Privacy Policy

Privacy Policy

This privacy policy (the “Privacy Policy”) applies to ReWalk Robotics Ltd., a limited company with registered offices at 3 Hatnufa st. Yokneam, Israel, incorporated and registered under the  law of Israel , together with all its subsidiaries (together “ReWalk Robotics”, “Us”, “We”, or the “Company”). ReWalk Robotics engages in the development and marketing of products intended for use in the rehabilitation of individuals with lower limb disability due to stroke, through websites, systems, physical products, mobile applications or any other services (the “Services”). 

This Privacy Policy describes the manner in which ReWalk Robotics handles and manages any information related to its clients and/or users of its Services (each, a “User” or “Users”). Such information may be subject to various legal requirements and obligations, including, but not limited to, the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (“GDPR”) and any other applicable laws or regulations governing the processing of personal data in the framework of the Services.

Contacting ReWalk Robotics / EU Representative

REWALK ROBOTICS acts as data controller and has appointed a Privacy Protection Associate (PPA).

The data protection officer and/or the EU Representative appointed by REWALK ROBOTICS shall be contacted by using the following information:

PPA: Ishay Tal
Address: 3 Hatnufa st. 6th fl. Yokneam, 2069203 Israel
Telephone: +972 4 959 0123
Email: ishay.tal@rewalk.com

EU Representative: Q-Site EU
Address: Gerrit Van der Veenstraat 84 HS, 1077 EL Amsterdam, Netherlands
Telephone: +31(0)20811-0550
Email: QsiteEU@qsitemed.com

Collection of Personal Identification Information

As part of its Services ReWalk Robotics may collect, maintain, store or process Personal Data or personal identification information from Users in a variety of ways, including, but not limited to, when Users visit ReWalk Robotics websites, register on such websites, fill out a form, sign a contract, purchase a product and in connection with other activities, use applications and benefit from Services proposed by ReWalk Robotics. Such personal identification information may include, as appropriate and relevant, name, date of birth, email address, mailing address, phone number, etc. in addition, and in some cases, the data may also include some medical information regarding the User health status. In addition, ReWalk Robotics may collect some usage data and marketing and communication data regarding its Users and websites visitors.  Some of this data and information may be collected through automatic means like cookies and similar technologies (please refer to the description below, under “Cookies Usage”).

Collection of Non-personal Identification Information

ReWalk Robotics may collect non-personal identification information about Users whenever they use a ReWalk Robotics website or application or other online service. Non-personal identification information may include technical information about Users means of connection, such as the operating system and the Internet service provider utilized, geographical information such as country of origin, behavioural information such as time spent on site, as well as further non-personal analytical data to improve customer experience, products and services.

ReWalk Robotics may also collect, use, and share aggregated data such as statistical or demographic data for any purpose, even if such data was derived from Users’ Personal Data, to the extent such data cannot be linked to any identified individual. Such anonymized or aggregated data, may be used by ReWalk Robotics as part of its Services and ongoing operations, including for research or statistical purposes, without further notice.

Each User recognizes and accepts that the performance of the Services may depend on the collection and processing of personal identification information and non-personal identification information. As a User, you do not have to provide ReWalk Robotics with your personal identification information, but in some cases, if you do not, it may mean that you won’t be able to use some of the Services. For example, ReWalk Robotics cannot provide you with any customer’s service and cannot treat any inquiry unless you will provide ReWalk Robotics with the relevant information for contacting you and responding to your inquiry. Similarly, ReWalk Robotics cannot provide you with any of its rehabilitation and/or exoskeleton products, unless you provide ReWalk Robotics with some medical information. 

Cookies and similar technologies

ReWalk Robotics may use cookies (including pixels, web beacons or any other similar technology) to improve the User’s experience in regard of the Services and website usage. Cookies are basically small files which are being implemented in User’s computer in order to gather a certain set of information used to customize the navigation and use of the Services, thus enabling certain unique functionalities. 

ReWalk Robotics may use various types of Cookies, including basic cookies designated for the proper and easy use of a website or system:

  • Essential Cookies – which are necessary for the site to work properly (usually appears under “ReWalk” cookie tag). Sometimes those cookies are just “Session Cookies” which are stored only temporarily during a browsing session and are deleted from your device when you close the browser.
  • Functional Cookies – designated to save your settings, such as language or other view preferences (also, under ReWalk Cookie tag).
  • Analytics Cookies – ReWalk Robotics may also use analytics cookies, which provide ReWalk Robotics with aggregated information which enables us to improve the way websites and systems works, usually through the use of Google analytics – a web analytics service. It is operated by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. The information generated by the cookie about your use of this website is usually transmitted to a Google server in the USA and stored there. ReWalk Robotics, as a website and systems operator have a legitimate interest in analysing user behaviour to optimize both its website and its advertising. 
  • Targeting Cookies – these cookies are used to collect information from any User to help ReWalk Robotics with serving the User with targeted advertisements relevant to them (e.g. Google’s AdWords Cookies). 

In addition, ReWalk Robotics may use social media cookies and plugins for improving Users experience and allowing the connectivity between its website and Services with the User’s social media accounts:

  • Facebook plugins and pixels (Like & Share buttons)
    Plugins for the social network Facebook, Facebook Inc., 1 Hacker Way, Menlo Park, California 94025, USA. The Facebook plugins can be recognized by the Facebook logo or the Like button on our site. For an overview of Facebook plugins, see https://developers.facebook.com/docs/plugins/.

When you visit our site, a direct connection between your browser and the Facebook server is established via the plugin. This enables Facebook to receive information that you have visited our site from your IP address. If you click on the Facebook “Like button” while you are logged into your Facebook account, you can link the content of our site to your Facebook profile. This allows Facebook to associate visits to our site with your user account. Please note that, as the operator of this site, we have no knowledge of the content of the data transmitted to Facebook or of how Facebook uses these data. For more information, please see Facebook’s privacy policy at https://www.facebook.com/policy.php.

If you do not want Facebook to associate your visit to our site with your Facebook account, please log out of your Facebook account.

  • Twitter plugin
    Functions of the Twitter service have been integrated into ReWalk Robotics’ website and app. These features are offered by Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA. When you use Twitter and the “Retweet” function, the websites you visit are connected to your Twitter account and made known to other users. In doing so, data will also be transferred to Twitter. We would like to point out that, as the provider of these pages, we have no knowledge of the content of the data transmitted or how it will be used by Twitter. For more information on Twitter’s privacy policy, please go to https://twitter.com/privacy.

Your privacy preferences with Twitter can be modified in your account settings at https://twitter.com/account/settings.

  • LinkedIn plugin
    ReWalk Robotics website uses functions from the LinkedIn network. The service is provided by LinkedIn Corporation, 2029 Stierlin Court, Mountain View, CA 94043, USA.

Each time one of our pages containing LinkedIn features is accessed, your browser establishes a direct connection to the LinkedIn servers. LinkedIn is informed that you have visited our web pages from your IP address. If you use the LinkedIn “Recommend” button and are logged into your LinkedIn account, it is possible for LinkedIn to associate your visit to our website to your user account. We would like to point out that, as the provider of these pages, we have no knowledge of the content of the data transmitted or how it will be used by LinkedIn.

More information can be found in the LinkedIn privacy policy at https://www.linkedin.com/legal/privacy-policy.

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

Managing cookies and opting out: aside from the essential and functional Cookies described above, you can always configure your browser to reject all cookies or notify you when a cookie is set, or use the “cookies bar” installed in the website to limit the use of cookies, but sometimes in that case, certain services, features, and functionality in our website may not be available to you.

How ReWalk Robotics Uses Collected Information

Principally, personal and non-personal identification information is used to provide the Users with the Services and to insure a full efficiency of the Services they have registered for or they requested in any other manner.

In this framework, ReWalk Robotics may collect and use Users’ personal and non-personal identification information for the following purposes:

  • To improve Services: Information Users provided will help ReWalk Robotics to respond to certain Users’ requests.
  • To personalize User experience: ReWalk Robotics may use non-personal identification information to understand how Users as a group use ReWalk Robotics Services.
  • To improve ReWalk Robotics ’s websites and other internet presence as well as other communication tools or tools for specific Services: ReWalk Robotics may use feedback that Users provide to improve its products and services.
  • To send periodic emails and other text messages and/or notifications: ReWalk Robotics may use the email address or mobile phone number provided by Users to respond to inquiries, questions, and/or other requests. If Users decide to opt-in to ReWalk Robotics notification list, they will receive periodic information that may include company news, updates, related product or service information, private sales, information from ReWalk Robotics service providers on joint projects etc. (the “Periodic Information Service”). For the case that, at any time, Users would like to unsubscribe from the Periodic Information Service, ReWalk Robotics includes detailed unsubscribe instructions at the bottom of each such email or other text message.

Legal Basis under the GDPR

As with respect to any personal identification information which is subject to the GDPR (personal identification information of Users residents of the EU), ReWalk Robotics will only process and use such information in accordance with the limitations set by the GDPR, i.e. when ReWalk Robotics have a Lawful Basis for such usage. Such Lawful Basis can be any of the following:

  • Processing actions which ReWalk Robotics need to take as part of a contract with a User – e.g. any action required for the fulfillment of an order or completion of any purchase, contacting a User per “Contact” form filled by them or subscribing a User to any Periodic Information Services.
  • Processing actions which are necessary to meet ReWalk Robotics’ responsibilities towards regulators, tax officials, law enforcement authorities, or otherwise required for meeting its legal responsibilities.
  • Where the use of your information is part of ReWalk Robotics’ legitimate interest as a commercial organization. For example, to operate and improve its services and to keep people informed about its products and services. In these cases, ReWalk Robotics will use any personal identification information at all times in a way which is proportionate and respects Users’ privacy rights, making sure that ReWalk Robotics legitimate interest is not overridden by Users’ interests or fundamental rights and freedoms.

In general, and as detailed above, ReWalk Robotics do not rely on consent as a legal basis for processing personal identification information.  Yet, in any case in which a User has provided consent to the processing of personal identification information, the User will always have the option to withdraw the consent by contacting ReWalk Robotics through the contact details provided above.

Protection of Personal Identification Information

ReWalk Robotics adopts appropriate data collection, storage and processing practices and security measures to protect against unauthorized access, alteration, disclosure or destruction of Users’ personal identification information within the limits of ReWalk Robotics’ role with respect to the relevant Services (as certain specific services may be rendered by third parties).

We take reasonable measures to ensure that any personal identification information data is being collected on an as needed basis in connection with the purposes set out in this Privacy Policy, and under strict minimalization requirements.

It is User’s sole responsibility to ensure the security and protection of any data transferred to ReWalk Robotics by the User, and ReWalk Robotics shall not be responsible for any such transfer made through an unsecured method (e.g. Email).

Sharing Personal Identification Information

ReWalk Robotics does not sell, trade, or otherwise transfer to third parties Users’ personal identification information. However each User accepts that his/her personal identification information can be transmitted to website hosting and editing partners and other sub-contractors who assist ReWalk Robotics in providing the Services, conducting its business, or servicing the User, so long as those sub-contractors undertake to process the information only according to ReWalk Robotics’ instructions and to comply with the applicable law regarding the protection of personal identification information. In addition, any such transfer will be made subject to contractual terms ensuring the security and protection of any personal identification information, in accordance with any legal requirements.

ReWalk Robotics may also release User’s personal identification information when it believes that such release is necessary to comply with the law, enforce its websites’ general terms of use, or protect its or others’ rights, property, or safety.

However, Users non-personal identification information may be provided to third parties for marketing, advertising, or other uses.

Data Retention 

ReWalk Robotics takes all reasonable measures to ensure that User’ personal data are processed for the minimum period necessary for the purposes set out in this Privacy Policy. The Personal Data will be retained by ReWalk Robotics according to the following criteria: 

  1. as long as REWALK ROBOTICS maintain an ongoing relationship with the User (e.g., where the User is a recipient of REWALK ROBOTICS’ services, or is lawfully included in REWALK ROBOTICS ’s mailing list and has not unsubscribed);
  2. as long as the User’ personal data are necessary in connection with the purposes set out in this Privacy Policy, for which REWALK ROBOTICS has a valid legal basis
  3. with the User’ prior consent, until the expiry of any additional retention period.

ReWalk Robotics undertakes to delete or to anonymise the User’ personal data upon expiry of the retention period as described above.

Data Processing Location

Any transfer of data which originates in the European Union (“EU”) to a country outside of the European Economic Area (EEA), shall be made in compliance with the provisions of chapter 5 of the GDPR. Such transfer can be made to countries which are recognized as providing an adequate level of legal protection or where ReWalk Robotics can be satisfied that alternative arrangements are in place to protect your privacy rights, e.g. signing a Standard Contractual Clauses which were published and authorized by the relevant EU authorities.

It is important to note that ReWalk Robotics are headquartered in Israel, a country which is considered by the European Data Protection Board to be offering adequate level of data protection regulation.   

Data subject rights

Under EU law, EU residents and individuals, have certain rights to apply to us to provide information or make amendments to how we process data relating them. Similar rights may be granted to Users under other jurisdictions. Those rights include:

  • right to access any personal identification data – any User can ask ReWalk Robotics to confirm whether or not ReWalk Robotics holds their personal identification data, and if so, the User can ask for a copy of their data.
  • right to correct personal identification data – any User can ask ReWalk Robotics to correct any of their personal identification data, which is incorrect, after verifying the accuracy of the data first.
  • right to erase personal identification data (the right “to be forgotten”) – any User can ask us to erase your personal identification data if you think ReWalk Robotics no longer need to use it for the purpose it has been collected for, or in any case in which the process of the data was based on consent, or if you believe ReWalk Robotics has used it unlawfully. Any such request for erasure will be subject to ReWalk Robotics obligations under the law (e.g. obligation to keep some records for tax or customs purposes), or any other lawful justification allowing ReWalk Robotics to keep the information.
  • right to restrict ReWalk Robotics use the personal identification data – any User can ask us to restrict the use of their personal identification data in certain circumstances.
  • right to object any use of personal identification data – any User can object to any use of their personal identification data which have been justified under a “Lawful Basis” of legitimate interest (see above) if the User believes their fundamental rights and freedoms to data protection outweigh ReWalk Robotics’ legitimate interest in using the information.
  • require ReWalk Robotics to refrain from using personal identification information for direct marketing purposes.
  • portability right – any User can ask ReWalk Robotics to transfer their personal identification information to another organization and/or provide them with a copy of their personal identification data.

For exercising any such User’s right, please contact us by sending an email to ishay.tal@rewalk.com. Those rights may only be exercised within the limits of any contractual or legal obligation. Each User has also a right to lodge a complaint with the supervisory authority from his country of residence, or from the country he is located when his personal data are collected. however, ReWalk Robotics will appreciate the chance to deal with any concern or inquiry before approaching the authorities, so please feel free to contact us in the first instance.

Links to other sites

ReWalk Robotics Website may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about the User or visitor. ReWalk Robotics do not control these third-party websites and is not responsible for their privacy statements. 

Acceptance of these terms

By using the Services, Users confirm their acceptance of this Privacy Policy. If a User does not agree with this Privacy Policy, ReWalk Robotics recommends to such User that he shall not use the Services. The continued use of the Services following the posting of changes to this Privacy Policy will be deemed as an acceptance of those changes.

Changes to this Privacy Policy

ReWalk Robotics has the discretion to update this Privacy Policy at any time. ReWalk Robotics will therefore revise the “last update date” at the bottom of this page. ReWalk Robotics encourages Users to frequently check this page for any changes. Users acknowledge and agree that it is their responsibility to review this Privacy Policy periodically and become aware of modifications.

Last updated Oct 2020

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