Last Revised: January 26th,2020
Shelby Technologies and Innovations Ltd. and its affiliates (the “Company”, “us” or “we”) respect the privacy of its website users (“User” or “you”) and is committed to protect its Users’ personal information. We believe that you have a right to know our practices regarding the information we may collect and use about you when you use our websites at https://www.nili-method.com/home/ or at http://nili-family-planner.com/ (collectively, the “Site”). Please read the following carefully to understand our views and practices regarding your personal information and how we will treat it.
Table of Content
- Who we are
- Your acknowledgment of this policy
- Which information may we collect about Users?
- How do we collect information about our Users?
- What are the purposes of the collection and processing of information?
- Sharing Personal Information with Third Parties
- Your Rights
- Location of Your Data
- Third Party Service Providers and Third Party Software
- Links to Third Party Websites
- Data Retention
- Have any Questions?
Who we are
In this policy, references to the “Company”, or to “we” or “us” are to Shelby Technologies and Innovations Ltd., which is a registered company in Israel (No. 516107026 at Rothschild 3, Tel Aviv, Israel. Individuals wishing to contact us about data protection issues may do so by writing to us at the above address or by emailing us at: firstname.lastname@example.org.
Your acknowledgment of this policy
Which information may we collect about Users?
We may collect two types of data and information from our Users:
Non-personal Information. The first type is non-identifiable and anonymous information. Non-personal information, which is being gathered, consists of technical information and behavioral information that does not pertain to a specific individual (“Non-Personal Information”).
You may access and browse the Site without disclosing personal information, although, like most websites, we passively collect certain Non-Personal Information from your devices, including: (i) technical information such as the type of browser, screen resolution, keyboard language, Wi-Fi connectivity etc.; and (ii) behavioral information which may include the User’s click-stream on the Site, the activities of the User on the Site and additional information of a similar nature (collectively, “Technical and Behavioral Information”). We may also use third-party service providers as further detailed under Section 11 herein, to obtain detailed analytics on the device and the User’s behavior on the Site.
Personal Information. The other type of information we collect is individually identifiable information. To put it simply, this information identifies an individual or is of a private and/or sensitive nature, such as your contact information you provided in order to register to our Service (“Personal Information”), including:
Personal Information which is provided voluntarily:
- Registration Details. You may register to our Service via the Site. In order to complete such registration, you will be required to provide us with certain Personal Information, including, inter alia, your full name, email address and telephone number.
- Your Response to the Questionnaire. Following the initial registration process, you will be required to complete the Questionnaire and provide us with additional Personal Information in order to enable us to customize the Service and provide you with adequate information and tips suitable to your personal needs. Such information shall include, inter alia,: your desired baby gender; the User’s date of birth, height and weight; health related details such as the date of your last menstruation, the length of your menstruation cycle, whether you have had an abortion and how often are you unwell; details regarding your nutrition and allergies; whether and in what frequency do you smoke, consume alcohol and exercise; and details related to the number of siblings and children you have, their gender and order.
- Credit card details. Our Service is provided to Registered Users who have completed the registration process and paid the registration fees. In order to pay such fees, Registered Users will have the option to use certain Online Payment Processors (as defined below) which will require Registered Users to fill out a billing form wherein such Registered User will be required to provide to the Online Payment Processors certain Personal Information (such as, a credit card number and other related billing information) (see Section 12 below regarding the payment method). We will not store such information on our servers. We only keep token information such Online Payment Processors will provide us with (and where applicable, the last four digits of your credit card number), and such information is strictly secured.
- Refund Requests: Registered Users may apply for a refund via the “Refund Request” page available on our Site. In order to apply for a refund you will be required to provide us with your newborn child’s birth certificate.
Personal Information collected via technology:
- Geolocation data: while using the Site we will access, collect, process, monitor and/or remotely store “geolocation data”, including through the collection of IP addresses and other similar information to determine your location for analytics and security purposes. Please note that we may also analyze your IP address, using our third party service providers, in order to determine the name of the company whose IP address you have used to browse our Site, for the purpose of locating prospects and in order to analyze our Site’s traffic.
- Technical and Behavioral Information: to the extent that the Technical and Behavioral Information detailed above under Section 4.1 will be linked to or associated with a specific individual, then such information will be considered as Personal Information.
- Identifiers: such as Internet Protocol (IP) address, your Unique Device Identifier (UDID), or other unique identifiers.
- We may cross-reference Personal Information with other Personal Information we have about you and any Non-Personal Information connected or linked to or associated with any Personal Information shall be deemed as Personal Information as long as such connection, linkage or association exists.
How do we collect information about our Users?
There are two main methods we use to collect information:
We collect information through your entry, connection, access and/or use of the Site. In other words, when you access or use the Site, we are aware of your usage of the Site, and may gather, collect and record the information relating to such usage. For example, when you use the Site, we gather your Technical and Behavioral Information.
We collect information which you provide us voluntarily. For example, we collect Personal Information that you provide us via the Questionnaire on our Site. We will inform you prior to collecting your Personal Information if it is requested on a voluntary basis and the consequences of not providing voluntary Personal Information.
What are the purposes of the collection and processing of information?
Non-Personal Information is processed in order to:
- Enhance the User’s experience on the Site;
- Create statistical information and learn about the preferences of Users and general trends on the Site (e.g. understand which features are more popular than others);
- Keep the Site safe and secured and for prevention of fraud and crime; and
- Improve, develop and upgrade the Site and our Service.
Personal Information is processed in order to:
- Enable the operation of the Site and administer your Account;
- Enable you to register to the Service;
- Enable us to process a Refund Request;
- Respond to your inquiry;
- Add your contact details to our mailing list for the purposes of sending you information and commercial materials, updates about the Company’s Services, new offerings, research or news by email, SMS, phone or through a web-browser notification. You have the right to opt-out of marketing messages at any time by following the instructions in such message or by contacting us at: email@example.com;
- Personalize your experience on the Site;
- Contact Users for marketing and sales purposes;
- Enable us to contact Users for the purpose of providing them with technical assistance and in order to provide them the Service;
- Ensure that content on the Site is presented in an optimal way for you and for your device (e.g. tablet, mobile phone);
- Conduct internal operations, including troubleshooting, data analysis, testing, research and statistical purposes;
- Keep the Site safe and secured and for prevention of fraud and crime;
- Comply with our legal obligations and in order to be able to protect our rights and legitimate interests, including in order to improve the Site;
- Maintain our data processing records and general administrative purposes;
- Email tracking – we may use tracking technology within the email we may send you in order to improve interactions with you and to better understand whether our emails were opened and read, and such tracking may include capturing the time and date in which you opened our email messages and the type of device you use to open such emails.
Note to our Users in the EU:
In order for the Company to process your Personal Information, as detailed herein, such processing must be justified by a “basis” for processing. Please note that the Personal Information processing activities detailed herein may be justified on the basis that:
- the processing is necessary to comply with a legal obligation – we may process your Personal Information for disclosure of information to authorities; and
- the processing is in our legitimate commercial interests – subject to your interests and fundamental rights, under our legitimate interest in marketing our Service via the Site and offering the public comfortable and safe access to our Site, we shall perform the Personal Information processing activities described herein, such as the processing of your Personal Information in order to personalize the Site, assisting us to prevent crime and fraud, manage our internal operations, maintaining records and email tracking. We may also use the information contained in certain cookies and other such files or tags based on such ground for our legitimate interests in a safe and user-friendly presentation of our Site. Where we rely on legitimate interests as a lawful basis, we will carry out a balancing test to ensure that your interests, rights and freedoms do not override our legitimate interests.
Note to non-EU Users:
BY ENTERING, CONNECTING TO, ACCESSING OR USING THE SITE, YOU CONSENT TO THE COLLECTION AND PROCESSING OF YOUR PERSONAL INFORMATION AS SPECIFIED HEREIN.
Sharing Personal Information with Third Parties
In addition to using the information collected by us for the purposes described under Section 6 above, we may also share your information in the following cases:
- The Company Personnel: Personal Information that we collect and process may be transferred to or accessed by personnel of the Company for the sole purpose of enabling the operation of the Site and Service and to contact you (as detailed in Section 6 above). Please note that all the Company personnel that will have access to your Personal Information are under an obligation of strict confidentiality with respect to such Personal Information.
- Service Providers: we share Personal Information with vendors, commercial software providers, consultants and data processers, online service providers who perform services on our behalf, including without limitation, companies that provide analysis, messaging services and services which host the Site. Please note that we collect, hold and manage your Personal Information through a third party’s cloud based services, as reasonable for business purposes, which may be located in countries outside of your jurisdiction. For more information regarding our Service Providers, please refer to Section 11 below.
For avoidance of doubt, the Company may transfer and disclose Non-Personal Information to third parties at its discretion including without limitation for statistical, analytical and research purposes and for customization, developing and improvement of our Site.
The Company acknowledges you have the right to access and change the Personal Information we collect and process. If you wish to access or to correct, amend, or delete Personal Information, please send us an email to: firstname.lastname@example.org and we will respond within a reasonable timeframe, but in any event no later than permitted by applicable law.
Note to our Users in the EU:
We hereby inform you of the following rights (by virtue of EU law), in respect of your Personal Information:
- Right to access: you may have the right to request a review of your Personal Information held by the Company. We may refuse to comply with your access request if the request is manifestly unfounded, excessive or repetitive in nature.
- Right to erasure: under certain conditions, you may be entitled to require that the Company will delete or “block” your Personal Information (e.g. if the continued processing of those data is not justified).
- Right to Portability: you may have the right to transfer your Personal Information between data controllers (i.e. to transfer your Personal Information to another entity). The right to data portability only applies where your Personal Information is processed by us with your consent or for the performance of a contract and when processing is carried out by automated means.
- Right to object to or withdraw consent: where that lawful basis for processing your Personal Information is either “public interest” or “legitimate interests”, those lawful bases are not absolute, and you may have a right to object to such processing. Where you object on grounds of legitimate interest, we shall no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims. If the processing of your Personal Information is based on your consent, you have the right to withdraw your consent to such processing at any time.
- The right to restrict processing – under certain circumstances, you may have the right to object to the processing of your Personal Information due to your particular situation.
- Right to lodge a complaint: you have the right to lodge a complaint before the relevant data protection authority or supervisory authority of your jurisdiction.
To exercise these rights, where applicable, please contact us by sending an email to: email@example.com.
Location of Your Data
Note to our Users in the EU:
If you are located in the EU, you have a right to request further information regarding the data transfer mechanisms used by us with respect to data transfers to third countries.
In order to keep your Personal Information safe, we apply strict safeguards when transferring it outside of the EEA, which may include the following:
- Transferring your personal information to countries approved by the European Commission as having adequate data protection laws, such as Israel;
- Entering into standard contracts that have been approved by the European Commission and which provide an adequate level of high quality protection, with the recipients of your Personal Information;
- Transferring your Personal Information to organizations that are Privacy Shield Scheme certified, as approved by the European Commission.
BY SUBMITTING YOUR PERSONAL INFORMATION THROUGH THE SITE, YOU ACKNOWLEDGE, AND AGREE, IN JURISDICTION WHERE SUCH CONSENT IS REQUIRED, TO SUCH TRANSFER, STORING AND/OR PROCESSING OF PERSONAL INFORMATION.
The Site is intended for Users over the age of eighteen (18). Therefore, the Company does not intend and does not knowingly collect directly Personal Information from children under the age of eighteen (18) and does not wish to do so. We reserve the right to request proof of age at any stage so that we can verify that minors under the age of eighteen (18) are not using the Site. If we learn that we collected Personal Information from minors under the age of eighteen (18) we will delete that information as quickly as possible. If you have reasons to suspect that the Company collected Personal Information from minors under the age of eighteen (18), please notify us at firstname.lastname@example.org and we will delete that information as quickly as possible.
Third Party Service Providers and Third Party Software
Note, that we collect, hold and/or manage your Personal Information through the Company’s authorized third parties vendors of certain products or services (such as hosting cloud services) (including, as applicable, their affiliates) solely and limited to providing us with such requested services, and not for any other purposes.
Such vendors may be located in a country that does not have the same data protection laws as your jurisdiction.
Such third parties service providers include without limitation the following categories of service providers:
- Hosting services, including our service providers:
Online Payment Processors
Links to Third Party Websites
We take appropriate measures to maintain the security and integrity of our Site and prevent unauthorized access to it or use thereof through generally accepted industry standard technologies and internal procedures.
Your Personal Information is hosted on AWS and DigitalOcean servers, which provide advanced strict security standards (both physical and logical).
Some of the security measures that we employ include, without limitation: highly secure services design and implementation using state of the art encryption and architectures mechanisms, restriction of access to your Personal Information to individuals who need access to it in order to process it on the Company’s behalf and implementation of a secured permission management and auditing system using specific and proprietary firewall and network access filtering as well as security group mechanisms.
Please note, however, that there are inherent risks in transmission of information over the Internet or other methods of electronic storage and we cannot guarantee that unauthorized access or use will never occur.
The Company will comply with applicable law in the event of any breach of the security, confidentiality, or integrity of your Personal Information and will inform you of such breach if required by applicable law.
TO THE EXTENT THAT THE COMPANY IMPLEMENTED THE REQUIRED SECURITY MEASURES UNDER APPLICABLE LAW, THE COMPANY SHALL NOT BE RESPONSIBLE OR LIABLE FOR UNAUTHORIZED ACCESS, HACKING, OR OTHER SECURITY INTRUSIONS OR FAILURE TO STORE OR THE THEFT, DELETION, CORRUPTION, DESTRUCTION, DAMAGE, OR LOSS OF ANY DATA OR INFORMATION INCLUDED IN THE PERSONAL INFORMATION.
The Company will retain the Personal Information for as long as we are comfortable that it is accurate and can be relied upon. Personal Information which is no longer required for the purpose for which is was initially collected will be deleted unless we have a valid justification to retain it which is permitted under applicable law, such as to resolve disputes or comply with our legal obligations.
Have any Questions?
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