Privacy Policy

(Last update:  February, 2021)


NewPace Ltd. (“Company”, "we", “us” or "our") respect your privacy and recognize that your privacy is important. This privacy policy (“Privacy Policy”) sets forth and governs the privacy practices of the Company and applies to users ("you" or "user") that access this Websites owned and operated by the Company and the Services therein. This Privacy Policy is an integrated part of our Terms and Conditions (“Terms”). Definitions herein shall have the meaning assigned to them in the Terms.  It is your responsibility to read this Privacy Policy thoroughly.
If you have any questions about this Privacy Policy, please contact us at: cr@newpacemedical.com (or as described below).


This Privacy Policy explains what data we may collect from our users, how such data may be used or shared with others, how we safeguard it and how you may exercise your rights related to your Personal Data, among others, and where applicable, as required according to the EU General Data Protection Regulation (“GDPR”) and the California Consumer Privacy Act (“CCPA”).


In the event you are a California resident and the CCPA apply to you – please review our CCPA Privacy Notice.

DATA COLLECTED AND PURPOSE OF USE
Depending on your interaction with the Website, we may collect two types of data from you, as follows:
The first type of information is un-identified and non-identifiable information pertaining to you, which may be made available or gathered via your use of the Website ("Non-personal Data"). We are not aware of the identity from which the Non-personal Data is collected. Non-personal Data which is collected may include your aggregated usage information and technical information transmitted by your device, including certain software and hardware information about your device (e.g., the device you use, the type of browser and operating system your device uses, language preference, access time and the website's domain name from which you linked to the Website, etc.), in order to enhance the functionality of the Website. We may also collect information about your activity on the Website (e.g., how many users visited the Website, which pages were viewed, etc.).


The second type of information is individually identifiable information, namely information that identifies an individual or may with reasonable effort identify an individual ("Personal Data"). Personal Data may include:

•    Contact Us Information: You may contact us through the communication means we make available to ask any question you may have or for other reasons. If you contact us, we may collect any information contained in any correspondence (e.g., your full name, email address and free text). We will use your contact details and save your contact history with us in order to respond to your inquiry, provide you with support, assistance or any other information requested by you.


•    Voluntarily Information: We may collect information that you provide us voluntarily. For instance, when you respond to communications from us or communicate with us via email.


•    Online Identifiers: When you access our Website, we may, either directly or indirectly (through our third-party service providers) collect your IP address cookies and user agents ("Online Identifiers"). We process this data under our legitimate interests of operating, providing, maintaining, protecting, managing, customizing and improving our Website, and the way in which we offer it; (ii) enhancing your experience with the Website; (iii) our legitimate interests of auditing and tracking usage statistics and traffic flow. In the event required under applicable law, we will obtain your consent to gather such information, for example, regarding the collection through the use of cookies. Please note that, we do not attempt to analyze or determine your identity based on such information or otherwise combine it with any information such as your name or email address. Your IP address may be collected by our third-party analytic partners that offer ways to opt-out of such collection, all as explained below. 


•    Career: In the event you apply for a job via our Website, we will collect your CVs and additional information such as your contact details. We will use the information you have provided solely to communicate with you, to manage our recruiting and hiring processes, and for compliance with corporate governance and legal and regulatory requirements. If you are hired, the information may be used in connection with employment and corporate management.

If we combine Personal Data with Non-Personal Data, the combined data will be treated as Personal Data for as long as it remains combined. 


 

SHARING INFORMATION WITH THIRD PARTIES
We will not share your Personal Data with third parties, outside as specifically mentioned herein:

(i)    Compelled Disclosures - To satisfy any applicable law, regulation, legal process, subpoena or governmental request; 
(ii)    Enforcement of our Rights - To enforce this Privacy Policy and the terms of our agreements, including the investigation of potential violations thereof; 
(iii)    Security Detections - To detect, prevent, or otherwise address fraud, security or technical issues; 
(iv)    Business Transfers and Affiliated Companies - When the Company is undergoing any change in control, including by means of a merger, acquisition or purchase of all or substantially all of its assets or with our parent company, any subsidiaries, joint ventures, or other companies under common control with the Company solely if and when applicable or necessary for the purposes described in this Privacy Policy, or in the event of any of the corporate transactions listed herein; 
(v)    Service Providers - To collect, hold and/or manage your Personal Information through our authorized third-party service providers, as reasonable for our business purposes; 
(vi)    Explicit Consent - If you provide us with your explicit approval to share your information prior to the disclosure.


For the avoidance of doubt, we may transfer and disclose or otherwise use Non-Personal Information, information which is linked to anonymous random identifiers or information that is aggregated in a non-identifiable way, at its own discretion.

COOKIES POLICY AND TRACKING TECHNOLOGIES
We or our third-party service providers may use cookies and other similar tracking technologies or methods of web and mobile analysis to gather, store, and track certain information related to your access of, activity and interaction with the Products and our Website, as applicable.   
A “cookie” is a small piece of information that a website assigns to your device while you access such website. Cookies are very helpful and may be used for a variety of different purposes. These purposes include, among other things, allowing you to navigate between pages efficiently, enabling automatic activation of certain features, remembering your preferences and making the interaction between you and the Website quicker, easier and smoother. Cookies are also used to help customize your experience and for advertising purposes (including personalized advertising). You can find out more information about cookies at www.allaboutcookies.org.


In general, there are several types of cookies that may be used on our Website including the following: 

(i)    Essential, Functionality, Operation & Security Cookies. These cookies are essential for enabling user movement around the Website, for the Website and certain features of the Products, as applicable, to function properly, and for security purposes (i.e., used for authentication purposes, prevent fraudulent use, and protect from unauthorized parties). This category of cookies either cannot be disabled, or if disabled, certain features of the Website or Products may not work. 
(ii)    Analytical, Measurement & Performance Cookies. These cookies are used to collect information about how our Website and Products are being used, in order to improve them and the way they are offered. These cookies enable us, for example, to assess the number of users who have viewed a certain page as well as their country of origin. 
(iii)    Targeting & Advertising Cookies.  These cookies are set by our third-party service providers. They may be used to build a profile of your interests and show you personalized content and advertisements. They work by uniquely identifying your browser and device.

The third-party cookies used on our Website are as follows:

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 may be limited.


Browser Opt-out:
•    Google Chrome
•    Firefox      
•    Internet Explorer
•    Safari
•    Edge
•    Opera


Self-Regulation Opt-out: 
You may opt-out directly from third party retargeting cookies or other ad-technology trackers through self-regulator services such as (1) the Network Advertising Initiative’s (“NAI”) website – NAI consumer opt-out page; or (2) the Digital Advertising Alliance’s (“DAA”) website – DAA opt-out page;  


Please note that once you choose opt out, part of the Services provided by us might no longer be available and some features may not work if you revoke the data transfer. 


DATA RETENTION
We retain the information we collect as long as it remains necessary for the purposes set forth above, all in accordance with applicable laws, or until an individual requests to opt-out of such collection, subject to applicable laws. We may at our sole discretion, delete or amend information from our systems, without providing any notice to you, once we deem it is no longer necessary for our purposes.

USERS’ RIGHTS & CONTROLS  
Data protection and privacy laws provide you with the ability to exercise some rights regarding your Personal Information that we hold (depending on your jurisdiction) such as: the right to access your Personal Information; the right of rectification; the right to the erasure of your Personal Information; the right to restrict the processing of your Personal Information; the right to object to the processing of your Personal Information; data portability; the right to file a complaint to a supervisory authority (in the event you are a resident of the European Economic Area ("EEA")); and, the right to withdraw consent. Please review our User Rights Policy for more information regarding the rights you may have under the relevant data protection and privacy laws in your jurisdiction.


If you wish to exercise any or all of the above rights, please fill out the Data Subject Request Form (“DSR”) available here , and send it to our privacy team at: cr@newpacemedical.com.


Where we are not able to provide you with the information for which you have asked, 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. In addition, the process of locating and deleting the data may take up to one (1) month (following the receipt of the validation proof we require) in accordance with 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.


SECURITY 
We take great care in implementing and maintaining the security of our Website and your information. We employ industry standard procedures and policies to ensure the safety of individuals’ information and prevent unauthorized use of any of such. We have implemented technical, physical and administrative security measures to protect the Personal Information, including without limitation by using industry standard encryption (SSL). In addition, we limit access to your information on our servers. The data collected by us is stored mainly on our local data servers. 
Although we take reasonable steps to safeguard information, we cannot be responsible for the acts of those who gain unauthorized access or abuse our Website and servers, and we make no warranty, express, implied or otherwise, that we will prevent such access.

THIRD PARTY WEBSITES
Our Privacy Policy only addresses the use and disclosure of information we collect from you. To the extent that you disclose your information to other parties via the Website (e.g., by clicking on a link to any other website or location) or via other sites throughout the Internet, different rules may apply to their use or disclosure of the information you disclose to them. You acknowledge that we are not responsible for the products, services, or descriptions of products or services that you receive from third party sites or to the content or privacy practices of those sites, and that this Privacy Policy does not apply to any such third party products and services. You are knowingly and voluntarily assuming all risks of using third party sites. You agree that we shall have no liability whatsoever with respect to such third party sites and your usage of them.

CHILDREN UNDER THE AGE OF 16
The Website is intended for use for any person over the age of 16 years old. The Company does not knowingly collect Personal Data from children under the age of 16 years old. We request that such individuals do not provide Personal Data through our Services nor access and browse the Website.

TRANSFER OF DATA
We may store or process your Personal Information in the EU, United States or in other countries. Thus, any information you provide to us through your use of our Website may be transferred to and processed in countries other than the country from which you accessed our Website. We will take appropriate measures to ensure that your Personal Information receives an adequate level of data protection upon its transfer. 

DO NOT TRACK DISCLOSURE
The website or our Services does not respond to Do Not Track signals. For more information about Do Not Track signals, please see: http://www.allaboutdnt.com/.

AMENDMENTS
We reserve the right to periodically amend or revise this Privacy Policy from time to time, at our sole discretion, so please re-visit this page frequently; Any changes to this Privacy Policy will become effective immediately upon the display of the revised version. The most recent version of the Privacy Policy will always be posted. If we do make any changes, the updated date at the top of the Privacy Policy will be reflected in the "Last Updated" heading. 

CONTACT US 
If you have any questions (or comments) concerning this Privacy Policy, you are welcome to contact us, as follows:
•    By email: cr@newpacemedical.com
•    By visiting this page on our website: https://www.newpacemedical.com/contact-us
•    By phone number: +972-4-7703313
•    By mail: Granit 13, North Industrial Park – Caesarea, POB 3112, 3088900, Israel.
 
We will make an effort to reply within a reasonable timeframe.