Last modified on: June 24, 2020
WeCare Apps Ltd.,(the “WeCare”, and also in this policy “we“, “us“, “our“) offers, through My Day mobile application (“My Day“), a caregiver/patient system that organizes daily schedule and tasks for people with memory impairment and older adults. We also provide various support and service activities related to My Day (“Services”).
Data privacy is important to us. This means that we process data with due care, while adopting and combining industry standard data collection, storage, and processing practices with security measures to protect against unauthorized access, alteration, disclosure, or destruction of a user’s personal information and always in accordance with applicable data protection laws.
- What personal data we collect (“Personal Data”)
- How we collect your Personal Data
- How we use your information
- How we share your information
- Data transfers and global processing
- How long we hold your Personal Data
- Marketing Messages
- Data Subject Rights
- Changes to This Privacy Notice
- How to Contact Us
- What Personal Data We Collect
- We may collect different categories of personal information depending on your activities on My Day and depending also on whether you are a Primary User or a Caregiver:
- When registering to My Day:
- When you register – name, an email address and chosen password.
- When you purchase a premium version of My Day, your payment information is processed by third party payment processing services – we do not collect or store this information. We shall receive and collect only the name of the country from where the payment was made and the device used for payment.
- When you use My Day – your entries in the various fields, including, but not limited to, reminders, names of your medicines, important dates, your contacts, addresses, etc. Some of this data may be inserted in the form of free text. We strongly advise you not to include any payment data in such content (i.e. credit card numbers).
- When you interact with us outside My Day, we may also collect details of other interactions that you have with us, together with any other information that you choose to provide us with, for example, through your interactions with our customer and technical support teams.
- We also anonymize and aggregate personal information (so that it does not identify you) and use it for purposes including testing our IT systems, research, data analysis, improving My Day, and developing new products and services. Such anonymized information includes technical information transmitted by User’s device regarding the hardware specifications (e.g. operating system type, version and device) and language preferences, as well as User’s country.
- You are not obligated to provide us with any of the above information under any applicable law. However, we will not be able to operate My Day and/or provide you with the Services or part of them, as applicable, if you do not agree, or if you withdraw your consent, or request to object (all as detailed under section 8 with respect to your rights) to our processing of these data items. Therefore, if you do not agree to us collecting the above Personal Data, please do not use My Day or Services.
- How We Collect Your Information
- We collect Personal Data Directly: from Users, whether Primary User or Caregivers – when they register on My Day and through their continuous use of My Day.
- Indirectly: through access granted to the application through the app store to various features of Users’ devices as approved according to the policies of app store in accordance with their privacy policies and settings on Users’ devices.
- How we Use Your Information
Here is what we do with your Personal Data that we collect as described above:
- We use all of the above personal data to operate, maintain, and provide to you with the My Day features and functionality and to provide you with the Services as requested by you.
- We use your information to send you emails with regards to your operation of the My Day (e.g., account verification, notify you of changes/updates to features, credentials change, technical and security notices), as well as to send you marketing communications (please see more details regarding this under “Marketing Communications”).
- We may use the above information to respond to your requests and messages, including with respect to your rights as data subject, as well as to initiate contact with you on issues related to My Day or Services or support and maintenance issues.
- We may use the information you provide to allow certain functions to perform as intended.
- To prevent, detect and fight fraud or other illegal or unauthorized activities
- We use anonymized, aggregate data, in order to gain insight on how you and other users use the My Day and Services and try and improve our My Day and Service, as well as to plan our marketing and advertisements.
- To ensure legal compliance – from our side (to legal requirements that apply to us and to our obligations under the Terms) and from your side (Compliance with laws applicable to you and with the Terms)
- We limit access by our employees to your information only to those who were specifically authorized by WeCare to access your information, as part of their job description.
Our Legal Bases for Processing:
With respect to such activities we will conduct as Controllers, we will only process your personal information where we have a legal basis to do so.
The following are the legal bases under which we process your information in the manners specified above:
- Performance of a contract to which WeCare and you, the data subject, are parties. Many of the uses described above are actions that involve processing of your information in order to meet our undertakings to you and respond to your requests and indications within the Services.
- Legitimate interests: We may use your information where we or our customers have legitimate interests to do so. For instance, we analyze users’ behavior on our services to continuously improve our offerings, and we process information for administrative, fraud detection and other legal purposes.
- Consent – some of the information you provide is based on your consent and will to provide it. In addition, we may ask you from time to time, through the Service or My Day interface, to provide your consent for specific uses (for example, to add you to our newsletter or send marketing communications to you in case we have never had any commercial relations regarding the products or services subject matter of such communication).
- How we Share Your Personal Data
1. No Sale to Third Parties. We do not, and will not, sell any of your personal data to any third party for advertising, marketing or any other purpose – including your name, address, email address or credit card information. We want to earn and maintain your trust, and we believe this is absolutely essential in order do that.
2. Service Providers: we employ other companies and people to perform tasks on our behalf and need to share your information with them in order to provide the Services. The categories of third party recipients of the Personal Data from us are as follows:
- Cloud and hosting – Firebase by Google
- Analytics tools provider – Mixpanel
- Analytics tools provider – Firebase & Analytics by Google
- Email campaign automation – Mailchimp
- Automation platform – Integromat
- Billing, processing payments – Apple’s App Store
- Billing, processing payments – RevenueCat
- Sending push notifications – One Signal
- Hosting – AWS
Our agents do not have any right to use, your personal information collected from our Services beyond what is necessary for the purpose of facilitating our provision of the My Day and Services.
- Compliance with the Law:We may disclose your information if we believe it’s necessary in order to comply with the law, such as to comply with a subpoena, regulation or legal request, respond to a government request, to address fraud or security issues, to protect the safety of any person, to enforce our agreements with you; to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing or to protect our own rights or property. If you are located in the EU, we may only do so based on legal requirements specified above of EU authorities. This includes sharing such information with our legal counsels.
- Business Transfers:If we are in a bankruptcy, merger, acquisition, reorganization or sale of assets, your information may be transferred as part of that transaction to a successor in interest and to the applicable legal authorities as well as legal counsels and other professional counsels involved such as accountants, and other officers of the government or of the applicable judiciary instance.
- Anonymized Information:We may provide third parties (for their needs, including advertising and tracking) with aggregated but anonymized information and analytics about our customers however, before we do so, we will make sure that it does not identify you.
- Data Transfers and Global Processing
Why Personal Data is Transferred?
As we operate globally, we may on occasion allow your personal data to be accessed and/or processed and from and/or transferred to countries other than your own location. We may do this where data is accessed/processed:
- By our service providers, for the purposes we specified above under the chapter “How we Share Your Personal Data”.
- By consenting to the collection and use of your personal information, you agree to your personal information being transferred and stored in this manner and for the specified purposes.
Our Legal Basis for performing such transfers across boundaries (when we act as Controllers):
- Model Clauses. With some of our processors, we use standard contractual clauses that are binding standards of processing of personal data committed to contractually by third parties processing information for us and on our behalf, such standard clauses are approved by the European Commission.
- In the absence of Model Clauses, Your consent. By using My Day and/or Services, you agree and understand that your information may be transferred from the EEA or other countries in which you may be using the Services, to other countries outside your own location (including outside the EEA), and specifically to the USA. The transfer will be to such third parties as described under “How we Share Your Personal Data”.You agree to such transfer, and you understand that data processed in these countries/regions is subject to different data protection laws, which may sometimes grant lesser degree of protection that the privacy laws and regulations applicable within the EEA for example.
- How long we hold your Personal Data
We retain the personal information that we collect from and about you for as long as it is needed to provide access to the My Day or to manage your account. We take reasonable steps to delete the personal information we collect if you opt out of receiving further communications from us, or if you ask us to delete your information. We may however retain and use personal information as necessary to comply with our legal and regulatory obligations, to resolve disputes and to enforce our agreements, and we may retain and use anonymous and aggregated information for performance reporting and analytic purposes and for product and service improvement.
You can request that your personal information be deleted by contacting WeCare at firstname.lastname@example.org
- Marketing Messages
- If you have said we can, we will send you marketing messages by email to keep you aware of what we’re up to and to help you see and find our products and services.
- You can stop receiving marketing messages from us at any time. You can do this by clicking on the ‘unsubscribe’ link in any email, and by contacting us at email@example.com
- Data Subject Rights
Each Data Subject has a few rights relating to their Personal Data held or processed by us:
- The right to be informed about how your personal information is being used.
- The right to access the personal information we hold about you.
- The right to request the correction of inaccurate personal information we hold about you.
- In some circumstances, the right to request that we delete your data
- The right to Restrict processing your personal data
- The right to object to processing activities, if the processing is based on our legitimate interest;
- The rights to withdraw consent at any time, if the processing is based on consent
- The right to object to processing of personal data for direct marketing purposes
- In some circumstances, the right to request that we transfer or port elements of your data either to you or another service provider – if the processing is based on your consent, and is made by automated means.
- The right to file a complaint with your Supervisory Authority.
9. Changes to This Privacy Notice
We may change this privacy notice from time to time, to reflect how we are processing your data, including following any regulatory changes or our internal policies.
If we make significant changes, we will make that clear on My Day or by some other means of contact such as email, so that you are able to review the changes before you continue to use My Day.
- How to Contact Us
We always want to hear from you!
Please don’t hesitate to contact us at firstname.lastname@example.org, and we will be happy to answer any questions you may have concerning this privacy notice, deal with your complaint, or help you exercise any of your rights as set out above.