When you browse or visit our website, www.get-grin.com (“Site”)
When you make use of, or interact with, our Site
When you subscribe to our distribution list(s) through the Learn More feature
When we process your job application
When you contact us (e.g. customer support, etc.)
When you request a product demo
When you, as a patient, make use of, or interact with our mobile or web application ("App").
When you sign up for an account and login to the App
When you, as a health professional, make use of, or interact with our platform ("Platform")
When you sign up for an account and login into the Platform
When you use the Platform
When you recommend a product in our Platform as a health professional
When you attend a marketing event, exchange business cards with us, or otherwise provide us with your Personal Information for marketing purposes
When we use the personal data of our service providers/vendors (e.g. contact details)
Table of contents:
What Personal Information we collect, why we collect it, and how it is used
How we protect and store your Personal Information
How we share your Personal Information
Transfers of Personal Information
Your privacy rights. How to delete your account
Use by children
Links to and interaction with third-party product
California privacy rights
Our California do not track notice
How to contact us
WHAT PERSONAL INFORMATION WE COLLECT, WHY WE COLLECT IT, AND HOW IT IS USED
Finally, please note that some of the abovementioned Personal Information will be used for detecting, taking steps to prevent, and prosecuting fraud or other illegal activity, identifying and repairing errors, conducting audits, and for security purposes. Personal Information may also be used to comply with applicable laws, with investigations performed by the relevant authorities, for law enforcement purposes, and/or to exercise or defend legal claims. In certain cases, we may or will anonymize or de-identify your Personal Information and further use it for internal and external purposes, including, without limitation, to improve the services and for research purposes. “Anonymous Information” means information that does not enable the identification of an individual user, such as aggregated information about the use of our services. We may use Anonymous Information and/or disclose it to third parties without restrictions (for example, in order to improve our services and enhance your experience with them).
HOW WE PROTECT AND STORE YOUR PERSONAL INFORMATION
Retention of your Personal Information. Your Personal Information (as described above) will be stored until we no longer need the information and proactively delete it or you send a valid deletion request. In some circumstances, we may store your Personal Information for longer periods of time, for example (i) where we are required to do so in accordance with legal, regulatory, tax, or accounting requirements, or (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, or (iii) if we reasonably believe there is a prospect of litigation relating to your Personal Information or dealings.
HOW WE SHARE YOUR PERSONAL INFORMATION
In addition to the recipients described in Section 3, we may share your Personal Information as follows:
With our business partners with whom we jointly offer products or services. We may also share Personal Information with our affiliated companies.
To the extent necessary, with regulators, to comply with all applicable laws, regulations, and rules, and requests of law enforcement, regulatory and other governmental agencies or if required to do so by court order;
If in the future, we sell or transfer some or all of our business or assets to a third party, we will (to the minimum extent required) disclose information to a potential or actual third-party purchaser of our business or assets. In the event that we are acquired by or merged with a third party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer or assign Personal Information in connection with the foregoing events.
In the event that we are acquired by, or merged with, a third party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer, disclose or assign your Personal Information in connection with the foregoing events, including, in connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or to another company; and/or
Where you have provided your consent to us sharing the Personal Information (e.g., where you provide us with marketing consents or opt-in to optional additional Services or functionality); and
Where we receive requests for information from law enforcement or regulators, we carefully validate these requests before any Personal Information is disclosed.
TRANSFERS OF PERSONAL INFORMATION
Storage: We store the Personal Information with the following storage companies: Amazon (AWS) – U.S.
Internal transfers: Transfers within the Grin group will be covered by an internal processing agreement entered into by members of the Grin group (an intra-group data processing agreement) which contractually obliges each member to ensure that Personal Information receives an adequate and consistent level of protection wherever it is transferred to.
External transfers: Where we transfer your Personal Information outside of EU/EEA (for example to third parties who provide us with services), we will generally obtain contractual commitments from them to protect your Personal Information. When Get Grinengages in such transfers of personal information, it relies on i) Adequacy Decisions as adopted by European Commission on the basis of Article 45 of the GDPR (for example, when we access from Israel), or ii) Standard Contractual Clauses issued by the European Commission.
You have a right to access Personal Information held about you. Your right of access may normally be exercised free of charge, however, we reserve the right to charge an appropriate administrative fee where permitted by applicable law;
You have the right to request that we rectify any Personal Information we hold that is inaccurate or misleading;
You have the right to request the erasure/deletion of your Personal Information (e.g. from our records). Please note that there may be circumstances in which we are required to retain your Personal Information, for example for the establishment, exercise, or defense of legal claims;
You have the right to object, to or to request restriction, of the processing;
You have the right to data portability. This means that you may have the right to receive your Personal Information in a structured, commonly used, and machine-readable format and that you have the right to transmit that data to another controller;
You have the right to object to profiling;
You have the right to withdraw your consent at any time. Please note that there may be circumstances in which we are entitled to continue processing your data, in particular, if the processing is required to meet our legal and regulatory obligations. Also, please note that the withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal;
You also have a right to request certain details of the basis on which your Personal Information is transferred outside the European Economic Area, but data transfer agreements and/or other details may need to be partially redacted for reasons of commercial confidentiality;
You have a right to lodge a complaint with your local data protection supervisory authority (i.e., your place of habitual residence, place of work, or place of alleged infringement) at any time or before the relevant institutions in your place of residence. We ask that you please attempt to resolve any issues with us before you contact your local supervisory authority and/or relevant institution.
USE BY CHILDREN. We do offer our products our Services for use by minors under 18. For minors below 18, you must have your parent's or guardian’s permission to agree to the Terms and obtain the right to access and use the Services. When we intend to collect Personal Information from or about children, we take additional steps to protect children's privacy, including, without limitation, limiting our collection of personal information from children to no more than is reasonably necessary to participate in an online activity; giving parents access or the ability to request access to the personal information we have collected from their children and the ability to request that the personal information be changed or deleted. In the event that we become aware that you provide Personal Information in violation of applicable privacy laws, we reserve the right to delete it. If you believe that we might have any such information, please contact us at email@example.com.
LOG FILES. We make use of log files. The information inside the log files includes internet protocol (IP) addresses, type of browser, Internet Service Provider (ISP), date/time stamp, referring/exit pages, clicked pages, and any other information your browser may send to us. We may use such information to analyze trends, administer the Site, track users’ movement around the Site, and gather demographic information.
We reserve the right to remove or add new analytic tools.
CALIFORNIA PRIVACY RIGHTS
For the purposes of this section, Personal Information means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household, or as otherwise defined by the California Consumer Privacy Act of 2018 (California Civil Code §§ 1798.100 to 1798.199) and its implementing regulations, as amended or superseded from time to time (“CCPA”).
Personal Information does not include information that is:
Lawfully made available from government records.
De-identified or aggregated.
Otherwise excluded from the scope of the CCPA. Please note that data collected from patients for the provisioning of medical services is not within the scope of the CCPA as this data is in the scope of the Health Insurance Portability and Accountability Act.
The chart above provides the types of Personal Information we have collected, disclosed for a business purpose, or used for business or commercial purposes in the preceding twelve months since this notice was last updated, as well as the sources from which that information was collected, the third parties with whom we shared Personal Information, and the purposes for which we collect Personal Information.
In the preceding twelve months, we have not sold any California resident’s Personal Information.
If you are a California resident, you may exercise the following rights:
Shine the Light. California Civil Code Section 1798.83 permits our customers who are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please send an email to firstname.lastname@example.org. Please note that we are only required to respond to one request per customer each year.
Please note, requests for access to or deletion of Personal Information are subject to our ability to reasonably verify your identity in light of the information requested and pursuant to relevant CCPA requirements, limitations, and regulations. To verify your access or deletion request, please provide us with your full name, date of birth, and Grin Platform user name.
OUR CALIFORNIA DO NOT TRACK NOTICE. Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers, but we may allow third parties, such as companies that provide us with analytics tools, to collect personally identifiable information about an individual consumer’s online activities over time and across different web sites when a consumer uses the Services.
HOW TO CONTACT US. If you have any questions, concerns, or complaints regarding our compliance with this notice and the Information protection laws, or if you wish to exercise your rights, we encourage you to first contact us at email@example.com.