We develop next-generation treatments for the central nervous system (“CNS“). Our products address deficiencies in current treatments for the growing population of moderate to severe Parkinson’s disease patients. While using our Website we keep your personal information personal and private. We will not sell, rent, share, or otherwise disclose your personal information to anyone except as necessary to provide our services or as otherwise described in this Policy.
- FROM WHOM DO WE COLLECT PERSONAL INFORMATION?
This Policy applies to our collection, use, and disclosure of the personal information of the following categories of individuals:
- Website Visitors: Individuals who visit our Website. For the purposes of this Policy, “Website” shall refer to https://neuroderm.com.
- Contacts: Individuals who volunteer certain contact information (such as their name and email address) to receive communications from us, including Individuals who provide us with their personal data by filling out the contact form in the Website in order to participate in our clinical trials or to receive more information regarding the clinical studies we are conducting (collectively “Services”).
- WHAT PERSONAL INFORMATION DO WE COLLECT?
- The Tracking Technologies. When you visit or access our Website, we use (and authorize third parties to use) web beacons, cookies, pixel tags, scripts, tags and other technologies (“Tracking Technologies“).
- Log Files. Just as when you visit and interact with most websites and services delivered via the Internet, when you visit our Website, we gather certain information and store it in log files. This information may include but is not limited to Internet Protocol (IP) addresses, system configuration information, URLs of referring pages, and locale and language preferences.
- Name, email address, and other contact information. We ask for and—at your option—collect your contact data (such as name and email address) from you when you submit web forms on our Website “Contact” page.
- Additional Personal Information. When contacts submit their personal information via the Website by filling in the contact form, they consent that the personal information they volunteer will be processed by us for purposes of the Services we provide (as described below).
- LEGAL BASIS FOR PROCESSING (EEA ONLY):
If you are an individual from the European Economic Area (EEA), please note that our legal basis for collecting and using your personal information will depend on the personal information collected and the specific context in which we collect it.
We will process your Personal Information for a variety of reasons, each of which is prescribed by relevant data protection laws.
- Consent– our processing of your personal information will primarily be necessary for us to provide you with the Services. However, on certain occasions we may ask for your consent to process personal information. In these instances your personal information will be processed in accordance with such consent and you will be able to withdraw this consent in writing at any time. Where we rely on your consent to process your personal information, you have the right to withdraw or decline consent at any time. Where we rely on our legitimate interests to process your personal information, you have the right to object.
- Fulfillment of a contract, compliance with a legal obligation– we process your personal information where it is necessary for the performance of a contract or in order for us to comply with our various legal and/or regulatory responsibilities.
- Legitimate interests – we also process your personal information where we deem such processing to be in our (or a third party’s) legitimate interests, always provided that such processing will not prejudice your interests, rights and freedoms. Examples of us processing in accordance with legitimate interests would include: (i) where we disclose your personal information to any one or more of our associate/subsidiary companies following a restructure or for internal administrative purposes; (ii) adhering to regulatory and statutory requirements; (iii) sharing personal information with our advisors and professional service providers (such as auditors) for ensuring our compliance with regulatory requirements and industry best practices.
- Special Categories of Personal Data– our processing of your personal information may also involve special categories of personal data, such as your genetic information of health information (as defined under Article 9 of the GDPR). We will process such information, as well as disclose it to competent authorities, where it is necessary for the following purposes (to the extent permissible by applicable law): (i) where you have given your explicit consent to the processing of such information for one or more specified purposes, (ii) where processing is necessary to protect your vital interests or of another natural person where you are physically or legally incapable of giving consent; (iii) processing is necessary for the purposes of preventive or occupational medicine, for medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems and services, subject to the obligation of professional secrecy; (iv) processing is necessary for reasons of public interest in the area of public health, such as protecting against serious cross-border threats to health or ensuring high standards of quality and safety of health care and of medicinal products or medical devices; and (v) processing is necessary for scientific research purposes or statistical purposes, subject to suitable measures safeguarding your interests.
- HOW DO WE USE YOUR PERSONAL INFORMATION?
Neuroderm only processes personal information in a way that is compatible with, and relevant for the purpose for which it was collected or authorized. As a general matter, for all categories of information we collect, we may use the information we collect to:
- provide, operate, maintain, improve, and promote the Website and Services;
- enable you to access and use the Website and Services;
- process and complete transactions, and send you related information, including purchase confirmations and invoices;
- send transactional messages, including responses to your comments, questions, and requests;
- send commercial communications, in accordance with your communication preferences, such as providing you with information about products and services, features, surveys, newsletters, offers, promotions, contests, and events about us and our partners; and send other news or information about us and our partners.
- monitor and analyze trends, usage, and activities in connection with the Website and Services and for marketing or advertising purposes;
- comply with legal obligations as well as to investigate and prevent fraudulent transactions, unauthorized access to the Services, and other illegal activities;
- personalize the Website and Services, including by providing features or content that match your interests and preferences; and
- process for other purposes for which we obtain your consent.
- INTEREST-BASED ADVERTISING & USER CHOICE
Through our Website, we may provide advertisements that are tailored to you, for example ads that are based on your recent browsing behavior across different websites, browsers, or devices.
You can turn off certain third party Tracking Technologies used for behavioral advertising purposes by visiting the Network Advertising Initiative or by visiting the DAA opt-out program or the EDAA consumer choice page (if you reside in the EU). Please note that certain Tracking Technologies operate at the device and browser level, so to fully opt-out across devices, you will need to do so on each device and browser individually.
- HOW DO WE SHARE YOUR PERSONAL INFORMATION?
Specifically, we do not permit our Service Providers to use any personal information we share with them for their own marketing purposes or for any other purpose than in connection with the services they provide to us.
In addition to sharing with Service Providers as described above, we may also share your information with others in the following circumstances:
- In the event of a merger, sale, change in control, or reorganization of all our part of our business;
- When we are required to disclose personal information to respond to subpoenas, court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims;
- Where we have a good-faith belief sharing is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our Services’ agreements, or as otherwise required to comply with our legal obligations; or
- as you may otherwise consent from time to time.
- INTERNATIONAL INFORMATION TRANSFERS
- DATA SUBJECT RIGHTS
Website Visitors and Contacts: If you reside in the EU (or in other jurisdiction that affords you with the below rights), you may request to:
- Receive confirmation as to whether or not personal information concerning you is being processed, and access your stored personal information, together with certain supplementary information.
- Receive personal information you directly volunteer to us in a structured, commonly used and machine-readable format.
- Request rectification of your personal information that is in our control.
- Request erasure of your personal information.
- Object to the processing of personal information by us.
- Request to restrict processing of your personal information by us.
However, please note that these rights are not absolute, and may be subject to our own legitimate interests and regulatory requirements. You also have a right to lodge a complaint with a supervisory authority.
We will retain your personal information for as long as necessary to operate our Website or provide Services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our policies. Retention periods shall be determined taking into account the type of information that is collected and the purpose for which it is collected for, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time.
- DATA SECURITY
We have implemented administrative, technical, and physical safeguards to help prevent unauthorized access, use, or disclosure of your personal information.
While we seek to protect your information to ensure that it is kept confidential, we cannot guarantee the security of any information. You should be aware that there is always some risk involved in transmitting information over the internet and that there is also some risk that others could find a way to thwart our security systems. As a result, while we strive to protect your personal information, we cannot ensure or warrant the security and privacy of your personal information or other content you transmit using our Services or the Website, and you do so at your own risk. Thus, we encourage you to exercise discretion regarding the personal information you choose to disclose.
- NOTE FOR MINORS
We do not knowingly collect or solicit personal information from anyone under the age of consent (as determined under the applicable laws where the individual resides; “Age of Consent”). By accessing, using or interacting with our Website or Services, you certify to us that you are not under the Age of Consent. In the event that we learn that we have collected personal information from an individual under the Age of Consent without verification of parental consent, we will delete that information upon discovery. If you believe that we might have any information from or about an individual under the Age of Consent, then please contact us through the contact details available below.
- CONTACT INFORMATION
You can contact us through the below contact details:
Attn: Data Protection Officer
Email address: DPO@neuroderm.com
3 Pekeris Street, Ruhrberg Science Bldg.,
Rabin Science Park,
Rehovot 7670212, Israel