| WHY THIS POLICY? |
Theranica is committed to protect the privacy of children who use Theranica’s app (“App”).This document supplements and is in addition to the Theranica general Privacy Policy available on Nerivio or Theranica website under “privacy policy”, which should be read alongside this Children Policy. |
| WHO ARE WE? |
This children’s privacy policy (“Children Policy”) explains how we, Theranica Bio-Electronics Ltd. (“Theranica” “we”, “our” or “us”) use, collect, process, and store personal information we collect or receive from or about children under the age of 13 in the US and 18 in the EU and the rest of the world (“you”, “Child” or “Children”) and their parent(s)/legal guardian (“Parents”). |
| WHAT INFORMATION WE COLLECT, AND WHY |
We collect and use your information for the following purposes:
- Opening an account by Parents. If a Child wants to use the App, its Parents are asked first to open an account for themselves and to add a Child Account. We collect from Parents the following information: full name, email address, country, date of birth, language, mobile phone details, phone number (optional), gender (optional), medical insurance details (optional) and user password. We use this information in order to create an account for the Parents and to allow them to login on the App. We will use commercial reasonable efforts in order to verify the parental authority of a Parent over a Child.
- Opening a Child’s account. Parents are required to provide the following information on behalf of their Child: full name, email address, date of birth, language, mobile phone details, phone number (optional), and gender (optional) of the Child. Country information is inherited from the Parent. We will open a Child account only if Parents have given their consent for us to create an account for their Child. For GDPR-protected individuals, Parents are requested to approve collection of the Child’s information and provide an optional consent for communication with the Child. We use this information in order to determine the Child’s age (and which laws apply to him/her) and allow Parents to create an account on behalf of their Child. We will also use this information in order to contact the Child in connection with technical support related to the use of the App, unless it is absolutely necessary to address the issue with the Parent. In such case, our technical support will approach the Parent to help us conduct further technical investigation.
- App Login. Children can login on the App once Parents have successfully open the Child account. We collect directly from the Child its password for login purposes.
- Use of the App. A Child can use the App without the intervention of a Parent. We collect directly from the Child the following personal information:
(i) Information on the treatment and associated symptoms and triggers provided by you before, during and/or after treatment (“User Feedbacks”), (ii) treatment information (“Treatment Data”) such as when your treatment start and end and geo-location of the treatment, (iii) Smartphone and connected Nerivio device details, (iv) actions and operations performed via the App (“User Analytics”) such as when you log-in, log-out, device connect and disconnect, etc. and (v) any other information you decide to provide via the App. User Feedbacks, Treatment Data are collected in order to make use of our services, register and/or record your migraine episodes and to create and keep track of your migraine diary. The smartphone & Nerivio device data, Treatment Data and User Analytics are collected in order to discover, investigate and improve technical issues for you and other users, develop new services, to control and operate the device and provide you reliable technical support in connection with our services.
- Re-fill request. Children can request re-fill of their device via the App. We collect directly from the Children the re-fill request information and also use Child’ user ID in its pharmacy in order to facilitate the fulfilment of the request by the relevant pharmacy, and to send emails and in-App notifications about the re-fill request status to the Child.
- Finally, please note that some of the abovementioned personal information will also be used for preventing and prosecuting fraud or other illegal activity, to identify and repair errors, to conduct audits, and for security purposes. Personal Information may also be used to comply with applicable laws, with investigations performed by the relevant authorities, law enforcement purposes, and/or to exercise or defend legal claims. In certain cases, we may or will anonymize or de-identify your personal information and disclose it to third parties without restrictions (for example, in order to improve our services and enhance your experience with them).
- If GDPR applies to you, we have a legal basis applicable to the processing of your personal information on the App.
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| HOW WE SHARE YOUR INFORMATION |
We share personal information collected from Children in a limited number of instances, such as:
- With/within our corporate group and our parent/sister companies;
- With our service providers that assist us in performing certain internal operations;
- To the extent necessary: (i) with regulators, to comply with all applicable laws, regulations and rules, and requests of law enforcement, regulatory and other governmental agencies or if required to do so by court order; (ii) if we believe disclosure may prevent the instigation of a crime, facilitate an investigation related to public safety or protect the safety of a Child using our sites or applications; (iii) to protect the security or integrity of our sites, applications, and other technology, as well as the technology of our service providers; (iv) to enable us to take precautions against liability or (v) if in the event that we are acquired by or merged with a third party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer or assign your personal information.
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| HOW WE PROTECT YOUR INFORMATION |
- We store your personal information on Amazon Web Services, with servers located in the United States. Where we transfer your personal information outside of EU/EEA, for example to third parties who help provide our products and services, we will use efforts to obtain contractual commitments from them to protect your Personal Information.
- We will keep your personal information until we no longer need it and proactively delete it or if you ask us to do so. In some circumstances we may store your personal information for longer periods of time, for example in order to comply with laws and regulations that apply to us or if we reasonably believe that we need it for litigation purposes.
- We have implemented appropriate technical, organizational and security measures designed to reduce the risk of accidental destruction or loss, or the unauthorized disclosure or access to your personal information. However, as the security of information depends in part on the security of the computer, device or network you use to communicate with us and the security you use to protect your user IDs and passwords, please make sure to take appropriate measures to protect this information.
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| YOUR RIGHTS! |
You have the following rights (but some of them apply to you only if you are protected by the GDPR): Right to access, right to rectify and right to delete your personal information; right to object, to or to request restriction, of the processing; right to data portability; right to object to object to profiling; right to withdraw your consent at any time and right to lodge a complaint with your local data protection supervisory authority. You can also decide to delete your account on the App. If you are a Parent, you can refuse to permit us to collect further personal information from your Child, and can request that we delete from our records the personal information we have collected in connection with your Child. Parents can request access to, change, or delete their Child’s personal information. To protect Children’s privacy and security, we will take reasonable steps to help verify a parent’s identity before granting access to any personal information. You can exercise your rights by contacting us at [email protected]. |
| QUESTIONS OR CONCERNS? NOT SURE YOU FULLY UNDERSTAND? |
Feel free to contact us at [email protected] can also consult Theranica’s privacy policy available on the www.nerivio.com or www.theranica.com websites under “privacy policy”. |
