EyeControl PLATFORM PRIVACY POLICY
Last updated: February 25, 2025
EyeFree Assisting Communication Ltd., a company operating under the brand name EyeControl (“EyeControl”, “we” or “us”) presents this privacy policy, as may be amended from time to time (the “Privacy Policy” or “Policy”) in order to provide our Users (as defined below) comprehensive information about EyeControl’s privacy and data protection practices in relation to Personal Information (as defined below) that is collected, used and/or otherwise processed by EyeControl and/or third parties acting on its behalf, through its websites and/or web applications for Users (the “Platform”) intended to improve the quality of life for “locked-in” or ventilated patients (the “Patients”) and to advance the method of communication at home or within medical centers by providing a wearable, screen free and simple to use communication device (the “Device”) which connects to our Platform. Our Platform and Device enable patients to communicate with medical staff, family members and caregivers.
Please note that a separate privacy policy is applicable to our https://www.eyecontrol.co.il website available at: Privacy Policy — EyeControl.
This Privacy Policy supplements our Platform T&Cs and our Platform Cookie Policy.
You also represent that all Personal Information you provide is accurate and up to date.
By using the Platform, you hereby provide your informed consent to the collection, processing and use of your Personal Information by EyeControl (including the
transfer of such Personal Information to third parties, as set forth in this Privacy policy), all, for the purposes and subject the terms set forth in this Privacy Policy.
For the purpose of this Privacy Policy, the following terms shall have the respective meanings set forth beside them:
“Account” means any User’s account on the Platform.
“Data Protection Laws” means the Israeli Data Protection Legislation, and any other privacy and data protection laws applicable to EyeControl with respect to the processing of Personal Information, according to the terms of the Privacy Policy.
“Care Provider” means an individual who provides healthcare services to the Patient; including but not limited to a licensed medical practitioner or a professional caretaker.
“Israeli Data Protection Legislation” means the Privacy Protection Law 5741-1981 (the “PPL”) and any regulations promulgated thereto, as amended, supplemented and superseded from time to time.
“Peer Supporter” means a family member, friend, or any other individual the Patient has authorized and invited to use the Platform in order to operate the Device.
“Personal Information” means any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual, or as otherwise defined in the Data Protection Laws. Personal Information does not include anonymized, aggregated, or purely statistical information.
“User”, “you” or “your” (including any alterations thereof) means any individual that uses the Platform and\or Device, including Patients, Peer Supporters, and Care Providers.
The term “Processing” shall have the meanings ascribed to it or to any essentially similar term in the Data Protection Laws.
“Services” are any services given by EyeControl in connection with the Device, including the Platform, operated by Eyefree Assisting Communication Ltd.
“Terms” or “T&Cs” means the Terms and Conditions for use of the Platform which are available at: https://eyecontrol-legal- public.s3.amazonaws.com/terms-and-
conditions/platform/home/latest/doc.htmlTerms which are not defined herein shall have the meaning ascribed to them in the Terms.
The collection and Processing of Personal Information commences on your initial registration to the Platform or first use of the Device. However, the Processing activity by us will include, inter alia, Personal Information provided by you to EyeControl outside the scope of the Platform and Device.
No legal obligation. We hereby inform you, and you hereby acknowledge that you have no legal obligation to provide us with any Personal Information (or any other information), and the provision of it is solely based on your free will and is done with your consent. However, you are aware that without the provision of your Personal Information, we will not be able to enable you to access and use the Platform and we will not be able to provide you with our Services.
The types of Personal Information each User will be required to provide or which we collect, include the following information:
We process the following Personal Information directly from you when you create an account on our Platform, when you use the Platform and Device, when you communicate with us or otherwise when you use our Services:
Your contact details including: first and last name, address, phone number, e-mail address, and the password you choose.
Any additional Personal Information you choose to provide us, when creating an Account, contacting us or otherwise. We kindly request that you provide us only with the essential information relevant to your request. Please note that by voluntarily disclosing Personal Information to us, you explicitly consent to the collection, processing, and utilization of such Personal Information in accordance with this Privacy Policy.
Patients: Personal Information that has been provided when setting the Patient’s preferences regarding the use of the Device, including, without limitation: language and gender, as well as medical information, including medical information needed for reimbursement process of the Ministry of Health (such as medical background including motor and cognitive state, auditory and vision
skills, relevant medical observations, ability to use the device or other communication devices, ID number, habits and lifestyle, family status.
Care Providers: job title and organization, contact details.
Physical and behavioral parameters of the Patient collected from the Device sensors, such as eye gestures and sleep habits.
Video recordings (only for ICU Patients using EyeControl-Med/Pro)
Technical data: When you use the Platform and\or Device, we may collect some Personal Information about you through cookies and other tracking technologies. Cookies are a commonly-used web technology that allows websites and apps to store and retrieve certain information on a user’s system, and track users’ online activities. We and our service providers may collect Personal Information about your use of our Platform and Device by such automated means, including but not limited to cookies, pixels, SDKs and other similar technologies. Cookies can be persistent (cookies that remain on your device for a set period of time or until you delete them) or session (cookies that are deleted as soon as you close the Platform).
We will use the Personal Information for the following purposes:
Allowing you to open your Account, and complete the registration and the activation of the Device, in order to enable you use the Platform and Device, providing you the Services and ensuring the Platform is connected to your Device.
Operating the Platform and facilitating the use of the Device.
To monitor and analyze your use of the Platform and Device.
Provide technical support.
To ensure that the Platform is functioning correctly and to monitor, investigate and fix any bugs.
When the Device is being used in medical centers or health organizations, those entities may use the Personal Information for medical purposes, such
as medical diagnosis of various medical conditions, and medical research, after receiving your separate informed consent.
We will use the User’s contact information to contact our Users (by e-mail, SMS, or any other available channels) with general or personalized service- related messages (such as system maintenance notices); to contact our Users with updates messages (such new features and services, etc.); and to transmit marketing and promotional communications regarding our Services, including our newsletter, subject to your separate consent If such is required in your jurisdiction. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or the instructions provided in any email we send.
We may use Personal Information in order to enforce this Privacy Policy, establish, exercise or defend our legal rights, resolve disputes, comply with any applicable law (including Data Protection Laws), or other requests from competent authority(ies).
Developing, customizing and improving the Device, the Platform and our Services.
To support and enhance our data security measures, including for the purposes of preventing and mitigating the risks of fraud, error or any illegal or prohibited activity.
For the technical administration and troubleshooting of the Platform.
To improve the usefulness and quality of the Platform and to enhance the positioning of the Platform.
To assist in determining the effectiveness of our Platform.
For commercial research and further development.
To create aggregated statistical data, inferred non-personal information or anonymized or pseudonymized data, which we or our business partners may use to provide and improve our respective Services.
and/or as otherwise authorized by you.
We retain the User's Personal Information for as long as such individuals are using our Services. If a User ceases to use our Services, we will continue to retain certain Personal Information of that User for the period required by our legal and regulatory obligations and/or for accounting purposes (i.e., as required by applicable laws regulating our Services, for bookkeeping purposes, and in order to have proof and evidence concerning our
relationship with that User, should any legal issues arise following the User’s discontinuance of use of our Services) and\or as permitted by law.
Please note that except as required by applicable law, we will not be obligated to retain your Personal Information for any particular period, and we are free to securely delete it for any reason and at any time, with or without notice to you.
We may share your Personal Information with certain third parties, as detailed below:
We may provide links within the Platform that permit Users to leave our Platform and enter third-parties’ sites or services. Those linked sites and services are provided solely as a convenience to you; the linking to those sites or services does not indicate any association with or endorsement by us. These linked sites and services are not under our control and EyeControl is not responsible for the availability of such external sites or services, and does not endorse and is not responsible or liable for the content, policies or practices available from such linked sites and services or any link contained in linked sites or service. Most of such linked sites and services provide legal documents, including terms of use and a privacy policy, governing the use thereof. It is advisable to read such documents carefully before using those sites and services. Please note that your access and/or use of any such sites, services and content are at your sole risk.
We endeavor to maintain reasonable administrative, technical and physical safeguards designed to protect the Personal Information we maintain against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. However, we cannot ensure the full security of any Personal Information collected by us, or guarantee that this Personal Information will not be accessed, disclosed, altered, or destroyed. We will make any legally required disclosures in the event of any compromise of Personal Information. To the extent the law allows us to provide such notification via e-mail or conspicuous posting on the Platform, you agree to accept notice in that form.
You may have the right to review your Personal Information that is stored in our database(s) and provide a request for an update, amendment and/or deletion if it is inaccurate or incorrect, by contacting us at hello@eyecontrol.co.il. We will act in accordance with the applicable Data
Protection Laws in order to comply with your request. Your rights may differ depending on your jurisdiction.
When you ask us to exercise any of your rights under this Privacy Policy and the Data Protection Laws, we may need to ask you to provide us certain credentials to make sure that you are who you claim you are, to avoid disclosure to you of Personal Information which is related to others that you are not authorized to receive, and to ask you questions to better understand the nature and scope of the Personal Information that you request to access.
As already mentioned above, you have the right to withdraw your consent to receive marketing materials, by contacting us through the “unsubscribe” instructions in the promotional communications you receive.
You may terminate your Account by contacting us as provided in the “Contact Us” section below. We may retain any Account information for internal purposes or as otherwise provided in this Privacy Policy and our Terms.
We may host, store, process, maintain or transfer the Personal Information to various sites worldwide, outside your jurisdiction including through cloud-based service providers, where the privacy laws may not be as protective as those in your jurisdiction. By using the Platform or Device, you hereby provide your informed consent to the use and/or processing and/or hosting, storage and/or transfer of your Personal Information to countries outside your jurisdiction as aforementioned. Where specific laws or regulations relating to data transfer apply to us, we will endeavor to ensure that the Personal Information is protected and transferred in a manner consistent with legal requirements.
The Platform is directed towards and designed for use by persons aged 18 and older, depending on the minority age in your jurisdiction. We do not solicit or knowingly collect Personal Information from children under the age of 18. If we nevertheless receive Personal Information from an individual who indicates that he or she is, or whom we otherwise have reason to believe is, under the age of 18, we will endeavor to delete such information from our systems. If you are an individual under the age of 18, you are required not to use our Platform and/or Services.
This Privacy Policy may change from time to time. If we decide to change our Privacy Policy, we will post the new privacy policy on our Platform. The new privacy policy will be effective from the date mentioned on the top page of the new policy. Where
such changes will require your specific consent under applicable law, we shall obtain it before applying the changes to the processing of your Personal Information.
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