SWEETCH PRIVACY POLICY
[Last Updated: Sep 2022]
This privacy policy (“Privacy Policy”) governs the data collection, processing, and usage made by Sweetch Health Ltd. (“Company”, “Sweetch”) “we” or “us”) with respect to the data we collect from individuals who use our services that include: (i) mobile application together with its related web interfaces and landing pages ("App"); and (ii) Cloud-based platform and web interface associated with the App ("Dashboard") (collectively, the "Services").
This Privacy Policy constitutes an integral part of the Services Terms and Conditions (together “Terms”), and provides you with information regarding our processing operations, including the lawful basis pursuant to which we process your Personal Data (as defined below), third parties to whom Personal Data will be transferred, data retention periods, as well as your rights under applicable privacy laws. Definitions used herein but not defined herein shall have the meaning ascribed to them in the Terms.
The users of the Services are: (i) App Users who use the App for achieving their personal health goals ("App User"); and (ii) third parties who use the Dashboard for monitoring their App Users' status and progress (e.g., a relevant healthcare provider of an App User), including our customers and partners who engaged us for providing the App Users with the Services ("Enterprise User" and "Enterprise Account Owner") (App User and Enterprise User together "you" or a "User"). You and the Company shall each be referred to herein as a "party" and collectively as the "parties".
It is important to note that the Services will track the App User’s daily activity and collect and analyze its Personal Data, including health-related data, as detailed hereunder, to define and create a personalized program and recommendations to assist the App User with achieving their personal health goals and manage their chronic condition.
You are not required by law to provide us with any Personal Data. Sharing Personal Data with us is entirely voluntary. However, in some cases, without providing your data we would not be able to provide you with all or some of our Services.
We reserve the right to periodically amend or revise the Privacy Policy, which will immediately affect the implementation of the revised Privacy Policy in the Services. The last revision date will be reflected in the “Last Modified” heading located at the top of the Privacy Policy. We will make a reasonable effort to notify you if we implement any changes that substantially change our privacy practices. We recommend that you review this Privacy Policy periodically to ensure that you understand our privacy practices and to check for any amendments.
We are Sweetch, a company incorporated in Israel. Our address is: 5 Jabotinsky St. Ramat Gan, Israel.
Under the European General Data Protection Regulation (”GDPR”), we are the data controller of the Services Users. That, without derogating from the responsibility and legal obligations of the relevant Enterprise Account Owner as the entity contracted us for providing you with Services.
Questions, comments, requests and complaints regarding this Privacy Policy and the information we hold are welcome and should be addressed to us contacting us through email: support@sweetch.com. All requests will be dealt with promptly and efficiently.
“Non-Personal Data”: means non-identifiable, including statistical and aggregated, and “de-identified” data which can no longer be associated with any individual with no limitation (even if was derived from Personal Data). That includes technical data transmitted to us by your device when you access and interact with the Services, such as the type of browser, type of operation system, type of device used, the time and date you access our services, navigation, language preference, etc. Also, such data may include data regarding Users’ daily activities, Services Usage, Clinical and demographic information, but only to the extent such data was stripped off any identifier and can no longer be associated with the specific User from whom it was collected. Non-Personal Data is used mainly for technical analysis, research and development of our services in order to provide, maintain, develop and enhance it, and is not used to identify individuals. Under this Privacy Policy, we can use any aggregated, statistical, and such de-identified data with no limitation. Such data may be included in our proprietary information and does not deem as Personal Data under the law.
“Personal Data”: means, information which identifies or may identify, with reasonable effort, an individual. Such data includes, inter alia, your name, address, phone number, email address billing information and online identifiers (such as IP address or Cookie ID). Also, in certain cases and if you as a User of our App, Personal Data may include further and broader information regarding your activity and interaction with us or our services.
The Personal Data we collect and process is:
Account Data:
App User’s Daily Habits and Health-related data (“Profile Data”):
App User’s Usage and Tracking Data (“Activity and Tracking Data”):
Contact us and Support Data (“Support Data”):
Technical and Usage Data (“Usage Data”):
***Please see additional information regarding Cookie’s usage below.
On any occasion where the processing of your Personal Data is based upon consent, you may withdraw such consent by contacting us through the contact means provided below.
Please note that the actual processing operation per each purpose of use and lawful basis detailed in the table above may differ. Such processing operation usually includes a set of operations, made by automated means, such as collection, storage, use, disclosure by transmission, erasure, or destruction. Transfer of personal data to third-party countries, as further detailed in the Data Transfer section, is based on the same lawful basis as stipulated in the table above.
Also, we may collect Personal Data that includes information of medical nature from you or the relevant Enterprise User. If you reside in the US, some of this information may, but not necessarily in all cases, be protected under the Health Insurance Portability and Accountability Act of 1996 and associated regulations ("HIPAA"). We will always treat such data with great care and in accordance with all applicable laws.
Health Connect data (for Android users) – if you are an Android user, as part of providing you with the App services, we may use Health Connect data. The use of information received from Health Connect will always adhere to the Health Connect Permissions Policy, including the Limited Use requirements.
In addition, we may use certain Personal Data to prevent potentially prohibited or illegal activities, fraud, misappropriation, infringements, identity thefts, and any other misuse of our services and to enforce the Terms, as well as to protect the security or integrity of our databases and our services, and to take precautions against legal liability. Such processing is based on our legitimate interests.
In our web interfaces, including any landing page or dashboard, we may use cookies, web beacons, pixels, SDKs, and other tools and technologies (together Cookies) to improve your experience while using our services. We may use various types of Cookies:
Please note that the data collected by Cookies may be linked to and combined with any other data, including Personal Data.
Cookie’s data is usually collected through the use of third-party services, like Google, Facebook, etc. In those cases, your Personal Data might be transferred to those third parties, which might link it and use it together with other information they have on you from other sources. Such data is “owned” and processed separately by those third-parties under their terms and conditions and the direct accounts or subscriptions you have with those third parties. For example, suppose you have a Facebook account, the Personal Data collected through Facebook’s Cookies on our website might be linked to other data that Facebook collects from you as a Facebook user, and might be used by Facebook per the independent agreements between you and Facebook.
The specific cookies we currently use in our Dashboard, and your choices with regard to such use are detailed in the dedicated cookie banner in the Dashboard.
According to the nature of your interaction with our services, we may collect information as follows:
We do not sell your Personal Data. We will only share it with third parties in the following events:
Where we share information with service providers and partners, we ensure they only have access to such information that is strictly necessary in order for us to provide the services. These parties are required to secure the data they receive and to use the data for pre-agreed purposes only, while ensuring compliance with all applicable data protection regulations.
As part of the App we may use certain SDKs (a Software development kit) which is a set of tools that provide us with the ability to build a custom app which can be based on, or connected to, another program. SDKs are used only in our Mobile App. SDK create the opportunity to enhance our Mobile App with more functionality, as well as include advertisement and push notifications, if applicable. SDKs will be used for collection of the same data types as detailed above, for the purposes detailed alongside.
Any information you provide us may be transferred to and processed in countries other than the country from which you accessed our services. If you are a resident of the European Economic Area ("EEA") we will take appropriate measures to ensure that your Personal Data receives an adequate level of data protection upon its transfer outside of the EEA. If you are a resident of a jurisdiction where the transferring of your Personal Data requires your consent, then your consent to this Privacy Policy includes your express consent for such data transfer.
You may have certain rights regarding your Personal Data
We acknowledge that different 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. Depending on your relationship with us (e.g., if you are a visitor of our website or an App User), data protection and privacy laws provide you with some of the following principal rights regarding your Personal Data, including (and depending on your jurisdiction): The right to access your Personal Data that we process; 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 processing 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, etc.
You may exercise any or all of your above rights in relation to your Personal Data by contacting us through the email address above.
Further, certain rights are available within the App: you may correct and revise the Account Information, Contact Data, Profile Data, etc. Also, you have the ability to delete your account. Therefore, we recommend you use the technical solutions we have provided you with to exercise your rights.
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, including the right to complain to the supervisor authority (in the event you are EEA resident). 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 Personal Data we collect as long as it remains necessary for the purposes set forth above, all in accordance with applicable laws or until an individual requests to opt-out of such collection. For example, we will retain any User’s data for at least 6 years after the termination of use, for the purpose of legal defense and in accordance with the relevant statute of limitation. Additionally, if you receive our services under a contract with a third party (such as the Enterprise Account Owner), the third party is responsible for setting the Retention terms. We may at our sole discretion, delete or amend information from our systems, without providing any notice to you, once we deem it is no longer necessary for our purposes.
We implement extensive security measures to reduce the risks of damage, loss of information and unauthorized access or misuse of Personal Data. We implement appropriate data collection, storage and processing practices and security tools to protect personal data against unauthorized access, alteration, disclosure or destruction. You should be aware that no security measures are completely fail-proof, and it is impossible to prevent any and all threats to the security of data and systems. Therefore, you should be aware that any processing of digital Personal Data holds certain inherent risks, and we cannot guarantee that our services and databases will be immune to any wrongdoings, malfunctions, unauthorized interceptions or access, malware attacks or other kinds of abuse and misuse.
Our services are not directed, nor is it intended for use by children (the phrase "child" shall mean an individual that is under age defined by applicable law which concerning the European Economic Area (“EEA “) is under the age of 16 and with respect to the U.S.A, under the age of 13) and we do not knowingly process a child’s information. We will discard any information that we receive from a user who is considered a "child" immediately upon our discovery that such a user shared information. Please contact us if you have reason to believe that a child has shared any information with us.