You are not required by law to provide us with any Personal Data. However, please note that some of our services and website features require the processing of certain Personal Data and without such data we may not be able to provide you with all or part of such services and features.
Last Updated: January 15, 2024
Section 1 - General Privacy Practices
We reserve the right to amend this Policy from time to time, at our sole discretion. The most recent version of the Policy will always be posted on the website. The updated date of the Policy will be reflected in the “Last Modified” heading. Any amendments to the Policy will become effective immediately, unless we notify you otherwise. If we materially change the way in which we process your previously collected personal data, we will provide you with prior notice, or where legally required, request your consent prior to implementing such changes. We strongly encourage you to review this Policy periodically to ensure that you understand our most updated privacy practices.
Echo Care Technologies Ltd. is the Data Controller (as such term is defined under the GDPR or equivalent privacy legislation) of your Personal Data of the Personal Data collected from you as a visitor or user of our website.
You may contact us as follows:
- By email: email@example.com
- By Phone: +972-8-613-3338
- By Mail: 5 Golda Meir St., Ness-Ziona, 7403649, Israel
Representative for data subjects in the EU and UK Contact Information:
PrighterGDPR-Rep by Maetzler Rechtsanwalts GmbH & Co KG
C/O EchoCare Technologies Ltd.
1010 Vienna, Austria
Please add the following subject to all correspondence: ID-15983622231
Below you can find information regarding the purposes for which we process your personal data as well as our lawful basis for processing, the definition of “personal” and “non-personal” data, and how it is technically processed.
During your interaction with the Website, we may collect aggregated, non-personal non-identifiable information (“Non-Personal Data“ ). We are not aware of the identity of the user from which the Non-Personal Data is collected. We collect Non-Personal Data regarding your use of the website, such as the scope, frequency, latency, pages accessed and viewed, time and date stamp, interactions with content and materials displayed through our website, language preference, and other technical information regarding the device used to access the website, for example type of device, type of browser, operating system, etc. Non-Personal Data may be used by us without limitation and for any purpose.
We may sometimes process and anonymize or aggregate Personal Data and identifiable information in a manner that shall create a new set of data that will be Non-Personal Data. Such a new data set can no longer be associated with any identified natural person.
If we combine Personal Data with Non-Personal Data, the combined information will be treated as Personal Data or for as long as it remains combined.
We may also collect from you, directly or indirectly, during your access or interaction with the website, individually identifiable information, namely information that identifies an individual or may, with reasonable effort, be used to identify an individual (“Personal Data”). The types of Personal Data that we collect as well as the purpose for processing and the lawfulness are specified in the table below.
On our website, we do not knowingly collect or process any Personal Data constituting or revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data, data concerning a person’s health or data concerning a person’s sex life or sexual orientation (“Special Categories of Personal Data”).
The table below details the processing of Personal Data, the purpose, lawful basis, and processing operations:
|Purpose and Operations
If you voluntarily contact us, e.g., through a “contact us” form in our website, you may be required to provide us with certain information such as your name, job title, company name, email address, and any additional information you decide to share with us.
|We will use this data to respond to your inquiry. The correspondence with you may be processed and stored by us in order to improve our internal operations, as well as in the event we reasonably determine it is needed for future assistance or to handle any dispute you might have with us. We may retain and manage such information through the use of external services and platforms such as CRM systems.
|We process such Contact Information subject to our legitimate interest.
|Newsletter & Updates Registration
In the event you sign up to receive our newsletter or other promotional materials, you will be requested to provide your contact details, such as email address.
|We will use the information you provide in order to include you in our mailing list and send you the materials you have signed up to receive.
|Our lawful basis for the processing of this data is your consent. You may withdraw your consent at any time by clicking the “unsubscribe” link which will be included in the email we will send you. You may also contact us through the above means of contact and request to unsubscribe.
|Online Identifiers and Advertising and Targeting data
When you interact with the website, we may collect online identifiers such as your Internet Protocol address (IP), Cookie-ID, etc., and other information that relates to your activity through the website, such as pages viewed, click stream data, login time and date stamp, etc. This data might be collected directly by us or by through our use of third parties’ cookies and advertisement platforms.
Similarly, we may collect Ad calls, which is a code shared with advertisers, include zip code, advertiser ID, the webpage the end user came from, the IP address, approximate location which assists the advertiser to determine which ads to place. The ad call will also include the end user’s preference regarding interest-based advertisement as further explained herein.
|Collection of device identifiers is needed for the following purposes:
(i) Internal statistics and analysis, for which device identifiers might be combined with usage data, for example, to analyze how many visitors have accessed certain content and from which country (where the country is extracted from the IP address) in order to enhance and improve our website and its content;
(iii) Marketing and advertising purposes. Our partners will process this data to manage and deliver advertisements and content more effectively and personally, including contextual, behavioral and interests-based advertising based on your activity, preferences or other data available to us or to our business partners and advertisers, including for re-targeting purposes.
|Our lawful basis for processing this data for technical and security purposes is based upon our legitimate interests.
If we will process your Personal Data for analytics and advertising purposes and to the extent required under applicable laws (e.g., if we use third party cookies), we will obtain your consent for such processing. In any such case, you may withdraw consent or change your preferences at any time by using the cookie settings tool available on our website.
Please note that the actual processing operation per each purpose of use and lawful basis detailed in the table above may differ. Such processing operation usually includes a set of operations made by automated means, such as collection, storage, use, disclosure by transmission, erasure, or destruction. The transfer of personal data to third-party countries, as further detailed in the Data Transfer Section, is based on the same lawful basis as stipulated in the table above.
In addition, we may use certain Personal Data to prevent potentially prohibited or illegal activities, fraud, misappropriation, infringements, identity thefts, and any other misuse of the website and to enforce the Terms, as well as to protect the security or integrity of our databases and the website, and to take precautions against legal liability. Such processing is based on our legitimate interests.
Depending on the nature of your interaction with us, we may collect the above detailed information from you, as follows:
There are several types of cookies, including without limitation:
- Essential, Functionality, Operation & Security Cookies – these cookies are essential for enabling Visitor movement around the website, for the website to function properly, and for security purposes (i.e., used to authenticate Visitors, prevent fraudulent use, and protect Visitor data from unauthorized parties). This category of cookies either cannot be disabled, or if disabled, certain features of the website may not work.
- Analytic, Measurement & Performance Cookies – these cookies are used to collect information about how Visitors use our website, in order to improve our website, content, and the way we offer them, as well as assess performance of the content and marketing campaigns. These cookies enable us, for example, to assess the number of Visitors who have viewed a certain page as well as their country of origin. It enables our website to remember information that changes the way it behaves or looks, such as your preferred language.
- Preference, Targeting & Advertising Cookies – these cookies are used to advertise across the internet and to display relevant ads tailored to Visitors based on the parts of the website they have visited (e.g., the cookie will indicate you have visited a certain webpage and will show you ads relating to that webpage).
You may find more information about the cookies we use as well as opt-out of cookies or change your preferences at any time by using the cookies setting tool available on our website.
Where we use third-party advertising cookies, such third-party may independently collect, through the use of such tracking technologies, some or all types of Personal Data detailed above, as well as additional data sets, including to combine such information with other information they have independently collected relating to your online activities across their network of websites, for the purpose of enhanced targeting functionality and delivering personalized ads, as well as providing aggregated analytics related to the performance of our advertising campaign you interacted with. These third parties collect and use this information under their own privacy policies, and we are not responsible for their privacy practices.
We share your data with third parties, including our partners or service providers that help us operate and make the most of the website. You can find here information about the categories of such third-party recipients.
|Categories of Recipients
|Our Affiliated Companies
|We may share Personal Data with our affiliated companies and subsidiaries in order to provide joint services, for example, marketing, improving our services, etc.
|Our Service Providers
|We share your Personal Data with our trusted service providers and business partners that perform business operations for us on our behalf (as data processors) and pursuant to our instructions. This includes the following categories of service providers:
• Advertising and marketing service providers, who help us with advertising measurements, email marketing, etc.;
• Data storage providers, with whom we entrust the hosting and storage of our data;
• Consent Manager (CMP), an external service that provides us with the ability to allow website visitors to control and manage their cookies preferences and consent;
• General IT and SaaS providers providing us with IT systems for the management of our daily conduct;
• Data analytics and data management providers, who help us improve, personalize and enhance our operation;
• Data security partners, who help us detect and prevent potentially illegal acts, violations of our policies, fraud and/or data security breaches and ensure compliance with legal obligations.
|In some cases when we buy media online, we may submit unique identifier. This unique identifier provided to the media owner, may become personally identifiable when and if such media owner combines our parameters with its own existed information about you, to which you gave your consent when first interacting with such media owner’s services (for example social media Services).
|Legal and Law Enforcement
|We may disclose certain Personal Data to law enforcement, governmental agencies, or authorized third parties, in response to a verified request relating to criminal investigations or alleged illegal activity or any other activity that may expose us, you, or any other Visitor to legal liability, and solely to the extent necessary to comply with such purpose.
When we share information with service providers and partners, we ensure they only have access to such information that is strictly necessary for us to operate the website. These parties are required to secure the data they receive and to use the data for pre-agreed purposes only while ensuring compliance with all applicable data protection regulations (such service providers may use other non-personal data for their own benefit).
In general, we retain the Personal Data we collect for as long as it remains necessary for the purposes set forth above, all under the applicable regulation, or until you express your preference to opt-out, where applicable.
Other circumstances in which we will retain your Personal Information for longer periods of time include: (i) where we are required to do so in accordance with legal requirements, or (ii) for us to have an accurate record of your interaction with us in the event of any inquiries or contact requests, or (iii) if we reasonably believe there is a prospect of litigation relating to your Personal Data. Please note that except as required by applicable law, we will not be obligated to retain your data for a particular period, and we may delete it for any reason and at any time, without providing you with prior notice of our intention to do so.
We take great care in implementing physical, technical, and administrative security measures for the website that we believe comply with applicable regulation and industry standards to prevent your information from being accessed without the proper authorization, improperly used or disclosed, unlawfully destructed, or accidentally lost.
Due to our global business operation, we may store or process your Personal Data in several territories, including, for example in Israel, the UK, EU, US or in other countries (whether directly or through the use of our vendors). Thus, your Personal Data may be transferred to and processed in countries other than the country from which you accessed our websites or otherwise the country of your jurisdiction. We will take appropriate measures to ensure that your Personal Data receives an adequate level of data protection upon its transfer in accordance with applicable law.
Further, when Personal Data collected within the EU is transferred outside the EU (and not to a recipient in a country that the European Commission has decided provides adequate protection) it shall be transferred under the provisions of the standard contractual clauses approved by the European Union. If you would like to understand more about these arrangements and your rights in connection therewith, please contact us at our email.
In addition, some of the third parties used for cookies management in our website, may store and process data globally, including in the US (e.g., Google Analytics servers). When granting consent for such cookies through the cookies tool on the website, you hereby acknowledge and approve such cross-border transfer, in accordance with such third party’s privacy practices.
According to data protection and privacy laws may grant you certain rights with regards to your Personal Data, all according to your jurisdiction. The rights may include one or all of the following: (i) request to amend your Personal Data we store accessing; (ii) review and access your Personal Data that we hold; (iii) request to delete your Personal Data that we hold (as long as we do not have a legitimate reason for retaining the data); (iv) restrict or object to the process your Personal Data; (v) exercise your right of data portability (vi) contact to a supervisory authority in your jurisdiction and file a complaint; and (vii) withdraw your consent (to the extent applicable).
When you contact us and request to exercise your rights regarding your Personal Data, we will require certain information from you in order to verify your identity and locate your data and that the process of locating and deleting the data may take reasonable time and effort, as required or permitted under applicable law. Data privacy and related laws in your jurisdiction may provide you with different or additional rights related to the data we collect from you, which may also apply.
You have the right to lodge a complaint with the EU Member State supervisory authority if you are not satisfied with the way in which we handled the complaint.
For additional rights under various jurisdictions, including US state laws, please refer to Section 2 “JURISDICTION-SPECIFIC NOTICES” herein below.
Interest-Based Advertising (“IBA”)
We do not sell your Personal Data. Our websites may include providing you with advertisements, therefore, we may “share” your Personal Data with third parties for personalized advertising purposes. If you wish to opt-out from the sharing of your personal data with third parties for the purpose of cross-contextual interest-based advertising there are many ways to do so, as further detailed below. Please note that even if you opt-out you may still see personalized ads based on information other companies and ad networks have collected about you, if you have not opted out of sharing with them.
For IBA opt out options on desktop and mobile websites, please visit:
- Digital Advertising Alliance (US)
- Digital Advertising Alliance (Canada)
- Digital Advertising Alliance (EU)
- Network Advertising Initiative
Additional information on opt-out rights and means is available through the designated cookie bar on our website.
The website is not intended for use by children (the phrase “child” shall mean an individual that is under the age defined by applicable law, which concerning the EEA is under the age of 16, and with respect to the US, under the age of 13), and we do not knowingly process children’s information. We will discard any information we receive from a user that is considered a “child” immediately upon discovering that such a user shared information with us. Please contact us at firstname.lastname@example.org if you have reason to believe that a child has shared any information with us.
Section 2 - Jurisdiction-Specific Notices
This section applies only to California residents. Pursuant to the California Consumer Privacy Act of 2018 (“CCPA”) effective November 2020, and as amended by the CPRA, effective January 1, 2023.
Please see the CCPA Privacy Notice which discloses the categories of personal information collected, purpose of processing, source, categories of recipients with whom the personal information is shared for a business purpose, whether the personal information is sole or shared, the retention period, and how to exercise your rights as a California resident.
Under the Colorado Privacy Act (“CPA”) if you are a resident of Colorado, acting only as an individual or household context (and not in a commercial or employment context, as a job applicant or as a beneficiary of someone acting in an employment context), your rights with respect to your personal data are described below.
“Personal Data” as defined in the CPA means: “information that is linked or reasonably linkable to an identified or identifiable individual” and does not include any of the following: publicly available information, de-identified or aggregated consumer, and information excluded from the CPA scope, such as: Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPPA) or 42 CFR Part 2- “Confidentiality Of Substance Use Disorder Patient Records”, Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or and the Driver’s Privacy Protection Act of 1994, Children’s Online Policy Protection Act of 1998 (COPPA), Family Educational Rights and Privacy Act of 1974, national Security Exchange Act of 1934, higher education data and employment data.
Under the Virginia Consumer Data Protection Act, as amended (“VCDPA”) if you are a resident of Virginia acting in an individual or household context (and not in an employment or commercial context), you have the following rights with respect to your Personal Data.
“Personal data” means any information that is linked or reasonably linkable to an identified or identifiable natural person. “Personal data” does not include de-identified data or publicly available information. Personal Data does not include de-identified data or publicly available data, and information excluded from the scope such as: HIPAA, GBPA, non-profit entities, higher education, employment data and FCRA, Driver’s Privacy Protection Act of 1994, Family Educational Rights and Privacy Act, Farm Credit Act.
Under the Connecticut Data Privacy Act, Public Act. No. 22-14 (the “CDPA”) if you are a resident of Connecticut, acting in an individual or household context (and not in a commercial or employment context or as a representative of business, non-profit or governmental entity), your rights with respect to your Personal Data are described below.
“Personal data” means any information that is linked or reasonably linkable to an identified or identifiable individual. It does not include de-identified data or publicly available information. If further does not include information excluded from the scope such as: HIPAA, GBPA, non-profit entities, higher education, employment data and FCRA, Driver’s Privacy Protection Act of 1994, Family Educational Rights and Privacy Act, Farm Credit Act.
The categories of Personal Data processed, purpose of processing, are detailed in Section 1C “DATA SETS WE COLLECT AND FOR WHAT PURPOSE”, categories of Personal Data shared with third parties, categories of third parties with whom data is shared, are detailed in Section 1F “DATA SHARING – CATEGORIES OF RECIPIENTS WE SHARE PERSONAL DATA WITH”. Disclosure of sale of data or targeted advertising are detailed in Section 1K “OPT OUT OPTIONS” above, and in the DSR Form.
Instructions on how to exercise your rights are detailed in the table above under Section 2B “ADDITIONAL NOTICE TO COLORADO RESIDENTS” details the rights you have under CDPA and how you may exercise your rights.
If you have any questions, concerns or complaints regarding our compliance with this notice and the data protection laws, or if you wish to exercise your rights, we encourage you to first contact us at email@example.com.