BRAIN.SPACE - Privacy policy

Last Revised: January 30, 2022

This privacy policy (“Privacy Policy”) governs the data collection, processing, and usage made by Eeg-Sense Ltd.(“Company”, “we” or “us”) with respect to the data we collect from individuals who access and use our website(respectively “Website” and “Visitors” or “you”).

This Privacy Policy constitutes an integral part of the Website Terms of Use (together “Terms”), and provides you with information regarding our processing operation, the lawful basis pursuant to which we process your Personal Data (as defined below), third parties to whom Personal Data will be transferred, data retention periods, as well as your rights under applicable privacy laws. Definitions used herein but not defined herein shall have the meaning ascribed to them in the Terms.

If you have any questions about this Privacy Policy, please contact us at [email protected]

You are not required by law to provide us with any Personal Data. Sharing Personal Data with us is entirely voluntary. However, in some cases, without providing your data we may not be able to provide you with all or some of our Content or other parts of the Website.

AMENDMENTS

We reserve the right to periodically amend or revise the Privacy Policy, which will immediately affect the implementation of the revised Privacy Policy on our Website. The last revision date will be reflected in the “Last Revised” heading located at the top of the Privacy Policy. We will make a reasonable effort to notify you if we implement any changes that substantially change our privacy practices. We recommend that you review this Privacy Policy periodically to ensure that you understand our privacy practices and to check for any amendments.

WHO ARE WE AND OUR EU REPRESENTATIVE

We are Egg-sense Ltd., a company incorporated in Israel. Our address is: 6 HaArba’a St. Tel Aviv, Israel. In the event that the European General Data Protection Regulation (”GDPR”) applicable to you, we are the data controller of the Website’s Visitors.

Questions, comments, requests and complaints regarding this Privacy Policy and the information we hold are welcome and should be addressed to us by using the contact details above. All requests will be dealt with promptly and efficiently.

COLLECTION OF NON-PERSONAL DATA

We may collect aggregated, non-personal and non-identifiable information which may be made available or gathered via your use of our Website (“Non-Personal Data“). We are not aware of the identity of the individual from which the Non-Personal Data is collected.

Also, 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 person. Non-Personal Data may be used by us without limitation and for any purpose, including for commercial, research, or statistical purposes, without further notice to you.

COLLECTION OF PERSONAL DATA

During your use of the Website, we will collect individually identifiable information, namely information that identifies an individual or may with reasonable effort be used to identify an individual (“Personal Data”). This may include online identifiers (e.g., IP address, cookies, etc), name, emails, address etc., subject to applicable law. If we combine Personal Data with Non-Personal Data, we will treat the combined data as Personal Data.

PROCESSING OF PERSONAL DATA – PURPOSES AND LAWFUL BASIS

We have included in the table below information about which data is processed, how we process and use your data and the lawful basis for which we do so subject to applicable laws, including the GDPR.

Type of Data

Purpose of Processing

Processing Action

Lawful Basis

If you voluntarily contact us in any manner, whether, whether by sending us an email or through other means of communications, e.g., any online form available on the Website, such as “Contact us” you may be asked to provide us with your contact information such as your full name, email address. Company and title. In addition, you can choose to provide us with additional information as part of your correspondence with us.

Addressing your inquiries and/or checking the option to partner with you.

We will collect and process this data, store it in our systems, and check it with our contact history solely to respond to your inquiries and provide you with the support or information you have requested. We will retain our correspondence with you for as long as needed, subject to applicable law. Note that such correspondences can be retained in databases we use for this purposes and which we bought from third parties (i.e., SaaS platform such as CRM). In such cases, your data may be shared and transferred to such third parties. For more information regarding data transfer and sharing see below

In case you contact us as a current partner or client -the lawful basis for processing your information will be the contract between you and us, meaning we will use the data for addressing your requests and inquiries.After completing any such request, we will retain your information as part of our business records under our legitimate interest. In the event you contacted us for partnering or to hear about our products we will also do so under our legitimate interest. In such cases, where we rely on our legitimate interest, you are entitled to object such processing based on our legitimate interests if you believe that your rights are overridden by our interests.

Online identifiers and other Technical Data

When you access our Website or interact with it, we may collect certain online identifiers, including your IP address.We may also collect technical Non-Personal Data transmitted from your device (e.g., actions in the Website, your browser type, language used, type of operating system, type of device, etc.) and approximate geographical location (country).

Improving & customizing the Website, safety, security and fraud prevention of our Website, and advertising purposes.

We, directly or through the use of third parties, will collect your data, aggregate it and statistically analyze it (whether alone or together with other Visitor’s data), aggregate, generate reports based on such analysis and retain records of any such usage data. We process and retain this data for enhancing your experience and auditing and tracking usage statistics and traffic flow, customizing the Website for you or adjusting its content, including advertisements, for your use.We also process it for protecting the security of the Website, as well as our and third parties’ rights (subject to applicable law requirements).

Processing of general, aggregated and statistical data for the proper management of our website and services, is based on the legal basis of our legitimate interests as a commercial business to track users who enter our Website for the mentioned purposes.when we use third-party cookies on the Website or collect online identifiers for our marketing activities, we will obtain your consent if required under applicable law.

HOW WE COLLECT INFORMATION

Depending on the nature of your interaction with us (i.e., if you are just a Visitor of our Website), we may collect information as follows:

(i) Automatically – we may use cookies (as elaborated in the section below) or similar tracking technologies to gather some information automatically when you interact with the Website.

(ii) Provided by you voluntarily – we will collect information if and when you choose to provide us with the information, such as communications with us through the “contact us” page, all as explained in this Privacy Policy.

SHARING DATA WITH THIRD PARTIES

We do not share any Personal Data collected from you with third parties or any of our partners except in the following events:

Legal Requirement: We will share your information in this situation only if we are required to do so to comply with any applicable law, regulation, legal process, or governmental request (e.g., to comply with a court injunction, comply with tax authorities, etc.);
Policy Enforcement: We will share your information, solely to the extent needed to (i) enforce our policies and agreements; or (ii) to investigate any potential violations thereof, including without limitations, detect, prevent, or take action regarding illegal activities or other wrongdoings, suspected fraud or security issues;
Company’s Rights: We will share your information to establish or exercise our rights, to prevent harm to our rights, property, or safety, and to defend ourselves against legal claims when necessary, subject to applicable law;
Third Party Rights: We will share your information, solely to the extent needed to prevent harm to the rights of our users, yourself, or any third party’s rights, property, or safety;
Service Providers – we share your information with third parties that perform services on our behalf (e.g. customer service, tracking cookies, servers, service functionality, marketing, and support, etc.) these third parties may be located in different jurisdictions.
Corporate Transaction - we may share your information in the event of a corporate transaction (e.g. sale of a substantial part of our business, merger, consolidation or asset sale). In the event of the above, our affiliated companies or acquiring company will assume the rights and obligations as described in this Privacy Policy;
Authorized Disclosures - we may disclose your information to third parties when you consent to a particular disclosure. Please note that once we share your information with another company, that information becomes subject to the other company’s privacy practices.

YOUR DATA SUBJECTS' RIGHTS UNDER PRIVACY PROTECTION LAWS

Depending on your jurisdiction, data protection and privacy laws provide you with the ability to exercise certain rights regarding your Personal Data that we process. The principal rights includes the right to access your Personal Data;the right to ensure your Personal Data is accurate, complete and up to date; the right to have your Personal Data amended or otherwise deleted; the right to object to the processing of your Personal Data; the right to send or “port” your Personal Data; the right to file a complaint with a supervisory authority in your jurisdiction; and the right to withdraw consent, subject to legal or contractual restrictions and reasonable notice;

If you wish to exercise any or all of the above rights, please send us email at: [email protected]

If we are unable to provide you with the information that you asked for, we will endeavor to explain the reasoning for this and inform you of your rights. We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any such information in accordance with applicable law.

DATA RETENTION

Unless you instruct us otherwise, and subject to applicable laws, we retain the Personal Data we collect for as long as needed to provide our Website and the associated services and to comply with our legal obligations, resolve disputes and enforce our agreements, if applicable.

SECURITY

We use physical, technical, and administrative security measures for the services that we believe comply with applicable laws and industry standards to prevent your information from being accessed without the proper authorization, improperly used or disclosed, unlawfully destructed or accidentally lost.

Please contact us at: [email protected] if you believe that your privacy was treated in a way that was not in accordance with this Privacy Policy. In the event of a security incident in which we discover that your Personal Data may be at risk, we will take reasonable efforts to notify you and the applicable authority (if we are required to do so, subject to applicable laws).

DATA TRANSFER

In the event that we need to transfer Personal Data out of your jurisdiction, we will take appropriate measures to ensure that your Personal Data receives an adequate level of protection as required under applicable law.

CHILDREN

The Website and our Platform are not intended for use by individuals who are under the age of 18. Therefore, the Company does not intend and does not knowingly collect any Personal Data directly from children under the age of 18, and does not wish to do so. If we become aware that an individual under the age of 18 has provided us with Personal Data, we will delete such data from our databases.

CONTACT US

If you have any questions (or comments) concerning this Privacy Policy, you are welcome to contact us, as follows:

By email: [email protected]

We will make an effort to reply within a reasonable timeframe.