Privacy Policy

Last modified: September 13, 2022

Healthy.io Ltd. (“Healthy”, “we”, “our” or “us”) puts great efforts in making sure that the Personal Data (as defined below) processed by us is safe and used properly, and that our data practices are properly communicated to our users and visitors.

This Privacy Policy describes how we collect, store, use, and disclose Personal Data relating to any individuals who visit or otherwise interact with our websites https://www.healthy.io/ or https://www.minuteful.com/ (“Visitor” or “you”), including their subdomains, and any online ads and content (collectively, our “Site”), or emails or communications in relation to the Site, including job candidates (“Candidates”). This Privacy Policy does not apply to specific services offered by Healthy, which have separate privacy policies. Specifically, this Privacy Policy describes our practices regarding:

1. Data Collection
2. Data Uses
3. Data Location
4. Data Retention
5. Data Sharing
6. Cookies and Tracking Technologies
7. Communications
8. Data Security
9. Data Subject Rights
10. Jurisdiction Specific Privacy Rights
11. Additional Notices

If you are a Visitor or a Candidate, please read this Privacy Policy carefully and make sure that you fully understand it.

You are not legally required to provide us with any Personal Data. If you do not wish to provide us with your Personal Data, or to have it processed by us or any of our Service Providers (defined below), please avoid any interaction with us or with our Site, or submit a request to exercise your rights as further explained in Section ‎9 below. This Privacy Policy may change from time to time (Section 11, Updates and Amendments). Your continued use of this Site after we make changes is deemed to be acceptance of those changes, so please check this Privacy Policy periodically for updates.

1. Data Collection

Throughout this Privacy Policy, the term “Personal Data” means any information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or device. However, Personal Data does not include any deidentified or aggregated information. We collect and generate the following types of Personal Data concerning our Visitors:

• Website usage information (connectivity, technical and aggregated usage data (such as user agent), IP addresses, device data (like type, OS, device id, browser version, locale and language settings used), activity logs, session recordings, and the cookies and pixels installed or utilized on their device;

• Visitor information that you provide us, such as information you provide when submitting an online form on the Site, including the “Contact Us” form, or through social media networks, for example your first and last name, e-mail address, phone number, job title, country of residence, health insurance plan, primary care physician’s (“PCP”) contact information (such as your PCP’s name, address, fax and/or phone number, and e-mail), or information we collect by contacting us or interacting with us through any other means. In this respect, please do not provide us with any Personal Data or sensitive information which is not required by us to process your request or inquiry.

We collect such data either automatically, through your interaction with us or with our Site, or through third party services, social media, analytics tools, webinars and events we organize or participate in, and other business initiatives.

• Candidates’ information: our Site includes a ‘Careers’ section, through which job Candidates may view Healthy’s open positions and apply for them. Throughout the application and recruitment process, Candidates may provide us (or we may otherwise have access to) Personal Data about them, such as identifying data, contact details, resume/CV, work-related data, professional qualifications, employment history, social media activity, etc. We may collect this data directly from you, as you provide it voluntarily through your application and candidacy review process, or from other sources such as recruitment agencies, background check services (as applicable and subject to applicable law), other employees of Healthy, or your references (collectively - “Candidates Personal Data”).

2. Data Uses and Legal Bases

We use Visitors’ Personal Data as necessary for the operation and provision of our Site; to comply with our legal and contractual obligations; and to support our legitimate interests in maintaining and improving our Site, e.g. in understanding how our Site is used and how our campaigns are performing, and gaining insights which help us dedicate our resources and efforts more efficiently; in marketing, advertising and selling our services; providing customer service and technical support; and protecting and securing our customers, users, visitors, ourselves and our services.

If you reside or are using the Site in a territory governed by privacy laws under which “consent” is the only or most appropriate legal basis for the processing of Personal Data as described herein (in general, or specifically with respect to the types of Personal Data you expect or elect to process or have processed by us), your acceptance of our Privacy Policy will be deemed as your consent to the processing of your Personal Data for all purposes detailed in this Policy. If you wish to revoke such consent, please contact us at [email protected].

Specifically, we use our Visitors’ Personal Data for the following purposes:

• To facilitate, operate, and provide the Site;

• To monitor, study, and analyze use of the Site;

• To contact you with general or personalized service-related messages, as well as promotional messages that may be of specific interest to you;

• To enforce our Terms of Use, policies and other contractual arrangements, to comply with court orders and warrants, and prevent misuse of the Site, and to take any action in any legal dispute and proceeding;

• To gain a better understanding on how individuals use and interact with our Site, and how we could improve their and others’ user experience, and continue improving our products, offerings and the overall performance of our Site and services;

• To facilitate and optimize our marketing campaigns, ad management and sales operations, and to manage and deliver advertisements for our products and services more effectively. Such activities allow us to highlight the benefits of using our services, and thereby increase your engagement and overall satisfaction with our services. This includes contextual, behavioral, and interests-based advertising based on your activity, preferences, or other data available to us or to our business partners;

• To support and enhance our data security measures, including for the purposes of preventing and mitigating the risks of fraud, error, or any illegal or prohibited activity;

• To create aggregated statistical data, inferred non-Personal Data, or anonymized or pseudonymized data (rendered non-personal and non-identifiable), which we or our business partners may use to provide and improve our respective services, or for any other purpose; and

• To comply with applicable laws and regulations.

In addition to the abovementioned uses of Visitors Personal Data, we may use Candidates Personal Data for the following purposes:

• To assess our Candidates’ skills, qualifications and to verify, consider and process their application and candidacy for any of our positions, and to communicate with them regarding such processes;

• To manage risk and enhance our security and anti-fraud measures, and to create aggregated statistical or inferred data regarding our Candidates, for further development and improvement of our recruitment processes; and

• To act as permitted by, and to comply with, any legal or regulatory requirements.

To the extent that we would wish to conduct any additional activities that may require the use of Candidates Personal Data, we will request the candidates’ specific consent in advance.

3. Data Location

We and our authorized Service Providers (defined below) maintain, store and process Personal Data in the United States of America, UK, Israel and other locations, as reasonably necessary for the proper performance and delivery of our Site and its services, or as may be required by law. While privacy laws may vary between jurisdictions, Healthy is committed to protecting Personal Data in accordance with this Privacy Policy and customary industry standards, regardless of any lesser legal requirements that may apply in their jurisdiction. To the extent we transfer Visitors’ Personal Data originating from the European Economic Area (“EEA”), Switzerland or the United Kingdom elsewhere, we rely on appropriate data transfer mechanisms as established under applicable law.

4. Data Retention

We retain your Personal Data for as long as it is reasonably necessary in order to maintain and expand our relationship and provide you with our Site and offerings; in order to comply with our legal and contractual obligations; to pursue our legitimate business purposes; or to protect ourselves from any potential disputes (i.e. as required by laws applicable to log-keeping, records and bookkeeping, and in order to have proof and evidence concerning our relationship, should any legal issues arise following your discontinuance of use), all in accordance with our data retention policy.

Please note that except as required by applicable law or our specific agreements with you, we will not be obligated to retain your Personal Data for any particular period, and we are free to securely delete it or restrict access to it for any reason and at any time, with or without notice to you. If you have any questions about our data retention policy, please contact us by e-mail at [email protected].

5. Data Sharing

We do not share, sell, or otherwise disclose your Personal Data for purposes other than those outlined in this Privacy Policy. However, we may disclose Personal Data that we collect or you provide as described in this Privacy Policy for the following reasons.

Legal Compliance: We may disclose or allow government and law enforcement officials access to your Personal Data, in response to a subpoena, search warrant or court order (or similar requirement), or in compliance with applicable laws and regulations. Such disclosure or access may occur if we believe in good faith that: (a) we are legally compelled to do so; (b) disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing; or (c) such disclosure is required to protect our legitimate business interests, including the security or integrity of our Site, products, and services.

Service Providers: We may engage selected third-party companies and individuals to perform services complementary to our own. Such service providers may include hosting and server co-location services, communications and content delivery networks (“CDNs”), data security services, fraud detection and prevention services, web analytics, e-mail distribution and monitoring services, session, call or activity recording and analysis services, remote access services, performance measurement, data optimization and marketing services, social and advertising networks, content providers, e-mail, voicemails, support and customer relation management systems, and our legal, financial and compliance advisors (collectively, “Service Providers“). Our Service Providers may have access to Personal Data, depending on each of their specific roles and purposes in facilitating and enhancing our Site, and may only use the data for such limited purposes as determined in our agreements with them. Our main Service Provider for Candidates Personal Data is Comeet Technologies Inc. (“Comeet”). Candidates are welcome and encouraged to review Comeet’s privacy notice.

Third Party Websites and Services: Our Site may include links to third party websites, and integrations with third party services. Such websites and third-party services, and any information you process, submit, transmit or otherwise use with such websites and third-party services, are governed by such third party’s terms and privacy practices and policies, and not by this Privacy Policy. We encourage you to carefully read the terms and privacy policies of such websites and third-party services.

Protecting Rights and Safety: We may share Personal Data with others if we believe in good faith that this will help protect the rights, property or personal safety of Healthy, any of our Visitors, users or customers, or any members of the general public.

Healthy Subsidiaries and Affiliated Companies: We may share Personal Data internally within our group, for the purposes described in this Privacy Policy. In addition, should Healthy or any of its subsidiaries or affiliates undergo any change in control or ownership, including by means of merger, acquisition or purchase of substantially all or part of its assets, Personal Data may be shared with or transferred to the parties involved in such an event. If we believe that such change in control might materially affect your Personal Data then stored with us, we will notify you of this event and the choices you may have via e-mail or prominent notice on our Site.

Your Health Plan: We may share Personal Data with your health plan, in the event you have a health plan and choose to provide us with that information. We share this data with your health plan to alert them to your potential interest in our services and our products. Additionally, after we confirm your PCP details with us – we will share certain information about your PCP, such as your PCP’s name, address, fax and/or phone number, and e-mail address with your health plan. For the avoidance of doubt, Healthy may share Personal Data in additional manners, pursuant to your explicit approval, or if we are legally obligated to do so, or if we have successfully rendered such data non-personal, non-identifiable and anonymous. We may transfer, share or otherwise use non-personal and non-identifiable data at our sole discretion and without the need for further approval.

6. Cookies and Tracking Technologies

We and our Service Providers use cookies and other technologies for performance, tracking, analytics and personalization purposes. We may share non-identifiable / aggregated extracts of such information with our partners for our legitimate business purposes.

Cookies are packets of information sent to your web browser and then sent back by the browser each time it accesses the server that sent the cookie. Some cookies are removed when you close your browser session. These are the “Session Cookies”. Some last for longer periods and are called “Persistent Cookies”. We use both types.

We use Persistent Cookies to remember your log-in details and make it easier for you to log-in the next time you access the Platform. We may use this type of cookies and Session Cookies for additional purposes, to facilitate the use of the Site’s features and tools. For more information regarding cookies, you may find the following websites useful: www.allaboutcookies.org, www.youronlinechoices.co.uk.

Whilst we do not change our practices in response to a “Do Not Track” signal in the HTTP header from a browser or mobile application, you can manage your cookies preferences, including whether or not to accept them and how to remove them, through your browser settings. Please bear in mind that disabling cookies may complicate or even prevent you from using the Site.

Additional information and a list of the cookies we use can be found in our Cookie Policy, which is available at: https://healthy.io/cookie-policy.

We also use analytics tools such as Google Analytics. These tools help us understand users’ behavior on our Site, including by tracking page content, and click/touch, movements, scrolls, and keystroke activities.

Further information about the privacy practices of our analytics service providers is available at: www.google.com/policies/privacy/partners/.

Further information about your option to opt-out of these analytics services is available at: https://tools.google.com/dlpage/gaoptout/

Please note that if you get a new computer, install a new browser, erase or otherwise alter your browser’s cookie file (including upgrading certain browsers), you may also clear the opt-out cookies installed once you opt-out, so an additional opt-out will be necessary to prevent additional tracking.

7. Communications

We may engage you in service and promotional communications through email, phone, SMS and notifications.

We may also notify you about new features, additional offerings, events, special opportunities or any other information we think you will find valuable. We may provide such notices through any of the contact means available to us (e.g., phone, mobile or email), through the Site, or through our marketing campaigns on any other sites or platforms.

If you do not wish to receive such promotional communications, you may notify Healthy at any time by sending an e-mail to: [email protected], or by following the “unsubscribe”, “stop”, “opt-out” or “change email preferences” instructions contained in the promotional communications you receive.

8. Data Security

We implement systems, applications, and procedures to secure your Personal Data, to minimize the risks of theft, damage, loss of information, or unauthorized access or use of information. However, although we make efforts to protect your privacy, we cannot guarantee that our Site will be immune from any wrongdoings, malfunctions, unlawful interceptions or access, or other kinds of abuse and misuse.

9. Data Subject Rights - Accessing, Correcting, and Deleting Your Personal Data

Individuals have rights concerning their Personal Data. You may request to access, correct, and delete your Personal Data by contacting us by e-mail at: [email protected]. However, we cannot accommodate a request to change your Personal Data if we believe that such change would either violate a legal obligation or cause the Personal Data to be incorrect. We may redact from the data which we will make available to you, any Personal Data related to others. Please note that these rights are not absolute and may be subject to our own legitimate interests and regulatory requirements.

Please note that when you ask us to exercise any of your rights under this policy or applicable law, we may need to ask you to provide us certain credentials to make sure that you are who you claim you are, to avoid disclosure to you of personal information related to others and to ask you to provide further information to better understand the nature and scope of data that you request to access. Such additional data will be then retained by us for legal purposes (e.g., as proof of the identity of the person submitting the request).

10. Jurisdiction Specific Privacy Rights

The law in certain jurisdictions may provide you with additional rights regarding our use of Personal Data. To learn more about any additional rights that may be applicable to you as a resident of one of these jurisdictions, please see below.

Your California Privacy Rights

If you are a resident of California, you have the additional rights described below. California Civil Code Section 1798.83 (California’s “Shine the Light” law) permits users of our Website that are California residents and who provide Personal Data in obtaining products and services for personal, family, or household use to request certain information regarding our disclosure of Personal Data to third parties for their own direct marketing purposes. If applicable, this information would include the categories of Personal Data and the names and addresses of those businesses with which we shared your Personal Data with for the immediately prior calendar year (e.g., requests made in 2022 will receive information regarding such activities in 2021). You may request this information once per calendar year. To make such a request, please send an email to contact us by email at: [email protected].

Your GDPR Privacy Rights

If you are a resident of the EEA, Switzerland, or the United Kingdom, you have the additional rights described below. You have certain rights with respect to your Personal Data under the GDPR, including the right to access and update your Personal Data, restrict how it is used, transfer certain Personal Data to another controller, withdraw your consent at any time, and the right to have us erase certain Personal Data about you. You also have the right to complain to a supervisory authority about our processing of your Personal Data. Specifically, the GDPR provides you with certain rights with regards to our processing of your Personal Data. These rights replace the similar rights provided in our Privacy Policy or are supplemental to such rights.

• Access and Update. You can review and change your Personal Data by contacting us by e-mail at: [email protected]. You may also notify us by email of any changes or errors in any Personal Data we have about you to ensure that it is complete, accurate, and as current as possible. We may also not be able to accommodate your request if we believe it would violate any law or legal requirement or cause the information to be incorrect.

• Restrictions. You have the right to restrict our processing of your Personal Data under certain circumstances. In particular, you can request we restrict our use of it if you contest its accuracy, if the processing of your Personal Data is determined to be unlawful, or if we no longer need your Personal Data for processing but we have retained it as permitted by law.

• Portability. To the extent the Personal Data you provide Healthy is processed based on your consent and that we process it through automated means, you have the right to request that we provide you a copy of, or access to, all or part of such Personal Data in structured, commonly used and machine-readable format. You also have the right to request that we transmit this Personal Data to another controller, when technically feasible.

• Withdrawal of Consent. To the extent that our processing of your Personal Data is based on your consent, you may withdraw your consent at any time by contacting us by e-mail at: [email protected]. Withdrawing your consent will not, however, affect the lawfulness of the processing based on your consent before its withdrawal, and will not affect the lawfulness of our continued processing that is based on any other lawful basis for processing your Personal Data.

• Right to be Forgotten. You have the right to request that we delete all of your Personal Data by contacting us by e-mail at: [email protected]. We will only delete your data when we no longer have a lawful basis for processing your Personal Data or after a final determination that your Personal Data was unlawfully processed. We may not accommodate a request to erase information if we believe the deletion would violate any law or legal requirement or cause the information to be incorrect. In all other cases, we will retain your Personal Data as set forth in this policy. In addition, we cannot completely delete your Personal Data as some data may rest in previous backups.

• Complaints. You have the right to lodge a complaint with the applicable supervisory authority in the country you live in, the country you work in, or the country where you believe your rights under applicable data protection laws have been violated. However, before doing so, we request that you contact us directly in order to give us an opportunity to work directly with you to resolve any concerns about your privacy.

• How You May Exercise Your Rights. You may exercise any of the above rights by contacting us by e-mail at: [email protected]. If you contact us to exercise any of the foregoing rights, we may ask you for additional information to verify your identity. We reserve the right to limit or deny your request if you have failed to provide sufficient information to verify your identity or to satisfy our legal and business requirements. Please note that if you make unfounded, repetitive, or excessive requests (as determined in our reasonable discretion) to access your Personal Data, you may be charged a fee subject to a maximum set by applicable law.

11. Additional Notices

Updates and Amendments: We may update and amend this Privacy Policy from time to time by posting an amended version on the Site. The amended version will be effective as of the date it is published. We will provide prior notice if we believe any substantial changes are involved via any of the communication means available to us or via the Site. After such notice period, all amendments shall be deemed accepted by you.

External Links: While our Site may contain links to other websites or services, we are not responsible for their privacy practices. We encourage you to pay attention when you leave our Site for the website or application of such third parties, and to read the privacy policies of each and every website and service you visit. This Privacy Policy applies only to our Site.

Children: Our Site is not designed to attract children under the age of 18. We do not knowingly collect Personal Data from children and do not wish to do so. If we learn that a person under the age of 18 is using the Site, we will attempt to prohibit and block such use and will make our best efforts to promptly delete any Personal Data stored with us with regard to such child. If you believe that we might have any such data, please contact us by e-mail at [email protected].

Data Controller: Healthy is the data controller of your Personal Data that is collected through the Site. Healthy has appointed a Data Protection Officer and representatives in both the European Union and the United Kingdom, identified below, in compliance with the General Data Protection Regulation and the UK Data Protection Act and UK-GDPR.

Data Protection Officer: Healthy has a Data Protection Officer, for monitoring and advising on Healthy’s ongoing privacy compliance and serving as a point of contact on privacy matters for data subjects and supervisory authorities. If you have any comments or questions regarding our Privacy Policy, if you have any concerns regarding your privacy, or if you wish to make a complaint about how your Personal Data is being processed by Healthy, you can contact our DPO at [email protected].

EU Representative: Maetzler Rechtsanwalts GmbH & Co KG (Prighter), which are located at Schellinggasse 3, 1010 Vienna, Austria, has been designated as Healthy’s representative in the European Union for data protection matters pursuant to Article 27 of the GDPR. Prighter may be contacted only on matters related to the processing of Personal Data. To make such an inquiry, please send an email to [email protected].

UK Representative: Healthy.io UK Ltd., which is located at The King's Fund 11-13, Cavendish Square, London, W1G 0AN, UK, has been designated as Healthy’s representative in the United Kingdom for data protection matters pursuant to Article 27 of the UK GDPR. Healthy UK may be contacted on matters related to the processing of Personal Data. To make such an inquiry, please send an email to [email protected].

Questions, Concerns or Complaints: If you have any comments or questions regarding our Privacy Policy, or if you have any concerns regarding your Personal Data held with us, please contact Healthy’s support at [email protected] or our Data Protection Officer at [email protected]. Our physical address is 8 Yitzhak Sadeh St., Tel Aviv 6777508, Israel. If you are a GDPR or UK-GDPR protected individual, you also have the right to lodge a complaint with an EU supervisory authority, or the UK Information Commissioner’s Office, as appropriate.