Effective: December 27, 2021
Our commitment to privacy
Interpretation and Definitions
The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.
- Account means a unique account created for You to access our Service or parts of our Service.
- Affiliate means an entity that controls, is controlled by or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.
- Application means the software program provided by the Company downloaded to any electronic device, named eyeNjoy
- Business, for the purpose of the CCPA (California Consumer Privacy Act), refers to the Company as the legal entity that collects Consumers' personal information and determines the purposes and means of the processing of Consumers' personal information, or on behalf of which such information is collected and that alone, or jointly with others, determines the purposes and means of the processing of consumers' personal information, that does business in the State of California.
- Company (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to GreenCTech LTD, 4 Berkowitz St., Tel Aviv. For the purpose of the GDPR, the Company is the Data Controller.
- Consumer, for the purpose of the CCPA (California Consumer Privacy Act), means a natural person who is a California resident. A resident, as defined in the law, includes (1) every individual who is in the USA for other than a temporary or transitory purpose, and (2) every individual who is domiciled in the USA who is outside the USA for a temporary or transitory purpose.
- Country refers to: Israel
- Data Controller, for the purposes of the GDPR (General Data Protection Regulation), refers to the Company as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data.
- Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.
- Health data is any health information relating to the health status of an individual that is created, collected, transmitted, or maintained by the Service.
- Protected Health Information (PHI) is any Health Data that is individually identifiable.
- Personal Data is any information that relates to an identified or identifiable individual. For the purposes for GDPR, Personal Data means any information relating to You such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity. For the purposes of the CCPA, Personal Data means any information that identifies, relates to, describes or is capable of being associated with, or could reasonably be linked, directly or indirectly, with You.
- Sale, for the purpose of the CCPA (California Consumer Privacy Act), means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Consumer's personal information to another business or a third party for monetary or other valuable consideration.
- Service refers to the use or operation of eyeNjoy™ products: Application, Device, Website, or API.
- Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used. For the purpose of the GDPR, Service Providers are considered Data Processors.
- Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
- You means the individual accessing, operating, or using the Service, or the company, or other legal entity on behalf of which such individual is accessing, operating, or using the Service, as applicable. You also refer to individuals examined by the Service under Your care.
Under GDPR (General Data Protection Regulation), You can be referred to as the Data Subject or as the User as you are the individual using the Service.
Collecting and Using Your Personal Data
Types of Data CollectedPersonal Data
While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:
- Email address
- First name and last name
- Phone number
- Address, State, Province, ZIP/Postal code, City
- Usage Data
Usage Data is collected automatically when using the Service.
Usage Data may include information such as Your Device's Internet Protocol address (e.g. IP address), Device information, browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.Information Collected while Using the Application
While using Our Application, in order to provide features of Our Application, You grant us the right to collect Health Data, pictures, eye movements and other Personal Data.
We use this information to provide Our Service, improve and customize Our Service.
Use of Your Personal Data
The Company may use Personal Data for the following purposes:
- To provide, maintain, and improve our Service, including to monitor the usage of our Service and for internal administrative and auditing purposes.
- To protect our services and users: for example, we will use it to investigate suspicious activity and attacks.
- To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.
- For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.
- To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
- To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.
- To manage Your requests: To attend and manage Your requests to Us. For example, if You share Your contact information to ask a question about our Service, We will use that personal information to respond to Your inquiry.
- For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred.
- For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience.
Disclosure of Your Personal Data
We may share Your personal information in the following situations:
- With Service Providers: We may share Your personal information with Service Providers to monitor and analyze the use of our Service, to contact You.
- For business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.
- With business partners: We may share Your information with Our business partners to offer You certain products, services or promotions.
- With Your consent: We may disclose Your personal information for any other purpose with Your consent.
- With Law Enforcement: To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations. To protect and defend the rights or property of the Company
Retention of Your Personal Data
The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.
Transfer of Your Personal Data
Your information, including Personal Data, is processed at the Company's servers and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.
Security of Your Personal Data
The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.
Collecting and Using Your Health Data
While using the Service we may generate, receive, store, maintain, and transmit Health Data. We understand that medical information is personal and should be kept private. We are committed to protecting Your Protected Health Information from misuse.
- Not use or disclose PHI other than as permitted or required by this contract or as required by law.
- Use appropriate safeguards, to prevent use or disclosure of PHI other than as provided for by the Agreement or as provided by law.
- Require that any subcontractor that creates, receives, maintains or transmits PHI on behalf of the Service agrees to the same restrictions and conditions that apply to Us.
- Receive, transmit, and store PHI created by the eyeNjoy Service on Your behalf or uploaded by You, individuals under Your care, or Your business associates.
- Process PHI stored on the eyeNjoy servers for the purpose of (i) providing You with monitoring, statistics, and data driven insights on individuals under Your care. (ii) improve the learning algorithms and the service eyeNjoy provides.
- Share, transmit, or provide electronic records containing PHI to Your business associates upon Your request as will be defined from time to time.
- De-identify PHI to enable health collaboration of anonymous data. Such de-identified information shall no longer be guarded as private information or PHI.
- Provide data aggregation services relating to Your health care operations.
- Carry out legal responsibilities.
- Use or disclose PHI with respect to applicable laws and regulation.
- Not request Us to use or disclose PHI in any manner that would not be permissible for You or Us under applicable law or regulation.
- Restrict the use and disclosure of PHI in any manner to comply with Your limitation(s) to Your notice of privacy practices, and to changes in, or revocation of, permission by Individual to use or disclose PHI shared by You.
Detailed Information on the Processing of Your Personal Data
The Service Providers We use may have access to Your Personal Data. These third-party vendors collect, store, use, process and transfer information about Your activity on Our Service in accordance with their Privacy Policies.
We may use third-party Service providers to monitor and analyze the use of our Service.
- Google Analytics
Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.
For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy
We may use Your Personal Data to contact You with newsletters, marketing or promotional materials and other information that may be of interest to You. You may opt-out of receiving any, or all, of these communications from Us by following the unsubscribe link or instructions provided in any email We send or by contacting Us.
We may use Email Marketing Service Providers to manage and send emails to You.
By using the Service, You are giving Your consent to processing Personal Data for the purposes described in this Policy and in the Service Terms of Service. The Company undertakes to respect the confidentiality of Your Personal Data and to guarantee You can exercise Your rights under the EU General Data Protection Regulation 2016/679 (“GDPR”).
- Request access to Your Personal Data.
- Request correction of the Personal Data that We hold about You.
- Object to processing of Your Personal Data.
- Request erasure of Your Personal Data.
- Request the transfer of Your Personal Data.
- Withdraw Your consent.
- Lodge a complaint with your local data protection authority.
Read more about your rights under the EU GDPR
Exercising of Your GDPR Data Protection Rights
You may exercise Your rights of access, rectification, cancellation and opposition by contacting Us. Please note that we may ask You to verify Your identity before responding to such requests. If You make a request, We will try our best to respond to You as soon as possible. Please understand, however, the rights enumerated above are not absolute in all cases.
We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Consumer or Device.
The CCPA provides California residents with specific rights regarding their personal information. If You are a resident of California, You have the following rights:
- The right to know about the personal information a business collects about them and how it is used and shared.
- The right to say no to the sale of personal information (opt-out).
- The right to delete personal information collected from them (with some exceptions).
- The right to non-discrimination for exercising their CCPA rights.
Read more about your rights under the CCPA regulations
Exercising Your CCPA Data Protection Rights
In order to exercise any of Your rights under the CCPA, and if You are a California resident, You can contact Us by email at WeCare@eyenjoy.com
Only You, or a person registered with the California Secretary of State that You authorize to act on Your behalf, may make a verifiable request related to Your personal information.
Your request to Us must:
- Provide sufficient information that allows Us to reasonably verify You are the person about whom We collected personal information or an authorized representative
- Describe Your request with sufficient detail that allows Us to properly understand, evaluate, and respond to it
We cannot respond to Your request or provide You with the required information if We cannot:
- Verify Your identity or authority to make the request
- And confirm that the personal information relates to You
We will disclose and deliver the required information free of charge within 45 days of receiving Your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonable necessary and with prior notice.
Any disclosures We provide will only cover the 12-month period preceding the verifiable request's receipt.
For data portability requests, We will select a format to provide Your personal information that is readily useable and should allow You to transmit the information from one entity to another entity without hindrance.
Our Service may collect personally identifiable information from children under the age of 13 provided by a parent or guardian, or directly by You as you sustain appropriate parental consent. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers.
Links to Other Websites
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
If you have any questions about any of these practices or eyeNjoy use of your personal information, please contact us at WeCare@eyenjoy.com.