providers may access such information. We use both session cookies (which expire once you exit the App or Portal) and persistent cookies (which stay on the User’s mobile device and/or computer until he/she deletes them) for the purpose of confirming the user's validity and for analytic purposes. Such Local Storage used by the App and/or Portal may store non-personal information (such as the different pages viewed by a User within the App or Portal or Internet connectivity) as well as geo-location data, which will be collected in accordance with the terms specified herein.

You can prohibit and/or delete the Local Storage, via uninstalling the App from your mobile device and/or through the Settings option of your device or browser. Most platforms and browsers will allow you to erase cookies from a device, block acceptance of cookies, or receive a warning before a cookie is stored. In order to erase or disable the Local Storage option you may use the settings option of your browser or device or according to the specific instructions provided by the third party service provider's privacy policy and terms of use. However, if you block or erase cookies, or change the settings of your device or browser, your App and/or Portal experience may be affected and may be limited.

13. Changes to the Privacy Policy

The terms of this Privacy Policy will govern the use of the App, the Portal and the Services and any information collected therein. Cnoga may change the terms of this Privacy Policy at any time and at its sole discretion, so please re-visit this page frequently. In case of any material changes, we will make reasonable efforts to post a clear notice on the App and/or Portal (if applicable) and/or send you an e-mail (to the extent that you provided us with such e-mail address) regarding such change. Such material changes will take effect seven (7) days after notice is provided on our App and/or Portal or sent via e-mail. All changes to this Privacy Policy are effective as of the stated “Last Revised” date. In the event that the TOU or this Privacy Policy should be amended to comply with any legal requirements, the amendments may take effect immediately, or as required by the law and without any prior notice.

14. Questions?

If you have any questions (or comments) concerning this Privacy Policy, you are most welcome to send us an e-mail to the following address, and we will make an effort to reply within a reasonable timeframe: support@cnoga.com