Privacy Policy

Last revised on: October, 2024

Neteera Technologies Ltd. (referred as “Neteera”, “we,” or “us”) develops advanced sensors for non-invasive, real-time monitoring of physiological parameters. Our technology enables continuous health monitoring without physical contact, providing real-time data. This technology is offered to our end users and to various healthcare providers (each “User(s)” or “you”) via our online services (the “Application(s)”). We also operate our website https://www.neteera.com/, as well as any other websites that we own and that link to this Privacy Policy (collectively, the “Website(s)”, and together with the Application – the “Services”).

We at Neteera know that our Users care how their Personal Information is used. This Privacy Policy explains our practices with respect to collecting, using, and disclosing your Personal Information when you access, download, install, register, use, or engage with our Services. If you do not agree to this Privacy Policy, please discontinue and avoid using our Services. You have the right to cease using our Services at any time, pursuant to this Privacy Policy and our Terms of Use, which this Privacy Policy is integrated into and forms part of.

1. Information We Collect

We collect and use the following types of information about you:

Non-Personal Information

Non-personal Information is information that does not relate to an identified or identifiable natural person. As such, we are not aware of the identity of the user from which the non-personal Information was collected.

We may anonymize or de-identify Personal Information collected through the Services or by other means, thereby rendering it non-personal information. We also collect aggregate user data regarding your use and activity on our Services. Non-personal information is not within the scope of this Privacy Policy, and we may use or disclose it to third parties for a variety of purposes.

For the avoidance of doubt, if we combine Personal Information with non-personal information (e.g., analytics data), the combined information will be treated as Personal Information as long as it remains combined.

Personal Information

Personal Information (or “Personal Data”, as these terms are defined under the applicable privacy laws) is information that identifies an individual or that may, with reasonable means, identify an individual.

We collect the following types of Personal Information:

When you interact with the Website:

Contact information: We collect your contact information (such as name, email address, phone number, country, website, and company name) when you submit web forms on our Website. Contact information is also collected when you choose to sign up to receive email communications from us. We may also ask you to submit your contact information if you wish to apply for a job, or when you choose to contact us for other reasons. All communications will be sent in accordance with applicable law. If you no longer wish to receive any communications, you may contact us at privacy@Neteera.com.
Device information: We collect from our Users specific types of connection details and information with regard to their device, software or hardware that may identify them, such as online identifiers, device unique identifiers (e.g., UDID, MAC address), IP address, and geolocation.
Online identifiers: We collect data on our visitors’ use of the Website. We may receive information such as activity, page content, click/touch, movement, scroll, and keystroke activity (in some cases).

When you interact with the Application:

When you interact with the Application, or when the medical staff interacts with the Application on your behalf (for the purpose of this Privacy Policy, both interactions with the Application will be considered as made by you), the following types of Personal Information may be collected:

Registration information: When you register to the Services through the Application, we may collect Personal Information such as full name, ID, email address, phone number, gender, date of birth, and address, as well as other relevant details that you agreed to share with us.
Health-related information: When using the Application, we collect Personal Information concerning your vital signs, as measured by our product.
Technical information: We may collect specific types of connection data and information with regard to your device, software, or hardware that may identify you. Such information may include geolocation data and IP address.
Communication information: We collect the necessary information when you send us an email or otherwise communicate with us, which may include Personal Information that you choose to include in your inquiries.

Certain Personal Information we collect may be considered Protected Health Information or Special Categories of Data under the applicable data protection laws and will be processed exclusively in accordance with those laws.

2. How and Why We Use Your Information

Personal Information we collect is processed for the following purposes:

Under certain circumstances, including when we rely on your consent to process your Personal Information, you have the right to object to such processing. For more information about this right and others, please see Section 7 (“Your Rights”).

If you have any questions about or need additional information concerning the legal basis for our collection and use of your Personal Information, please contact us through the contact details available below.

3. To Whom Do We Disclose Your Personal Information

We work with third parties who help us provide our Services (“Service Providers”). These Service Providers help us store information (such as cloud storage companies), deliver customer support, monitor and analyze the performance of our Services, provide marketing support, and otherwise operate and improve our Services. Service Providers may only process Personal Information pursuant to our instructions and must comply with privacy laws, as well as other relevant data security and confidentiality obligations.

We do not permit our Service Providers to use any Personal Information disclosed for any purpose other than in connection with the services they provide to us.

In addition to disclosing Personal Information to Service Providers, we may also disclose your Personal Information to other third parties, subject to the following circumstances:

With other subsidiaries or affiliated companies;
In the event of a merger, sale, change in control, or reorganization of all or 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;
To enforce our policies, including without limitation our Terms of Service, or to protect the security or integrity of our Services;
Where we have a good-faith belief disclosure 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 policies, or as otherwise required to comply with our legal obligations; or
As you may otherwise consent from time to time.

We may also disclose non-personal information (such as anonymous usage data, referring/exit pages and URLs, platform types, number of clicks, etc.) with authorized third parties to help them understand the usage patterns for certain Services.

4. Storage and Processing

Information collected through Neteera’s Website may be stored and processed in the United States, Israel, Europe, or any other country in which Neteera, its affiliates, or Service Providers maintain facilities. When transferring Personal Information of European Economic Area (“EEA”) or UK residents outside the EEA or UK, we transfer such Personal Information only to countries approved by the European Commission as providing adequate level of data protection or, alternatively, enter into legal agreements that ensure an adequate level of data protection.

5. How We Protect Your Personal Information

Personal Information is protected by robust safeguards to ensure secured processing. For example, we ensure Personal Information is encrypted both in transit and at rest, and any access is strictly limited to a minimum number of authorized individuals who are subject to confidentiality commitments.

We will take all steps necessary to ensure that your Personal Information is treated securely and in accordance with this Privacy Policy. However, please note that the transmission of Personal Information via the internet is not completely secure. While we make every effort to protect your Personal Information, we cannot guarantee its security. We encourage you to exercise discretion regarding the Personal Information you choose to disclose.

6. Cookies and Tracking Technologies

When you visit or access our Websites, we use (and authorize 3rd parties to use) pixels, cookies, events, and other technologies (collectively, “Tracking Technologies”). Those allow us to automatically collect information about you, your device, and your online behavior in order to enhance your navigation in our Websites, improve our Websites’ performance, perform analytics, and customize your experience. In addition, we may merge data we have with data collected through these tracking technologies and data we may obtain from other sources, and, as a result, such data may become Personal Information.

For more information about the cookies we use please read our Cookies Policy.

Additionally, our Website includes social media features, such as the Facebook Like button and other widgets. These features may collect your IP address and which page you are visiting on our Website and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our Website. Your interactions with these features are governed by the privacy policy of the organization providing it.

7. Your Rights

Data protection laws in certain jurisdictions provide Users with certain statutory rights to their Personal Information. If you reside in the EU or UK, you have the right to take the following actions regarding your Personal Information, subject to the applicable restrictions:

Right of access: The right 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.
Right to data portability: The right to receive your Personal Information in a structured, commonly used, and machine-readable format.
Right to correction: The right to request rectification of your Personal Information that is in our control.
Right to deletion: The right to request erasure of your Personal Information.
Right to object to processing: The right to object or withdraw consent to the processing of your Personal Information.
Right to restrict processing: The right to request to restrict the processing of your Personal Information.
Right not to be subject to automated decision-making: Under certain circumstances, you have the right to opt out of the use of automated decision-making in relation to your Personal Information.

Please note that these rights are not absolute and may be subject to our own legitimate interests and regulatory requirements.

If you wish to raise a complaint on how we have handled your Personal Information, you can contact us at the contact details available below. You also have a right to lodge a complaint with your applicable supervisory authority.

8. Our Retention of Your Personal Information

We only process and store Personal Information for the period necessary to achieve the purpose for which it was collected or for the duration required by laws and regulations we are subject to. Retention periods are determined based on the type of the Personal Information collected and the purpose for which it is collected, considering the requirements applicable to the situation and the need to destroy outdated or unused Personal Information at the earliest reasonable time.

9. Minors

We do not knowingly collect or solicit personal information from anyone under the age of majority (as determined under the applicable laws where the individual resides; “Age of Majority”). By accessing, using, or interacting with our Services, you confirm that you are not under the Age of Majority. In the event we discover that we have collected Personal Information from an individual under the Age of Majority without verified parental consent, we will delete that information upon discovery. If you believe we might have any information about an individual under the Age of Majority, then please contact us through the contact details available below.

10. Links to Other Websites

We are not responsible for the practices of websites or services linked to or from the Neteera Services, including the information or content contained therein. When you use a link to navigate from the Services to another website or service, your browsing and interaction are subject to that third party’s own rules and policies.

11. Additional Information for US Residents

This part of the Privacy Policy addresses the specific disclosure requirements under:

The California Consumer Privacy Act of 2018 (Cal. Civ. §§ 1798.100–1798.199), as amended by the California Privacy Rights Act of 2022, and the regulations enacted thereunder (collectively: “CCPA”)
The Virginia Consumers Data Protection Act of 2021
The Colorado Privacy Act of 2023
Connecticut Data Privacy Act of 2023
The Utah Consumer Privacy Act of 2022.
Oregon Consumer Privacy Act of 2023; and
Texas Privacy and Security Act of 2023.

Depending on the applicable jurisdiction, Personal Information may not include: publicly available information that is lawfully made available in government records; information that a User has made available to the public, including via widely distributed media; de-identified or aggregated information, and information excluded from US Privacy Laws such as Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPPA); clinical trial data, and any Personal Information covered by certain sector-specific privacy laws, such as the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA), and the Driver’s Privacy Protection Act of 1994.

Collection, disclosure and sharing of Personal Information:

In the preceding twelve (12) months, we have collected the following Personal Information:

Category A- Identifiers: A real name, unique personal identifier, online identifier, Internet Protocol address, email address, social security number, driver’s license number, passport number, and other similar identifiers.

Category B- Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)): A name, physical characteristics or description, address, telephone number.

Category C – Characteristics of protected classifications under California or federal law: Race, color, sex/gender, pregnancy, childbirth, breastfeeding, gender identity/expression, medical condition, ancestry, disability, genetic information, age.

Category D – Commercial information: Products and services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

Category E – Biometric information.

Category F- Internet or other electronic network activity information: Browsing history, search history, information on a User’s interaction with a website, application, or advertisement.

Category G- Geolocation data: Physical location or movements.

Category H- Sensory data: Audio, electronic, visual, or similar information.

Category I- Professional or employment-related information: Current or past job history or performance evaluations.

Category K – Inferences drawn from any of the information above to create a profile about a User reflecting the User’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Category L – Sensitive Personal Information (also defined as “Sensitive Data” under certain US privacy laws):

Precise geolocation (i.e., data that locates an individual within a geographic area that is equal to or less than the area of a circle with a radius of 530 meters).
Genetic data/processing of genetic or biometric information for the purpose of uniquely identifying a User.
Personal Information collected and analyzed concerning a User’s health.
Personal Information collected and analyzed concerning a User’s sex life or sexual orientation.
Personal Information revealing mental or physical health diagnosis.
Social security, driver’s license, state identification card, or passport number.

We collect such Personal Information from the following categories of sources:

Directly and indirectly from your activity on our Services: For example, directly from you when you inquire about our Website or provide information via our Applications, or indirectly, we collect your usage data automatically from measurement tools.
Directly from you: For example, from forms you complete, when you contact us, etc.
Indirectly from you: For example, when you view or interact with certain content, web pages, or ads.
From third parties: For example, from Service Providers who assist us in performing the Services, advertising networks, internet service providers, data analytics providers, social networks, and data brokers.

We may use the Personal Information collected for the following purposes:

To fulfill or meet the reason you provided the Personal Information for (support, respond to a query, etc.)

To improve and provide our Services
To maintain our Services
For marketing our Services
For analyzing your use of the Services
To respond to law enforcement
To enforce our policies, to defend from claims or exercise our legal rights
For any other reason detailed in this Privacy Policy.

We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

We do not “Sell” or “Share” personal information, as these terms are defined under US Privacy Laws.

In the preceding twelve (12) months, we disclosed your Personal Information. When we disclose Personal Information, we enter a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except the performance of the contract. We also prevent the recipient from Selling or Sharing your Personal Information.

In the preceding twelve (12) months, we disclosed the categories of Personal Information described above for the following purposes. We ensure all purposes are valid “business purposes,” as defined under the applicable US Privacy Laws:

User Rights Under US Privacy Laws

US Privacy Laws provide Users with specific rights regarding their Personal Information, in addition to the rights described under section 7 (“Your Rights”):

Right to Opt-out from profiling in furtherance of decisions that produce legal or similarly significant effects concerning you: You have the right to request to opt-out from processing involving profiling, in furtherance of decisions that produce legal or similarly significant effects concerning you. “Profiling” means any form of automated processing performed on Personal Information to evaluate, analyze, or predict personal aspects related to your economic situation, health, personal preferences, interests, reliability, behavior, location, or movements.
Right to non-discrimination: The right not to receive discriminatory treatment by the business for the exercise of privacy rights, including an employee’s, applicant’s, or independent contractor’s right not to be retaliated against for the exercise of their rights, denying a consumer goods or services, charging different prices or rates for goods or services, providing you a different level or quality of goods or services, etc. We may, however, charge different prices or rates or provide a different level or quality of goods or services if that difference is reasonably related to the value provided to us by your Personal Information.
Right to limit the use or disclosure of Sensitive Personal Information: You have the right to request to limit the collection of your Sensitive Personal Information (as this term is defined under the applicable US Privacy Laws) to that use which is necessary to maintain our Services.
Right to opt-out of cross-contextual targeted advertising: You have the right to opt-out of the sharing of your Personal Information for “cross-contextual behavioral advertising,” often referred to as “interest-based advertising” or “targeted advertising.” As stated above, please note that we do not share your Personal Information for these purposes.
Right to opt-out of the sale of Personal Information: The right to opt-out of the sale of your Personal Information, as these terms are defined under the applicable privacy laws. As stated above, please note that we do not sell your Personal Information.

The following table describes the rights you may be entitled to. Please note that some rights are only available for residents of specific jurisdictions:

Authorized Agents

“Authorized agents” may submit opt-out requests on a consumer’s behalf.

If you are a Virginia or Colorado resident, you have the right to appeal any rejection to your request. The appeal request shall be submitted through our email address: privacy@Neteera.com.

If you are a Virginia resident, you can lodge a complaint with the Virginia Attorney General through his/her contact information available here: https://www.oag.state.va.us/contact-us/contact-info or file the complaint at: https://www.oag.state.va.us/consumer-protection/index.php/file-a-complaint.
If you are a Colorado resident, you can lodge a complaint with the Colorado Attorney General at https://complaints.coag.gov/s/contact-us.

Special requirements under the CCPA: Under the CCPA, if you have elected to use an authorized agent or if you are an authorized agent who would like to submit requests on behalf of a consumer, the following procedures will be required prior to acceptance of any requests by an authorized agent on behalf of a California User. Usually, we will accept requests from qualified third parties on behalf of other consumers, regardless of either the consumer or the authorized agent’s state of residence, provided that the third party successfully completes the following qualification procedures:

When a consumer uses an authorized agent to submit a request to know or a request to delete, a business may require that the consumer do the following:

1. 1. Provide the authorized agent signed permission to do so or power of attorney.
  2. Verify their own identity directly with the business.
  3. Directly confirm with the business that they provided the authorized agent permission to submit the request.

We may deny a request from an authorized agent that does not submit proof that they have been authorized by the consumer to act on their behalf.

Notice of Financial Incentive

We do not offer financial incentives to consumers for providing Personal Information.

Additional disclosures for California residents:

Direct Marketing Requests: California Civil Code Section 1798.83 permits you, if you are a California resident, to request certain information regarding disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please contact us via the details below.

“Do Not Track” Settings: Cal. Bus. And Prof. Code Section 22575 also requires us to notify you how we deal with the “Do Not Track” settings in your browser. As of the effective date listed above, there is no commonly accepted response for Do Not Track signals initiated by browsers. Therefore, we do not respond to the Do Not Track settings. Do Not Track is a privacy preference you can set in your web browser to indicate that you do not want certain information about your web page visits tracked and collected across websites. For more details, including how to turn on Do Not Track, visit: www.donottrack.us.

12. Changes to this Policy

All changes to this Privacy Policy are effective when posted on this page. If we make significant changes to the Privacy Policy, we will notify you via email and/or a prominent notice on our Website prior to the change becoming effective and update the “effective date” at the top of this page.

13. How to Contact us

If you have any questions about this Privacy Policy, our practices, or your dealings with our Services, please contact us at privacy@Neteera.com.

IS-0015 Privacy Policy Rev 3.0