This Privacy Policy (“Privacy Policy”) explains how information is collected and used by BrainQ Technologies Ltd. (“BrainQ” or “we”, “us”, “our”).
This Privacy Policy applies to the data practices on the BrainQ website at https://brainqtech.com/ (“Website”).
We are committed to protecting and respecting data privacy. Please read this Privacy Policy carefully.
When you visit our Website, you can submit an inquiry through our online contact form. When you contact us, you will be asked to provide information such as your full name, email address and the subject of your inquiry. We refer to this entire data as “Inquiry Information”.
When you visit the Website, we record and collect certain information about your interaction with the Website, including the IP address from which you access the Website, time and date of access, type of browser used, language used, links clicked, and actions taken while using the Website ("Analytics Information").
We process information you provide us when you submit eligibility form for our clinical trials.
When you visit the "Clinical Trials” page on our Website, where we have provided information on our clinical trial in the US, you may submit an eligibility form to assess if you are eligible for our clinical trials in the US. When you fill this form, we will collect information on your age range, current health condition and medical history. We will also ask you to provide your full name and contact information, such as your email address. You are not obliged to provide your Eligibility Information.
(“Eligibility Information”)
We process your Inquiry Information to contact you about your inquiry and handle your inquiry.
We process your Inquiry Information to send you marketing communications such as newsletters and other useful announcements. We will only do so if you provided your consent to receive these communications from us. You may revoke your consent at any time by contacting us via our online contact form available at Contact Us or via the unsubscribe link in each marketing communication you receive from us.
We process your Analytics Information to provide, maintain and improve your user experience when accessing our Website.
We also process the Analytics Information to improve our email communications.
We will use the Analytics Information to prevent fraud, resolve disputes, troubleshoot problems, assist with any investigations, enforce our terms of use for the Website and take other actions otherwise permitted by law.
To assess if you qualify for our clinical trials in the US
We process your Eligibility Information to assess if you qualify for our clinical trials in the US. If you are eligible for our clinical trials, we will contact you to provide further information on how to enroll to our clinical trials.
If you are not eligible, we may use your Eligibility Information to contact you in the future, in case you are eligible for other clinical trials.
If you do not wish to be contacted by us, you may assess your eligibility through our Website without providing your contact information, and directly contact one of our clinical trial locations in the US.
We will not share your information with third parties, except in the events listed below or when you provide us your explicit and informed consent.
We will share your personal information with our service providers who assist us with the internal operations of the Website. These companies are authorized to use your personal information in this context only as necessary to provide these services to us and not for their own promotional purposes. Our service providers include, for example, companies that provide software or other support services to help us run the Website.
If you have violated our Website Terms of Use or any applicable law, we will share information with authorized authorities and with third parties (such as legal counsels and advisors), for the purpose of handling of the violation or breach.
We will share information if we are required to do so by a judicial, governmental or regulatory authority or as otherwise required by law.
If the operation of our business is organized within a different framework, or through another legal structure or entity (such as due to a merger or acquisition), we will share information only as required to enable the structural change in the operation of the business.
Cookies are text files, comprised of small amount of data, that are saved on your computer or other device (e.g. smartphone, tablet, etc.) when you use the internet and visit various websites.
The information that the cookies maintain is read by the website you visit, during the session of your visit to the website (these are called ‘session’ cookies), and when you return to visit it again (these are called ‘persistent’ cookies). We also use technologies called web beacons and web pixels for purposes similar to the use of cookies.
We use cookies for a number of purposes, as briefly explained below:
Necessary. Cookies that are strictly necessary for the functioning of the Website. The Website cannot operate properly without these cookies. You can set your browser to block or alert you about these cookies, but if you block these cookies, some parts of the Website may not function properly.
Unclassified. Unclassified cookies are cookies that we are in the process of classifying, together with the providers of individual cookies.
Further information about the types of cookies that we use and purpose for which we use them are described in the chart below:
| Expiry
|
Essential for Website Functionality? | Provider | Cookie Description | Cookie Type | Cookie Name |
| Persistent | Yes | Google.com | This cookie is used to distinguish between humans and bots. This is beneficial for the website in order to make valid reports on the use of their website. | Necessary | rc::a |
| Session | Yes | Google.com | This cookie is used to distinguish between humans and bots. | Necessary | rc::b |
| Session | Yes | Google.com | This cookie is used to distinguish between humans and bots. | Necessary | rc::c |
| Persistent |
Yes |
Google.com |
This cookie is used to distinguish between humans and bots. | Necessary |
rc::d-15# |
| Session |
No |
perf.hsforms.com |
Unclassified |
Unclassified | embed/v3/counters.gif |
You can always delete the cookies saved on your device through the settings of your computer browser or device. You can also disable cookies for future use through the settings of your computer browser or device.
We will retain Inquiry Information and Analytics Information for the duration needed to support our ordinary business activities operating the Website or for a longer period to comply with our legal obligations, resolve disputes, establish and defend legal claims and enforce our agreements.
If we transfer your personal data for processing at locations outside your jurisdiction, we will abide by data transfer rules applicable to these situations.
The following is the contact information of BrainQ:
BrainQ Technologies Ltd.
3/7 “Hi Tech Village” Givat Ram, Jerusalem
Israel
Email: [email protected]
The legal basis under EU law for processing Analytics Information is our legitimate interest in maintaining, developing and enhancing the Website.
The legal basis under EU law for processing your Inquiry Information for the purpose of responding to and handling your inquiry is our legitimate interests in responding to your inquiry.
The legal basis under EU law for processing your Inquiry Information to send you marketing communications is your consent.
The legal basis under EU law for processing your personal data for the purpose of handling instances of abusive use of the Website is our legitimate interests in defending and enforcing against violations and breaches that are harmful to our business.
The legal basis under EU law for sharing your personal data where we are legally required to, is our legitimate interests in complying with mandatory legal requirements imposed on us.
The legal basis under EU law for processing your personal data in the event of a change in our corporate structure is our legitimate interests in our business continuity.
Please note that you are no obligated to provide us with Inquiry information, but if you choose not to provide us with such information, this means you will not be able to submit an inquiry to us. As a condition of using the Website, we collect Analytics Information, so if you choose not to provide Analytics Information you should not use the Website.
We do not knowingly process Eligibility Information on EU individuals, as the eligibility assessment form on our “Clinical Trials” page is intended for potential US patients only.
Purposes for processing your personal data
We process your personal data for purposes described above in this Privacy Policy, including for purposes of responding to and handling your inquiries, sending you marketing communications if you've provided consent, and providing and maintaining our Website.
Recipients of your personal data
Please see the section above titled "How We Share Your Data" for information about recipients of your personal data.
If you are in the EU, you have the following rights under the GDPR in relation to BrainQ’s processing of your Inquiry Information and Analytics Information:
Right to Access your personal data that we process and receive a copy of it.
Right to Rectify inaccurate personal data we have concerning you and to have incomplete personal data completed.
Right to Data Portability, that is, to receive the personal data that you provided to us, in a structured, commonly used and machine-readable format. You have the right to transmit this data to another service party. Where technically feasible, you have the right that your personal data be transmitted directly from us to the party you designate.
Right to Object, based on your particular situation, to using your personal data on the basis of our legitimate interest. However, we may override the objection if we demonstrate compelling legitimate grounds, or for the establishment, exercise of defense of legal claims. You may also object at any time to the use of your personal data for direct marketing purposes.
Right to Restrict the processing of your personal data (except for storing it) if you contest the accuracy of your personal data, for a period enabling us to verify its accuracy; if you believe that the processing is unlawful and you oppose the erasure of the personal data and request instead to restrict its use; if we no longer need the personal data for the purposes outlined in this Policy, but you require them to establish, exercise or defense relating to legal claims, or if you object to processing, pending the verification whether our legitimate grounds for processing override yours.
Right to be Forgotten. You have the right to ask us to erase your personal data under certain circumstances, such as when you object to us processing your data and we have no compelling legitimate grounds to override your objection, we will erase your personal data pursuant to your request. However, we may still process your personal data in some instances, including for example, if processing it is necessary to comply with a legal obligation we are subject to under laws in EU Member States or for the establishment, exercise or defense of legal claims.
Right to Withdraw Consent. If our processing is based on your consent, such as processing your personal data for marketing purposes, you may withdraw your consent at any time by contacting us via our online contact form available at Contact Us or via the unsubscribe link in each marketing communication you receive from us.
If you wish to exercise any of the rights described above, contact us at [email protected] .
We reserve the right to ask for reasonable evidence to verify your identity before we provide you with information. Where we are not able to provide you the information that you have asked for, we will explain the reason for this.
Retention of your Personal Data
Please see the section above titled "Data Retention and Security" for a description of how long we retain your personal data.
Cross-boarder Personal Data Transfers
We transfer personal data across national boarders, including from the European Economic Area (EEA) to Israel. The European Commission has determined that Israel provides an adequate level of protection of personal data.
Subject to applicable law, you have the right to lodge a complaint with your local data protection authority. If you are in the EU, then according to Article 77 of the GDPR, you can lodge a complaint to the supervisory authority, in particular in the Member State of your residence, place of work or place of alleged infringement of the GDPR. For a list of supervisory authorities in the EU, click here.
From time to time, we may change this Privacy Policy. If we do so, we will make efforts to proactively notify you of such changes. In any event, the latest version of the Privacy Policy will always be accessible on the Website.
Last Updated: August 25, 2022