Privacy Policy – Medisafe Project, updated May 2016

This Privacy Policy applies to your use of the MEDISAFE mobile device application (the “App”) and related website located at www.medisafe.com/privacy (including the mobile-optimized versions of such website, the “Site”) owned by MEDISAFE PROJECT LTD. The App may be used in conjunction with authorized connected devices of the iConnect brand (including the iCap and iSort), which are products of TIMERCAP LLC, and are referred to as “Connected Devices”. Individually or collectively both companies may be referred to as “we” or “us”. The App and the Site are referred to together as the “Application”.  

The integrated offering comprised of the Application and the Connected Device and any part thereof is referred to as the "Solution". 

‘You’ refers to any user of the Solution, including individuals who use the Application and/or Connected Devices to track medication compliance, healthcare providers who use the Application to monitor compliance of users under their supervision and “Medfriends” (described below).  If you do not agree to the terms of this Privacy Policy, including with respect to (a) the collection and processing of Health Information (as defined below), (b) the collection and processing of your geo-location data (c) our cookies policy, (d) cross-border transfer of data and (e) marketing, please do not click “START NOW” or “Sign up” and do not use the Solution.

We have the highest regard for your privacy and personal information and realize that the success of our service depends on the trust that users have in the way we handle their personal information. This policy sets out our commitments and explains the rights that you have with respect to your personal information.

INFORMATION COLLECTION AND USE
Medisafe respects your right to privacy. While you may use some of the functionality of the Site without registration, use of the Solution and certain tools of the Site require registration. If you use our Site without registering, we only collect information through the use of cookies, web beacons and navigational data collection. While we cannot directly identify you, in some jurisdictions, this information is still subject to applicable data protection laws and requires your consent to our cookies policy as described below. If you choose to register with us, you will be asked to provide Personal Information (as defined below) and may also be asked to input personal Health Information. It is your voluntary decision whether to provide us with any such Personal Information or Health Information, but if you refuse to provide such information we may not be able to register you to use the Solution or your use of the Solution may be limited.

Collecting and Using Your Information
Collecting and Using Your Personal Information and Health Information (Actively Provided Information)
Whenever you submit information via our App or Site, or otherwise in connection with your use of the Application, and whenever you use a Connected Device, including, but not limited to, by telephone or email with customer service, you consent to the collection and processing of your Health Information and geo-location data and other personal information you provide to us, our cookies policy, cross-border transfer of data, and the use of your data for marketing purposes, all in accordance with this Privacy Policy. Medisafe and TimerCap respect your right to privacy. Please read this Privacy Policy for more information about collection, storage, use, processing, combination, deletion and disclosure of your Personal Information.

“Personal Information” means information that can be directly associated with a specific person (and includes Health Information). When you register or update your information on our Site or through our App, we collect Personal Information including your:

·         first and last name,

·         e-mail address,

·         year of birth,

·         gender,

·         language

·         geographic location, including your zip code.

If you are a healthcare provider, during registration you will be asked to provide information regarding your professional qualifications as well as other Personal Information.  

During registration or subsequently, you may choose to use certain features of the Application and/or Connected Devices that will allow you to input other Personal Information with respect to your health, such as the medications you take, the date of your prescription, the number of refills you have made, how often you take your medication, the frequency you would like us to send you reminders to take your medication, whether you take your medication, your doctor’s name and the name of your pharmacy (“Health Information”). Some of this Health Information will be collected when you use the Application and/or Connected Devices. We will send you reminders to take your medications in accordance with this information.

You may also send family members or friends an invitation to be your “Medfriend” by means of the Application, so that such Medfriends will receive alerts regarding your compliance with your medication regime. By sending such invitation, you represent that you have the right to contact the Medfriends and that you consent to our sending Personal Information about your medications and your compliance with your medication regime to the Medfriends. Sharing of your Personal Information in this manner is solely your responsibility.

You may use the Application and/or Connected Devices in order to share your Personal Information or other information with your doctor or healthcare providers.  Such sharing may be enabled by inviting your healthcare provider to monitor your Personal Information, by accepting an invitation from your healthcare provider to download and use the Application and/or Connected Devices, or otherwise using the Application and/or Connected Device settings to share your information with your healthcare provider; in these cases you consent to our sending Personal Information about your medications and your compliance with your medication regime with your healthcare providers. Confirm with your healthcare provider that they have sent you an invitation to download Medisafe. Such sharing of your information is at your discretion and is solely your responsibility.

If you are a healthcare provider using the Application to invite individuals under your supervision to use the Application and/or Connected Devices, you agree not to include any Personal Information about you or your professional qualifications in the text of these invitations.  We may also use your Personal Information in order to provide you with personalized third party content or links to third party sites that might interest you, as part of the feed on the Application. We provide this third party content and/or links to third party sites for information purposes only and are not liable for such content or sites. For more information see the “Links to other Websites or Apps” section below.

We may also use the Personal Information (1) to identify your account for purposes of providing you with customer services and to respond to your requests, (2) to provide you the specific services you select (including the requested reminders), (3) to help diagnose problems with our servers, to make the Application and/or Connected Devices more useful, for other internal purposes or to customize the Application and/or Connected Devices and personalize their content for you; and (4) to send you texts, emails or other communications regarding general adherence information, Application and/or Connected Devices maintenance, updates, or changes to this Privacy Policy or any other relevant agreements. Please note that we reserve the right to send you such service related communications without offering you the opportunity to opt out of receiving them unless you cancel your account.

While we take great care to keep your Personal Information confidential and secure, when you share your health or medication information with others or provide feedback regarding health matters, medications and otherwise, including by means of social media sites, or when you participate in a forum on the Application, any information disclosed that may be automatically made public, and such information will not be considered Personal Information by us. You should exercise caution when disclosing any information (including Personal Information) in such ways, as you do not know who will access or use such information and for what purposes. Your Personal Information will not be combined with other information and will not be used for other purposes, except as explained in this policy. Please note that we are not subject to medical secrecy obligations.

Ensuring the accuracy and completeness of the Personal Information and any other information that you provide in connection with your use of the Application and/or Connected Devices is important. Inaccurate or incomplete information will affect the functioning of the Application and/or Connected Devices, as well as the information you receive from us and our ability to contact you.

Automatic Data Collection
Site: We collect information about your use of the Site (IP address, type of computing or mobile device you use, language of your operating system, the Internet browser you are using, geo-location and use of the Site) through the use of various technologies, such as cookies, web beacons and navigational data collection (log files, server logs, clickstream). For more information on our cookies policy, please see below.

App: When you download and install our App onto a mobile device, we assign a random number to your App installation. We do not use this number to identify you personally unless you choose to become a registered user of the App. We use this random number in a manner similar to our use of cookies as described in this Privacy Policy. Because the random number is assigned to your installation of the App itself, it cannot be removed through the settings of your App or your device. If you do not want us to use the random number for the purposes for which we use cookies, please do not install our App. Instead, please use your mobile device browser to access our Site.

Connected Device:  When you use a Connected Device, Personal Information, including the time the Connected Device is used and the associated medication, is collected automatically.

 

The App may automatically collect certain information about you when you use the App, such as the type of computing or mobile device you use, your device’s IP address and/or unique device ID, your device’s operating system, the language of your operating system and the Internet browser you are using. We may use third party service providers to collect such information, in order to assist us with the following: pseudonymized installation tracking, social media recommendations, anonymized crash tracking, anonymized behavior tracking and testing (including in real time) and anonymized A/B testing. We collect such information in order to facilitate use and ensure technical functioning of the App and/or Connected Devices, dynamically generate and deliver targeted content, statistically monitor usage of the App and/or Connected Devices, and improve the overall quality of our users’ experiences.

Data collected automatically on the Site or App and/or Connected Devices may be used, for example, to help diagnose problems with our servers, to make the Site, App and/or Connected Devices more useful, to customize Site, App and/or Connected Devices and personalize their content for you.

Cookies
A cookie is a small piece of text that is sent to a visitor’s browser. The browser provides this piece of text to the device of the originating visitor when this visitor returns. We use cookies to help personalize your Medisafe experience. A “persistent” cookie may be used to help save your settings and customizations. Also, if you log in to the Site, such a cookie will be used to recognize you as a valid user so you will not need to log in each time you use the Site. Most Web browsers automatically accept cookies, but allow you to modify security settings so that you can approve or reject cookies on a case-by-case basis or reject all cookies. You can configure your web browser to remove cookies by following the directions provided in your Internet browser’s “help” section.

·         Safari

·         Opera

·         Firefox

·         Google chrome

·         Internet explorer

Also, you are free to delete any existing cookies at any time. If you delete or disable cookies from our Site, some parts or functions of the Site may not work properly for you.

Sharing of Your Personal Information with Third Parties and Service Providers
Medisafe and TimerCap respect your right to privacy. This privacy policy explains Medisafe’s and TimerCap’s policies regarding the collection, use, disclosure and protection of Personal Information. Please read it carefully.

We will not publish your Personal Information without your explicit consent. However, we might share your Personal Information, as is reasonably necessary, without your consent with: (1) our contractors or consultants who are bound by an obligation of confidentiality, provided that we will only share Personal Information to the extent necessary with such contractors or consultants; and 2) affiliates of our company for the purposes of improving our marketing strategies, for research purposes and for entering into commercial contracts in order to provide our users with Medisafe’s and/or and TimerCap’s services.

We participate in Apple’s HealthKit framework. In order to learn more, please follow this link:https://www.apple.com/ios/whats-new/health/. This framework allows various apps to share health and fitness data, as well as allowing the integration of data directly from health and fitness devices. HealthKit gives you control over which data you share. You will be asked to provide separate consent for each type of data to be shared. You will also be asked which authorized app will share or receive your data. We will not sell any personal data (including data obtained from Apple’s HealthKit framework) and will not use this data for advertising purposes. We will use data that you consent that we receive from HealthKit for medical research purposes, internally in order to improve our products and services and in the form of aggregated and/or analytical data as described in the Use of Aggregated Data section of the Privacy Policy and may transfer this data to third parties for such purposes. We may provide our users with the ability to share their data with other authorized applications on their device after receiving their consent for the same. Please note that, while all applications or devices authorized by HealthKit must agree to Apple’s terms, when you share information with third party apps, such information will be subject to their privacy policy, over which we have no control, We will not sell any personal data or disclose any personal information (including data obtained from Apple’s HealthKit framework) and will not use this data for advertising purposes.
Please note that we may share your de-identified data, except Apple HealthKit data, with such third parties without obtaining such consent.

Additionally, you may choose to share your Personal Information with pharmacies with which we partner and/or third party coupon companies, in order that we may send you coupons and/or provide you with reminders to get your prescription refilled. If you choose to share your Personal Information in this manner, please note that such information may be disclosed to the coupon companies and/or pharmacies and will be subject to their privacy practices.

We may share your Personal Information with third parties, such as research institutes, healthcare systems or doctors, for research purposes and so that they can cross-check such information with other information that they have about you, for research purposes and for improvement of our services. We will first obtain your consent for the same. Please note that we may share your de-identified data with such third parties without obtaining such consent.

From time to time, we may also ask whether you would like us to share your Personal Information with another company that may want to send you information about their products or services. If you consent to such transfer by us of your Personal Information to another company, please note that the information provided will be subject to such company’s privacy practices and shall not be within our control.

Sometimes we may provide limited access to your Personal Information to the extent necessary to our contractors and consultants, including vendors and suppliers that provide us with development services, technology, services, or content for the operation, development and maintenance of our Application and/or Connected Devices or data and analysis on Application and/or Connected Devices use. Such access is limited to the information reasonably necessary for the contractor or consultant to perform its services to us. We also require that such contractors and consultants agree to protect the privacy of your Personal Information and agree not to use or disclose Personal Information for any purpose other than providing us with products and services and as required by law.

In addition we may share your personal data with third parties, such as law enforcement authorities, courts and tribunals, to respond to law enforcement requests or other legal requests or pursuant to a requirement imposed by law, order, judgment or decree.

We may also share your Personal Information with legal advisors, consultants, or courts in order to protect and defend our rights and property or those of Application and/or Connected Device users. We may also transfer your Personal Information in the event of a merger, acquisition or sale of all or a portion of our assets.

Use of Aggregated Data
We may analyze all information we receive and/or combine your Personal Information, including Health Information and information regarding your use of the Application and/or Connected Devices, with information from other users to create aggregated data that may be disclosed to and utilized by us, our affiliates and by third parties without restriction, on commercial terms that we can determine in our sole discretion for purposes of content marketing, for research purposes, in order to understand behavior patterns and in order to increase adherence to medication regimens. As an exception to the above, we will not include data received via Apple HealthKit In the aggregated data we share with and/or sell to affiliates or third parties. Such aggregated data will not contain any information that could be used to contact or identify you. We also use a tool called “Google Analytics” to collect information about the use of the Application and/or Connected Devices. Google Analytics collects information such as how often users visit the Application, what pages they visit when they do so, and what other sites they used prior to coming to the Application. Google Analytics collects only the IP address assigned to you on the date you use the Application and/or Connected Devices, as well as information regarding your operating system, language and information regarding your use of the Application and/or Connected Devices, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with Personal Information. We use the information we get from Google Analytics only to improve the Application and/or Connected Devices. Google’s ability to use and share information collected by Google Analytics about your use of the Application and/or Connected Devices is restricted by the Google Analytics Terms of Use located at

 http://www.google.com/analytics/terms/us.html

and the Google Privacy Policy located at http://www.google.com/policies/privacy/.

DISABLING THE SERVICE, ACCESS, CORRECTIONS AND DELETION
At any time, you can stop the collection of your information by uninstalling the App and refraining from using the Site and/or Connected Devices. You may also request that your Personal Information be deleted from our active databases. We cannot restore information that we have deleted. You are responsible for backing up the data that you store on the Application and/or by use of the Connected Devices. We may retain any data in non-identified form, subject to applicable law.

You may contact us as specified below under “How to Contact Us” to access information that we keep about you or update or correct such information or ask for its deletion. We will retain your information for as long as you continue to use our Site, App and/or Connected Devices and for a reasonable period of time afterwards.

You have the right to object to direct marketing.

LINKS TO OTHER WEBSITES OR APPS
Our Application may link to or refer to websites or mobile device applications that we do not control. Any Personal Information you provide on the linked pages is provided directly to this third party and is subject to this third party’s provider’s privacy policy. This Privacy Policy does not apply to such other websites or applications, and we are not responsible for the privacy practices or content of any website or application not controlled by us. If you have any concerns, we urge you to review the terms of those other websites or applications for more information about their applicable policies.

SECURITY
We take reasonable steps to protect Personal Information as you transmit it to us and to protect such information from loss, misuse and unauthorized access, disclosure, alteration or destruction. However, you should keep in mind that no Internet transmission is ever completely secure or error-free.

If you use and/or access the Application and/or Connected Devices on or from an Android device which you or someone else rooted or on or from an iOS device which you or someone else jail broke, we shall not be responsible for the security of your data, including your Personal Information, and you shall bear all responsibility for any breach, illegal access, loss and/or corruption of such data.

CHILDREN
Our Application and/or Connected Devices are intended for use by persons 18 years of age and older. Under no circumstances should the Application and/or Connected Devices be used by children under 14 years of age, and we will not knowingly collect Personal Information from any person we know to be in this age group. If you are using the Application and/or Connected Devices for the benefit of a child, please do not provide information relating to such child unless you have obtained the child’s parents’ or guardians’ consent, including their consent to this Privacy Policy. If you discover that your child has been using the Application and/or Connected Devices without your consent, or that someone has been using the Application and/or Connected Devices for or on behalf of your child without your consent, please contact us using the information below under “How to Contact Us,” and we will take reasonable steps to delete the child’s information from our active databases.

INTERNATIONAL TRANSFERS
We store your Personal information on servers located in the United States.  We may access or process Personal Information from Israel, which has been recognized by the European Union as providing an adequate level of protection in relation to automated international transfers of personal data from the European Union to Israel. Additionally, we may use subcontractors that are located in countries other than your own, and send them or provide them with access to information we receive. All our subcontractors will be subject to non-disclosure and non-use obligations. Nevertheless, some countries may have levels of protection of personal and other information which are not as high as in your country of residence or business.

We may transfer our databases containing your Personal Information if we sell our business or part of it.

HOW TO CONTACT US
If you have any questions, comments, requests, or concerns related to this Privacy Policy or the privacy practices for our Application, please contact us at:

MEDISAFE
ATTN: Medisafe Project LTD.
Building #25, MATAM, Haifa 31905, Israel

Info@Medisafe.com 

 

If you have any questions, comments, requests, or concerns related to the iConnect products, including iCap and iSort, please contact us at:

TIMERCAP

ATTN: TimerCap, LLC

484 East Los Angeles Ave., #110, Moorpark, CA 93021

Info@TimerCap.com

 

CHANGES TO PRIVACY POLICY
From time to time we may need to change this Privacy Policy. You will be informed of such change in advance, and you will always have the possibility to stop using the service as explained above.

This Privacy Policy was last updated in May 2016.