Hanita is committed to protecting the privacy of all individuals in respect of whom we hold any personal data, regardless of whether those persons are customers, potential customers, business partners or otherwise and regardless of how we have come to possess the personal data.
Hanita will ensure that all personal data that you submit to us, or which we collect, via various channels, including without limit via your interaction with our website, through written correspondence (including e-mail) and from our distributors, doctors and hospitals, is only used for the purposes set out in this policy and that it shall be held and stored safely and in compliance with the applicable laws.
VP Business Development
What is Personal Data?
Our policy is not to require or to receive any information relating to any person’s health, including data relating to dimensions of your eyes and lens requirements or any other information that Israeli law or the GDPR considers to be sensitive or in a special category (“Sensitive Data“), unless that information has been anonymized before being sent to us so that we cannot identify to whom the information relates.
Any Sensitive Data that we identify in our systems will be anonymized so that we cannot connect it to you (“Anonymized Data“) and we will purge all Sensitive Data that we receive or find on our systems at any time.
We will also ensure that we receive no Sensitive Data from clinical trials conducted on our behalf other than where it has been anonymized by the institution conducting the trials or it has been converted into aggregated statistics in which the Sensitive Data relating specifically to an identifiable individual cannot be ascertained.
How We Collect Personal Data
We generally collect personal data from you in the following ways:
We collect statistical information regarding use of our website. This includes information about your browsing actions and patterns on the website, which we may use in order to provide you with a more personal experience. We also aggregate all statistical information regarding the browsing actions and patterns of all visitors to our website and this aggregated statistical information does not identify you.
How we Process your Personal data
“Processing” personal data means performing any operation or set of operations on personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction of the personal data.
The personal data that you provide to us or that we receive from other sources will be kept confidential. We will only hold, use and disclose your personal data in a manner that is fully compliant with Israeli law and the GDPR and in accordance with our legitimate business purposes, which include:
We will not process your personal data for any other reason than those stated above, unless we first receive your express prior written consent or we are legally required to. The legal basis for processing your personal data is made up of one or more of the following reasons:
How we share your Personal data
As Hanita personnel are generally located in Israel, when they access the personal data from the third party servers, the personal data is effectively also transferred out of the EU to Israel and part or all of that personal data may be stored in Israel, such as when it is downloaded onto the Hanita employee’s hard drive.
New business owners
If we or our business merges with or is acquired by another business or company, we will share your personal data with the new owners of the business or company and their advisors. If this happens, we will notify you of such event in advance, subject to restrictions in transferring commercially sensitive information.
How long we will hold your information
To the extent permissible by applicable law, we will retain your personal data for such period plus 12 further months as is necessary to satisfy or to fulfill the following:
We have put in place reasonable administrative, organizational and technical safeguards and security measures to protect personal data from unauthorized access, disclosure, destruction or alteration, accidental loss, misuse or damage. We regularly review and monitor such safeguards and security measures and update them when we deem it to be required. However, no measures can provide an absolute guarantee against unauthorized access.
You should understand that the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data while it is being transmitted to our website or sent to us by email via third party networks. Once we have received your information, we will use the procedures and security features described above to reduce the possibility of unauthorized access.
Your Rights in Connection with Your Personal Data Held by Us.
You have certain rights in relation to personal data about you that we hold. Details of these rights and how to exercise them are set out below. We will require evidence of your identity before we are able to act on any request with respect to exercising any rights. For convenience, please address any requests to us regarding your rights below by email to Yakir Kushlin, [email protected]
Right of Access
You have the right at any time to ask us for a copy of the personal data about you that we hold. Israeli law and GDPR provides certain instances where we may refuse your request for a copy of your personal data, or certain parts of the personal data that we hold. If we refuse your request or any element of it, we will provide you with our written reasons for doing so as soon as possible.
Right of Correction or Completion
If personal data we hold about you is not accurate, out of date or incomplete, you have a right to have the data rectified, updated or completed.
Right of Erasure
You have the right to request that personal data we hold about you is erased if:
Right to object to or restrict processing
You have the right to object to our processing of your personal data and you also have the right to object to use of your personal data for direct marketing purposes.
Right of Data Portability
You have a right to receive any personal data that we hold about you in a structured, commonly used and machine-readable format, provided that:
Please note that if you are requesting the personal data to be transferred to a third party’s system, we cannot guarantee technical compatibility with that system.
To the extent that we are processing your personal data based on your consent, you have the right to withdraw your consent at any time.
If you are unhappy about our use of your personal data, please do notify us, providing the reasons and we will endeavor to rectify the problem.
You may address any complaints to Yakir Kushlin ([email protected]).
If you are based in the EU, you may also lodge a complaint with any Data Protecton Authority set up to supervise and enforce the GDPR (“DPA“). There is a DPA in each EU member state and you may report to any DPA, although generally you will report to the DPA set up in the member state in which you are located. Here is a list of all DPAs and their contact details: http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm However, we do take your rights with respect to your personal data very seriously and will appreciate the chance to resolve any issues that you may have before you address a DPA.
Third Party Websites
Further Information on Data Protection and Personal Privacy
If you have any enquiries or if you would like to contact us about our processing of your personal data, including to exercise your rights as outlined above, please contact us by email on Yakir Kushlin. You may contact Yakir Kushlin by email to [email protected].
When you contact us, we will ask you to verify your identity.