Last Revised: September 16, 2020
1. Information We Collect
We collect two types of data and information from our Users: Non-Personal Information and Personal Information.
- Personal Information: The second type of information we collect is individually identifiable information, such as name, email address, and telephone number (“Personal Information”). We collect Personal Information when
- A User or individual chooses to provide Personal Information in the Contact Us Form, a similar form on the Site or through other means outside of the Site. Personal Information collected may include the User’s or individual’s full name, address, e-mail address, phone number, and in the case of Site forms, any text the User voluntarily writes in the “message” box and other Personal Information provided by a User in a Site form.
- A User provides his/her name, e-mail and company name when he/she requests to download articles or brochures from the Site.
When you voluntarily submit your Personal Information to us through a Site form, you will separately be asked to consent to INSIGHTEC’s collection and use of the information that you submit so that INSIGHTEC may respond to your inquiry or request.
The only Personal Information we collect automatically from all Users of the Site is IP address (or media access control (“MAC”) address, as applicable). We use this Personal Information as described below.
2. How We Use and Share the Information
- Non-Personal Information. We use the Non-Personal Information we collect to operate the Site, for statistical and research purposes relating to use of our Site, for customization and improvement of our Site (e.g. enhancing the Users’ experience by analyzing trends and Users’ preferences in using the Site and updating the Site to better align with Users’ preferences) and to help tailor future commercial services.
- Personal Information. We use the Personal Information we collect to:
- Contact Users to provide technical assistance and support.
- Provide Users who subscribe to our newsletters with INSIGHTEC updates and news.
- Provide Users with a copy of their information submitted in a Site form (e.g., a User who completes a quiz receives an email copy of his/her quiz responses).
- Communicate with Users and individuals who have consented to receive communications about INSIGHTEC’s services or products or who have consented to receive such communications in the course of participating in INSIGHTEC’s programs or service offerings, such as its Neuravive education program.
- Determine general geolocation information (i.e., country) from which the User’s computer is connected to the Internet in order for us to provide tailored content (e.g., Users in the United States see information about products available in the United States) as well as in order to safeguard our Site.
- Verify the User’s identity for the purpose of dealing with inappropriate interactions with the Site.
- We share Personal Information with third parties in the following circumstances:
- To determine general geolocation information (i.e., country) from which the User’s computer is connected to the Internet in order for us to provide tailored content (e.g., Users in the United States see information about products available in the United States) as well as in order to safeguard our Site.
- To verify the User’s identity for the purpose of dealing with inappropriate interactions with the Site.
- To comply with applicable law, regulation, legal process, subpoena or governmental request
- To detect, prevent, or otherwise address fraud, security or technical issues related to the Site
- To respond to claims that any content available on the Site violates the rights of third parties
- To protect the rights, property, or personal safety of INSIGHTEC, its Users, or the general public
- When INSIGHTEC is undergoing any change in control, including by means of merger, acquisition or purchase of all or substantially all of its assets
- Pursuant to your explicit approval prior to the disclosure
- Personal Information. We use the Personal Information we collect to:
3. Deletion or Modification of Personal Information
We do not knowingly solicit, collect or use Personal Information from children under the age of thirteen (13). We reserve the right to request proof of age at any stage so that we can verify that minors under the age of thirteen (13) are not using the Site. If we learn that we collected Personal Information from children under the age of thirteen (13), we will endeavor to delete that information as quickly as possible. Please contact INSIGHTEC at: firstname.lastname@example.org if you have reasons to suspect that INSIGHTEC collected Personal Information from children under the age of thirteen (13).
We implement commercially reasonable administrative, technical, physical and organizational security measures to maintain the security and integrity of our Site and User Personal Information and protect against loss, misuse, or improper access through generally accepted industry standard technologies and internal procedures. Please note, however, that there are inherent risks in transmission of information over the Internet or other methods of electronic storage, and we cannot guarantee that unauthorized access or use of your Personal Information will never occur.
6. Third Party Service Providers
7. Tracking Technologies
8. International Data Transfer
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, as permitted by applicable laws. Please note that we may transfer such information to a country and jurisdiction that does not have the same data protection laws as your jurisdiction. With respect to Personal Information about individuals in the EU, INSIGHTEC transfers such Personal Information to Israel and, for such transfers, relies on the fact that the European Commission has determined that Israel provides adequate safeguards for protection of Personal Information.
9. Direct Marketing
On our Contact Us page, you may choose to receive company news, newsletters, product announcements and such, informing you of certain updates or about our new products or services. You will separately be asked on the Contact Us page to consent to our collection and use of your e-mail address so that we can send you such information, if you so choose. You may withdraw your consent at any time by sending a written notice to INSIGHTEC by e-mail to the following e-mail address: email@example.com. You also may object to our processing of your Personal Information for direct marketing purposes at any time by sending a written notice to INSIGHTEC at that same email address, and we will cease processing your Personal Information for those purposes upon receipt of your objection. INSIGHTEC does not share email addresses with third parties for third parties’ direct marketing activities.
Consistent with California law, INSIGHTEC does not disclose Personal Information to third parties for third parties’ direct marketing purposes. California residents who have questions regarding this law and INSIGHTEC’s compliance with it may contact us as set forth below.
10. Links to Third Party Websites
Our Site may include links to third-party websites. We do not endorse or recommend such third-party websites and we are not responsible for the privacy practices of the operators of such websites. Please be aware that when you access a third-party’s website via a link on our Site, you are bound by the privacy policies and practices of that third party. We urge you to be aware of and read the privacy policies relating to your use of such third-party websites.
12. Information for Individuals in the EU and UK
- INSIGHTEC is a “controller” (entity that determines the purposes and means of processing your Personal Information) with regard to the Personal Information you share on the Site and certain Personal Information collected about you outside the Site which INSIGHTEC controls, and INSIGHTEC can be contacted at firstname.lastname@example.org. INSIGHTEC’s Data Protection Officer can also be contacted at email@example.com.
- For individuals in the EU: VeraSafe has been appointed as INSIGHTEC’s representative in the EU for data protection matters, pursuant to Article 27 of the EU’s General Data Protection Regulation. VeraSafe can be contacted in addition to or instead of INSIGHTEC on matters related to the processing of Personal Information. To make such an inquiry, please contact VeraSafe using this contact form: https://www.verasafe.com/privacy-services/contact-article-27-representative or via telephone at: +420 228 881 031. Alternatively, VeraSafe can be contacted at: VeraSafe Netherlands BV, Keizersgracht 391 A, 1016 EJ Amsterdam, The Netherlands.
- For individuals in the UK: VeraSafe has been appointed as INSIGHTEC’s representative in the United Kingdom for data protection matters, pursuant to Article 27 of the United Kingdom General Data Protection Regulation. VeraSafe can be contacted in addition to or instead of INSIGHTEC on matters related to the processing of Personal Information. To make such an inquiry, please contact VeraSafe using this contact form: https://verasafe.com/public-resources/contact-data-protection-representative or via telephone at +44 (20) 4532 2003. Alternatively, VeraSafe can be contacted at: VeraSafe United Kingdom Ltd., 37 Albert Embankment, London SE1 7TL, United Kingdom.
- As a data subject, you have the right to request from INSIGHTEC access to, rectification of, erasure of, and/or restriction of processing of your Personal Information. You also have the right to object to further processing of your Personal Information and to request that your Personal Information be transferred to a third party. To exercise any of these rights, please contact INSIGHTEC at firstname.lastname@example.org. INSIGHTEC will respond to you in accordance with applicable law.
- You may withdraw your consent to the processing of your Personal Information at any time without such withdrawal affecting the lawfulness of processing that occurred before the withdrawal. You may unsubscribe to INSIGHTEC newsletters by clicking the “Unsubscribe” button at the bottom of each newsletter, or you may email email@example.com to withdraw your consent to the processing of your Personal Information.
- INSIGHTEC transfers Personal Information to Israel and, for such transfers, relies on the fact that the European Commission has determined that Israel provides adequate safeguards for protection of Personal Information.
- If you have a concern with the handling of your Personal Information, you may lodge a complaint with the applicable Supervisory Authority in the country in which you reside; however, INSIGHTEC asks that you first contact INSIGHTEC at firstname.lastname@example.org so that INSIGHTEC may attempt to fully address your concern.
13. California Privacy
The California Consumer Privacy Act of 2018 (“CCPA”) provides certain rights to individuals who reside in the State of California (“CA Consumers”). Below is a description of CA Consumers’ rights concerning their personal information and INSIGHTEC’s practices regarding the collection, use, disclosure and sale of personal information about CA Consumers.
CA Consumers’ Rights
CA Consumers have the right to request that INSIGHTEC disclose what personal information it collects, uses, discloses and sells. A CA Consumer may request details concerning any or all of the following: (i) specific pieces of personal information that INSIGHTEC has about the CA Consumer; (ii) categories of personal information INSIGHTEC has collected about the CA Consumer; (iii) categories of sources from which the personal information is collected; (iv) categories of personal information about the CA Consumer that INSIGHTEC sold or disclosed for a business purpose; (v) categories of third parties to whom the personal information was sold or disclosed for a business purpose; and (vi) the business or commercial purpose for collecting or selling personal information. To make any of these requests, please email INSIGHTEC at email@example.com or call +1-844-739-3204. Once INSIGHTEC receives your request, we will need to verify that you are the person about whom INSIGHTEC has collected personal information. In some situations, INSIGHTEC may require you to provide additional information about yourself as part of this verification process. INSIGHTEC will inform you of additional information it requires (if any) to verify your identity after it receives your request. If INSIGHTEC is not able to verify your identity by reasonable methods, INSIGHTEC may deny your request, and in such case, INSIGHTEC will provide you a reason in writing as to why it cannot comply with your request.
CA Consumers have the right to request the deletion of their personal information which is collected or maintained by INSIGHTEC. To make a deletion request, please email us at firstname.lastname@example.org or call +1-844-739-3204. Once INSIGHTEC receives your request, as described above, INSIGHTEC will verify that you are the person about whom INSIGHTEC has collected personal information. Please be aware that there are certain exceptions to the right of deletion of personal information. INSIGHTEC will inform you in writing if there is any such exception or if there is any other reason why INSIGHTEC cannot comply with your request.
A CA Consumer may use an authorized agent (which may be a person or a business entity registered with the CA Secretary of State) to submit any of the requests described above on the CA Consumer’s behalf. The authorized agent must follow processes specified above for submitting such requests. When a CA Consumer uses an agent to submit a request, INSIGHTEC may require the CA Consumer to provide the agent with signed permission to submit such request and may also require the CA Consumer to verify his/her own identity directly with INSIGHTEC. INSIGHTEC may deny a request from an agent if the CA Consumer does not submit proof to INSIGHTEC that the agent has been authorized by the CA Consumer to act on the CA Consumer’s behalf.
CA Consumers have the right to not receive discriminatory treatment for the exercise of privacy rights under the CCPA. INSIGHTEC will not discriminate against any CA Consumer for the exercise of those rights.
INSIGHTEC’s practices regarding the collection, use, disclosure and sale of personal information about CA Consumers
Please be advised that INSIGHTEC does not sell personal information about any CA Consumers, including but not limited to any information about minors.
The table below describes the categories of CA Consumers’ personal information INSIGHTEC has collected in the last 12 months, categories of sources from which that information was collected and the business or commercial purpose for which the information was collected:
|Category of personal information INSIGHTEC has collected||Category of source from which information was collected||Business/commercial purpose for which information was collected|
|Identifiers (e.g., name, online identifier, email address and similar identifiers)||CA Consumers; advertising networks||For INSIGHTEC’s marketing purposes|
|Phone numbers||CA Consumers||For INSIGHTEC’s legitimate interests and business purposes|
|Geolocation data||CA Consumers||For INSIGHTEC’s marketing purposes|
|Health information||CA Consumers; advertising networks||For INSIGHTEC’s provision of customer service|
|Health insurance information||CA Consumers||For INSIGHTEC’s provision of customer service|
|Inferences drawn from health information and health insurance information to create a profile about a person||CA Consumers||For INSIGHTEC’s provision of customer service|
|Professional or employment-related information||CA Consumers||For INSIGHTEC’s legitimate interests and operational purposes|
The table below describes the categories of CA Consumers’ personal information that INSIGHTEC has disclosed to third parties for a business purpose and corresponding categories of third parties to whom the information was disclosed in the last 12 months:
|Category of personal information that INSIGHTEC has disclosed||Category of third party to whom personal information was *disclosed|
(*Please note “disclosed”, as used in this table, denotes storage of personal information on Insightec’s vendor’s/service provider’s storage platform for Insightec’s operational purposes)
|Identifiers (e.g., name, online identifier, email address and similar identifiers)||INSIGHTEC’s vendors/service providers|
|Phone Numbers||INSIGHTEC’S vendors/service providers|
|Geolocation data||INSIGHTEC’s vendors/service providers|
|Health information||INSIGHTEC’s vendors/service providers|
|Health insurance information||INSIGHTEC’s vendors/service providers|
|Inferences drawn from health information and health insurance information to create a profile about a person||INSIGHTEC’s vendors/service providers|
|Professional or employment-related information||INSIGHTEC’s vendors/service providers|