This website (the “Website”) is operated by Pollogen Ltd. (“Pollogen”), with its registered office at Koifman 6 Tel Aviv, Israel. Pollogen respects the privacy of visitors to this Website and other persons with whom we interact (“you” or “Data Subjects”). Pollogen developed this Privacy Statement to provide information about our practices regarding the collection, use, and disclosure of information about Data Subjects.
This Privacy Statement applies to information collected on this Website or otherwise in connection with the provision of our products and services (“Pollogen Services”). If you are only using this Website and do not have other dealings with Pollogen, please note that many of the details below, including details relating to the type of information collected about you and the use thereof, DO NOT apply to you. We have tried to make it as clear as we can where certain information is not relevant to you, but in case there are any ambiguities or if you need clarification, please contact us as per the instructions in this statement below.
Please take the time to read and understand this Privacy Statement. By using this Website or otherwise proceeding with your interaction with Pollogen after having been referred to this Privacy Statement, you acknowledge that you understand and agree (where such agreement is requested or required under the applicable law) to the terms of this Privacy Statement.
Pollogen will occasionally update this Privacy Statement to reflect company and Data Subjects’ feedback as well as any legal or regulatory requirements. You are bound by any such revisions and should therefore periodically review this Privacy Statement to be informed of how your information is being handled.
* POLLOGEN EMPLOYEES:
This Privacy Statement is not intended to cover the collection and processing of personal data of Pollogen’s employees, in their capacity as such.
1. COLLECTION OF YOUR PERSONAL INFORMATION
Personal information, such as your e-mail address, name, address, telephone number, nationality, occupation, professional field, health conditions and concerns, interests and other information that you provide or otherwise referred to below, may be collected in the following ways:
Information that you provide to Pollogen:
If you choose to share information as part of the Website’s interactive content (including our Contact Us pages, Get a Quote page, comments, chat rooms, message boards, public discussions, or any other features open to you), any personal information that you choose to share or disclose, may be collected and used by Pollogen.
If you are interacting or have a relationship with Pollogen, whether through the use of the Website or otherwise, including offline or through other websites, networks or systems operated or used by Pollogen, and you choose to share information with us through forms, correspondence, conversations, meetings, business card, contracts, purchase orders, attendance in tradeshows or other events, our social media pages etc., any personal information that you choose to share or disclose, may be collected and used by Pollogen.
If you have an actual or prospective business relationship with Pollogen, including if you an actual or prospective customer, vendor, supplier or service provider, you may be required to provide us with additional personal information such as I.D. number and card copy, passport number and copy, bank account details and other financial data, that is necessary for Pollogen to have a business relationship with you.
Information that we collect or generate about you:
This includes (by way of a non-exhaustive list):
• Information about Pollogen Services which you have reviewed, were interested in, requested a quote for or purchased, and our interactions with you;
• When you visit the Website, cookies are used to collect technical information about the services that you use, and how you use them. For more information on the cookies used by Pollogen, please see the section “Use of Cookies” below;
• Where applicable, we may receive or collect the above and/or other information from third parties such as our web and analytical services providers; If you have been contacted by us without having provided your contact information to us, we may have lawfully obtained the above and/or other information from other third parties such as “yellow pages” or other publicly available registries, referrals, data suppliers, or our distributors or business partners that may identify you as a lead or potential client; and
• If you are a prospective buyer or business partner, we may receive credit information about you from credit information providers.
Collection of anonymised data through the Website:
Pollogen collects, via the Website, anonymous demographic information, such as your ZIP code, age, gender, preferences, interests and favourites and other respective data. There is also information about your computer hardware and software that is automatically collected by the Website. This information can include amongst others: your IP address, browser type, domain names, access times and referring Website addresses. This information is used by Pollogen for the operation of the service, to maintain quality of the service, and to provide general statistics regarding use of the Website.
Third party websites:
The Website contains links to other websites that may offer useful information. Pollogen encourages you to review the privacy statements of websites you choose to link to from the Website so that you can understand how those websites collect, use and share your information. Pollogen is not responsible for the privacy statements or other content on websites outside of the Website and Websites’ family of websites. The foregoing includes the case where third-party websites may provide information concerning the collection and use by Pollogen of personal data. In such case, the provisions of this Privacy Statement prevail and supersede any such information.
Update of information and Opt-Out:
You may contact us to update or correct much of your personal information that you provide to us through the Website or other means other than the limited information described below under the Regulatory Requirements and Law Enforcement Section, or to opt-out from our mailings and other services and communications that you may have signed up for. To do so, please contact us at marketing@pollogen.com
2. USE OF YOUR PERSONAL INFORMATION
Pollogen uses personal information, among other things, as follows:
• to deliver the services you have requested, to interact with you and provide or procure responses for comments, questions and requests if posted by you on the Website or otherwise made;
• to operate the Website;
• to protect our materials and content, and the security of our networks and systems;
• to efficiently market and sell our products and services, including by categorizing and classifying Data Subjects in order to personalize our services and advertising to, and interaction with, such persons;
• to inform you of other products or services available from Pollogen;
• we may also contact you via surveys to conduct research about your opinion of current services or of potential new services that may be offered;
• to ensure that the we can facilitate efficient transactions with, and perform our obligations and exercise our rights under contracts with you, if relevant;
• to improve, calibrate and customize our products and services;
• to efficiently manage our business correspondents;
• in general, to efficiently, effectively and securely manage and protect our business, assets and facilities;
• to otherwise fulfil legitimate business purposes (e.g. in relation to a sale of all or part of our business);
• to comply with any legal or regulatory obligations to which we are subject (including compliance with any request from regulatory authorities or other relevant public authorities (see “Regulatory Requirements and Law Enforcement” below);
• to establish, exercise or defend our legal rights or for the purpose of legal proceedings;
• for the prevention and detection of crime or acts of dishonesty, malpractice or other improper or unauthorized conduct; and
• we may use non-sensitive personal data for any other purpose for which we may use sensitive personal data, as detailed below.
Sensitive personal data that we may collect about you:
Certain forms of “sensitive personal data” are subject to specific protection or restriction by law in certain territories, including the EU. For these purposes, “sensitive personal data” is data relating to: racial or ethnic origin; political opinions; religious philosophical beliefs; trade union membership; genetic data; biometric data; data concerning health or sex life or sexual orientation. In addition, we will process data on criminal activity or proceedings, which, although not sensitive data in a strict sense, is treated in a similar way.
We will only process your sensitive personal data if permitted by law and only if one of the following conditions is met:
• you have given explicit consent in writing to the processing of the data (and, for that purpose, if such data is provided by you through the Website, then your submission of the respective form, comment or post in the Website will constitute “explicit consent” in writing);
• the processing is necessary to protect your health, safety or other vital interests in an emergency (or that of another person) where you are physically or legally incapable of giving consent;
• the data in question has been made public by you;
• the processing is necessary for the purpose of, or in connection with, any actual or prospective legal proceedings, for the purpose of obtaining legal advice or otherwise for the purposes of establishing, exercising or defending legal rights subject to applicable local legislation or where courts are acting in their judicial capacity;
• the processing is necessary for reasons of substantial public interest on the basis of local law which is proportionate to the aim pursued and which contains appropriate safeguarding measures;
• the processing is necessary for preventative or occupational medicine;
• the processing is necessary for prevention or detection of crime or acts of dishonesty, malpractice or other improper or unauthorized conduct;
• the processing is necessary for archiving purposes in the public interest or scientific and historical research purposes or statistical purposes; or
• the processing is otherwise permitted by law.
In each case, we will meet any legal requirements and enforce any applicable duties of confidentiality vigorously, for example in relation to access to health records.
Disclosure of Personal Information to Third Parties:
Pollogen does not sell, rent or lease its customer lists to third parties. We may share your personal information within the Pollogen group of companies for the purposes described above. Pollogen will take steps to ensure that the personal information is accessed only by employees of such companies that have a need to do so for the purposes described in this Statement.
In addition, Pollogen may share data with trusted partners and service provides outside Pollogen corporate group for some or all of the purposes described above, including without limitation to help us advertise and market our products and services, perform statistical analysis, surveys, campaigns, send email or postal mail, provide customer support, host databases, provide contact platforms, provide project management tools, process payments or arrange for deliveries and provide financial and legal advice and services. In addition, Pollogen may refer questions posted in our Website to third parties such as local distributors, for response. All such third parties are or will be prohibited from using your personal information except to provide these services to Pollogen, and they are required to maintain the confidentiality of your information.
We may also share personal information with third parties for the following purposes:
• if we sell any of our business or assets, in which case we may disclose your personal data to the prospective buyer for due diligence purposes;
• if we are acquired by a third party, in which case personal data held by us about you may be disclosed to the third-party buyer;
• if required by competent authorities for legal, tax and financial reasons; and
• to the extent required by law, for example if we are under a duty to disclose your personal data in order to comply with any legal obligation, establish, exercise or defend our legal rights.
3. TRANSFERS OF PERSONAL INFORMATION OUTSIDE THE EUROPEAN ECONOMIC AREA
The personal information that we collect from you may be transferred to, and stored at, a destination outside the country in which you reside. It may also be processed by staff operating outside of that country who work for Pollogen, professional advisors or banks.
Where we transfer your personal information to another country, we will ensure that any transfer of your personal information is compliant with data protection law.
You can obtain more details of the protection given to your personal information when it is subject to an ex-EEA Transfer (including a copy of the standard data protection clauses which we have entered or will enter into with recipients of your personal information, if required) by contacting us in accordance with the “Contacting us” section below.
4. USE AND DISCLOSURE OF NON-PERSONAL INFORMATION
Pollogen will not treat as confidential any information that you provide that is not personally identifiable, such as questions, comments, ideas, or suggestions. You should be aware that Pollogen will be free to disclose through any means and use for any purpose such information in its sole discretion. By providing such information to Pollogen, you understand and agree that no relationship has been created between Pollogen and yourself, and Pollogen has no obligation to you whatsoever regarding such information. Where such communications are personally identifiable, they will be treated in accordance with Section 2 above.
5. USE OF COOKIES
General
The Website uses “cookies”. A cookie is a small piece of data sent from a website and stored on the user’s computer or device by the user’s web browser, while the user is browsing. It is used to enable websites to function or to provide information to the owners of a website, or other third parties which receive data obtained from that website. When you visit any web site, it may store or retrieve information on your browser, mostly in the form of cookies. This information might be about you, your preferences or your device. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you and can only be read by a webserver in the domain that issued the cookie to you.
The cookie will remain in the cookies file of your browser after the closing of the browser, and will be reactivated when the Website is reopened, unless removed. You may delete the cookie at any time.
Purposes
One of the primary purposes of cookies is to help you personalize your online experience and provide a convenience feature to save you time. The purpose of a cookie is to tell the webserver that you have returned to a specific page. For example, if you personalize the Website pages, or register with Website services or sites, a cookie helps the Website to recall your specific information on subsequent visits. This simplifies the process of recording your personal information, such as billing addresses, shipping addresses, and so on. When you return to the Website, the information you previously provided can be retrieved, so you can easily use the Website’s features that you customized.
Other primary purposes of cookies include:
• The tracking of Website usage and collecting and recording information about visitors and their use of the Website. This helps us improve the way our Websites work, identify what our users are interested in, and assess the effectiveness of our content by providing statistics and data relating to website use.
• Marketing: Marketing cookies allow us (or third parties) to monitor the behavior of users of our Websites, so as to effectively target relevant content delivery, including advertisements, to users, based on their specific interests on our Websites and of third-party sites. This information also enables us to monitor the effectiveness of our digital marketing campaigns and to understand how useful our advertisements are.
Please note that third parties may use cookies. The kind of cookies and the consequent data processing carried out by such third parties are regulated by their privacy policy. Please see below.
Controlling Cookies
You have the ability to accept or decline cookies. The instructions for removing cookies from your computer or mobile device depend on the operating system and web browser you use. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of the Website’s services. For more information about cookies, including how to set your internet browser to reject cookies, please go to www.allaboutcookies.org.
Third Party Cookies
We use the following third-party systems that rely on use of cookies data:
1. Google Analytics – This Website uses Google Analytics to analyse the use of this Website. Google Analytics uses cookies, to collect standard Internet log information and visitor behaviour information in an anonymous form. The information generated by the cookie about your use of the Website (including IP address) is transmitted to Google. This information is then used to evaluate visitors’ us of the Website and to compile statistical reports on Website activity.
Google’s privacy policy is available at: http://www.google.com/privacypolicy.html.
You can opt-out from Google Analytics using currently available method available at https://tools.google.com/dlpage/gaoptout/.
2. Hotjar web analytics – This Website uses Hotjar web analytics service. Hotjar may record mouse clicks, mouse movements and scrolling activity where we use this information to improve user experience. Hotjar collects information regarding pages visited, actions which are taken, country, device used, operating system, and browser used. Hotjar does not collect personal information that you do not voluntarily enter in this Website. Hotjar does not track your browsing habits across web sites which do not use Hotjar services. For more information about cookies used by Hotjar you may visit:
https://www.hotjar.com/legal/policies/cookie-information.
If you do not want to be tracked by Hotjar on websites, you can turn it off with a “do not track” header or visit https://www.hotjar.com/legal/compliance/opt-out.
3. Display advertising (remarketing) – This Website uses Google Display Advertising to reflect your interests across the web (remarketing). To determine your interests, Google will track your behavior across the web using cookies.
You can view, delete or add interest categories associated with your browser using Google’s Ads Preference Manager, available at: http://www.google.com/ads/preferences/. However, this opt-out mechanism uses a cookie, and if you clear the cookies from your browser yours opt-out will not be maintained. To ensure that an opt-out is maintained in respect of a browser, you should use the Google browser plug-in available at: http://www.google.com/ads/preferences/plugin.
4. Social Media – When we perform advertising campaigns on Facebook, Instagram and LinkedIn, we use cookies placed by such websites for some or all of the purposes described above. For additional information relating to Facebook, you may visit:
https://www.facebook.com/policies/cookies/;
For additional information relating to Instagram:
https://help.instagram.com/1896641480634370
and for additional information relating to LinkedIn, you may visit:
https://www.linkedin.com/legal/cookie-policy
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SECURITY OF YOUR PERSONAL INFORMATION
Pollogen makes reasonable efforts to secure your personal information from unauthorized access, use or disclosure. Pollogen secures the personal information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use or disclosure. However, Pollogen cannot guarantee that it is completely secure from people who might attempt to evade our security measures or intercept transmissions over the Internet.
Where personal information is recorded in hard copy, we take organizational measures to secure such information, such as storing paper records containing personal data in locked cabinets.
7. REGULATORY REQUIREMENTS AND LAW ENFORCEMENT
Pollogen may be required, by court order or as otherwise required by law, to divulge personal information to law enforcement authorities, the courts, or regulatory authorities. Pollogen will cooperate in responding to such requests, in accordance with the regulatory or legal process, and will take appropriate measures to ensure that the requester understands the sensitive nature of any health-related personal information they receive.
If you contact us regarding your experience with using any of our products, we may use the information you provide in submitting reports to the U.S. FDA and/or similar regulatory bodies in other jurisdictions, and as otherwise required of us by law or governmental audit. We may also use the information to contact your healthcare professional to follow up regarding an unexpected event involving the use of any one of our products. You understand that in order to comply with the law, Pollogen may not be permitted to comply with your request to amend or remove personal information that was provided to Pollogen by a healthcare professional or a consumer regarding an adverse event or reaction involving medicine, medical products or medical devices.
8. ONLINE PRIVACY FOR CHILDREN
Pollogen is committed to protecting the privacy of children. We do not intend to collect personal information from children under 18 years old, however Pollogen is dependent on the Website’ users to identify themselves as children under 18 years old and therefore Pollogen will assume no liability thereon if the user’s age was not stated properly or at all. If a child has provided us with personal information, the parent or guardian of that child may contact us at marketing@pollogen.com
9. RETENTION OF PERSONAL INFORMATION
How long we hold your personal information for will vary. The retention period will be determined by various criteria including:
• the purpose for which we are using it – we will need to keep the data for as long as is necessary for that purpose; and
• legal obligations – laws or regulation may set a minimum period for which we have to keep your personal information.
10. YOUR RIGHTS
You have several legal rights in relation to the personal information that we hold about you. These rights include:
• the right to obtain information regarding the processing of your personal information and access to the personal information which we hold about you;
• the right to withdraw your consent to our processing of your personal information at any time. Please note, however, that we may still be entitled to process your personal information if we have another legitimate reason (other than consent) for doing so;
• in some circumstances, the right to receive some personal information in a structured, commonly used and machine-readable format and/or request that we transmit those data to a third party where this is technically feasible. Please note that this right only applies to personal information which you have provided to us;
• the right to request that we rectify your personal information if it is inaccurate or incomplete;
• the right to request that we erase your personal information in certain circumstances. Please note that there may be circumstances where you ask us to erase your personal information, but we are legally entitled to retain it;
• the right to request that we restrict our processing of your personal information in certain circumstances. Again, there may be circumstances where you ask us to restrict our processing of your personal information, but we are legally entitled to refuse that request; and
• the right to lodge a complaint with the data protection regulator (details of which are provided below) if you think that any of your rights have been infringed by us.
You can exercise your rights by contacting us using the details set out in the “Contact Information” section below.
You can find out more information about your rights by contacting the data protection regulator in your jurisdiction, or by searching their website. A list of National Data Protection Authorities in Europe can be found at http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080
. If you are unsure about which is the correct regulator, please feel free to contact us as provided above for assistance.
11. CONTACT INFORMATION
Pollogen welcomes your comments and questions regarding this Privacy Statement. If you believe that the Website has not adhered to this Privacy Statement or if you would like further information on the collection, use, disclosure, transfer or processing of your personal information or the exercise of any of the rights listed above, please address questions, comments and requests to marketing@pollogen.com
We will use commercially reasonable efforts to promptly determine and remedy the problem.
