Privacy Policy

NeuroDerm Ltd. of 3 Pekeris Street, Ruhrberg Science Bldg., Bell Entrance, Rabin Science Park, Rehovot, Israel (“NeuroDerm” and all references, as the context requires, to “we”, “us” or “our”) is committed to protecting and respecting your rights to privacy. The basis on which any personal data we collect from you, or that you provide to us through our website neuroderm.com (the “Site”), will be processed by us on a lawful basis as set forth in this Privacy Policy and in our Terms and Conditions (the “Terms”).

Please read the following carefully to understand our views and practices regarding your personal data and how we will collect, use including in respect of any use of the Services (as defined below) and disclose information. This Privacy Policy applies to all of the software, services, information, tools, features and functionality offered by NeuroDerm on the Site (the "Services"). Should we ask you to provide certain personal data when using our Services, you can be assured that it will only be used in accordance with this Privacy Policy.

IMPORTANT: BY USING THE SERVICES, YOU GIVE YOUR CONSENT THAT ALL PERSONALLY IDENTIFIABLE INFORMATION ("PERSONAL DATA") THAT YOU SUBMIT OR THAT IS COLLECTED THROUGH THE SERVICES MAY BE PROCESSED BY NEURODERM IN THE MANNER AND FOR THE PURPOSES DESCRIBED IN THIS PRIVACY POLICY.
IF YOU DO NOT AGREE TO THE TERMS AND CONDITIONS SET FORTH HEREIN, PLEASE DO NOT SUBMIT ANY PERSONAL DATA AND/OR USE THE SERVICES AND/OR THE SITE.

We recommend that you read this Privacy Policy in full, but here are some key issues we hope you will find useful:

Overview of the main Issues covered under this Privacy Policy
1. The use of your Personal Data
2. Third Parties Processing Your Personal Data
3. Links to Third Party Websites
4. Your Privacy Rights
5. Information Security
6. Minors
7. Enforcement
8. Updates to this Privacy Policy
9. Contact Us

Data We Collect. When you use the Services, we may collect your Personal Data that you upload and/or transmit through the Services, including device information (i.e. log data) for the following purposes:

a. to handle any questions or complaints you may have about NeuroDerm;

b. to respond to your queries or other corresponding you have submitted through the Site;

c. to place Cookies and similar technologies as described herein;

d. to improve the user experience and the content of the Site and to optimize and tailor the use of our Sites and our communication to you; and

e. to enable internal record keeping and/or to comply with our legal obligations.

Your Rights. Upon receipt of your written request and enough information to enabling us to identify you and subject to applicable law, we will disclose to you the Personal Data we hold about you, correct, amend or delete any Personal Data that is inaccurate and notify any third party who received this Personal Data from us of the necessary changes. Where we rely on your consent to process Personal Data, you have the right to withdraw or decline your consent at any time and where we rely on legitimate interests, you have the right to object. To learn more about how to exercise your rights please review Section 4 below.

Keeping your Personal Data Accurate. We take reasonable steps to ensure that the Personal Data we process is accurate, complete, and current, but we depend on our users to update or correct their Personal Data whenever necessary. Upon receipt of your written request and enough information to enabling us to identify you, we will disclose to you the Personal Data we hold about you. Upon your request, and subject to applicable law, we will also correct, amend or delete any Personal Data that is inaccurate and notify any third party who received this Personal Data from us of the necessary changes. Where we rely on your consent to process Personal Data, you have the right to withdraw or decline your consent at any time and where we rely on legitimate interests, you have the right to object. To learn more about how to exercise your rights please review Section 4 below.

Keeping your Personal Data Secure. We take generally accepted technical and organizational measures to protect your Personal Data from unauthorized access, unauthorized alteration, misuse or destruction. The server on which the Services are hosted and/or through which the Services are processed may be outside the country from which you access them and may be outside your country of residence. Most of the information is saved to the cloud for backup.

Transfer of your Personal Data. Some of the uses of the Personal Data may involve the transfer of your Personal Data to various service provider of us, established in countries around the world that may have different levels of privacy protection than your country. However, we take additional measures when information is transferred from the European Economic Area (EEA). This includes having standard contractual clauses approved by the European Commission in our contracts with parties that receive information outside the EEA. We also rely on European Commission adequacy decisions about certain countries, as applicable, for data transfers to countries outside the EEA. Here is a list of our main service providers.

Children. The Services are not directed towards children under 18, they are not allowed to register with or use the Services.

1. The use of your Personal Data

When you use our Site and/or otherwise contact us we act as a data controller. This Privacy Policy explains how we use and might share your Personal Date received via our Site, our business partners or directly from you.

Legal basis.
We will only collect and process Personal Data about you where we have a lawful basis and only for specific and limited purposes.
You can decline to submit Personal Data, in which case we may not be able to provide you with part or all of the Services.
We rely on the following legal grounds:

Based on your consent. Where you have given consent and to the extent that you have not objected to the use of your Personal Data within this context, including for analytics, advertising and marketing activities.
For the fulfilment of contractual obligations. Mainly, when you contact us and/or request us to receive more information on the Company, including to provide you with the Services and when you apply for a job at the Company.
For the pursuit of our legitimate interests. To the extent necessary, we may process your Personal Data, in order to protect the legitimate interests of NeurDerm or third parties. This includes our commercial interests, including our interest in improving your user experience in our Site and protecting the security and integrity of the Site, and internal record keeping.
Due to legal obligation. We may be obligated to process some of your Personal Data to comply with applicable laws and regulations.

Where we rely on your consent to process Personal Data, you have the right to withdraw or decline your consent at any time and where we rely on legitimate interests, you have the right to object.

We ask only for Personal Data that is adequate, relevant and not excessive for the purposes for which we asked such Personal Data. The specific purposes of the different types of Personal Data collected are listed below.

We will not collect or use Personal Data for purposes other than those described in this Privacy Policy and/or in any other legal instrument in effect between us.

Unless stated otherwise in this Privacy Policy, we will not share, sell, auction off or give away your Personal Data to any third-party or other organization without first obtaining your prior written consent. For further information on information sharing see Section 2 ("Third Parties processing your Personal Data") below.

Type of Personal Data being Processed:

Personal Data you provide us directly

General Information: When you choose to communicate with us, we may collect the following Personal Data. Please note that you do not have to provide the below mentioned Personal Data, but in such a case we may not be able to provide you with the requested Services.

• Your first and last name
• Email address
• Telephone number
• User communications. When you send an email or other communication to us, we may retain those communications in order to process your inquiries, address complaints, respond to your requests and improve our Services.

This Personal Data is necessary in order to provide you information, support or other services that you request from us. Furthermore, we are required to keep such information in accordance with legal requirements applicable to the Service.

When applying for a job.

We receive Personal Data about you as a candidate for positions at NeuroDerm, such as: contact information, address, Curriculum Vitae (resumé) information (including information such as skills, work experience, education), notes submitted with the application, the position for which you have been or are being considered, email and other correspondences in connection with your candidacy, information from references, information about your candidacy and employment options, materials you or other parties (such as evaluators or background check providers) submitted in relation to your candidacy.
We use your Personal Data to evaluate and consider you as a candidate for positions, in accordance with our processes and policies for evaluating employment candidates, to contact you for your candidacy status and interviews, to schedule meetings and interviews, amongst others.

Cookies, Device and Traffic Information.

When you use our Site, details of your usage may be automatically registered by our systems and/or through web analysis tools owned by our business partners. Such information may include your IP address, mobile device configuration, browser or mobile carrier, operating system, http-header user agent, device-specific information, exit point and usage time. We collect and may use such information to prepare aggregated statistic reports of user’s activity, which do not contain any personal data.

We also use cookies to improve the security and functionality of the Site and your user experience. A cookie is a small piece of information which is sent to and stored on your device. Cookies do not damage your device. Most browsers or devices may allow you to block cookies, but you may not be able to use some features within our Site if you block them. Below you will find more detailed information about our cookies and the reason for using them.

Necessary Cookies. These cookies are necessary for the Site to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as filling in forms. For example, we use a third party cookie by Google named “_grecaptcha cookie” which provides spam protection and blocks bots and other automated attacks, e.g., prevents fake signups and remove invalid email addresses.

Functional Cookies. These cookies are set by us our by third party service providers we use to implement additional functions or to enhance features on our Site. For example, our accessibility tool uses cookies in order to remember your accessibility settings, including any choice of yours to move or hide the accessibility widget.

Advertising Cookies. These cookies enable to generate personalized advertisements or content on third-party websites by containing a unique ID Google uses to remember your preferences and other information. These cookies are used to be able to deliver content that fits your interests on third party websites. When you visit our site via Chrome, Google may use your interactions on our website together with personal information you have provided to Google and its business partners.

If you choose to block these cookies, you will not necessarily receive less advertising, just that the advertising you receive will be less targeted to your preferences.
Information we obtain from third parties.

We sometimes supplement the information that you provide with information that is received from third parties (see further information below under Section 2 ("Third Parties processing your Personal Data") below).

Record Keeping.
In all circumstances, Personal Data will be retained in accordance with applicable data privacy laws, including the EU General Data Protection Regulation 2016/679 (the “GDPR”), as following: (i) for no longer than is necessary in relation to the purposes for which such Personal Data was collected or otherwise processed; (ii) In the event you withdraw your consent and there are no more legitimate grounds for the processing; or (iii) as necessary to comply with legal obligations, resolve disputes and enforce our agreements.
Once data is no longer lawfully required it will be destroyed securely.

2. Third Parties Processing Your Personal Data

Personal Data may be transferred, processed, hosted and stored in countries outside: (i) the country from which you access the Services; (ii) your country of residence; and/or (iii) the European Economic Area (“EEA”), that may have different levels of privacy protection than your country.

However, we take additional measures when information is transferred from the European Economic Area (EEA). This includes having standard contractual clauses approved by the European Commission in our contracts with parties that receive information outside the EEA. We also rely on European Commission adequacy decisions about certain countries, as applicable, for data transfers to countries outside the EEA. By submitting your Personal Data through the Services, you consent, acknowledge, and agree that we may collect, use, transfer, and disclose your Personal Data as described in this Privacy Policy.

Information Shared with Third Parties.
We share your Personal Data with third parties as an essential part of being able to operate the Site and provide the Services to you. We require that these parties agree to process such Personal Data for the purpose of providing the contracted service to us and in compliance with applicable law and any other appropriate confidentiality, privacy and security measures and protocols.
Below you can find a list of the categories of our service providers by whom Personal Data may be processed or transferred to and for what purposes.

CATEGORY OF RECIPIENT / SERVICES	REASON FOR TRANSFER
Infrastructure, storage and security	• Secured storage of all Personal Data. • Data management. • Prevent fake signups and remove invalid email addresses. • Website maintenance and content management. • Website’s server • IT support
Customer Service and Communications	• Email services.
HR services	• recruiting and applicant tracking platform.
User Experience	• implementing application and/or features relating to our Site's functionality and appearance. • NeuroDerm’s Site uses YouTube API Services to display videos, which are bound by the YouTube Terms of Service: https://www.youtube.com/t/terms.
Analytics	• See information under the “Cookies, Device and Traffic information” Section above.

Personal Data may be shared with, or transferred to, our affiliated corporate group entities (entities controlled by, under common control with, or controlling us, directly or indirectly).
We may also share some of your Personal Data in the following circumstances:

A. If we have a good faith belief that access, use, preservation or disclosure of such Personal Data is reasonably necessary to: (i) satisfy any applicable law, regulation, legal process or enforceable governmental request; (Ii) enforce applicable agreements and/or their terms, including investigation of potential violations thereof; (iii) detect, prevent, or otherwise address fraud, security or technical issues; or (iv) protect against imminent harm to the rights, property or safety of NeuroDerm, its users or the public as required or permitted by law.

B. If we become involved in a merger, acquisition, or any form of sale of some or all of our assets or in the event of our bankruptcy, insolvency, reorganization, receivership, or assignment for the benefit of creditors, or the application of laws or equitable principles affecting creditors' rights generally, you will be notified on a best efforts basis via email and/or a prominent notice on our website, of any change in ownership, uses of your Personal Data, and choices you may have regarding your Personal Data. In any of the circumstances above, your Personal Data will continue to be used in accordance with this Privacy Policy.

3. Links to Third Party Websites

Links to other sites may be provided by us as a convenience to our users. NeuroDerm has not reviewed all of the sites linked to the Site and is not responsible for the content of any off-site pages or any other sites linked to the Site, including their privacy practice. Your visiting any other off-site pages or other sites is at your own risk. We are not responsible for the privacy practices or the content of other sites and you visit them at your own risk. We recommend you to carefully read the terms of use and privacy policies of such off-site pages. This Privacy Policy applies solely to Personal Data collected by us.

4. Your Privacy Rights

According to applicable data protection laws and regulations, you may have the following rights:
a) requesting information on Personal Data that we hold about you;
b) demanding that the information be rectified should it be incorrect;
c) asking that your data be deleted, if NeurDerm is not permitted or is not legally obliged to retain the data;
d) demanding that the processing of your data be restricted;
e) objecting to the processing by us;
f) requesting that any Personal Data submitted by you will be transferred in a generally useable, machine-readable, and standardized format.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to an unauthorized recipient.
We do not charge for complying with a correction request, however, for all other requests, we may charge a small fee to cover its costs.

We may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others, or would be extremely impractical, or for which access is not otherwise required.

Furthermore, we commit to notify you, when it is needed under applicable law, and data protection authorities within the timeframe specified in applicable law about personal data breaches related to your Personal Data.

For further information about the above mentioned rights and how to exercise them, please contact us in accordance with the “Contact Us” Section below.

5. Information Security

We follow generally accepted industry standards to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of Personal Data. We have physical, electronic, and procedural security measures and safeguards to reasonably protect Personal Data. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security. If you have reason to believe that your use of the Services is no longer secure, please immediately notify us of the problem by contacting us in accordance with the “Contacting Us” section below.

Nothing in this Privacy Policy is interpreted as an obligation to store information, and we may, at our own discretion, delete or avoid from recording and storing any and all information.

6. Minors

The Services are not directed towards children under 18, they are not allowed to register with or use the Services or provide Personal Data. If you are under the age of 18 or the age of legal majority where you reside if that jurisdiction has an older age of majority, you must obtain parental consent (or consent from your legal guardian) prior to using our Services. We do not knowingly contact or engage with children under the age of 18 (or the age of legal majority where you reside if that jurisdiction has an older age of majority) without said parental consent (or consent from your legal guardian). If you have reason to believe that children data is collected, you are kindly requested to immediately report it to us.

7. Enforcement

NeuroDerm regularly reviews its compliance with this Privacy Policy. Please feel free to direct any questions or concerns regarding this Privacy Policy or our treatment of Personal Data by contacting in accordance with the “Contacting Us” Section below. We will cooperate with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of Personal Data that cannot be resolved between NeuroDerm and an individual.
If you're based in the European Economic Area and think that we haven't complied with data protection laws, you have a right to lodge a complaint with the Data Protection Commission in the United Kingdom or the European Union or with your local supervisory authority.

8. Updates to this Privacy Policy

We may update this Privacy Policy from time to time without notification. Nevertheless, we will notify you about significant changes in the way we treat your Personal Data already submitted by placing a prominent notice on the website. We encourage you to periodically review this Privacy Policy for the latest information about our privacy practices. Please take a look at the “LAST UPDATED” legend at the bottom of this page to see when this Privacy Policy was last revised. Any changes to this Privacy Policy will become effective when we post the revised Privacy Policy on the Site. Your use of the Services following these changes means that you accept the revised Privacy Policy.

9. Contact Us

If you have any questions about this Privacy Policy, concerns about the way we collect or process your Personal Data, or if you wish to delete all information regarding your use of the Services, please feel free to contact us at: info@neuroderm.com

Last Updated: August 8, 2023