Privacy policy

Information you actively provide us

The Service is available only to registered users. You may register with the Platform directly or through your social network account.

Registration. If you register with the Platform directly, we will seek basic information from you such as your name, email address, mobile phone number, physical address and other information that personally identifies you or could be used to personally identify you (the “Personal Information“).

If you choose to register with your social network account (Facebook, etc.), you give us access to retrieve your basic profile information on the social network. The particular categories of information we retrieve from your social network account are the scope of information that the social network makes available to us by default, according to your privacy settings there. The information we collect in this manner typically includes your full name, email address, profile picture and other profile information such as date of birth and gender – to the extent you have these in your profile and the social network gives us access to them.

Payment information. Our third-party billing providers will collect your payment method and billing information for the purpose of collecting the fees applicable to you. The payment information we may store if permitted by you includes your payment card type and the last four digits of the payment card.

Mobile phone number. We collect your mobile phone number. We will use that number to send you Service alerts and notifications via text messages (SMS) and pop-up notifications.

Inquiries. If you contact us for questions or complaints, or for technical support, we will collect the information related to your inquiry. This may include your user ID on the Service, email address and other contact information, depending on the nature of your inquiry.

Information we collect

Medical data. We may collect medical data, solely to the extent needed to provide you with our services. This data may include the doctors, dentists or other healthcare specialists, professionals, providers, or organizations (collectively, “Practitioner(s)”) you have visited and/or Practitioners recommended to you by us, your reasons for visit, your dates of visit, and other medical and health information you choose to share with us by completing medical history forms or otherwise. We may also receive access from Practitioners to some medical data with respect to you (such as diagnosis and/or treatment details) collected or aggregated by such Practitioners, solely for the purpose of providing you with the services. For the avoidance of doubt, all Practitioners are external (third party) service providers and not part of our personnel, and we will not have liability for any part of the medical data and diagnosis with respect to you which may be collected by any Practitioner.

Geolocation information. We collect your precise geolocation when you use the App and your approximate location when you use the Website, provided that you have authorized or consented to it.

Analytic Information. When you access or use the Service, we use analytics tools of third parties to automatically collect information about your use of the Service. This information includes your session durations, the content you accessed on the Service, your interactions and user-interface clicks with respect to such content, referring URLs, and the frequency and scope of your use of the Service, including session recordings which include your real-time behavior when using the Service (the session recording do not include personal data that may identify you).

Device information. We may collect information about your personal computer or mobile device, including its model, its operating system, unique device identifiers, the browser you use, its version and language (i.e. locale) preferences, mobile network information and the Internet Protocol (IP) address through which you accessed the Service.

Other information. We may also collect additional information, which may be Personal Information, as otherwise described to you at the point of collection or pursuant to your consent. You may still access and use part of the Service if you choose not to provide us with any Personal Information, but features of the Service that require your Personal Information will not be accessible to you.

CHILDREN’S PRIVACY

The Service is not intended for children under the age of 18 or people who lack or have limited capacity to act. We do not knowingly or intentionally collect information about children who are under 18 years of age, except as provided by their legal custodians for the purpose of providing such children with Service.

USE OF COLLECTED INFORMATION

Contract: Your consent to your contract to provide the service serves as the legal basis for processing your information. You may withdraw consent at any time, without affecting the lawfulness of data processing we carried out based on your consent before such withdrawal.

We use the information we collect to fulfill our contract with you for the following purposes:

• Operating the Service and providing its features and functionalities.
• Handling the administrative aspects of the Service, such as billing you for applicable fees.
• Sending you updates, notifications and other communications related to the Service (including alerts).
• Providing you with support, handling complaints and contacting you when necessary.
• Enforcing the Terms of Use and this Policy and preventing misuse of the Service.
• Complying with any applicable law and assisting law enforcement agencies and competent authorities, if we believe it is necessary or justified.
• Taking any action in any case of dispute involving you, with respect or in relation to the Service.

Legitimate interest: we have weighed your right to privacy based on the need to adapt to your needs and also offer you our products and, thus, we also process your data for:

• Sending you information bulletins, as well as the improvement and customizing the Service and developing new services.
• Generating statistical and aggregated information about users of the Service.
• Sending commercial communications about our own products and services, similar to those contracted.

MEDICAL DATA

Under the laws of specific jurisdictions (such as HIPAA in the United States), the medical data collected by Air Doctor may be considered “protected health information” (PHI) or similarly defined terms. To the extent not prohibited by applicable law, Air Doctor may use and disclose your PHI in such ways as instructed or permitted by your Practitioner(s).

In the event that Air Doctor shall collect any Protected Health Information (PHI) as such term is defined under HIPAA from US subjects, or from individuals to whom HIPAA or US laws in general apply, Company will ask such subjects to e-sign an authorization (the “Air Doctor Authorization”), with the decision to e-sign the Air Doctor Authorization being entirely voluntary. By choosing to e-sign the Air Doctor Authorization, you will agree that Air Doctor may use and disclose your PHI in the same way it uses and discloses your Personal Information that is not PHI. These uses and disclosures are described in this Privacy Policy. To the extent any provision in the Air Doctor Authorization shall be inconsistent with this Privacy Policy or other provisions of the Terms of Use, then the provisions in the Air Doctor Authorization shall only apply with respect to your PHI. If you do not e-sign the Air Doctor Authorization, then your Personal Information that is not PHI shall be governed by this Privacy Policy, and your Personal Information that is PHI shall be used and disclosed solely in such ways as instructed or permitted by your Practitioner(s).

SHARING INFORMATION COLLECTED

We may share the information outlined in this Policy with others, in any of the following instances:

• With our contractors and service providers (such as data storage providers and billing providers), in order to operate, maintain and enhance the Service;
• With the Practitioners who need to know your medical data in order to assist you and provide the relevant medical services;
• If you have breached the Terms of Use, abused your rights to use the Service, or violated any applicable law. Your information may be shared with competent authorities and with any third party, if we believe it is necessary or justified;
• If the operation of the Service is organized within a different framework, or through another legal structure or entity (such as due to a merger or acquisition);
• We may share Personal Information with our corporate group entities for internal administrative purposes, but their use of such information must comply with the Policy;
• We may share Personal Information (possibly including information received from Practitioners, specifically your diagnosis and treatment details) with your insurance company as required for the purpose of providing you with our services;
• We may share Personal Information with “Assistance Companies”, which are third parties to which we may refer you in order to provide assistance services in relatively urgent cases, requiring hospitalization or evacuation, and which may need to receive your Personal Information (including health data and possibly including information received from Practitioners, specifically your diagnosis and treatment details) in order to properly assess medical and other situations and provide the necessary assistance.

YOUR RIGHTS: ACCESSING, UPDATING OR DELETING YOUR PERSONAL INFORMATION AND OBTAINING A COPY OF IT

You may ask to access the Personal Information about you that is stored in our systems, or have us

update, correct or delete such information. You may also be entitled to obtain from us the personal data you provided us (which, for the avoidance of doubt, will not include aggregated data we obtained from other sources, even if also applicable to you) in a structured, commonly used and machine-readable format, and have the right to transmit those data to another controller. If you wish to exercise any of these rights, contact us using the App or Website, in the “My Account” main section, “Manage Your Account” sub-section or by email to [email protected].

OPPOSITION TO COMMERCIAL PURPOSES AND TREATMENTS BASED ON LEGITIMATE INTEREST

Among other things, we process your personal data and profile for marketing purposes. You have the right to object at any time to processing your personal data for such marketing and for purposes based on legitimate interest. If you raise such an objection for marketing purposes, we will no longer process your personal data for such purposes.

AGGREGATED INFORMATION

We may freely use the information we collect, as outlined above, to compile anonymized or aggregated information that does not identify you. We may share, sell or otherwise communicate and make available such anonymized or aggregated information to any other third party, at our sole discretion.

COOKIES

Cookies are small text files sent to your web browser when you access a website. Different types of cookies are used for different purposes, such as to collect statistical information about your use of a website. We use cookies for analytics purposes explained in the “Information we collect” section above. We do so through Google Analytics cookies and analytics tools of other third parties.

If you wish to block cookies, you may do so through your browser’s settings or by installing a cookie-blocking application for your mobile device. You can delete cookies that are already on your computer and you can set your browser to prevent them from being placed thereafter. Please refer to the browser’s help menu for further information. Please also bear in mind that disabling cookies may adversely indirectly affect your user experience on the Platform.

Cookie Declaration 

Cookie Preferences 

TRANSFER OF DATA OUTSIDE YOUR TERRITORY

We may store and process information in Israel and other countries, such as EU states. We may also process information using cloud services. The laws in such territories may provide a lesser degree of data protection than the laws of your own country. You agree to the transfer of your information to such other countries for the purpose of processing as described in this Policy, including through cloud services.

INFORMATION SECURITY

We implement measures to reduce the risks of damage, loss of information and unauthorized access or use of information. These measures do not provide absolute information security. Therefore, it is not guaranteed and you cannot expect that the Service will be immune from information security risks.

CALIFORNIA RESIDENTS

The following disclosure is made to residents of California pursuant to California Online Privacy Act (CA Civil Code § 22575): When you use our Service, other parties, such as Google, may collect personally

identifiable information about your activities over time and across different websites or online services. We do not respond to browsers’ “Do Not Track” requests.

EUROPEAN CITIZENS

The following disclosures are made to citizens of member states of the European Union (EU) pursuant to the European General Data Protection Regulation (GDPR):

• Right to be informed: If requested we will provide you with a privacy notice to tell you how we are using your personal data.
• Right of access: You have the right to obtain access to your own personal data at any time so you are aware of and can verify the lawfulness of processing. Information will be supplied within one month of receipt of the request. This can be extended by a further two months where requests are complex or numerous. This will be provided free of charge unless you ask for multiple copies or the request is manifestly unfounded or excessive. We can also refuse your request if it adversely affect the rights and freedoms of others or is manifestly unfounded or excessive. You can make a subject access request by contacting us using the App or Website, in the “My Account” main section, “Manage Your Account” sub-section.
• Right of rectification: You have the right to have your personal data rectified if it is inaccurate or incomplete. If we have disclosed this to third parties, we will tell you if this is appropriate and we will inform them of the rectification where possible. We must respond within one month, extendable by two months where the request for rectification is complex.
• Right of erasure: You have the right to request the deletion of personal data where there is no compelling reason for its continued processing or if we are processing it in an unlawful manner – for example if we are using it for a different purpose than originally stated.
• Right to restrict: data processing: Under certain circumstances, you have a right to ‘block’ or suppress processing of personal data. When processing is restricted, we are permitted to store the personal data, but not further process it. We can retain just enough information about you to ensure that the restriction is respected in future.
• Right to data portability: You can obtain and reuse your personal data for your own purposes across different services. This right applies where the processing is based on your consent or for the performance of a contract; and when processing is carried out by automated means.
  • Right to object: You have the right to object to: o Processing based on legitimate interests or the performance of a task in the public interest/exercise of official authority (including profiling);
  • o Direct marketing (including profiling); and
  • o Processing for purposes of scientific/historical research and statistics.
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If we process personal data for the performance of a legal task or our organization legitimate interests, you must have an objection on “grounds relating to your particular situation”. We must stop processing the personal data unless:

• o We can demonstrate compelling legitimate grounds for the processing, which override the interests, rights and freedoms of the individual; or
• o The processing is for the establishment, exercise or defense of legal claims.
• Right to withdraw consent at any time: You may contact Air-doctor to request this. Although we may not be able to accept your request for certain types of data, please contact us if you wish to discuss this further.

• Right to complain: You have the right to complain in any matter relating to our service, including how we use your personal data. Please contact us at [email protected]. You can also contact our EU Representative: Juliana Kyriakides, [email protected]

DATA RETENTION

We retain Personal Information for as long as it is legally required for the purposes set forth above. We may delete any information from our systems, without notice to you, once we deem it is no longer necessary for the purposes set forth above.

If you withdraw your consent to us processing your Personal Information, we will erase it from our systems (unless the data is required for Air Doctor to establish, exercise or defend against legal claims).

In particular, Personal Information provided with respect to your insurance policies will be deleted once no longer needed for us to provide you with services (for example, once the relevant policy expires), unless you have received medical services covered by the policy, in which case we will retain the Personal Information related to that policy as and to the extent required by applicable law.

Please note that uninstalling the App from your device will not necessarily cause your Personal Information to be deleted from our systems or from the Service. Most data will be deleted once no longer needed in order to provide you with services (e.g. after your relevant insurance policy expires), however if you used our services in order to receive any medical services, the data will be retained in accordance with legal requirements.

SURVEYS

From time to time, we may send you surveys or requests to provide feedback (such as scoring service quality), for the purpose of improving service quality. By receiving our services, you provide your express approval to receive such surveys and requests for feedback; However, answering such survey and/or providing feedback will always be optional, not mandatory (and not a condition to receive the services), and at your sole discretion.

NEWSLETTERS

We may send newsletters, but only to registered users, and all newsletters we send will contain an “unsubscribe” link.

CHANGES TO THIS PRIVACY POLICY

We may change this Policy, in which case we will seek your consent to those changes. If you do not consent to the amended Policy, we may terminate your account and block your access to, and use of, the Service. Your following usage of the Platform shall also be deemed as acceptance of the amended Policy.

LANGUAGE

This Policy was originally written in English, and we may translate it into other languages for your convenience. In any contradiction between the versions of these Terms of Use, the provisions of the English version shall prevail.

CONTACT US

You may contact us with any questions or comments, at: [email protected] or using the App or Website.

Our postal address is: Air Doctor Ltd.,

Hashaked 1

Beit Nekofa 9083000

Israel

Effective date of the policy: August 28, 2023