Privacy Policy

Privacy Policy and Notice of Privacy Practices

Last Updated: October 2022

This privacy policy (“Privacy Policy”) governs how we, Get-Grin Inc. (“Grin” “we”, “our” or “us”) use Personal Information (defined below) that we collect, receive and store pertaining to you (“User”, “you”) in connection with the following use cases:

When you browse or visit our website, www.get-grin.com (“Site”)

When you make use of, or interact with, our Site

When you subscribe to our distribution list(s) through the Learn More feature

When we process your job application

When you contact us (e.g. customer support, etc.)

When you request a product demo

When you, as a patient, make use of, or interact with our mobile or web application ("App").

When you sign up for an account and login to the App

When you, as a health professional, make use of, or interact with our platform ("Platform")

When you sign up for an account and login into the Platform

When you use the Platform

When you recommend a product in our Platform as a health professional

When you attend a marketing event, exchange business cards with us, or otherwise provide us with your Personal Information for marketing purposes

When we use the personal data of our service providers/vendors (e.g. contact details)

The Site and the Platform are referred to herein as the “Services”.

We greatly respect your privacy, which is why we make every effort to provide a platform that would live up to the highest of user privacy standards. Please read this Privacy Policy carefully, so you can fully understand our practices in relation to Personal Information.

Table of contents:

Introduction

Terms of use

What Personal Information we collect, why we collect it, and how it is used

How we protect and store your Personal Information

How we share your Personal Information

Transfers of Personal Information

Your privacy rights. How to delete your account

Use by children

Links to and interaction with third-party product

Log files

Analytic technologies

California privacy rights

Our California do not track notice

How to contact us

This Privacy Policy may be updated from time to time and therefore we ask you to check back periodically for the latest version of the Privacy Policy, as indicated below. If there will be any significant changes made to the use of your Personal Information in a manner different from that stated at the time of collection, we will notify you by posting a notice on our Site or by other means.

INTRODUCTION. We have implemented this Privacy Policy because your privacy, and the privacy of other users, is important to us. This Privacy Policy explains our online information practices and the choices you can make about the way your Personal Information is collected and used in connection with the Services. “Personal Information” means any information that may be used, either alone or in combination with other information, to personally identify an individual. Please note that this is a master privacy policy and some of its provisions only apply to individuals in certain jurisdictions. For our HIPAA Privacy Notice please click https://www.get-grin.com/HIPAA.

Important note: Nothing in this Privacy Policy is intended to limit in any way your statutory right, including your rights to a remedy or means of enforcement.

TERMS OF USE. This Privacy Policy forms part of our Terms of Use which is available at www.get-grin.com/terms (“Terms”). Any capitalized but undefined term in this Privacy Policy shall have the meaning given to it in the Terms.

WHAT PERSONAL INFORMATION WE COLLECT, WHY WE COLLECT IT, AND HOW IT IS USED

Finally, please note that some of the abovementioned Personal Information will be used for detecting, taking steps to prevent, and prosecuting fraud or other illegal activity, identifying and repairing errors, conducting audits, and for security purposes. Personal Information may also be used to comply with applicable laws, with investigations performed by the relevant authorities, for 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 further use it for internal and external purposes, including, without limitation, to improve the services and for research purposes. “Anonymous Information” means information that does not enable the identification of an individual user, such as aggregated information about the use of our services. We may use Anonymous Information and/or disclose it to third parties without restrictions (for example, in order to improve our services and enhance your experience with them).

HOW WE PROTECT AND STORE YOUR PERSONAL INFORMATION

Security. 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 such information appropriate to the nature of the information concerned. However, please note that we cannot guarantee that the information will not be exposed as a result of unauthorized penetration to our servers. Nevertheless, we make commercially reasonable efforts to make the collection and security of such information consistent with this Privacy Policy and all applicable laws and regulations. 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.

Retention of your Personal Information. Your Personal Information (as described above) will be stored until we no longer need the information and proactively delete it or you send a valid deletion request. In some circumstances, we may store your Personal Information for longer periods of time, for example (i) where we are required to do so in accordance with legal, regulatory, tax, or accounting requirements, or (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, or (iii) if we reasonably believe there is a prospect of litigation relating to your Personal Information or dealings.

HOW WE SHARE YOUR PERSONAL INFORMATION

In addition to the recipients described in Section 3, we may share your Personal Information as follows:

With our business partners with whom we jointly offer products or services. We may also share Personal Information with our affiliated companies.

To the extent necessary, 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;

If in the future, we sell or transfer some or all of our business or assets to a third party, we will (to the minimum extent required) disclose information to a potential or actual third-party purchaser of our business or assets. 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 Personal Information in connection with the foregoing events.

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, disclose or assign your Personal Information in connection with the foregoing events, including, in connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or to another company; and/or

Where you have provided your consent to us sharing the Personal Information (e.g., where you provide us with marketing consents or opt-in to optional additional Services or functionality); and

Where we receive requests for information from law enforcement or regulators, we carefully validate these requests before any Personal Information is disclosed.

TRANSFERS OF PERSONAL INFORMATION

Storage: We store the Personal Information with the following storage companies: Amazon (AWS) – U.S.

Internal transfers: Transfers within the Grin group will be covered by an internal processing agreement entered into by members of the Grin group (an intra-group data processing agreement) which contractually obliges each member to ensure that Personal Information receives an adequate and consistent level of protection wherever it is transferred to.

External transfers: Where we transfer your Personal Information outside of EU/EEA (for example to third parties who provide us with services), we will generally obtain contractual commitments from them to protect your Personal Information. When Get Grinengages in such transfers of personal information, it relies on i) Adequacy Decisions as adopted by European Commission on the basis of Article 45 of the GDPR (for example, when we access from Israel), or ii) Standard Contractual Clauses issued by the European Commission.

• YOUR PRIVACY RIGHTS. HOW TO DELETE YOUR ACCOUNT
  1. Rights: The following rights (which may be subject to certain exemptions or derogations) shall apply to certain individuals (some of which only apply to individuals protected by the GDPR):

You have a right to access Personal Information held about you. Your right of access may normally be exercised free of charge, however, we reserve the right to charge an appropriate administrative fee where permitted by applicable law;

You have the right to request that we rectify any Personal Information we hold that is inaccurate or misleading;

You have the right to request the erasure/deletion of your Personal Information (e.g. from our records). Please note that there may be circumstances in which we are required to retain your Personal Information, for example for the establishment, exercise, or defense of legal claims;

You have the right to object, to or to request restriction, of the processing;

You have the right to data portability. This means that you may have the right to receive your Personal Information in a structured, commonly used, and machine-readable format and that you have the right to transmit that data to another controller;

You have the right to object to profiling;

You have the right to withdraw your consent at any time. Please note that there may be circumstances in which we are entitled to continue processing your data, in particular, if the processing is required to meet our legal and regulatory obligations. Also, please note that the withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal;

You also have a right to request certain details of the basis on which your Personal Information is transferred outside the European Economic Area, but data transfer agreements and/or other details may need to be partially redacted for reasons of commercial confidentiality;

You have a right to lodge a complaint with your local data protection supervisory authority (i.e., your place of habitual residence, place of work, or place of alleged infringement) at any time or before the relevant institutions in your place of residence. We ask that you please attempt to resolve any issues with us before you contact your local supervisory authority and/or relevant institution.

1. You can exercise your rights by contacting us at support@get-grin.com.You may use an authorized agent to submit a request on your behalf if you provide the authorized agent written permission signed by you. To protect your privacy, we may take steps to verify your identity before fulfilling your request. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly in accordance with applicable law or inform you if we require further information in order to fulfill your request. When processing your request, we may ask you for additional information to confirm or verify your identity and for security purposes, before processing and/or honoring your request. We reserve the right to charge a fee where permitted by law, for instance, if your request is manifestly unfounded or excessive. In the event that your request would adversely affect the rights and freedoms of others (for example, would impact the duty of confidentiality we owe to others) or if we are legally entitled to deal with your request in a different way than initially requested, we will address your request to the maximum extent possible, all in accordance with applicable law.

1. Deleting your account: Should you ever decide to delete your Account, you may do so by emailing support@get-grin.com. If you terminate your Account, any association between your Account and the information we store will no longer be accessible through your Account. However, given the nature of sharing on the Services, any public activity on your Account prior to deletion will remain stored on our servers and will remain accessible to the public.

USE BY CHILDREN. We do offer our products our Services for use by minors under 18. For minors below 18, you must have your parent's or guardian’s permission to agree to the Terms and obtain the right to access and use the Services. When we intend to collect Personal Information from or about children, we take additional steps to protect children's privacy, including, without limitation, limiting our collection of personal information from children to no more than is reasonably necessary to participate in an online activity; giving parents access or the ability to request access to the personal information we have collected from their children and the ability to request that the personal information be changed or deleted. In the event that we become aware that you provide Personal Information in violation of applicable privacy laws, we reserve the right to delete it. If you believe that we might have any such information, please contact us at support@get-grin.com.

LINKS TO AND INTERACTION WITH THIRD-PARTY PRODUCTS. The Site may enable you to interact with or contain links to your Third Party Account and other third-party websites or services that are not owned or controlled by us (each a “Third Party Service”). We are not responsible for the privacy practices or the content of such Third Party Services. Please be aware that Third Party Services may collect Personal Information from you. Accordingly, we encourage you to read the terms and conditions and privacy policy of each Third Party Service that you choose to use or interact with.

LOG FILES. We make use of log files. The information inside the log files includes internet protocol (IP) addresses, type of browser, Internet Service Provider (ISP), date/time stamp, referring/exit pages, clicked pages, and any other information your browser may send to us. We may use such information to analyze trends, administer the Site, track users’ movement around the Site, and gather demographic information.

ANALYTIC TECHNOLOGIES

Google Analytics. The Site uses a tool called “Google Analytics” to collect information about the use of the Website. Google Analytics collects information such as how often users visit this Website, what pages they visit when they do so, and what other websites they used prior to coming to this Website. We use the information we get from Google Analytics to maintain and improve the Website and our products. We do not combine the information collected through the use of Google Analytics with the Personal Information we collect. Google’s ability to use and share information collected by Google Analytics about your visits to this Website is restricted by the Google Analytics Terms of Service, available at https://marketingplatform.google.com/about/analytics/terms/us/, and the Google Privacy Policy, available at http://www.google.com/policies/privacy/. You may learn more about how Google collects and processes data specifically in connection with Google Analytics at http://www.google.com/policies/privacy/partners/. You may prevent your data from being used by Google Analytics by downloading and installing the Google Analytics Opt-out Browser Add-on, available at https://tools.google.com/dlpage/gaoptout/.

• Mixpanel. We collect Personal Information such as your email address and your user activity through the use of Mixpanel. Mixpanel’s ability to use and share information is governed by the Mixpanel Terms of Use, available at https://mixpanel.com/terms/, and the Mixpanel Privacy Policy, available at https://mixpanel.com/privacy/. You can opt out of Mixpanel’s services by clicking on the following link: https://mixpanel.com/optout/.
• Facebook Pixels and SDKs. We use Facebook pixels or SDKs, which are tools that provide help to website owners and publishers, developers, advertisers, business partners (and their customers), and others who integrate, use and exchange information with Facebook, as such the collection and use of information for ad targeting. Please note that third parties, including Facebook, use cookies, web beacons, and other storage technologies to collect or receive information from your websites and elsewhere on the internet and use that information to provide measurement services and target ads. Facebook’s ability to use and share information is governed by the Facebook Tools Terms, available at: https://www.facebook.com/legal/technology_terms/. You can prevent your data from being used by Facebook Pixels and SDKs by exercising your choice through these mechanisms: http://www.aboutads.info/choices or http://www.youronlinechoices.eu/.

We reserve the right to remove or add new analytic tools.

CALIFORNIA PRIVACY RIGHTS

For the purposes of this section, Personal Information means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household, or as otherwise defined by the California Consumer Privacy Act of 2018 (California Civil Code §§ 1798.100 to 1798.199) and its implementing regulations, as amended or superseded from time to time (“CCPA”).

Personal Information does not include information that is:

Lawfully made available from government records.

De-identified or aggregated.

Otherwise excluded from the scope of the CCPA. Please note that data collected from patients for the provisioning of medical services is not within the scope of the CCPA as this data is in the scope of the Health Insurance Portability and Accountability Act.

The chart above provides the types of Personal Information we have collected, disclosed for a business purpose, or used for business or commercial purposes in the preceding twelve months since this notice was last updated, as well as the sources from which that information was collected, the third parties with whom we shared Personal Information, and the purposes for which we collect Personal Information.

In the preceding twelve months, we have not sold any California resident’s Personal Information.

If you are a California resident, you may exercise the following rights:

1. Right to Know and Access. You may submit a verifiable request for information regarding the: (1) categories of Personal Information collected, sold, or disclosed by us; (2) purposes for which categories of Personal Information are collected or sold by us; (3) categories of sources from which we collect Personal Information; (4) categories of third parties with whom we disclosed or sold Personal Information; and (5) specific pieces of Personal Information we have collected about you during the past twelve months.
2. Right to Delete. Subject to certain exceptions, you may submit a verifiable request that we delete Personal Information about you that we have collected from you.
3. Right to Equal Service and Price. You have the right not to receive discriminatory treatment for the exercise of your CCPA privacy rights, subject to certain limitations.
4. Submit Requests. To exercise your rights under the CCPA, please contact us at support@get-grin.com.
5. Authorizing an Agent. To authorize an agent to make a request to know or delete on your behalf, please send a written authorization signed by you and the authorized agent to us via the Contact Information section.

Shine the Light. California Civil Code Section 1798.83 permits our customers who are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please send an email to support@get-grin.com. Please note that we are only required to respond to one request per customer each year.

Please note, requests for access to or deletion of Personal Information are subject to our ability to reasonably verify your identity in light of the information requested and pursuant to relevant CCPA requirements, limitations, and regulations. To verify your access or deletion request, please provide us with your full name, date of birth, and Grin Platform user name.

OUR CALIFORNIA DO NOT TRACK NOTICE. Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers, but we may allow third parties, such as companies that provide us with analytics tools, to collect personally identifiable information about an individual consumer’s online activities over time and across different web sites when a consumer uses the Services.

HOW TO CONTACT US. If you have any questions, concerns, or complaints regarding our compliance with this notice and the Information protection laws, or if you wish to exercise your rights, we encourage you to first contact us at support@get-grin.com.