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, our Cookie Policy ("Cookie 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 USE THE SERVICES.
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 enable you to carry out the main purpose of the Services, meaning receiving information of a general nature about NeuroDerm and its business activities;
b. to handle any questions or complaints you may have about NeuroDerm;
c. to respond to your queries or other corresponding you have submitted through the Site;
d. to place Cookies and similar technologies as described in our Cookie Policy;
e. 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
f. to enable internal record keeping and/or to comply with our legal obligations.
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
We will only collect and process Personal Data about you where we have lawful bases. Lawful bases include consent (where you have given consent), contract (where processing is necessary for the performance of a contract with you (e.g. to deliver the Services you have requested) and “legitimate interests”. 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 process your Personal Data only for specific and limited purposes, including the provision of the Services. We ask only for Personal Data that is adequate, relevant and not excessive for such purposes and internally to help us improve our Services and to help resolve any problems. 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. 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.
Furthermore, 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.
In order to provide you with our Services, we may collect the following types of information:
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 some of the features of the Services.
• Your first and last name
• Email address
• Telephone number
• User communications. When you send an email or other communication to us, including CV’s where you apply for a job at NeuroDerm, 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.
Personal Data we collect automatically.
We may also collect Personal Data about you through the use of cookies and other technologies. This may occur when you visit our Site or third-party websites and may include the following information:
• Information about your device browser and operating system;
• The IP address of the device you are using;
• Usage Patterns record information regarding the method and nature of your use of the Services;
• Links that you click while interactive with our Services.
For further information about the cookies we use and how we use them please see our Cookie Policy here.
This information helps us to understand the usage and preferences of our users, to improve the way the Services work and look, and to create new features and functionality.
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); For further information about the cookies we use and how we use them please see our Cookie Policy here.
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, including for the purpose of providing you with the Services; (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
By providing any Personal Data to us pursuant to this Privacy Policy you fully understand and unambiguously consent to this Privacy Policy and to the collection and processing of such Personal Data. 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. Some of the uses and disclosures mentioned in this Privacy Policy may involve the transfer of your Personal Data to various 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. 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. In this regard please click here in order to review the list of the main third parties service providers and their compliance to the GDPR.
Information Shared with Third Parties. We share your Personal Data with third parties as an essential part of being able to provide the Services to you and only in the following limited circumstances.
• We provide Personal Data to trusted service provider for the purpose of processing Personal Data on our behalf in Israel and/or abroad. We require that these parties agree to process such Personal Data based on our instructions and in compliance with this Privacy Policy, any applicable law and any other appropriate confidentiality, privacy and security measures and protocols.
• NeuroDerm's servers that are used to store your Personal Data are owned and hosted by [ ] (their privacy policies may be found at: [ ] [add hyperlink].
• The Site is hosted by SPD Hosting LTD 2021(their privacy policy may be found at: https://spd.hosting/filestock/file/1568621050182-0.pdf
• 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. The Google Privacy Policy may also be viewed at http://www.google.com/policies/privacy.
• Other Service providers: We share your Personal Data in connection with the provision of the Services or in relation to the performance of our relations, including, without limitation, for: (i) HR services; (ii) analysis and statistics; and (iii) improving our user experience (e.g. implementing application and/or features relating to our Site's functionality and appearance). When dealing with such providers, we require them to strictly comply with all applicable data protection rules and laws, as well as the specific rules applicable to their activities and the protection of the information they process in the course of such activity.
• We have your consent.
• Legal Requirements. We may share your Personal Data when 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.
• 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
NeuroDerm processes Personal Data only for the purposes for which it was collected and in accordance with this Privacy Policy, the Terms, The Cookie Policy or any applicable service agreements. 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. 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.
Upon receipt of your written request and enough information to permit us to identify you and your Personal Data we will disclose to you the Personal Data we hold about you. Upon your request, 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. 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. Requests to delete Personal Data are subject to any applicable legal and ethical reporting or document retention obligations imposed on NeuroDerm and/or its affiliates.
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.
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.
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).
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: [email protected]
Last Updated: November 1, 2020
