Privacy Policy

Last Updated: November2022

We created this Privacy Policy because we highlyVALUE your Personal Data and information.

Please read it as itincludes important information REGARDING your Personal Data and information.

1.     Privacy Statement

BIOME TECH Ltd. is an Israelicompany having its principal office at Tel Aviv, Israel (“BIOME”” or “We”).

BIOME develops and operates an innovative autobiography creating and social-network-likeApp which allow the Users to write about their real life and experiences so theirloved ones could read about their journey in this world and all their memorieswill last forever. Using BIOME, the user can share his \ her life story, tobuild their own real and authentic memory book, share or provide it to whomthey may chose, when the time comes (the “Services” or the “App”).

BIOME also creates and operatesits marketing website available at: https://www.bio-me.app/ (the“Website”).

ThisPrivacy Policy refers to the Services, App and the Website, BIOME’s customersor potential customers, customers’ end-users, BIOME’s employees and serviceproviders, and the users of the app and Website.

This PrivacyPolicy sets forth our policy with respect to information that can be associatedwith or which relates to a person and/or could be used to identify a person,such as a name, an identification number, location data, an online identifieror to one or more factors specific to the physical, physiological, genetic,mental, economic, cultural or social identity of that natural person, all asdefined by the General Data Protection Regulation (GDPR) (EU) 2016/679  (“Personal Data”).

 

"Non-Personal Data," as used in this Privacy Policy,is therefore any information that does not relate to a person and cannot beused to identify a person.  The limitations and requirements in this PrivacyPolicy on how we gather, use, disclose, transfer, and store/retain PersonalData do not apply to Non-Personal Data as We may use.

2.    Data that we use, receive, collect,process, share, or store and how we use it.

2.1.       BIOME uses,receives, collects, processes, or stores only that Information which is necessary toprovide its services and operate its business.

2.2.       We might use, receive,collect, process, or store Personal Data on potential customers, customers,employees, service providers, users of the App and Website etc.  

2.3.       This Informationmay include Personal data such as:

2.3.1.    Information relatedto Customer or Potential Customers and End User: Full Name, Profile image,Email address, Heritage timeline Email, Heritage safebox Email, Date of birth,Language, Registration date, Subscription plan, financial information (i.e.,billing information, credit card information), Audio, electronic, visual, andsimilar information, such as images and audio or video uploaded by the User.

2.3.2.    In addition to theabove, more information related to employees and / or candidates: Demographicdata (i.e., gender, date of birth etc.), CVs, ID number/Passport number, Education,and employment history etc.

2.3.3.    More Informationregarding Suppliers: Business email addresses, VAT Number, Signature, etc.

 

2.3.4.    Weuse cookies and similar tracking technologies to track the activity on our App and Websiteand hold certain information. Cookies are files with a small amount of datawhich may include an anonymous unique identifier. Cookies are sent to yourbrowser from a website and stored on your device. Tracking technologies alsoused are Users Tokens, beacons, tags, and scripts to collect and trackinformation and to improve and analyze our Website and App. You can instructyour browser to refuse all cookies or to indicate when a cookie is being sent.However, if you do not accept cookies, you may not be able to use some portionsof our Website or App. Examples of cookies we use:

o   Session cookies – for operating our Website or App.

o   Preference cookies – for remembering your preferences and various settings.

o   Security cookies – for security purposes.

 

2.3.5.     This Personal Data provided to us voluntarily and/or throughthe data owner’s consent to collect and process it, and/or the processing thereofis necessary to provide the Services,and/or meet contractual obligations entered into by the dataowner or and BIOME, and/or the processing thereof is necessary for BIOME tocomply with its legal obligations, and/or the processing thereof is for thepurposes of legitimate interests pursued by BIOME .

 

2.3.6.     We use this Personal Data in a manner that isconsistent with this Privacy Policy and applicable laws and regulations. We mayuse the Personal Data as follows: 

2.3.6.1.                      Processing and Analyzing:  In order toprovide BIOME ’s Services, App and operate its business, BIOME may use the PersonalData for processing and analyzing purposes.

2.3.6.2.                      Specific Purpose: If you providePersonal Data for a specific purpose, BIOME may use said Personal Data inconnection with the purpose for which it was provided. For instance, if youcontact BIOME by email, we will use the Personal Data you provide to answeryour question or resolve your problem and will respond to the email address usedto contact us. 

2.3.6.3.                      Internal Business: We may use yourPersonal Data for internal business purposes, including, without limitation, tohelp us improve our Services, App and Website content and functionality, tobetter understand our Customers and Users, to protect against, identify oraddress wrongdoing, to enforce our contracts and this Privacy Policy, toprovide you with Customer service, and to generally manage and operate our business(e.g., pay salaries and make considerations). 

2.3.6.4.                      Marketing: We may use any Personal Data you provide us with to contact you in thefuture for our marketing and advertising purposes, including, without limitation,to inform you about new services we believe might be of interest to you, and todevelop promotional or marketing materials and provide those materials to you. If you receive direct marketing BY MISTAKE OR without your specificconsent and/or YOU wish to opt-out, you ARE required to contact us at support@bio-me.app .

2.3.6.5.                      Statistics: We may use any Personal Data you provide us with togenerate statistical reports containing aggregated information.

2.3.6.6.                      Security and Dispute Resolution: We may use Personal Data to protect the security of our App, Website and Services,to detect and prevent cyberattacks, fraud, phishing, identity theft, and data leaks,to verify genuine software licenses, to resolve disputes, and to enforce ouragreements.

2.3.6.7.                      Data Retention, Archives: We retain and archive Personal Data so long as itnecessary to operate our business and maintain our App, Website and Services,meet contractual obligations, laws, and regulations, defend from legal claims, subjectto our retention policies and this Privacy Policy.

2.3.6.8.                    Transfer/Share/Disclose Data: We may share your Personal Data with our partner,contractors and service providers who process Personal Data on behalf of BIOME toperform certain business-related functions. We may provide them withinformation, including Personal Data, in connection with their performance ofsuch functions. While we do so, we make sure that they are bound to maintain saidPersonal Data in accordance with this Privacy Policy.  When we disclosethe Personal Data, we enter a contract that describes the purpose and requiresthe recipient to both keep that personal information confidential and not useit for any purpose except performing the contract. We may also share userspecific information (i.e. name and family name) with relevant authorities(i.e. Population and immigration authorities, Registrar for inheritance matters)for validation of  the User’s status andPersonal Data if required to do so in order to provide our services (Forexample in bequeathing requests etc.).      

2.3.6.9.                      Cloud Services: We may need toshare Personal Data with our cloud service. For example, assist in protectingand securing our App, Website or Services the cloud service admin may needaccess to Personal Data to provide those functions. In such cases, the cloudservice provider must abide by our data privacy and security requirements and isnot allowed to use Personal Data they receive from us for any other purpose.

2.3.6.10.                 Development and Customer Service: For example, to provide customer service and support orassist in protecting and securing our systems and services our development andcustomer service team may require access to Personal Data. In such cases, ourpersonnel must abide by our data privacy and security requirements and policyand are not allowed to use Personal Data for any other purpose.

2.3.6.11.                 Corporate Sale, Merger, Reorganization, Dissolution or SimilarEvent: Personal Data may be part of the transferredassets. You acknowledge and agree that any successor to or acquirer of BIOME (orits assets) will continue to have the right to use your Personal Data and otherinformation in accordance with the terms of this Privacy Policy.   

2.3.6.12.                 Law Enforcement: In order to, forexample, respond to a subpoena or request from law enforcement, a court or agovernment agency (including in response to public authorities to meet nationalsecurity or law enforcement requirements), or in the good faith belief thatsuch action is necessary to (a) comply with a legal obligation, (b) protect ordefend our rights, interests or property or that of third parties, (c) preventor investigate possible wrongdoing in connection with the Services, App andWebsite (d) act in urgent circumstances to protect the personal safety of Usersof the App, Website and  Services or thepublic, or (e) protect against legal liability.

2.3.6.13.                 Other Purposes: If we intend touse any Personal Data in any manner not consistent with this Privacy Policy,you will be informed of such anticipated use prior to or at the time thePersonal Data is processed.

If you have a reasonable basis to assume or you know that any of theabove mentioned is not met, you ARE required to PROMPTLY inform us, withoutdelay, by sendING us AN email to: support@bio-me.app.

2.4.       Non-Personal Data: SinceNon-Personal Data cannot be used to identify you in person, we may use suchdata in any way permitted by law.

3.    How We Store and Transfer Personal Data.  

3.1.       In order to provide our App, Website and Services, manageand operate our business, we use third parties cloud services such as:

o   The Amazon Cloud Services, which comply with the GDPR andis ISO 27001, 27017,27018 certified (for AWS full statement see https://aws.amazon.com/blogs/security/all-aws-services-gdpr-ready/. BIOME stores some of its Information, which may containPersonal Data, at AWS cloud services in the EU (Frankfurt (.

 

3.2.       In orderto deliver our services and/or operate our business, information, which mayinclude Personal Data, may be processed by our third parties service providers(“Suppliers”). We transfer only the minimum data that is necessary forconducting our services. The data is transferred only to Suppliers approved byus that allow compliance with GDPR.

3.3.       Personaldata may be transferred, stored, and processed in countries outside the EU orEuropean Economic Area (EEA). Such transfer to third countries may includecountries that do not ensure an adequate level of data protection as requiredby EU privacy laws. We implement information security techniques &technical measures according to the industry best practices and/or third parties’contractual obligations to maintain their information security level adequateto BIOME level.

3.4.       Inaddition to the security and privacy controls that we have put in place, wealso use the EU’s Standard Contractual Clauses (SCC) as a valid transfermechanism according to the GDPR when we need to transfer Personal Informationoutside of the EU or adequate level countries (such as Israel).

3.5.       We maytransfer Personal Data to Israel country where we maintain our headquarter facility.Israel is considered by the EU as having adequate data protection law.

4.     Personal Data Security

4.1.       We arestrongly committed to protecting your Personal Data and information, and wewill take reasonable technical, organizational and legal steps and measures, accepted in our industry, to keep your Personal Datasecure and protect it against loss, misuse or modification. However, nonetwork, server, database or Internet or email transmission is ever fullysecure or error-free. Therefore, you should take special care in deciding whatinformation you disclose.

4.2.       If younotice any security risks or violations, we advise you to report them to us at support@bio-me.appso that we may resolve them as soon as possible.

4.3.       Werecommend that you use, disclose and share your Personal Data and informationwith caution and do not give out Personal Data and information unless it isnecessary, as we cannot guarantee the security of data over the internet andcannot control the actions of other users of the Services and App with whom youchoose to share Personal Data and information.

5.    Individual rights: Accessing, Updating,Correcting,  Deleting, RestrictingInformation Processing and Data portability right.

5.1.       You may have the rightto request access to some of your Personal Data being stored by us. Once wereceive and confirm your request, we will disclose to you, inter alia:

o   The categories of personal information we collected about you.

o   Our business or commercial purpose for collecting that personalinformation.

o   The categories of third parties with whom we share that personalinformation.

o   The specific pieces of personal information we collected about you (alsocalled a data portability request).

 

5.2.       You can also ask to correctand update any inaccurate Personal Data or ask to delete Personal Datathat we process about you. The foregoing is subject to our policies and theapplicable laws and regulations.  Once wereceive and confirm your request, we will delete (and direct our service providersto delete) your personal information from our records, unless an exceptionapplies by the GDPR.

5.3.       In order to exercise these rights, you can contact usat: support@bio-me.app. Only you or other person that youauthorize to act on your behalf may make a request related to your PersonalData.

5.4.       Non-Discrimination. We will not discriminate against you for exercisingany of your GDPR rights. Unless permitted by the GDPR, we will not: Deny youruse of our App, Website and Services and /or provide you a different level orquality of Services, App or Website.

5.5.       We may retainyour Personal Data for any period permitted or required under applicable laws.Even if we delete your Personal Data it may remain stored on backup or archivalmedia for an additional period of time due to technical issues or for legal,tax or regulatory reasons, or for legitimate and lawful business purposes.

5.6.       You may have theright to restrict processing if one of the following applies:

5.6.1.    The accuracy of the PersonalData is contested by the data owner;

5.6.2.    The processing isunlawful and the data owner objects to having their Personal Data erased,instead requesting that its use be restricted;

5.6.3.    Your service providerno longer needs the App Data for the purposes of the original processing, butthe data is required by the data owner for establishing, exercising or defendinglegal claims;

5.6.4.    The data owner hasobjected to processing pending verification of whether the legitimate groundsof your service provider override those of the data owner.

If you wish to object to processing, you are required to contact usat support@bio-me.app .  

6.    General

6.1.       This Privacy Policydoes not apply to any Personal Data that you provide to third-parties.  

6.2.       This Privacy Policyapplies only to the App, Services and Website; it doesnot apply to third-party websites or services linked to by the App, Website andServices or whose services we distribute. Links from the App, Website or thedistributed third-parties’ services do not imply that we endorse or havereviewed said third-party websites or services. We suggest contacting these third-partiesdirectly for information regarding their privacy policies. 

7.    Change in Terms and Conditions

The Services and ourbusiness may change from time to time. As a result, at times it may benecessary for us to make changes to this Privacy Policy. We reserve the right, atour sole discretion, to update or modify this Privacy Policy at any time(collectively, “Modifications”). Modifications to this Privacy Policywill be posted on the App, Website or Services with a revised ‘Last Updated’ dateat the top of this Privacy Policy.

Please review this Privacy Policy periodically, and especially before youprovide any Personal Data or information. This Privacy Policy was last updatedon the date indicated above. Your continued use of the Services, App andWebsite following the implementation of any Modifications to this PrivacyPolicy constitutes acceptance of those Modifications. If you do not accept any Modificationto this Privacy Policy, your sole remedy is to cease accessing, browsing andotherwise using the Website, App or our Services.  

8.    Dispute Resolution

8.1.       If you have a complaint about BIOME’s privacy practices,you should write to us at: support@bio-me.app .

Our Contact details:

Email: support@bio-me.app .

Official address: Dr Avraham Eliyahu Harkavy St 9,Tel Aviv-Yafo, Israel.

8.2.       We will take reasonable steps to work with you to attemptto resolve your complaint.

9.     General Inquiries and complaints

9.1.       You may have theright to lodge a complaint with a supervisory authority. However, prior todoing so, you are welcome to contact us by email at support@bio-me.app in order to resolve the issue for the benefit of all parties.

9.2.       Oursupervisory authority is the Israeli Data Protection authority.