Website Privacy policy
Last updated: November 5, 2024
1. INTRODUCTION AND GENERAL BACKGROUND
1.1 Popai.health Inc. and its affiliates ("Popai", "we" or "us") present this privacy policy, as may be amended from time to time (the "Privacy Policy") in order to provide our website user ("User", "you" or "your") information about Popai’s privacy and data protection practices in relation to Personal Data that is collected, used and/or otherwise processed by Popai and/or third parties acting on its behalf, through its website https://www.popai.health/ (the "Website").
1.2 When accessing, browsing and using the Website, you may be required to provide Popai with Personal Data about yourself that is protected by law. As a result, Popai, as data controller, has implemented appropriate security measures in order to protect your Personal Data.
1.3 If you have questions or concerns regarding this Privacy Policy, please contact us at contact@popai.health
1.4 PLEASE SEE OUR FULL PRIVACY POLICY BELOW IN ORDER TO BETTER UNDERSTAND OUR PRACTICES IN DETAIL.
2. WHAT PERSONAL DATA DO WE PROCESS AND FOR WHAT PURPOSES?
2.1. When we use the term “Personal Data” in this Privacy Policy, we mean (i) information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly to an individual.
2.2 Detailed below are the categories of Personal Data, purposes, lawful basis, and processing:
2.2.1 Category 1 -
Category of Personal Data: (a) Identification data or identifier: i.e., first and last name, country. (b) Contact details: i.e., email address. (c) Any information you decide to add in the empty box (i.e., date, area of subject and content of your exchanges with Popai's staff)
How we collect Personal Data: Such Personal Data is provided directly from the User on the Website, via the ‘Book a Call’ and ‘Get started’ form operated by a service provider on our behalf.
Purposes: Managing your demo request
Purposes: Managing your demo request
Example of use of Personal Data: (a) to schedule a demonstration of our products and services with our staff (b) to potentially purchase our products and services
Legal Basis (for EEA Users only): To take steps prior to entering into a contract
2.2.2 Category 2 -
Category of Personal Data: Online Identifiers, advertising and analytics data:
We will collect online identifiers when the User interacts with the Website, such as Internet Protocol address (IP), Cookie-ID, country, and other information that relates to User’s activity through the Website, such as pages viewed, click stream data, login time and date stamp, etc.
How we collect Personal Data: Such data is automatically collected from the Website directly by us or through our use of third parties' cookies. For more information on the cookies and other tracking technologies used, section 3. For U.S. Users: We do not respond to web
Purposes: Improving the Website
Example of use of Personal Data: (a) to monitor and analyze your use of the Website (b) to develop, customize and improve the Website (c) research and further development, analysis and statistics.
Example of use of Personal Data: (a) to monitor and analyze your use of the Website (b) to develop, customize and improve the Website (c) research and further development, analysis and statistics.
Legal Basis (for EEA Users only): Your consent. You may withdraw your consent or change your preferences at any time by using the cookie settings tool available on our Website
2.2.3 Category 3 -
Category of Personal Data: Online Identifiers, advertising and analytics data:
We will collect online identifiers when the User interacts with the Website, such as Internet Protocol address (IP), Cookie-ID, country, and other information that relates to User’s activity through the Website, such as pages viewed, click stream data, login time and date stamp, etc.
How we collect Personal Data: browser-based DNT signals at this time, but we do not collect information about users’ online activities across third-party websites. For more information, visit: https://www.eff.org/issues/do-not-track
Purposes: Supporting and enhancing data security measures of the Website
Legal Basis (for EEA Users only): Legitimate interest of Popai to secure its Website and User’s experience.
In addition, please note that we may use some of the Personal Data described above to:
(a) – manage any litigation, for example to take action against any identified security breach, manage any dispute or litigation and seek advice from lawyers, auditors, and other professional advisers. Regarding EU legal basis, such processing is based on Popai’s legitimate interest in defending our rights and interests.
(b) – comply with legal and regulatory obligations, for example to perform any reporting and notifications obligations we may be subject to, to competent governmental agencies and authorities; process your requests to exercise your rights; detect, investigate, prevent, or take action against illegal activities, fraud, or situations involving potential threats to the rights. Regarding EU legal basis, such processing is based on legal and regulatory obligations to which we are subject.
3. COOKIES
Each time you visit our Website we may automatically collect online identifiers and analytics data through cookies and other tracking technologies. This data is necessary for the proper functioning of the Website, as well as internal business analytics purposes.
Most browsers allow you to control cookies, including whether or not to accept them and how to remove them. You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser. However, please be aware that some features of the Site may not function properly or may be slower if you refuse cookies. If you block or delete cookies, not all tracking that we have described in this Privacy Policy will stop.
We use cookies provided by Google Analytics to collect statistical information about the use of the Site. We use Google Analytics to learn more about the types of users that visit the Site, their activities on the Site, and to help improve the Site. To provide this service, Google Analytics may collect certain information about you from your computer, including but not limited to: information regarding your visit (such as the pages you visit and the length of your visit), information about your device (such as your IP address), how you got to the website, and other information about you. You can learn more about Google Analytics and how it collects and processes data (including how to control the information sent to Google) by visiting: www.google.com/policies/privacy/partners/. You can opt-out of Google analytics, here: https://tools.google.com/dlpage/gaoptout (which requires you to install a browser add-on).
4. WITH WHOM DO WE SHARE PERSONAL DATA?
4.1 We may share your Personal Data with third parties as detailed below:
4.1.1 With our Affiliates. Your Personal Data will be shared with our affiliates to manage the Website and the companies' services.
4.1.2 Service Providers and Business Partners. We share Personal Data with selected third party companies and individuals we engage to perform services on our behalf, such as improving and optimizing the Website and process Personal Data in the context of provision of analytical services to us and for operational, commercial and technical purposes related to the management of the Website and its services, including data storage providers, data security services, fraud detection and prevention services, product analytics, etc. .
4.1.3 Governmental, Administrative or Judiciary Authorities. We will disclose or allow government and law enforcement officials access to certain Personal Data, exclusively in response to a subpoena, search warrant or court order (or similar requirement), or in compliance with applicable laws and regulations.
4.1.4 Corporate Transactions. We may share Personal Data in connection with any proposed or actual financing, reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).
4.1.5 Lawyers and Interested Parties. We will share Personal Data exclusively in case of the management of possible disputes and other legal matters where appropriate, including with respect to the Website; to establish, protect, or exercise our legal rights; as required to enforce agreements; to defend against legal claims or demands; to detect, investigate, prevent, or take action against illegal activities, fraud, or situations involving potential threats to the rights.
4.2 We will not sell or otherwise disclose Personal Data for monetary or other consideration to any third parties (and have not done so over the last twelve (12) months).
4.3 We will not share your Personal Data for cross-contextual behavioral advertising (and have not done so over the last twelve (12) months).
5. HOW IS PERSONAL DATA TRANSFERRED OUTSIDE OF YOUR COUNTRY?
5.1 We may host, store, process, maintain or transfer the Personal Data to various sites worldwide, outside your jurisdiction, including through cloud based service providers.
5.2 Where specific laws or regulations relating to Personal Data transfer apply to us, we will endeavor to ensure that the Personal Data is protected and transferred in a manner consistent with legal requirements.
5.3 EEA Transfers. When we transfer Personal Data from within the European Economic Area ("EEA") to countries or international organizations that are based outside the EEA, the transfer takes place on the basis of an adequacy decision by the European Commission, or in the absence of an adequacy decision, other legally permitted safeguards under the applicable data protection law, such as standard contractual clauses ("SCCs").
6. HOW LONG DO WE STORE PERSONAL DATA FOR?
We retain Personal Data for as long as a User is using our Website. Other circumstances in which we will retain your Personal Data for longer periods of time include: (1) where we are required to do so in accordance with legal and regulatory requirements, or (2) for us to have an accurate record of your interaction with us in the event of any inquiries or contact requests, or (3) if we reasonably believe there is a prospect of litigation.
7. HOW DO WE KEEP YOUR PERSONAL DATA SECURE?
7.1 We endeavor to maintain appropriate technical and organizational measures compliant with industry standards to protect Personal Data in particular, against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. However, we cannot completely ensure the security of any Personal Data you transmit to us over the internet or guarantee that this Personal Data will be absolutely protected from unauthorized disclosure or use.
7.2 If you have found a vulnerability or would like to report a security incident, you may send an email to contact@popai.health
8. WHAT RIGHTS DO YOU HAVE REGARDING PERSONAL DATA?
8.1 Please note that under certain circumstances and depending on your jurisdiction, you are entitled to specific rights regarding your Personal Data (subject to some exceptions).
8.2 When you ask us to exercise any of your rights under this Privacy Policy and the applicable privacy and data protection laws, we may need to ask you to provide us with certain credentials to make sure that you are who you claim you are, to avoid disclosure to you of Personal Data 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 Personal Data that you request to access.
8.3 Applicable privacy and data protection laws in your jurisdiction may provide you with different or additional rights related to the Personal Data we collect from you, which may also apply.
8.4 Please note that you can deliver your request by contacting us at contact@popai.health.
8.5 If you are a California resident, you are entitled to request: (a) what Personal Data we have collected; (b) deletion of your Personal Data; (c) correction of your inaccurate Personal Data; (d) to limit the use or disclosure of sensitive personal Data (to the extent we use or disclose such data); (e) to receive a copy of your Personal Data; (f) to the extent applicable, you have the right to opt-out of: (i) “sharing” of your Personal Data for targeted advertising (“cross-contextual behavioral advertising”); (ii) sale of your Personal Data to third parties.
Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a request related to your Personal Data. If you are an authorized agent making a request on behalf of another individual, you must provide us with signed documentation that you are authorized to act on behalf of that individual.
8.6 If you are based in the EU/EEA, you are entitled to request us to: (a) access your personal data in order to obtain clear, transparent and understandable Data on how we process your personal data and on your rights (as provided in this Policy), as well as a copy of your personal data; (b) rectify your personal data in case your personal data are obsolete, inaccurate or incomplete; (c) object the processing of your personal data when the processing is based on legitimate interest; (d) in certain circumstances under Applicable Laws, restrict the processing of some of your personal data during a limited period of time; (e) withdraw your consent when it has been obtained and processing is based on consent; (f) request data portability, meaning that you can request the transfer of the personal data provided by him or her to another data controller; (g) in certain circumstances you can request to delete your personal data; (h) lodge a complaint with your national data protection authority.
If you have a complaint about how we use your personal data, we would always prefer you to contact us first. However, you may also make a complaint to your local data protection authority in the EU/EEA. If you are unsure which data protection authority to contact, please contact us at contact@popai.health.
1. CHILDREN
The Website is directed towards and designed for use by persons aged 18 and older. If we nevertheless receive Personal Data 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 Personal Data from our systems.
2.DOES THIS PRIVACY POLICY APPLY TO THIRD PARTY LINKS?
You may, during your use of the Website, access links to or other websites operated by third parties.
Please note that this Privacy Policy only applies to Personal Data that we (or third parties on our behalf) collect from or about you on the Website only and we cannot be responsible for Personal Data collected and stored by third parties. Third party websites have their own terms and conditions and privacy policies, and you should read these carefully before you submit any Personal Data to these websites. We do not endorse or otherwise accept any responsibility or liability for the content of such third-party websites or third-party terms and conditions or policies.
3.CHANGES TO THIS PRIVACY POLICY
4.CONTACT INFORMATION AND DATA CONTROLLER INFORMATION
This Privacy Policy may change from time to time. If we decide to change our Privacy Policy, we will post new or updated privacy policy on our Website. Each version of this Privacy Policy will be identified by its effective date, which you can find at the top of this Privacy Policy.
If you have any comments or questions regarding this Privacy Policy or the information practices in connection with the Website, please contact us at contact@popai.health .