Privacy Policy

UNITI SMART PRIVACY POLICY

[Last Updated: January 2022]

Uniti Smart LTD (“Company”, “we” or “us”) is the developer, owner and operator of a smart herbal storage hardware ("Product") and integrated app ("Uniti App" or "App" and collectively with the Product "System") and website [Amir – add link to the website] ("Website").

This privacy policy (“Privacy Policy”) explains Company's practices regarding the collection, storage, usage and disclosing of certain data, including Personal Data (as such term is defined below) from individuals who access and use our Website ("Visitor") and/or individuals who purchase the Company's Product, download and use the Uniti App (each a "User" and collectively with the Visitor "you").

This Privacy Policy constitutes an integral part of the Uniti Smart Terms of Use and any other agreement between you and the Company (“Terms”). Definitions used herein but not defined herein shall have the meaning ascribed to them in the Terms or in the relevant privacy protection regulation.

If you have any questions about this Privacy Policy, please contact us at: shmulik@unitismart.com

AMENDMENTS

We reserve the right to periodically amend or revise this Privacy Policy or any part herein, which will immediately affect the implementation of the revised Privacy Policy on our Website or App. The last revision date will be reflected in the “Last Updated” heading located at the top of this 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.

WHO ARE WE AND CONTACTING US

Uniti Smart Ltd [Amir – add below Company's address, Telephone and Email]

Tel:

Email:

Questions, comments, requests and complaints regarding this Privacy Policy and the information we hold are welcome and should be addressed to us by using the contact details above. All requests will be dealt with promptly and efficiently.

OUR EUROPEAN REPRESENTATIVE UNDER ARTICLE 27 TO THE GDPR

[DPR DESIGNATION - TBD]

DATA CONTROLLER / DATA PROCESSOR FOR GDPR PURPOSES

Under the European General Data Protection Regulation (”GDPR”), we are considered as the Data Controller of the Product’s Personal Data and any other personally identified information collected by or uploaded to the System automatically as part of the Product Usage or by the User directly. Also, we are the Controller of the Personal Data collected on the Website.

COLLECTION OF NON-PERSONAL DATA

We may collect aggregated, non-personal and non-identifiable information which may be made available or gathered via your use of the System or interaction with the Website (“Non-Personal Data“). We are not aware of the identity of the individual from which the Non-Personal Data is collected.

Also, we may sometimes process and anonymize or aggregate personal data and identifiable information in a manner that shall create a new set of data that will be considered as Non-Personal Data. Such a new data set can no longer be associated with any identified person.

Non-Personal Data may be used by us without limitation and for any purpose, including for commercial, research, or statistical purposes, without further notice to you.

COLLECTION OF PERSONAL DATA

During your use of the Website or the System, we will process individually identifiable information, namely information that identifies an individual or may with reasonable effort be used to identify an individual (“Personal Data” or “Personal Information” as defined under applicable law). This may include online identifiers, name, emails, etc., subject to applicable law.

If we combine Personal Data with Non-Personal Data, we will treat the combined data as Personal Data.

PROCESSING OF PERSONAL DATA – PURPOSES AND LAWFUL BASIS

In the table below we have included information about which data is processed, how we process and use your data and the lawful basis for which we do so subject to the GDPR.

The data we collect from our Users in the App, Product or Website:

Type of Data	Purpose of Processing	Lawful Basis	Processing Operations
As Part of Ordering a Product through the Website
If you wish to order and reserve the Product through the Website, you will be required to provide us with certain information: Identification and contact data: Full name, Email address, Username and password, etc. Account data: Name, Email, Age, Gender, etc. Transaction and Reservation data: your address and method of payment details;	To allow us to complete your reservation and provide you with product. Also, some data would remain and will be retained in our systems as part of our record keeping.	The fulfillment of the Contract between you and us – providing you with the Product you ordered. We will keep records of any transaction as part of our legitimate interest. That means that you can ask us in such cases to limit our use of such data. Also, some data will be retained by us under our legal obligations, such as financial record keeping.	We will process and keep the transaction data in our systems, use your payment information for completing the purchase, transfer your shipment information to our shipment partners and we will keep record of any such transaction as part of our business records, including in our financial systems.
As Part of Registering to the App and opening an Account in the system
Through the User's registration Process and opening an Account, the User will be required to provide the Uniti App with its contact details such his name,email address, username and password, or log in to one of his social media accounts. Also, the App may request you to provide us with additional demographic information, such as: Date of birth, body measurements, gender, habits, etc.	We will collect the Registration Information to designate your Account and allow you to use the App. In addition, we will use this data to adjust the Product, System and App for your needs and optimize your benefit from its use. Also, your email address will be used to contact you, to send you needed information related to our App (e.g., notify you regarding any updates to our App, etc.), promotional and marketing emails and any other information regarding your usage of the System.	Our processing of this data is necessary for performing our contract with you – meaning, we will use this information solely in order to open your Account as requested and provide you with the services therein. In the event we contact you for marketing purposes we will process your registration information subject to your consent (provided when you sign up), and you will be able to opt-out from receiving such marketing information an any time through a designated link provided in the applicable marketing email we sent you.	For opening an Account and subscribing to our services: collection of your data, storage, analysis of the data and customizing the System and the services for your characteristics and needs. We will also archive and save that data to allow the continuity of the services to you. For providing you with information we will use your data for email delivery. In addition, we may use your data to create an aggregated or de-idntified data set, which can no longer identifiy you, and therefore such new data set shall not be deemed as Personal Data
Data collected through the ongoing usage of the Product and System
Through your use of the System you will upload to the System certain information regarding your System usage or usage preferences, such as – your reviews regarding certain used herb specie and your herbs' weight. Also, the Product shall collect certain data automatically. Such data may be the weight of herbs, the humidity and temperature in the room around, etc.	We will collect the information provided voluntarily by you data to adjust our services for your needs and optimize your benefit from its use. As part of our services and per your authorization and free will, we will transfer such data to your applicable Dispenser for review and recommendations, including the offering of additional services. We also may use this data for upgrading and developing our services.	Our processing of this data is necessary for performing our contract with you – meaning providing you with the services as you requested. As for the transfer of your data to the applicable Dispenser, the lawful basis is your consent. As for improving and developing our services, the lawful basis for using your data for those purposes is the necessity of processing for our legitimate interests. We are using your data for those needs only after ensuring that such use is done in a minimal, secured, and where possible, de-identified manner.	Processing actions – data collection, storage, analysis (including big data analysis), usage optimization and customization, and record keeping of the data. We will also transfer some of your data to your applicable Dispenser through online transmission, where you have requested us to do so. As for improving and developing our services, we are doing so through the further AI and big-data analysis of your data, together with other Users’ data. We do so in a manner which is, to the extent possible, minimal and de-identified, in order to ensure that your identity itself is not inherently used for such improvement and development. Usage data is also being stored and recorded, and also analyzed in an aggregative and statistical manner to provide us with general insights regarding the use of our services. We may encrypt the data in our systems for security and confidentiality purposes.
When and if you will contact us with any inquiry or request as a User of the System
If you voluntarily contact us in any manner, whether for support, to submit a request or for other inquiries, whether by sending us an email or through other means of communications, e.g., any online form available on the System or designated interface in the App, you may be asked to provide us with your contact information such as your full name and email address. That, in addition to the inquiry subject and content.	We will use this data and our contact history solely to respond to your inquiries and provide you with the support or information you have requested. We will retain our correspondence with you for as long as needed, subject to applicable law.	The lawful basis for processing your information will be the contract between you and us, meaning we will use the data for addressing your requests and inquiries. After completing any such request, we will retain your information as part of our business records under our legitimate interest.	We are collecting your data, transmitting it to our system and storing it in it (including third party systems, e.g., CRM), and responding to you by email or any other means of contact provided by you. We also keep record of all our correspondence with you.
Online identifiers and other Technical Data
When you access or use our App, we may collect certain online identifiers, including your IP address. We may also collect technical Non-Personal Data transmitted from your device (e.g., actions in the App, your browser type, language used, type of operating system, type of device, etc.) and approximate geographical location (country).	We use this data for our legitimate interests of (I) operating, providing, maintaining, protecting, managing, customizing, and improving the App and how we offer it; (ii) enhancing your experience; (iii) auditing and tracking usage statistics and traffic flow; (iv) protecting the security of the System, as well as our and third parties’ rights (subject to applicable law requirements); and (v) advertising purposes.	Such processing is part of our legitimate interests as a commercial business. If we use third-party cookies on the App or collect online identifiers, we will obtain your consent if required under applicable law.	Collection of data, aggregation and statistical analysis, report generation, record keeping and storage.

The data we collect from our Website Visitors:

Type of Data	Purpose of Processing	Lawful Basis	Processing Operations
When accessing and using the Website
While accessing the Website you will be required to provide us with your Geo location (e.g. country).	We will collect such information in order to adjust the Website to your location and jurisdiction to offer you with applicable services relevant to your country.	Contract – we will collect and use such data only as provided directly and intentionally by you, to offer you with our relevant services.	We will adjust the website to offer you with the services relevant for your location.
“Contact Us” information through the Website
If you voluntarily contact us in any manner, whether for support, to submit a request or for other inquiries, whether by sending us an email or through other means of communications, e.g., any online form available on the Website, you may be asked to provide us with your contact information such as your full name and email address.	We will use this data and our contact history solely to respond to your inquiries and provide you with the support or information you have requested. We will retain our correspondence with you for as long as needed, subject to applicable law.	If you are not an active User of our services, and yet you will contact us with any request or inquiry, we will process and retain your data under our legitimate interest as part of our daily business conduct and after ensuring that your privacy and rights are kept. After completing any such request, we will retain your information as part of our business records under our legitimate interest.	We are collecting your data, transmitting it to our system and storing it in it (including third party systems, e.g., CRM), and responding to you by email or any other means of contact provided by you. We also keep record of all our correspondence with you.
Online identifiers and other Technical Data
When you interact with the Website, we may collect certain online identifiers, including your IP address. Also, we may collect some additional data through Cookies and similar technologies as explained below. We may also collect technical Non-Personal Data transmitted from your device (e.g., actions in the Website, your browser type, language used, type of operating system, type of device, etc.) and approximate geographical location (country). ** See additional information in our “Cookie Usage” part below	We use this data for our legitimate interests of (i) operating, providing, maintaining, protecting, managing, customizing, and improving the Website and how we offer it; (ii) enhancing your experience; (iii) auditing and tracking usage statistics and traffic flow; (iv) protecting the security of the Website, as well as our and third parties’ rights (subject to applicable law requirements); and (v) advertising purposes.	Such processing is part of our legitimate interests as a commercial business. If we use third-party cookies on the Website or collect online identifiers, we will obtain your consent if required under applicable law.	Collection of data, aggregation and statistical analysis, report generation, record keeping and storage.

COOKIES USAGE

Like many other websites, the Website and parts of our System use cookies to improve your experience while you navigate the through them. We may use various types of cookies:

Essential Cookies – which are necessary for the site to work properly (usually appears under our name/cookie tag);
Functional Cookies – designated to save your settings on the site - your language preference or other view preferences (also, under our name/cookie tag);
Session Cookies – used to support the 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 products and services and serve you with targeted advertisements that we believe will be relevant to you (e.g., Google’s AdSense or TagManager 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 the Website and System and further developing it e.g., Google analytics, Google Firebase Catalytic, Hotjar, etc.
Third-party services used by us – for example, an external service supporting our career and recruiting options through the Website (e.g., Comet or Workday), or an external service which allows us to screen short videos on our 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.

Also note, that cookie’s data is usually collected through third-party services, like Google, Facebook, etc. In those cases, your Personal Data might be transferred to those third parties, which might use it, as a “joint controller” of the data, meaning that the data is also “owned” and processed by them under their terms and conditions. Under those terms and conditions and the direct accounts or subscriptions you have with those third parties, your Personal Data might be linked to other data collected by the relevant third party and processed in its systems, for its purposes, and under its management. For example, suppose you have a Facebook account, the Personal Data collected through Facebook’s Cookies in our Website might be linked to other data Facebook collects and might be used by Facebook per the independent agreements between you and Facebook.

What Are Your Choices Regarding Cookies?

If you’d like to delete cookies or instruct your web browser to delete or refuse cookies, please visit the help pages of your web browser, or use the designated cookies bar in the Website.

Please note, however, that if you delete cookies or refuse to accept them, you might not be able to use all of the features we offer, you may not be able to store your preferences, and some of our pages might not display properly.

For the Chrome web browser, please visit this page from Google;

For the Internet Explorer web browser, please visit this page from Microsoft;

For the Firefox web browser, please visit this page from Mozilla;

For the Safari web browser, please visit this page from Apple.

For any other web browser, please visit your web browser’s official web pages.

Where Can You Find More Information About Cookies?

You can learn more about cookies and the following third-party websites:

All About Cookies: http://www.allaboutcookies.org/
Network Advertising Initiative http://www.networkadvertising.org/

SHARING DATA WITH THIRD PARTIES

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

Sharing of Data with an applicable Dispenser: As explained before, and as per your consent, we will share your usage and preferences data with your applicable Dispenser to allow him to optimize your treatment and usage of our services properly by providing you with your preferred herbs for example;
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 users, yourself, or any third party’s rights, property, or safety;
Business Purpose - we may disclose your personal information to a third party for a business purpose, as detailed above.
Service Providers – we share your information with third parties that perform services on our behalf (e.g. customer service, tracking, 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.

YOUR DATA SUBJECTS' RIGHTS UNDER PRIVACY PROTECTION LAWS

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 to them. Those rights might include:

right to access your Personal Data - you can ask us to confirm whether or not we have and use your Personal Data, and if so, you can ask for a copy of your data;
right to correct your Personal Data - you can ask us to correct any of your Personal Data that is incorrect, after verifying the accuracy of the data first;
right to erase your Personal Data - you can ask us to erase your Personal Data if you think we no longer need to use it for the purpose we collected it from you. You can also ask for such erasure in any case in which the process of your data was based on your consent, or where we have used it unlawfully, or where we are subject to a legal obligation to erase your Personal Data. any request for such erasure will be subject to our obligations under the law (e.g., our obligation to keep some records for tax or customs purposes);
right to restrict our use in your Personal Data - you can ask us to restrict our use of your Personal Data in certain circumstances;
right to object to how we use your Personal Data - you can object to any use of your Personal Data which we have justified by our legitimate interest if you believe your fundamental rights and freedoms to data protection outweigh our legitimate interest in using the information;
you can always require us to refrain from using your data for direct marketing purposes;
you can ask us to transfer your information to another organization or provide you with a copy of your Personal Data (Portability Right).

We may not always be able to do what you have asked. Also, not all those rights apply in every jurisdiction. Yet, we encourage you to contact us with any such request, and we will be happy to assist you.

You have the right to lodge a complaint at any time before the relevant supervisory authority for data protection issues. However, we will appreciate the chance to deal with your concerns before you approach the authorities, so please feel free to contact us in the first instance.

DATA RETENTION

Unless you instruct us otherwise and subject to applicable laws, we retain the information we collect for as long as needed to provide our services and to comply with our legal obligations, resolve disputes and enforce our agreements if applicable. Basically, and as a minimum, this means that your data will be retained for as long as you have an Account in our systems and use our services.

Also, and following the termination of your Account, we may keep some of your Personal Data as a user of our services for more extended periods for protecting our legal interests or under any safety or other legal requirements.

As for cookies data and technical marketing data, usually the data will be retained in an identified manner for periods of 14-36 months, subject to the relevant system. However, note that as explained before, once you delete the cookies from your device or otherwise restrict the use of cookies, we will have no linkage between your identity and your cookies data (yet, the third-party provider may have such data relating to you, under the separate terms between you and any such third party, e.g., Facebook’s terms of use as a user of Facebook).

SECURITY

We use physical, technical, and administrative security measures for the services that we believe comply with applicable laws and industry standards to prevent your information from being accessed without the proper authorization, improperly used or disclosed, unlawfully destructed or accidentally lost.

However, unfortunately, the transmission of information via the internet and online data processing cannot be 100% secure. As such, although we will do our best to protect your Personal Data, we cannot guarantee the security of data transmitted via the System and the Website, thus any transmission of your data shall be done at your own risk.

DATA PROCESSING LOCATION

We may store or process your Personal Data in a variety of countries, including the United States. Any transfer of data that 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, e.g.:

transfer to a country that is recognized as providing an adequate level of legal protection;
transfer under a proper agreement containing the Standard Contractual Clauses published and authorized by the relevant EU authorities;
where we can be satisfied that alternative arrangements are in place to protect your privacy rights through the use of any other mechanism under the GDPR.

It is important to note that we are headquartered in Israel, a country that the European Data Protection Board had provided with an adequacy decision, meaning Israel's legislation provides an adequate level of protection to Personal Data.

Suppose you are a resident of a jurisdiction where the transferring of your Personal Data requires your consent. In that case, your consent to this Privacy Policy includes your express consent for such transfer of your data.

LINKS TO OTHER SITES

Our 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 you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Website, we encourage you to read the privacy notice of every Website you visit.

CHILDREN

Our System and Website are not directed, nor is it intended for use by children (the phrase "child" shall mean an individual that is under age defined by applicable law which concerning the European Economic Area (“EEA “) is under the age of 16 and with respect to the U.S.A, under the age of 13) and we do not knowingly process a child’s information. We will discard any information that we receive from a user who is considered a "child" immediately upon our discovery that such a user shared information. Please contact us if you have reason to believe that a child has shared any information with us.

You must be of legal age to enter this site

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