ENTITYMED PRIVACY POLICY

1. WHAT TYPES OF INFORMATION DO WE COLLECT?

• Non-Personal Information, means information that may be made available to us, or collected automatically via your use of the Services, that does not enable us to identify the person from whom it was collected, or to whom such data pertains. Non-Personal Information usually consists of either technical, analytical, or aggregated information that is not linked to a specific individual;
• Personally Identifiable Information (PII) or Personal Information, means information that pertains to or relates to a specific individual, where such individual is identified or may be identified with reasonable efforts or together with additional information we have access to. Identification of an individual also includes the association of such individual with a persistent identifier such as a name, face image an identification number, a persistent cookie identifier, etc., i.e. an identifier that does not expire at the end of your session in our Services.  Personal Information does not include information that has been anonymized or aggregated; provided, that, such information can no longer be used to identify a specific natural person;

2. HOW DO YOU COLLECT INFORMATION FROM ME?

• We collect information through your use of the Services. In other words, we are aware of your usage of the Services and may gather, collect and record the information relating to such usage, including by using “cookies” and other tracking technologies, as further detailed below.

• We collect information which you provide us voluntarily. For example, we collect Personal information which you voluntarily provide us when you request to use the Services (i.e., photo of your face) and/or receive communications from us or when you contact us directly via the Services.

• In addition, we may publish open positions at EntityMed via our Services or social media such as LinkedIn and others. In connection with such opportunities, we collect information that is voluntarily provided to us by the job candidates (“Candidates”) when they apply to any of the open positions published by us, by e-mail, via the Services or otherwise, and only as necessary for the recruitment process, as further detailed in below.

3. WHY DO YOU COLLECT AND PROCESS MY INFORMATION?

• To provide and operate our Services.
• In order to anonymize it and then after it has been anonymized and cannot be used to identify you, to create cumulative statistical data and other cumulative information that is non-personal, with which we and/or our business partners might make use in order to operate and improve our Services and offer related products.
• Be able to contact Users who requested such contact to be made, for the purpose of providing them with further information on EntityMed and its Services;
• To prevent, detect, mitigate, and investigate fraud, security breaches, or other potentially prohibited or illegal activities;
• To comply with any applicable rule or regulation and/or response or defend against legal proceedings versus us or our affiliates.
• To act upon and comply with requests you may make pursuant to this Privacy Policy and the privacy laws that apply to you. 

4. WHAT ARE YOUR LEGAL GROUNDS FOR COLLECTING MY PERSONAL INFORMATION?

• With your consent: We ask for your agreement to process your information for the specific purposes stated herein and you have the right to withdraw your consent at any time. For example, we ask for your consent to obtained and process your information (which may contain Personal Information) to the Services. 
• Legitimate interests: We process your information for our legitimate interests while applying appropriate safeguards that protect your privacy. This means that we process your information for purposes like detecting, preventing, or otherwise addressing fraud, abuse, security, usability, functionality, or technical issues with our Services; protecting against harm to the rights, property, or safety of our Services, our Users or the public as required or permitted by law; enforcing legal claims, including investigation of potential violations of this Privacy Policy; and in order to comply and/or fulfill our obligations under applicable laws, regulation, guidelines, industry standards and contractual requirements, legal process, subpoena or governmental request. 

5. WHO DO YOU SHARE MY INFORMATION WITH AND WHY?

• Internally and for the provision of the Services – We may share information with our Customers (solely to the extent you receive the Services directly from our Customer), employees, for the purposes described in this Privacy Policy. In addition, should EntityMed or any of its affiliates undergo any change in control, including by means of merger, acquisition, or purchase of substantially all of its assets, your information may be shared with the parties involved in such event under strict security conditions, for the purpose of evaluating such event and in accordance with the terms of this Privacy Policy. If we believe that such a change in control might materially affect your Personal Information then stored with us, we will notify you of this event and the choices you may have, through a prominent notice on our Services.

• Protecting Our Rights and Safety – We may share your information to enforce this Privacy Policy and/or the Terms of Use https://entitymed.com/legal., including investigation of potential violations thereof; to detect, prevent, or otherwise address fraud, security, or technical issues; or otherwise, if we believe in good faith that this will help protect the rights, property or personal safety of any of our users, or any member of the general public.

• Third Parties & Business Partners – We may share your information with a number of selected service providers, whose services and solutions are required or otherwise facilitate achievement of the purposes of processing set forth above. These third parties serve in facilitating and enhancing our Services, namely, among others, to allow cloud hosting services (e.g. Google firebase). Our third-party Services providers act as our sub-processors and may only process your information according to our instructions (which are given in accordance with the terms hereof). We remain responsible for any processing of your information done by such third-party service providers on our behalf not in accordance with the terms hereof, except for events outside of such service providers’ reasonable control.

• Law Enforcement – We may cooperate with government and law enforcement officials to enforce and comply with the law. We may therefore disclose any information to government or law enforcement officials as we believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), to protect our or a third party’s property and legal rights, to protect the safety of the public or any person, or to prevent or stop any activity we may consider to be or to pose a risk of being, illegal, unethical, inappropriate or legally actionable. 

6. WHERE DO YOU TRANSFER OR STORE MY INFORMATION?

• The country to which Personal Information has been transferred has been determined by the EU Commission to be a country providing adequate protection to the privacy rights of EU residents. 
• Application of Standard Contractual Clauses (also known as "Model Clauses") where appropriate.

7. WHAT ARE MY RIGHTS?

• Right of access. You may have a right to know what information we hold about you and, in some cases, to have the information communicated to you. We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any information. 
• Right to correct Personal Information. We endeavor to keep the information that we hold about you accurate and up to date. Should you realize that any of the information that we hold about you is incorrect, please let us know and we will correct it as soon as we can.
• Data deletion. In some circumstances, you have a right to request that some portions of the Personal Information that we hold about you be deleted or otherwise anonymized.
• Data portability. In some circumstances, you may have the right to request that data that you have provided to us is provided to you, so you can transfer this to another data controller.
• Restriction of processing. In some cases, you may have the right to request a restriction of the processing of your Personal Information, such as when you are disputing the accuracy of your information held by us.

8. DO YOU USE COOKIES OR SIMILAR TRACKING TECHNOLOGIES?

9.  HOW DO YOU KEEP MY INFORMATION SECURE?

10.  HOW LONG WILL YOU RETAIN MY INFORMATION?

11.  HOW DO YOU PROTECT THE PRIVACY OF CHILDREN?

12.  HOW DO YOU USE THE INFORMATION OF JOB CANDIDATES?

13.  UPDATES TO THIS PRIVACY POLICY

14.  GENERAL INFORMATION

15.  HOW CAN I CONTACT YOU?

16.  CONTACT US