V-LAP Application Privacy Policy

Introduction

Vectorious Medical Technologies Ltd. (“we”, “our”, “us”) is committed to protecting and respecting your privacy. We are an Israeli-based company with a registered office at 24 Raoul Wallenberg St. Tel Aviv, Israel. For the purposes of the General Data Protection Regulation (the “GDPR”), we are the data controller. This policy outlines how we process any personal data or usage information collected from you or provided by you in connection with your use of our V-LAP Patient Application (the “Application”). Please read this policy carefully to understand your rights regarding your personal data and how we will collect, use and process it. If you do not agree with this Privacy Policy or any part of it, please contact your clinical study coordinator.

What information do we collect, and how do we use it?

Personal information concerning participants in clinical studies provided to us by the clinical study site is considered pseudo-anonymized and does not contain direct identifiers that can connect the data to a specific participant.  

Information you provide to us.

As a participant in our clinical study, you provide us with the following information:

• Medical History
• Demographics
• Current Medical Status
• Lab Test Results

Information measured and provided by the V-LAP system. During the use of the V-LAP system as part of the clinical study, you provide us with the following information :

• V-LAP pressure measurements.

We rely on your clinical study participation informed consent as the legal basis for collecting and processing this information.

Technical usage information. When you visit the application, we automatically collect the information sent to us by your mobile phone or other access device. This information includes:

• The status of location services state (Android only)
• The status of Bluetooth state
• Charging status (whether the device is connected to a power source)
• Time zone settings
• Data collected via Google Analytics

We do not use cookies, and we do not use any of the information provided to us for marketing communication.

The information we collect and process is minimized and limited to only what is necessary for the success of our clinical study. We use this information:

• To conduct research and development, provide quality assurance and product validation.
• To comply with our regulatory requirements for compliance purposes.

How do we share your personal data?

We share your information with selected recipients. These categories of recipients include:

• SaaS-based and Cloud storage providers to store the data you provide and for disaster recovery services, as well as for the performance of V-LAP system and the clinical study.
• Professional services suppliers include but are not limited to medical, regulatory, statistic, quality assurance, and other professional services advisors that assist us in the clinical study processes.
• We will share your information with law enforcement agencies, public authorities or other organizations if legally required to do so, or if we have a good faith belief that such use is reasonably necessary.

We will also disclose your information to third parties:

• If we sell any business or assets, in which case we will disclose your data to the prospective buyer of such business or assets or
• If we or substantially all our assets are acquired by a third party, in which case information held by us about our users will be one of the transferred assets.

Where do we store your personal data?

The information that we collect from you may be transferred to and stored at/processed in Israel and Ireland. Your personal data is also processed by staff operating outside the EEA who work for us or for one of our suppliers. We will take all steps reasonably necessary to ensure that your personal data is treated securely and in accordance with this policy.

• Adequate Countries: Israel, and other countries which were found to have an adequate level of protection for personal data by decision of the European Commission.
• Model Clauses: The personal data that we collect from you will be transferred to and stored in and processed in other countries under the Commission’s model contracts for the transfer of personal data to third countries.

The Security of Your Personal Data

We have implemented physical, technical, and administrative controls designed to prevent unauthorized access or data breaches and maintain data security. These safeguards vary based on the sensitivity of the personal data that we collect and store.

Although we take appropriate measures to safeguard against unauthorized disclosures of personal data, we cannot assure you that your personal data will never be disclosed, altered or destroyed in a manner that is inconsistent with this privacy policy.

How long do we store your personal data?

We will retain your information as follows:

• We retain your personal data for as long as it is necessary to fulfill the purposes for which it was collected, and in compliance with legal obligations.
• Clinical data collected during the study will be stored for 15 years after the end of the study.

Your Rights:

‍You have the right to request access to the personal data we hold about you and receive certain information on how we use your personal data and who we share it with. You also have the right to ask us to correct your personal data where it is inaccurate or incomplete and we will endeavour to do so without undue delay. In certain circumstances, you have the right to request that we delete the personal data we hold about you:

• If you have provided your personal data to us with your consent and you wish to withdraw your consent, and there is no other ground under which we can process your personal data; or
• Where you believe the personal data we hold about you is being unlawfully processed by us.

In certain circumstances, you have the right to request that we restrict (stop any active) processing of your personal data:

• Where you believe the personal data we hold about you is inaccurate, and we need time to verify its accuracy.
• Where we want to erase your personal data as the processing is unlawful, but you want us to continue to store it.
• Where we no longer need your personal data for the purposes of our processing, but you require us to retain the data for the establishment, exercise or defence of legal claims; or

You may also object to our processing of your personal data based on our legitimate interests. We will stop processing your personal data unless we can demonstrate an overriding legitimate ground. To exercise any of these rights above, please contact us at info@vectoriousmedtech.com . In addition, you have the right to complain to any applicable data protection supervisory authority. Please note that these rights are limited in certain situations, such as when fulfilling your request could adversely affect other individuals or compromise company trade secrets or intellectual property, where there are overriding public interest reasons or where we are required by law to retain your personal data.

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Complaints

If you wish to make a complaint about how we process your personal data, please contact us first at info@vectoriousmedtech.com. We will do our best to address your request promptly. This is without prejudice to your right to launch a claim with the data protection supervisory authority in the EU country in which you live or work where you think we have infringed data protection laws.

Changes

Any changes we will make to this policy in the future will be posted on this page. Please check back frequently to see any updates or changes to this policy.

Contact

Questions, comments and requests regarding this policy are welcomed and should be addressed to info@vectoriousmedtech.com