SWEETCH PRIVACY POLICY

This Privacy Policy explains how Sweetch Health Ltd. (“we”, “us” or “Sweetch”) collects and uses data. If not otherwise defined herein, capitalized terms have the meaning given to them in the Sweetch Terms of Service, which is available at http://sweetch.com/terms-of-use/ (the “Terms”).

Sweetch respects your right to privacy. Your ability to make informed choices about the use of your information is important to us. This Privacy Policy explains Sweetch’s policies regarding the collection, use, disclosure and protection of any information we receive.

If you reside or are located in the European Economic Area (“EEA”) Sweetch is the data controller of all personal information collected via the Services, as set out in this Privacy Policy.

 

Personal Information We Collect

Personal information that you may provide through the Services or otherwise communicate with us includes:

  • Login and account information, such as your first name, last name, username or similar identifier and password;
  • Contact information, such as your email address and telephone number;
  • Data on physical characteristics, such as your date of birth, gender, weight, height, meals reporting, health habits;

We request additional personal information from you to enable particular features within our Services. For example, we request access to your device’s location data to provide personalized activity and weight plans and your device calendar to schedule a personalized plan. This personal information includes your:

  • Movement data from your device;
  • Calendar information; and/or
  • location data.

You may provide us with the contact information of your friends, family members, contacts, or colleagues (“Friend/s”) such that your Friends will receive your progress updates. These progress updates will include information about your Activity and other achievements. By providing us with such information you (a) represent and warrant that you have received each of your elected Friends’ consent for the provision of your information and for these purposes and (b) consent to sending your Friend such progress updates.

When interacting with our Services, certain data is automatically collected from your device or web browser. More information about these practices is included in the “Cookies and Pixel Tags” section of this Privacy Policy below. This data includes your:

  • Device IDs; and
  • IP addresses.

It is your voluntary decision whether to provide us with any such Personal Information, but if you choose not to provide such information some features which require your personal information may not be available and we may not be able to provide you with the Services.

 

Children

Sweetch does not knowingly collect personal information from children under the age of 16. In the event you become aware that an individual under the age of 16 has enrolled without parental permission, please advise us immediately.

 

Tools to Manage What Personal Data We Collect

When using our Services, we also provide in-time notice or obtain consent for certain practices. For example, we will obtain consent to use your location, access your calendar, or send push notifications.

In many cases, your mobile device platform will provide additional tools to allow you to control when your device collects or shares particular categories of personal information. For example, your mobile device may offer tools to allow you to manage location sharing. We encourage you to familiarize yourself with and use the tools available on your devices.

 

Why and How Do We Use Your Personal Information?

We use your personal information in the following ways:

  • To Provide the Features of the Services You Request

When you use our Services, we will use your personal information to provide the requested product or service. For example, if you contact our customer services, we will use information about you, such as your email address, name or date of birth to help you resolve a problem or questions.

If you use our Services to track your fitness activity or physical characteristics, we will collect this personal information and store it so that you can review it. Your fitness activity data may include data you enter about your activity or data collected by your device during your activity such as location data and movement data. We may use this activity data to calculate further information about your activity, such as distance walked or run, or calories burned, so that the calculated information can be provided to you as part of the functionality of the Services.

In many cases, to use particular features within our Services you may need to provide us with additional data or additional consent to use particular data in a certain way. For example, to allow us to personalize your activity plan, we may need access to your calendar. Similarly, to share content with your Friends, you may be required to provide your Friends’ contact. Moreover, on our initial communication with any of your Friends we will request their consent to be contacted.

  • To Communicate Information about our Services

We may use the contact details you provided to send you marketing communications about similar Sweetch services where permitted by applicable law (unless you have opted-out). In other cases, we ask for your consent to send you marketing information. We may use the information that you provide to us to personalize communications on products and services that may be interesting for you.

  • To Operate, Improve and Maintain our Services

We may use personal information about how you use our Services to enhance your user experience and to help us diagnose technical and service problems and administer our Services.

  • To Protect Our or Others’ Rights, Property or Safety

We may also use your personal information about how you use our Services to prevent or detect fraud, abuse, illegal use, violations of the Terms, and to comply with court orders, governmental requests or applicable law.

  • For General Research and Analysis Purposes

by analyzing all information we receive, including all information concerning users and fitness activity, we may compile statistical information across a variety of platforms and users (“Statistical Information”). Statistical Information helps understand trends and customer needs so that new products and services can be considered and so existing products and services can be tailored to customer desires. Statistical Information is anonymous. We may share such Statistical Information with our partners, without restriction, on commercial terms that we can determine in our sole discretion.

  • Use of Wellness Information

As discussed above, we collect information about your fitness activity or your physical characteristics (together, “Wellness Information”) to provide our Apps and other services. Because of the personal nature of this data, we strive to provide you with clear information about how Wellness Information will be used. As this data may be considered sensitive in certain jurisdictions, we take appropriate measures in protecting and using this information and, where required by applicable law or under our internal policies, will obtain your consent for use of your Wellness Information.

  • Other Purposes

We may also use your personal data in other ways and will provide specific notice at the time of collection and obtain your consent where necessary.

  • Legal Grounds

To process your personal data, we rely on certain legal grounds, depending on how you interact with our Sites and Apps.

When you use the Services, we need your personal information to fulfill our contract with you. For example, we need your contact details to provide you access to the Services.

When you use our Services, for certain purposes we rely on your consent for processing to fulfill our contract with you (for example, access to your calendar for personalized activity plan).

We also rely on other legal grounds, such as our legitimate interests as a business, to comply with a legal obligation, or to protect your vital interests.

 

Sharing Your Personal Information

We do not share or sell the personal information that you provide us with to other organizations without your express consent, except as described in this Privacy Policy. We disclose personal information to third parties under the following circumstances:

  • We may disclose your personal information to our subsidiaries and corporate affiliates for purposes consistent with this Privacy Policy.
  • We may employ third party companies and individuals to administer and provide the Services on our behalf (such as customer support, hosting, email delivery and database management services). These third parties are permitted to use your personal information only to perform these tasks in a manner consistent with this Privacy Policy and are obligated not to disclose or use it for any other purpose.
  • We may send your elected Friends your progress updates where you and the applicable Friend provided consent.
  • We may provide the IP address assigned to you on the date you used the Services to Segment.io, Inc. (“Segment”) in order to receive an analysis of the use of our Services. We do not combine the information collected through the use of Segment with your personal information. Please see the Segment Terms of Service (available at https://segment.com/docs/legal/terms/) and the Google Privacy Policy (available at https://segment.com/docs/legal/privacy/) for additional information.
  • We may disclose information about you to government or law enforcement officials or private parties as required by law, and disclose and use such information as we believe necessary or appropriate to (a) comply with applicable laws and lawful requests and legal process, such as to respond to subpoenas or requests from government authorities; (b) enforce the Terms of Services; (d) protect our rights, privacy, safety or property, and/or that of you or others; and (e) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.
  • We may disclose your personal information with any other third party where you have provided your consent.
  • We may also transfer personal data we have about you in the event we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, spin-off, dissolution or liquidation).

 

Protection and Management of Your Personal Information

  • Security

We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, while we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security

  • International Transfers of your Personal Data

The personal information we collect (or process) in the context of our Services will be stored in the USA and other countries. Some of the data recipients with whom we share your personal information may be located in countries other than the country in which your personal data originally was collected. The laws in those countries may not provide the same level of data protection compared to the country in which you initially provided your data. Nevertheless, when we transfer your personal information to recipients in other countries, including the USA, we will protect that personal data as described in this Privacy Policy and in compliance with applicable law.

We take measures to comply with applicable legal requirements for the transfer of personal information to recipients in countries outside of the EEA that do not provide an adequate level of data protection. We use a variety of measures to ensure that your personal data transferred to these countries receives adequate protection in accordance with data protection rules; this includes signing the EU Standard Contractual Clauses, verifying the recipient has adopted Binding Corporate Rules or adheres to the EU-US and Swiss-US Privacy Shield Framework.

  • Retention of your Personal Information

We will retain your personal information for as long as your account is active or as needed to provide you the Services. If you wish to cancel your account or request that we no longer use your information to provide you the Services, please contact us at the email address listed below. We will retain and use your personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances we may anonymize your personal information (so that it can no longer be associated with you), in which case we may use this information indefinitely without further notice to you.

 

Your Rights Relating to Your Personal Information

If you would like information in relation to your rights or would like to exercise any of them, you may contact us via privacy@sweetch.com or our postal address provided below. If you reside or are located in the EEA, you may ask us to take the following actions in relation to your personal information that we hold:

  • Opt-out. Stop sending you direct marketing communications. You may continue to receive Services-related and other non-marketing emails.
  • Access. Provide you with information about our processing of your Personal Information and give you access to your personal information.
  • Correct. Update or correct inaccuracies in your personal information.
  • Delete. Delete your personal information.
  • Transfer. Transfer a machine-readable copy of your personal information to you or a third party of your choice.
  • Restrict. Restrict the processing of your personal information.
  • Object. Object to our reliance on our legitimate interests as the basis of our processing of your personal information that impacts your rights.

We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or response to your requests regarding your personal information, you may contact us at privacy@sweetch.com or submit a complaint to the data protection regulator in your jurisdiction. You can find your data protection regulator here.

 

Third Parties and Online Links to Other Sites

Sweetch users can link to other websites of third-parties that provide useful information/services. Any personal information you provide on the linked pages is provided directly to this third-party and is subject to that third-party’s provider’s privacy policy. We do not have access to the information collected by such partners. Except as described above, Sweetch is not responsible for the content or privacy practices of websites to which we link. Links from our Services to third-parties or other websites are provided for your convenience. We encourage you to learn about the privacy practices of each website before providing them with personal information. We cannot be held responsible for any third-party websites and accessing their content will be subject to their own privacy policies, which again – we advise you to check.

 

Changes to Our Privacy Policy

Applicable law and our practices change over time. If we decide to update our Privacy Policy, we will post the changes on our Services. If we materially change the way in which we process your personal information, we will provide you with prior notice, or where legally required, request your consent prior to implementing such changes. We strongly encourage you to periodically read our Privacy Policy and keep yourself informed of our practices. This Privacy Policy was last modified in June 2018.

 

Comments and Questions

If you have any comments, requests or questions about our privacy policy, please contact us at privacy@sweetch.com or use or our postal address:

Sweetch Health ltd.
48 Derech Begin
Tel Aviv 6618005
Israel