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Equashield Privacy and Data Protection Policy and Notice



Equashield Medical Ltd. and its subsidiaries (“Equashield”, “we”, “our” or the “Company”, and their cognates) respects the privacy of its customers, and is committed to protecting the personal information you may share with us. (these and any others with respect to whom we collect personal data, shall collectively be referred to as “Customers” or “you” or “Data Subjects”).

Equashield is a medical device company providing a state-of-the-art Closed System Transfer Device (CSTD) for the safe handling of hazardous drugs, designed to protect healthcare workers from the risks associated with exposure to hazardous drugs and vapors (the “Services”).

This policy and notice (the “Privacy Policy”) explains the types of information we may collect from you, that we may receive about you or that you may provide in the course of your interest in our Services, business transactions, conferences and webinars. We are transparent about our practices regarding the information we may collect, use, maintain and process and describe our practices in this policy and notice. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

For the purposes of EU General Data Protection Regulation (the “GDPR”), CCPA and other applicable privacy laws:

Equashield is a data controller (the “Controller”) in relation to the Personal Data of our Customers and prospective customers

1. WHICH INFORMATION MAY WE COLLECT?

Summary: we collect various categories of personal data in order to meet our contractual obligations, and also to meet various legitimate interests, such as fraud prevention and marketing.

We may collect data about you in connection with your transactions with us, or in processing data for our Customers. One type of data is non-identifiable and anonymous information (“non-personal data”). We also collect several categories of personal data (“Personal Data”).

Data we collect about you from your transactions with us:

Personal Data which is being gathered consists of any details which are personally identifiable provided consciously and voluntarily by you, or by an organization you represent or are associated with or through your use of our websites (as described below). This may include your name (first and last), email address, phone number, postal address, position and organization name and other information you may choose to provide to Equashield. Additionally, we may obtain location data related to the geographic location of your laptop, mobile device or other digital device on which the Equashield websites are used.

You do not have any legal obligation to provide any information to Equashield, however, we require certain information in order to perform contracts, or to provide any services. If you choose not to provide us with certain information, then we may not be able to provide you or your organization with some or all of the services.

By submitting requests for support or information via the websites, Equashield will collect details, including also your name, facility name, phone number and personal or company email you provided, country and other such information. Equashield may use this information to offer Equashield’s services and support.

Equashield also collects Personal Data through the use of CCTV cameras. This may consist of video images of you in the public spaces at Equashield sites, as well as records of your entrances and exits of the Equashield sites, buildings and office floors. Equashield may not be aware of the nature of the information collected through our services (for example, through our CCTV systems), and such information may include sensitive or special categories of Personal Data, but we do not knowingly collect such data about our Customers, employees, site visitors etc.

2. HOW DO WE COLLECT PERSONAL DATA OF YOURS ON EQUASHIELD FACILITIES AND SERVICES?

Summary: we collect personal data when you or your organization send it to us, or when a vendor sends it to us so; we collect personal data through our websites and services.

We collect Personal Data required to provide Services when you register interest, or when you provide us such information by entering it manually or automatically, or through your use of our websites, facilities and Services, or in connection with site visits, in the course of preparing a contract, or otherwise in engaging with us. We also may collect Personal Data when you call us for support, in which case we collect the information you provide us. We also collect Personal Data through our CCTV recordings which automatically collect information about your presence in the Equashield facilities.

We also collect Personal Data through your use of our websites. In other words, when you are using the websites, we are aware of it and may gather, collect and record the information relating to such usage, either independently or through the help of third-party services as detailed below. This may include technical information and behavioral information such as the user’s Internet protocol (IP) address used to connect your computer to the Internet, your uniform resource locators (URL), operating system, type of browser, browser plug-in types and versions, screen resolution, Flash version, time zone setting, the user’s ‘clickstream’ on the websites, the period of time the user visited the websites, methods used to browse away from a page, and any phone number used to call our customer service number. We likewise may place cookies on your browsing devices (see section 'Cookies' below).

3. WHAT ARE THE PURPOSES OF PERSONAL DATA WE COLLECT?

Summary: we process personal data to meet our obligations, protect our rights, and manage our business.

We will use Personal Data to provide and improve our services to our Customers and others and meet our contractual, ethical and legal obligations. All Personal Data will remain accurate complete and relevant for the stated purposes for which it was processed, including for example:

Processing which is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract:
  • notifying you about changes to our service and products;
  • contacting you for the purpose of providing you with technical assistance and other related information about the products;
  • replying to your queries, troubleshooting problems, detecting and protecting against error, fraud or other criminal activity;
  • contacting you to give you commercial and marketing information about events or promotions or additional services and products offered by Equashield, including in other locations;
  • soliciting feedback in connection with your use of the services;
  • tracking use of Equashield facilities and services to enable us to optimize them;
  • contacting you to inform you of additional services which may be of interest to you;
Processing which is necessary for the purposes of the legitimate interests pursued by Equashield or by a third party of providing an efficient and wide-ranging service to customers:
  • notifying you about changes to our service and products;
  • contacting you for the purpose of providing you with technical assistance and other related information about the products;
  • replying to your queries, troubleshooting problems, detecting and protecting against error, fraud or other criminal activity;
  • contacting you to give you commercial and marketing information about events or promotions or additional services and products offered by Equashield, including in other locations;
  • soliciting feedback in connection with your use of the services;
  • tracking use of Equashield facilities and services to enable us to optimize them;
  • contacting you to inform you of additional services which may be of interest to you;
Processing which is necessary for compliance with a legal obligation to which Equashield is subject:
  • compliance and audit purposes, such as meeting our reporting obligations in our various jurisdictions, and for crime prevention and prosecution in so far as it relates to our staff, Customers, facilities etc;
  • if necessary, we will use personal data to enforce our terms, policies and legal agreements, to comply with court orders and warrants and assist law enforcement agencies as required by law, to collect debts, to prevent fraud, infringements, identity thefts and any other service misuse, and to take any action in any legal dispute and proceeding;
  • for security purposes and to identify and authenticate your access to the parts of the facilities;
we may collect personal data of our Customers’ personnel, which will be used for the purposes set out above.

4. SHARING DATA WITH THIRD PARTIES

Summary: we share personal data with our service providers, partners, and group companies, and authorities where required.

We may transfer Personal Data to:

Members of our Group: This includes any member of our group, which means subsidiaries – whether wholly or partially owned by Equashield, and co-owned companies.

Third Parties. We transfer Personal Data to third parties in a variety of circumstances. We endeavor to ensure that these third parties use your information only to the extent necessary to perform their functions, and to have a contract in place with them to govern their processing on our behalf. These third parties may include business partners, suppliers, affiliates, agents and/or sub-contractors for the performance of any contract we enter into with you. They may assist us in providing the services we offer, processing transactions, fulfilling requests for information, receiving and sending communications, analyzing data, providing IT and other support services or in other tasks, from time to time. These third parties may also include analytics and search engine providers that assist us in the improvement and optimization of our websites, and our marketing.

We periodically add and remove third party providers. At present our third-party providers to whom we may transfer personal data include also the following:
  • Website analytics (such as Google Analytics);
  • Document management and sharing services (such as Microsoft);
  • Customer ticketing and support (such as Salesforce CRM);
  • On-site and cloud-based database services (such as SAP Cloud)
  • Vendor and customer Interface (such as Shopify);
  • CRM software (such as Salesforce);
  • ERP software (such as SAP);
  • Data security, data backup, and data access control systems;
  • Project Management system;
  • Call center systems;
  • Customer service providers for Equashield products;
  • Our lawyers, accountants, and other standard business software and partners.

In addition, we may disclose your personal data to third parties if some or all of our companies or assets are acquired by a third party including by way of a merger, share acquisition, asset purchase or any similar transaction, in which case personal data may be one of the transferred assets. Likewise, we may transfer personal data to third parties if we are under a duty to disclose or share your personal data in order to comply with any legal or audit or compliance obligation, in the course of any legal or regulatory proceeding or investigation, or in order to enforce or apply our terms and other agreements with you or with a third party; or to assert or protect the rights, property, or safety of Equashield, our Customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction and to prevent cybercrime.

For avoidance of doubt, Equashield may transfer and disclose non-personal data to third parties at its own discretion.

5. WHERE DO WE STORE YOUR DATA?

Summary: we store your personal data across multiple locations globally

We store your Personal Data in servers owned or controlled by Equashield, or processed by third parties on behalf of Equashield, by reputable cloud-service providers in the US (see the following section regarding international transfers).

6. INTERNATIONAL DATA TRANSFERS

Summary: we transfer personal data within and to the EEA, UK, USA, Israel and elsewhere, with appropriate safeguards in place.

EU Personal Data may be transferred to, and stored and used at, a destination outside the European Economic Area (EEA) that may not be subject to equivalent Data protection laws to those of the EU. Where your Data is transferred outside of the EEA, we will take all steps reasonably necessary to ensure that your Data is subject to appropriate safeguards, and that it is treated securely and in accordance with this privacy policy. Equashield transfers data to other jurisdictions as follows:

  • To the United States of America. Equashield’s subsidiary is located in the US, and data transfers to it are subject to Standard Contractual Clauses. Additionally, Equashield stores Personal Data on servers located in the US, and all transfers of EU data to them, as well as to other third-party vendors located within the US, are subject to the EU Standard Contractual Clauses.
  • To the state of Israel, subject to GDPR adequacy decision.
We may transfer your personal data outside of the EEA, in order to:

  • store or backup the information;
  • enable us to provide you with the services and products and fulfil our contract with you;
  • fulfill any legal, audit, ethical or compliance obligations which require us to make that transfer;
  • facilitate the operation of our group businesses, where it is in our legitimate interests and we have concluded these are not overridden by your rights;
  • to serve our Customers across multiple jurisdictions; and
  • to operate our parent company, subsidiaries and affiliates in an efficient and optimal manner.

  • 7. DATA RETENTION

    Summary: we retain personal data according to our data retention policy, as required to meet our obligations, protect our rights, and manage our business.

    Equashield will retain personal data it processes only for as long as required in our view, to provide the services and as necessary to comply with our legal and other obligations, to resolve disputes and to enforce agreements. We will also retain personal data to meet any audit, compliance and business best-practices.

    Data that is no longer retained may be anonymized or deleted. Likewise, some metadata and statistical information concerning the use of our services are not subject to the deletion procedures in this policy and may be retained by Equashield. We will not be able to identify you from this data. Some data may also be retained on our third-party service providers’ servers until deleted in accordance with their privacy policy and their retention policy.

    8. SERVICES AND WEBSITES DATA COLLECTION AND COOKIES

    Summary: with your consent, we place cookies on your device. You control our use of cookies through a cookie management tool on our websites, or through your device and browser.

    When you access or use our Services or websites, Equashield may use industry standard technologies such as cookies, pixels and similar technologies, which store certain information on your computer or browsing device and which will allow us to identify the computer or device and in some cases to identify them with the user, and to enable automatic activation of certain features, and make your user experience more convenient and effortless. We use different types of cookies: some cookies are strictly necessary, they are required for the operation of our websites and Services under our terms with you; We also use analytical and performance monitoring cookies, which allow us to recognize and count the number of visitors and to see how visitors move around our websites and services when they are using it. Finally, we use functionality cookies which are used to recognize you when you return to our Site. This enables us to personalize content to your preferences, including for example, your choice of language or region.

    Different cookies are kept for different periods. Session cookies are used to keep track of your activities online in a given browsing session; these cookies generally expire when the browser is closed but may be retained for a period on your device. Permanent cookies remain in operation even when you have closed the browser; they are used to remember your login details and password. Third-party cookies are installed by third parties with the aim of collecting certain information to research behaviour, demographics. Third party cookies on our site include, for example, Google Analytics. Likewise, pixels from Facebook and others enable integration of third party service providers (eg Twitter, Youtube, Pintrest, Instagram) may be embedded on our site. Third party cookies will be retained according to the terms of those third parties, and you can control those cookies in your browser settings.

    We use cookies and other technologies on the basis that they are necessary for the performance of a contract with you, or because using them is in our legitimate interests of improving, optimizing and personalizing our services, and these are not overridden by your rights.

    Most browsers will allow you to erase cookies from your computer’s hard drive, block acceptance of cookies, or receive a warning before a cookie is stored. However, if you block or erase cookies your online experience on our websites and services will be limited.

    How to disable cookies: the effect of disabling cookies depends on which cookies you disable but, in general, the websites and some services delivered through them may not operate properly, may not recognize your device, may not remember your preferences and so on, if cookies are disabled or removed. However, allowing or disabling cookies is your choice and in your control. If you want to disable cookies on our site, you need to change your browser settings to reject cookies. How you can do this will depend on the browser you use. Further details on how to disable cookies can be found here: Microsoft Edge, Google Chrome, Firefox, Safari.

    Our services and websites may, from time to time, contain links to external sites. We are not responsible for the operation, privacy policies and practices or the content of such sites.

    9. SECURITY AND STORAGE OF INFORMATION

    Summary: we take data security very seriously, invest in security systems, and train our staff. In the event of a breach, we will notify the right people as required by law.

    We take great care in implementing, enforcing and maintaining the security of the personal data we process. Equashield implements, enforces and maintains security measures, technologies and policies to prevent the unauthorized or accidental access to or destruction, loss, modification, use or disclosure of personal data. We likewise take steps to monitor compliance of such policies on an ongoing basis. Where we deem it necessary in light of the nature of the data in question and the risks to data subjects, we may encrypt data. Likewise, we take industry standard steps to ensure our websites and services are safe.

    Note however, that no data security measures are perfect or impenetrable, and we cannot guarantee that unauthorized access, leaks, viruses and other data security breaches will never occur.

    Within Equashield, we endeavor to limit access to personal data to those of our personnel who: (i) require access in order for Equashield to fulfil its obligations, including also under its agreements, and as described in this Privacy Policy, and (ii) have been appropriately and periodically trained with respect to the requirements applicable to the processing, care and handling of the Personal Data, and (iii) are under confidentiality obligations as may be required under applicable law.

    Equashield shall act in accordance with its policies and with applicable law to promptly notify the relevant authorities and data subjects in the event that any personal data processed by Equashield is lost, stolen, or where there has been any unauthorized access to it, all in accordance with applicable law and on the instructions of qualified authority. Equashield shall promptly take reasonable remedial measures.

    10. EU DATA SUBJECT RIGHTS

    Summary: depending on the law that applies to your personal data, you may have various data subject rights, such as rights to access, erase, and correct personal data, and information rights. We will respect any lawful request to exercise those rights.

    Data subjects with respect to whose data Californian law applies, please see section 11 below.

    Data subjects with respect to whose data GDPR applies, have rights under GDPR and local laws, including, in different circumstances, rights to data portability, rights to access data, rectify data, object to processing, and erase data. It is clarified for the removal of doubt, that where personal data is provided by a customer being the data subject's employer, such data subject rights will have to be effected through that customer. In addition, data subject rights cannot be exercised in a manner inconsistent with the rights of Equashield employees and staff, with Equashield proprietary rights, and third-party rights. As such, job references, reviews, internal notes and assessments, documents and notes including proprietary information or forms of intellectual property, cannot be accessed or erased or rectified by data subjects. In addition, these rights may not be exercisable where they relate to data that is not in a structured form, for example emails, or where other exemptions apply. If processing occurs based on consent, data subjects generally have a right to withdraw their consent.

    A data subject who wishes to modify, delete or retrieve their Personal Data, may do so by contacting Equashield (privacy@equashield.com). Note that Equashield may have to undertake a process to identify a data subject exercising their rights. Equashield may keep details of such rights exercised for its own compliance and audit requirements. Please note that Personal Data may be either deleted or retained in an aggregated manner without being linked to any identifiers or Personal Data, depending on technical commercial capability. Such information may continue to be used by Equashield.

    Data subjects in the EU have the right to lodge a complaint, with a data protection supervisory authority in the place of their habitual residence. If the supervisory authority fails to deal with a complaint, you may have the right to an effective judicial remedy.

    11. CALIFORNIA RESIDENTS

    Your Rights and Choices

    The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

    Access to Specific Information and Data Portability Rights

    You have the right to request that Equashield disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:
    • The categories of personal information we collected about you.
    • The categories of sources for the personal information we collected about you.
    • Our business or commercial purpose for collecting or selling that personal information.
    • The categories of third parties with whom we share that personal information.
    • The specific pieces of personal information we collected about you (also called a data portability request).
    • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
    • sales, identifying the personal information categories that each category of recipient purchased; and
    • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

    Deletion Request Rights You have the right to request that Equashield delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

    We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
    • Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
    • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
    • Debug products to identify and repair errors that impair existing intended functionality.
    • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
    • We may Protect our legal interests, to defend our rights in a case of potential, threatened, or actual litigation, and to enforce our rights.
    • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
    • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
    • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
    • Comply with a legal obligation.
    • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

    Exercising Access, Data Portability, and Deletion Rights

    To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us to privacy@equashield.com.

    Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

    You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

    • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
    • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

    We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

    Making a verifiable consumer request does not require you to create an account with us.

    We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

    Response Timing and Format

    We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.

    If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

    Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

    We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

    Non-Discrimination

    We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
    • Deny you goods or services.
    • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
    • Provide you a different level or quality of goods or services.
    • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
    However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

    Other California Privacy Rights

    California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Websites that 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 privacy@equashield.com.

    12. GENERAL

    Minors. We do not knowingly collect or solicit information or data from or about children under the age of 16 or knowingly allow children under the age of 16 to register for Equashield services. If you are under 16, do not register or attempt to register for any of the Equashield Service or send any information about yourself to us. If we learn that we have collected or have been sent Personal Data from a child under the age of 16, we will delete that Personal Data as soon as reasonably practicable without any liability to Equashield. If you believe that we might have collected or been sent information from a minor under the age of 16, please contact us at: privacy@equashield.com, as soon as possible.

    Changes to this Privacy Policy. The terms of this Privacy Policy will govern the use of the services, websites, and any information collected in connection with them. Equashield may amend or update this Privacy Policy from time to time. The most current version of this Privacy Policy will be available at: https://www.equashield.com/privacy/. Changes to this Privacy Policy are effective as of the stated “Last Revised” date and your continued use of our services will constitute your active acceptance of the changes to and terms of the Privacy Policy.

    Equashield aims to process only adequate, accurate and relevant data limited to the needs and purposes for which it is gathered. It also aims to store data for the time period necessary to fulfill the purpose for which the data is gathered. Equashield only collects data in connection with a specific legitimate purpose and only processes data in accordance with this Privacy Policy. Our policies and practices are constantly evolving and improving, and we invite any suggestions for improvements, questions or comments concerning this Privacy Policy, you are welcome to contact us (details below) and we will make an effort to reply within a reasonable timeframe.

    Equashield contact details: privacy@equashield.com



    Last Revised: May 25, 2021