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Medical Doctor PRIVACY POLICY

[Last Updated: May 30, 2022]

This privacy policy (“Privacy Policy”) governs the data collection, processing, and usage made by Medical Doctor International Studies Ltd. together with its subsidiaries and affiliated companies, including Medical Doctor International Studies (Sweden) LTD (“Company”, “Medical Doctor”, “we” or “us”) with respect to the data we collect from individuals who access and use our website (respectively “Website” and “you”).

This Privacy Policy constitutes an integral part of the Website Terms of Use (together “Terms”), and provides you with information regarding our processing operation, the lawful basis pursuant to which we process your Personal Data (as defined below), third parties to whom Personal Data will be transferred, data retention periods, as well as your rights under applicable privacy laws. Definitions used herein but not defined herein shall have the meaning ascribed to them in the Terms. 

You are not required by law to provide us with any Personal Data. Sharing Personal Data with us is entirely voluntary. However, in some cases, without providing your data we would not be able to provide you with all or some of our services.

1. AMENDMENTS

We reserve the right to periodically amend or revise the Privacy Policy, which will immediately affect the implementation of the revised Privacy Policy on our Website. The last revision date will be reflected in the “Last Modified” heading located at the top of the Privacy Policy. We will make a reasonable effort to notify you if we implement any changes that substantially change our privacy practices. We recommend that you review this Privacy Policy periodically to ensure that you understand our privacy practices and to check for any amendments.

2. WHO ARE WE 

We are Medical Doctor International Studies Ltd., a company incorporated in Israel. Our address is: Yigal Alon 94 (Alon tower 2), Tel-Aviv, Israel. Under the European General Data Protection Regulation (”GDPR”), we are the data controller of the Website Visitors.

[I recommend adding the details of one of your local European subsidiaries to avoid the need to appoint a European representative]

If you have any questions or comments about this Privacy Policy, or any concerns with respect to how your privacy any information are handled, please contact our privacy team at:_________. 

3. Applicability 

This Policy applies to our Users and Visitors (collectively “you”), as further detailed herein: 

“Visitor” shall mean any individual browsing our Website.

“User” shall mean an individual registering and opening an account (such as students using our Moodle platform), or registered to any other service or offer we provide through our Website.

4. WHICH DATA DO WE COLLECT AND FOR WHAT PURPOSE?  

“Non-Personal Data”: means data which can no longer, by reasonable means, be associated with any individual. Such data includes statistical and aggregated data, that is mainly technical data which is transmitted to us by your device or web browse when you access and interact with the Website. Such data includes the type of browser, type of operation system, type of device used, the time and date you access the Website, navigation, language preference, etc. Non-Personal Data is used mainly for technical analysis of the Website’s activity to provide, maintain, develop and enhance it, and is not used to identify individuals. Under this Privacy Policy, we can use Non-Personal Data with no limitation. That, even if such anonymized data was derived from Personal Data. Such data may be included in our proprietary information and does not deem as Personal Data under the law.

“Personal Data”: means, information which identifies or may identify, with reasonable effort, an individual. Such data includes, inter alia, your name, address, phone number, billing information and online identifiers (such as IP address or Cookie ID). 

Please see below the table which specifies the Personal Data we collect and how we use it:

Please note that, the actual processing operation per each purpose of use and lawful basis detailed in the table above, may differ. Such processing operation usually includes set of operations, made by automated means, such as collection, storage, use, disclosure by transmission, erasure or destruction. Transfer of personal data to third party countries as further detailed in the Data Transfer section is based on the same lawful basis as stipulated in the table above. 

In addition, we may use certain Personal Data to prevent potentially prohibited or illegal activities, fraud, misappropriation, infringements, identity thefts and any other misuse of Our service, as well as to protect the security or integrity of our databases and websites, and to take precautions against legal liability. Such processing is based on out legitimate interests. 

5. COOKIES USAGE

We use cookies to improve your experience while you use our services. We may use various types of Cookies:

• Essential Cookies – which are necessary for the Website to work properly (usually appears under our name/cookie tag);

• Functional Cookies – designated to save your settings on the Company Website - your language preference or other view preferences (also, under our name/cookie tag);

• Session Cookies – used to support the Company Website's functionality – such Cookies are stored only temporarily during a browsing session and are deleted from your device when you close the browser.

• Targeting Cookies - these cookies are used to collect information from you to help us improve our services and serve you with targeted advertisements that we believe will be relevant to you (e.g., Google’s Cookies). 

• Social networks Cookies - Social Plug-In Cookies (e.g., Facebook, Twitter, LinkedIn Cookies, or pixels, etc.) enable sharing your usage information with your social network’s accounts.

• Analytics Cookies - give us aggregated and statistical information to improve our services and further developing it e.g., Google analytics, Google Firebase Catalytic, etc. 

• Third-party services used by us – for example, an external service supporting our recruiting options through the Company Website (e.g., Comet or Workday), or an external service which allows us to screen short videos on the Website (e.g., YouTube or Vimeo).

Please note that the data collected by the use of Cookies may be linked to and combined with any other data, including Personal Data.

In addition, Cookie’s data is usually collected through the use of third-party services, like Google, Facebook, etc. In those cases, your Personal Data might be transferred to those third parties, which might link it and use it together with other information they have on you from other sources. Such data is “owned” and processed separately by those third-parties under their terms and conditions and the direct accounts or subscriptions you have with those third parties. For example, suppose you have a Facebook account, the Personal Data collected through Facebook’s Cookies on the Company Website might be linked to other data that Facebook collects from you as a Facebook user, and might be used by Facebook per the independent agreements between you and Facebook.

The specific cookies we currently use and your choices with regard to such use are detailed HERE.

6. HOW DO WE COLLECT INFORMATION

According to the nature of your interaction with our services, we may collect information as follows:

• Provided by you voluntarily – we will collect information if and when you choose to provide us with information, such as filing any contact form. 

• Automatically – we may use cookies and similar tracking technologies (as elaborated in the Cookies Section above) to gather some information automatically when you access the Company Website. 

• Provided to us by third parties – as part of our digital marketing efforts as described hereunder.  

7. DATA SHARING – CATEGORIES OF RECIPIENTS WE SHARE PERSONAL DATA WITH

We do not share any Personal Data collected from you with third parties or any of our partners except in the following events:

• Academic institutions: We may share Personal Data with various academic institutions as well as our business partners , if you specifically request us to provide them with your Personal Data or if you provide us with your explicit approval to share your information before the disclosure.

• Legal Requirement: We will share your information in this situation only if we are required to do so to comply with any applicable law, regulation, legal process, or governmental request (e.g., to comply with a court injunction, comply with tax authorities, etc.);

• Policy Enforcement: We will share your information, solely to the extent needed to (i) enforce our policies and agreements; or (ii) to investigate any potential violations thereof, including without limitations, detect, prevent, or take action regarding illegal activities or other wrongdoings, suspected fraud or security issues;

• Company’s Rights: We will share your information to establish or exercise our rights, to prevent harm to our rights, property, or safety, and to defend ourselves against legal claims, when necessary, subject to applicable law;

• Third Party Rights: We will share your information, solely to the extent needed to prevent harm to the rights of our customers, yourself, or any third party’s rights, property, or safety;

• Service Providers: we share your information with third parties that perform services on our behalf (e.g. customer service, tracking cookies, servers, service functionality, marketing, and support, etc.) these third parties may be located in different jurisdictions. 

• Corporate Transaction: we may share your information in the event of a corporate transaction (e.g. sale of a substantial part of our business, merger, consolidation or asset sale). In the event of the above, our affiliated companies or acquiring company will assume the rights and obligations as described in this Privacy Policy; 

• Authorized Disclosures: we may disclose your information to third parties when you consent to a particular disclosure. Please note that once we share your information with another company, that information becomes subject to the other company’s privacy practices. 

Where we share information with service providers and partners, we ensure they only have access to such information that is strictly necessary in order for us to provide the services. These parties are required to secure the data they receive and to use the data for pre-agreed purposes only, while ensuring compliance with all applicable data protection regulations.

8. DATA TRANSFERS

Any information you provide us may be transferred to and processed in countries other than the country from which you accessed our services. If you are a resident of the European Economic Area ("EEA") we will take appropriate measures to ensure that your Personal Data receives an adequate level of data protection upon its transfer outside of the EEA. If you are a resident of a jurisdiction where the transferring of your Personal Data requires your consent, then your consent to this Privacy Policy includes your express consent for such data transfer.

9. YOUR RIGHTS

Individuals have certain rights under applicable privacy laws with regards to their Personal Data. Subject to your jurisdiction (and additional conditions), these rights may include might include:

• The right to be informed –you have the right to be provided with information regarding our data collection and privacy practices, as detailed in this Policy. If you have any additional question, please contact us. 

• The right to access your Personal Data – you have the right to request a confirmation from us that we process your Personal Data, and in some cases, be provided with a copy of the Personal Data we process.

• The right of rectification - you have the right to require to update Personal Data which is not correct;

• The right to the erasure of your Personal Data – you have the right to require the erasure of certain Personal Data if specific conditions are satisfied. This right is not absolute. We may reject your request under certain circumstances, including where we must retain the data in order to comply with legal obligations or defend against legal claims, etc.;

• The right to restrict the processing of your Personal Data – you may be entitled to limit the purposes for which we process your Personal Data if specific conditions are satisfied;

• The right to object to the processing of your Personal Data – you have the right to object to the processing of Personal Data, in the event the basis for processing is our legitimate interests, however, we will be permitted to continue the processing if our legitimate interests override your rights, or when processing is necessary to establish, exercise or defend a legal claim or right, etc.; 

• Data portability – you have the right to have your Personal Data "port" to a third-party; 

• The right to file a complaint to a supervisory authority – specifically, with regards to Personal Data collected about you in the EEA or UK, please contact the applicable EU Data Protection Authority.

• The right to withdraw your consent – when the lawful basis for the processing of your Personal Data is your consent. For example, you may unsubscribe at any time from our mailing list.

You may exercise any or all of your above rights in relation to your Personal Data by contacting us through the contact information provided above.

Where we are not able to provide you with the information for which you have asked, we will endeavor to explain the reasoning for this and inform you of your rights, including the right to complain to the supervisor authority (in the event you are EEA resident). We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any such information in accordance with applicable law. 

10. RETENTION 

In general, we retain the Personal Data we collect for as long as it remains necessary for the purposes set forth above, all under the applicable regulation, or until you will express your preference to opt-out, where applicable. 

The criteria used by us to determine our retention periods are as follows: 

• We retain Personal Data for the periods needed in order to achieve the purpose for which Personal Data was collected

• We retain Personal Data for the periods needed in order to comply with our obligations under applicable laws. 

• If you have a dispute with us, we may retain certain types of Personal Data as necessary and applicable to your claims, including any legal proceedings between us, until such dispute was resolved, and following, if we find it necessary, in accordance with applicable statutory limitation periods. In addition, in the event you request to exercise your rights, we will maintain the applicable correspondence for as long as needed to demonstrate compliance. 

We may at our sole discretion, rectify or erase information from our systems, without prior notice to you, once we deem it is no longer necessary for such purposes.

11. SECURITY

We implement extensive security measures to reduce the risks of damage, loss of information and unauthorized access or misuse of Personal Data. We implement appropriate data collection, storage and processing practices and security tools to protect personal data against unauthorized access, alteration, disclosure or destruction. You should be aware that no security measures are completely fail-proof, and it is impossible to prevent any and all threats to the security of data and systems. Therefore, you should be aware that any processing of digital Personal Data holds certain inherent risks, and we cannot guarantee that our services and databases will be immune to any wrongdoings, malfunctions, unauthorized interceptions or access, malware attacks or other kinds of abuse and misuse.

12. CHILDREN

Our Website is not directed nor is it intended for use by children under the age of sixteen (16) and we do not knowingly process a child’s information. We will immediately discard any information that we receive from a visitor that is considered a child upon our discovery that such a visitor shared information with us. If you are under the age of eighteen (16), please be sure to read the terms of this Policy carefully with your parents or other legal guardians. Please contact us through the above means of contact if you have reason to believe that a child has shared any information with us.