Privacy Policy

StoneFree Solutions LTD, PbC. PRIVACY POLICY
Please read this Privacy Policy (“Privacy Policy”) carefully. To use the Services as defined in our Terms and Conditions, you, as a User of the Services as defined in the StoneFree Solutions LTD Terms and Conditions (“Terms & Conditions”) referenced below, must consent to this Privacy Policy. If you do not consent to the terms of the Privacy Policy, please do not access or use the Services.
This Privacy Policy incorporates by reference our HIPAA Notice of Privacy Practices

INTRODUCTION

Your privacy is important to StoneFree Solutions LTD, and StoneFree Solutions LTD is committed to carefully managing your individually identifiable information (“Personal Information”) in connection with the Services that StoneFree Solutions LTD provides. “Personal Information” means any information that may be used, either alone or in combination with other information, to personally identify an individual, including, but not limited to, a first and last name, a personal profile, an email address or other contact information. This Privacy Policy describes the information practices for StoneFree Solutions LTD, including what type of information is gathered and tracked, how the information is used, and with whom the information is shared. StoneFree Solutions LTD is committed to protecting the privacy of the data you provide in the Service as appropriate, but at the same time encouraging you to interact with and share information about your progress with other users using the Services.

StoneFree Solutions LTD is also committed to protecting the privacy of your protected health information (“Protected Health Information”). “Protected Health Information” is a subset of Personal Information that is information about you, including demographic information, that may identify you and that relates to your past, present or future physical or mental health or condition; related health care services; or related to the past, present, or future payment for the provision of health care to you.

For a description of how we may use and disclose your Protected Health Information to carry out treatment, payment or health care operations and for other purposes that are permitted or required by law, including the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”), please refer to our HIPAA Notice of Privacy Practices (“HIPAA Notice”). Any conflict between this Privacy Policy and the HIPAA Notice with respect to such submitted Protected Health Information shall be governed by the HIPAA Notice.

Each User’s participation is also governed by the StoneFree Solutions LTD Terms and Conditions which is entered into and agreed to by each User prior to using the Website and the Mobile App. Unless we define a term in this Privacy Policy, all capitalized terms used in this Privacy Policy have the same meanings set forth in our Terms & Conditions.

Information That StoneFree Solutions LTD Collects
5. Personal Information. We have implemented this Privacy Policy because your privacy, and the privacy of other Service users, is important to us. We operate in accordance with applicable data protection legislation and regulations. We recognize the importance of protecting the privacy of Personal Information collected about our users. This Privacy Policy discloses what Personal Information we gather, how we use it, and how you can correct or change it. It is our intention to give you as much control over your Personal Information as possible to preserve your privacy, while still allowing us to utilize that Personal Information in the course of our business to provide you a valuable service.

Consent and Modification. By using the Service, you consent to the terms of this Privacy Policy and to our processing of Personal Information for the purposes set forth herein. If you do not agree to this Privacy Policy, please do not use the Service. We reserve the right, at our discretion, to change this Privacy Policy at any time, which change shall become effective upon posting by the Company on the Website, the Mobile App, via the Service or sending you an email or other notification. You will be deemed to have agreed to Additional Terms (as defined in the Terms & Conditions) by your decision to continue accessing the Mobile App or the Website or otherwise using any of the Services following the date in which such Additional Terms become effective. By using the Services, you also consent to our use of Personal Information both retrospectively and prospectively.

Receipt and Collection of Information. We collect Personal Information from Users. In each case, you will only be required to provide the Personal Information that we need in order to be able to provide the services you have requested. You may be entitled under data protection laws to access and review the Personal Information that we hold on you, if you provide the necessary consent and background information and pay any mandated fee. All such communications regarding access to your personal data should be addressed to: support@stonefreesolutions.com. Such inquiries should clearly be marked as data protection queries and as being time sensitive.
In particular, we receive and/or collect Personal Information from you in the following ways:

StoneFree Solutions LTD may collect and process Personal Information when User registers for or uses the Services.
StoneFree Solutions LTD may collect and process certain Personal Information from User such as the User’s name, telephone number, e-mail address, mailing address, telephone number, user name, and password. StoneFree Solutions LTD uses the Users’ Personal Information that StoneFree Solutions LTD collects for the following general purposes: to fulfill User’s request for use of certain features of the Website and/or the Mobile App, to conduct surveys, and for StoneFree Solutions LTD’s billing purposes.
StoneFree Solutions LTD may also collect and process Personal Information relating to User’s use of the Services and any details of any e-mail correspondence or any other social media interactions that User has with StoneFree Solutions LTD. StoneFree Solutions LTD will collect only as much Personal Information as StoneFree Solutions LTD needs for the purposes specified in this Privacy Policy, for purposes specified at the time of collection of the Personal Information, or for other purposes that you consent to in the future.

Personal Health Information. StoneFree Solutions LTD may obtain your personal health information from your health care provider upon User’s request and prior approval. StoneFree Solutions LTD may collect certain personal health information [through connected devices and by other means] such as User’s height, weight, blood pressure, blood glucose and gender, and display User’s biometrics to User based on these inputs.

Demographic & Non-Identifying Information. StoneFree Solutions LTD may collect and process demographic information from or about User from time to time, such as information about User’s gender, age, country, and zip code (“Demographic Information”). StoneFree Solutions LTD may collect this information through various forms and in various places in the Services, including account registration forms, contact forms, or when User otherwise interacts with the Website and/or the Mobile App. To the extent that StoneFree Solutions LTD combines any non-personally identifiable Demographic Information with User’s Personal Information that StoneFree Solutions LTD collects directly from User on the Website and the Mobile App, StoneFree Solutions LTD will treat the combined data as Personal Information under this Privacy Policy. StoneFree Solutions LTD also collects data about User, including about User’s make-up, fitness level, health indicators, and related information that does not identify User and that enables User to fully participate in the Service.

Information StoneFree Solutions LTD Collects or Stores as User Accesses and Uses the Services. In addition to any Personal Information or other information that User chooses to submit to StoneFree Solutions LTD via StoneFree Solutions LTD’s Services, StoneFree Solutions LTD and StoneFree Solutions LTD’s third party service providers may use a variety of technologies that automatically (or passively) store or collect certain information whenever User visits or interacts with the Services (“Usage Information”). This Usage Information may be stored or accessed using a variety of technologies that may be downloaded to User’s personal computer, browser, laptop, tablet, mobile phone or other device (“Device”) whenever User visits or interacts with StoneFree Solutions LTD’s Website or the Mobile App. To the extent StoneFree Solutions LTD associates Usage Information with User’s Personal Information StoneFree Solutions LTD collects directly from User on the Website, StoneFree Solutions LTD will treat it as Personal Information. This Usage Information may include:

User’s IP address, UDID or other unique identifier (“Device Identifier”). A Device Identifier is a number that is automatically assigned to User’s Device used to access the Website or Mobile App, and StoneFree Solutions LTD’s computers identify User’s Device by its Device Identifier;
User’s Device functionality (including browser, operating system, hardware, mobile network information);
User’s subscription level;
the URL that referred User to StoneFree Solutions LTD’s Website;
the areas within StoneFree Solutions LTD’s Website or Mobile App that User visits and User’s activities there, including remembering User, User’s preferences and pages User requested and/or viewed;
User’s Device location;
User’s Device characteristics; and certain other Device data, including the time of day, among other information.

TRACKING TECHNOLOGIES

11. StoneFree Solutions LTD may use various methods and technologies to store or collect Usage Information (“Tracking Technologies”). Tracking Technologies may set, change, alter or modify settings or configurations on User’s Device. This information may be shared with partners in order to accomplish various health and business purposes, including but not limited to a) measuring and improving the user experience, b) capturing user participation and adherence to the treatment logic of the application, c) measuring completion of various milestones tied to health or business outcomes, d) auditing participation and performance of individual participants, for both health and billing purposes.

USE OF PERSONAL INFORMATION

12. Except as set forth in this Privacy Policy or as specifically agreed to by User, StoneFree Solutions LTD will not disclose any information StoneFree Solutions LTD gathers from User. Except as set forth in this Privacy Policy, StoneFree Solutions LTD does not share User’s Personal Information with third parties for those third parties’ direct marketing purposes. StoneFree Solutions LTD may provide to third parties information about User that does not allow User to be identified or contacted, including where such information is combined with similar information of other users of StoneFree Solutions LTD’s Website, Mobile App and Services. For example, StoneFree Solutions LTD might inform third parties regarding the number of unique users who visit and/or use StoneFree Solutions LTD’s Services, the demographic breakdown of the registered users of StoneFree Solutions LTD’s Services, or the activities that users engage in while on StoneFree Solutions LTD’s Website or Mobile App.

StoneFree Solutions LTD may use User’s information that StoneFree Solutions LTD collects about User:
to contact User occasionally to inform User of new Services features, or news or articles StoneFree Solutions LTD thinks will be of interest to User. StoneFree Solutions LTD may send User regular updates on issues StoneFree Solutions LTD thinks will be of interest to User;
to contact User with regard to User’s use of the Services and, in StoneFree Solutions LTD’s discretion, changes to the Services and/or the service policies;
for internal business purposes;
for purposes disclosed at the time User provides User’s information or as otherwise set forth in this Privacy Policy;
to provide User with information or services or process transactions that User has requested or agreed to receive including to send User electronic newsletters;
to provide User with marketing materials or relevant advertising, promotions and recommendations from StoneFree Solutions LTD or our business partners;
to enable User to participate in a variety of the Service features;
to process User’s account registration, including verifying User’s information is active and valid;
to identify User as the author of any comments that User sends to StoneFree Solutions LTD to be posted on the Website or Mobile App;
to ensure that content on the Website and Mobile App is presented in the most effective manner for User and for User’s computer or mobile device;
to provide User with information relating to any events held by StoneFree Solutions LTD, where User has consented to be contacted for such purposes; and
to provide User with access to User’s personal account.
User can always opt out of utilizing the Service, and accordingly opt out of StoneFree Solutions LTD’s use of User’s Personal Information, by sending an email to nitzan@stonefreemedical.com

DISCLOSURE OF INFORMATION TO THIRD PARTIES

14. StoneFree Solutions LTD may share User’s Personal Information, including performance measurement information associated with User’s name that is collected or generated at the Website, Mobile App or through the Services.

Personal Information may occasionally be transferred to third parties who act for StoneFree Solutions LTD for further processing in accordance with the purposes for which the data was originally collected or for purposes to which User has subsequently consented. For example, sometimes a third party may have access to User’s Personal Information in order to support StoneFree Solutions LTD’s information technology or to handle mailings on StoneFree Solutions LTD’s behalf. If StoneFree Solutions LTD transfers User’s Personal Information to an outside agent or organization for such purpose, StoneFree Solutions LTD will take appropriate measures in an effort to protect User’s privacy and the Personal Information StoneFree Solutions LTD transfer.

StoneFree Solutions LTD may, in StoneFree Solutions LTD’s sole discretion, share or transfer Personal Information where permitted or required by law, to comply with legal process, to interact with anti-fraud databases, to protect User’s vital interests, to protect the security or integrity of StoneFree Solutions LTD’s databases or the Website and the Mobile App, to enforce the Terms & Conditions or protect the business or reputation of StoneFree Solutions LTD and/or its Business Customers, to take precautions against legal liability, to protect and defend the rights or property of StoneFree Solutions LTD and/or its Business Customers, for required institutional risk control, or for resolving disputes, inquiries or complaints with respect to User’s use of the Website, Mobile App and Services.

StoneFree Solutions LTD reserves the right to disclose and transfer all Personal Information: (i) to an operator of the Website or Mobile App or applicable database provided such entity agrees to be bound by the terms and conditions hereof to the extent applicable; or (ii) to a successor in interest of StoneFree Solutions LTD in connection with a merger, consolidation, restructuring, change of control, the sale of substantially all of StoneFree Solutions LTD’s interests and/or assets or other organizational change, including, during the course of any due diligence process, provided such successor entity agrees to be bound by the terms and conditions hereof.

USER CONTENT

18. “User Content” is any content, materials or information (including without limitation, any text, information, graphics, messages, photos, images or nutritional information), data, questions, comments, suggestions or other content, including personally identifiable information that you, User, submit, upload, post, e-mail, transmit, or otherwise make available via StoneFree Solutions LTD’s Services. User Content may include, but is not limited to, User’s personal health information and, when you voluntarily provide us with Personal Information in User Content or otherwise through the Services, User’s information will be treated as Personal Information under this Privacy Policy.

Any User Content provided by you remains your property. However, by providing User Content to StoneFree Solutions LTD, you grant StoneFree Solutions LTD a worldwide, perpetual, irrevocable, transferrable, royalty-free license, with the right to sublicense, to use, copy, modify, create derivative works of, distribute, publicly display, publicly perform, and otherwise exploit in any manner such User Content in all formats and distribution channels now known or hereafter devised (including in connection with StoneFree Solutions LTD’s business and on third-party sites and services), without further notice to or consent from you, and without the requirement of payment to you or any other person or entity.

You represent and warrant that: (i) you own the User Content submitted by you on, through or in connection with StoneFree Solutions LTD’s Services, or otherwise have the right to grant the license set forth herein, and (ii) the posting of your User Content on, through or in connection with StoneFree Solutions LTD’s Services does not violate the privacy rights, publicity rights, copyrights, contract rights or any other rights of any person or entity. You agree to pay for all royalties, fees, and any other monies owing any person or entity by reason of any User Content posted by you to or through StoneFree Solutions LTD’s Services.

StoneFree Solutions LTD reserves the right, in its sole discretion, to reject, refuse to post or remove any User Content, or to restrict, suspend, or terminate User’s access to all or any part of the Services at any time, for any or no reason, without prior notice or explanation, and without liability. StoneFree Solutions LTD assumes no responsibility for monitoring the Services for inappropriate User Content or conduct. If at any time StoneFree Solutions LTD chooses, in its sole discretion, to monitor the Services, StoneFree Solutions LTD nonetheless assumes no responsibility for the User Content, no obligation to modify or remove any inappropriate User Content, and no responsibility for the conduct of the User submitting any such User Content. StoneFree Solutions LTD may remove any User Content at any time for any reason (including, but not limited to, upon receipt of claims or allegations from third parties or authorities relating to such User Content), or for no reason at all.

TRACKING AND TARGETING COOKIES

22. StoneFree Solutions LTD and its partners may use cookies or similar technologies to analyze trends, administer the website, track users’ movements around the website, and to gather demographic information about our user base as a whole. Users can control the use of cookies at the individual browser level.

StoneFree Solutions LTD uses cookies to remember users’ settings (e.g. language preference), for authentication. Users can control the use of cookies at the individual browser level. If you reject cookies, you may still use our website, but your ability to use some features or areas of our website may be limited.

DATA RETENTION

24. StoneFree Solutions LTD retains Personal Information and other User information for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting or reporting requirements.

The criteria used to determine the period of storage of Personal Information is the respective statutory retention period. After expiration of that period, the corresponding data is routinely deleted, as long as it is no longer necessary for the fulfillment of the contract or the initiation of a contract.

By using the Services, User consents to StoneFree Solutions LTD’s retention of Personal Information.

SECURITY

27. StoneFree Solutions LTD employs procedural and technological measures, consistent with industry practice. Such measures are reasonably designed to help protect your Personal Information from loss, unauthorized access, disclosure, alteration or destruction. StoneFree Solutions LTD may use firewalls, password protection, secure socket layer, and other security measures to help prevent unauthorized access to your Personal Information.

StoneFree Solutions LTD limits access to Personal Information to those employees and contractors of StoneFree Solutions LTD and its affiliates who need access to perform their job function. StoneFree Solutions LTD will only transfer your data to trusted third parties who provide sufficient guarantees to implement appropriate technical and organizational measures to protect your data and comply with the General Data Protection Regulation (GDPR) requirements.

StoneFree Solutions LTD employs firewalls, intrusion detection systems, and system monitoring to protect against unauthorized access to systems storing Personal Information. All the technology employed by StoneFree Solutions LTD is designed to meet industry standards for security.

StoneFree Solutions LTD also maintains strict physical security at its data centers and restricts access to your Personal Information to those StoneFree Solutions LTD employees and contractors who need access to perform their job function.

StoneFree Solutions LTD has procedures in place to deal with any suspected Personal Information breach. StoneFree Solutions LTD will notify you and any applicable regulator of a breach where StoneFree Solutions LTD is legally required to do so.

StoneFree Solutions LTD takes reasonable steps to ensure the reliability of any third-party service providers that it engages to store and process your Personal Information.

Unfortunately, the transmission of information via the internet is not completely secure. Although StoneFree Solutions LTD will do its best to protect your Personal Information, StoneFree Solutions LTD cannot guarantee the security of your Personal Information transmitted to StoneFree Solutions LTD’s Website or the Mobile App. Any transmission of Personal Information is at your own risk. Once StoneFree Solutions LTD has received your Personal Information, StoneFree Solutions LTD will use strict procedures and security features to try to prevent unauthorized access.

YOUR RIGHTS

34. If you reside in certain territories, including the European Economic Area (EEA), you have a number of rights in relation to your Personal Information. While some of these rights apply generally, certain rights apply only in certain limited cases. These rights are described below:

Right to access: You have the right to request information about the Personal Information StoneFree Solutions LTD holds about you at any time. You can contact StoneFree Solutions LTD to request information about what Personal Information StoneFree Solutions LTD has about you, and to request the correction or deletion of any Personal Information that is incomplete, incorrect, unnecessary, or outdated.
Right to erasure: You have the right to ask StoneFree Solutions LTD to delete or remove Personal Information where there is no good reason for StoneFree Solutions LTD to continue to process it. You also have the right to ask StoneFree Solutions LTD to delete or remove your Personal Information where you have successfully exercised your right to object to processing, where StoneFree Solutions LTD may have processed your information unlawfully or where StoneFree Solutions LTD is required to erase your Personal Information to comply with local law. Note, however, that StoneFree Solutions LTD may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Right to object to processing: You have the right to object to the processing of your Personal Information where StoneFree Solutions LTD is relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where StoneFree Solutions LTD is processing your Personal Information for direct marketing purposes. In some cases, StoneFree Solutions LTD may demonstrate that it has compelling legitimate grounds to process your information which override your rights and freedoms.
Right to restriction of processing: You have the right to ask StoneFree Solutions LTD to suspend the processing of your Personal Information in the following scenarios: (a) if you want

StoneFree Solutions LTD to establish the data's accuracy; (b) where StoneFree Solutions LTD’s use of the data is unlawful but you do not want StoneFree Solutions LTD to erase it; (c) where you need StoneFree Solutions LTD to hold the data even if StoneFree Solutions LTD no longer requires it as you need it to establish, exercise or defend legal claims; or (d) you have objected to StoneFree Solutions LTD’s use of your data but StoneFree Solutions LTD needs to verify whether it has overriding legitimate grounds to use it.
Right to data portability: To the extent StoneFree Solutions LTD processes your Personal Information by automated means, you have the right to receive your Personal Information from StoneFree Solutions LTD in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
‍
Right to withdraw consent: If StoneFree Solutions LTD relies on your consent (or explicit consent) as its legal basis for processing your Personal Information, you have the right to withdraw that consent at any time. Withdrawal of consent will not affect the lawfulness of processing before the withdrawal. You can withdraw your consent by contacting StoneFree Solutions LTD at nitzan@stonefreemedical.com
Right to complain: If you believe that StoneFree Solutions LTD’s processing of your Personal Information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work, or the place of the alleged infringement.

If you would like to exercise any of these rights, please contact StoneFree Solutions LTD at the contact details listed below. StoneFree Solutions LTD will promptly respond to your request.

CHANGES TO PRIVACY POLICY

36. StoneFree Solutions LTD reserves the right to update or change this Privacy Policy at any time and you should check this Privacy Policy periodically. Your continued use of the Service after StoneFree Solutions LTD posts any modifications to the Privacy Policy on this page will constitute your acknowledgment of the modifications and your consent to abide and be bound by the modified Privacy Policy. If StoneFree Solutions LTD makes any material changes to this Privacy Policy, StoneFree Solutions LTD will notify you either through the email address you have provided us or by placing a prominent notice on the Website or Mobile App.

Contact Information
37. If you have any questions or concerns or complaints about our Privacy Policy, you may contact us at:

StoneFree Solutions LTD
Attn: Legal Department
123 Privacy Lane
Data Privacy, State 12345
Email: nitzan@stonefreemedical.co