Last Updated: July 2023
We, at Everysight Ltd. (“we”, “us”, or “ours”), put great efforts in making sure that we secure personal information related to you and use it properly.
This policy explains our privacy practices for processing personal information related to you, when you use the Everysight smartglasses (“Device”), the companion applications provided by us (“App”), the www.everysight.com and if applicable, other domain names and sub-domains (collectively, “Sites”), the development kit and development portal (“Dev Kit”), and if any our data tracking, collection and management services or when you engage with us through other registration or contact channels (collectively with the Device, App, Sites and Dev Kit: “Services”).
The term “personal information” refers to information that identifies an individual or relates to an identifiable individual. For example, personal information is your name, email address, telephone number, and other contact details which you submit to us or that we collect.
We process personal information related to you subject to the terms of this policy. This policy does not apply to any third-party websites, services or applications, even if they are accessible through our Services.
This policy is an integral part of our terms of service, available at: https://everysight.com/legal/terms-of-service/ or, if applicable, of any other Services subscription agreement entered into between you (or the entity that you are acting on its behalf) and us (“Terms of Service”). Unless we define a term in this policy, all capitalized terms used in this policy have the same meanings as in our Terms of Service.
The summary of this policy will give you a quick and clear view of our practices. Please take the time to read our full policy.
A Summary of the Policy
The Personal Information Related to You that You Provide Us – We receive and store any information you enter on our Sites or give us in any other way. If you create an account, when you use the Services or Device or App, when you interact with us or when you purchase a product or Services from us using the online store. Such information includes personal information related to you, for example: name, company name, email address, password, your payment details and additional personal information related to you that you provide when you contact us.
The Personal Information Related to You that We Collect – We collect, including by using third parties' web analytics and session replay services, usage information about the time, type and manner of use of the Services.
The Personal Information Related to You that You Upload – You can upload content with personal information related to you and to others. Please use caution and do not upload personal information related to others without their appropriate consent.
What Do We Do with Personal Information Related to You? – We provide and maintain the Services, make it better, continue developing it and protect us, our customers and the Services from misuse and law violations.
Sharing Information with Others – We use service providers, for example, to process payments, provide support and send email messages. We will transfer information when we change our corporate structure, and we will share the information with our affiliated entities.
Disclosure of Information to Authorities – We will obey orders and other lawful requirements by authorities to disclose information.
Aggregated and Analytical Information – Aggregated data is not identifiable. We use it for legitimate business purposes. Read more.
Your Choice – We will give you choices about the ways we use and share personal information related to you, and we will respect the choices you make. At any time, you can unsubscribe our mailing lists or newsletters, by either clicking the ‘unsubscribe’ link within the emails you receive from us or by contacting us. Our Services do not currently respond to Do Not Track (DNT) signals.
Accessing Personal Information Related to You - At any time you can request access to personal information related to you that we keep.
Specific Provisions for U.S. Residents – If you reside in the United States, further terms apply to our processing in relation to your rights as a data subject under United States laws that govern the protection of privacy and personal information.
Specific Provisions for EU Residents – If EU data protection laws apply to the processing the processing of personal information related to you by us, then further terms apply.
Data retention – We retain data to provide the Services and for legitimate and lawful purposes, as further explained in the data retention section.
Transfer of Data Outside your Territory – The Services are cloud-based Services. We store and process information in various territories at our clients’ discretion and we will store them at additional sites, at our discretion. These service providers provide us adequate security and confidentiality commitments.
Information Security – We implement systems, applications and procedures to secure personal information related to you, to minimize the risks of theft, damage, loss of information, or unauthorized access or use of information.
Changes to this Policy – We will update our policy from time to time after giving proper notice.
Contact Us – Please contact our privacy team at: email@example.com for further information.
1. The Personal Information Related to You that You Provide
We receive and store any information you enter on our Sites or give us in any other way.
You provide with us information when you register to the Services through our Sites at: www.everysight.com or www.goeverysight.com, when you create an account, when you use the Device or App, when you interact with us or when you purchase a product or Services from us using the online store. Such information includes personal information related to you, for example: name, company name, email address, postal address, and phone number.
You may also provide us your gender, date of birth, and other information that is not considered personal information.
As a paying user of the Services, we will receive limited transaction details (for example, your name, the amount paid and the date of payment), from the payment service provider that processed your payment. Your payment details (such as credit card number) will be provided by you directly to the payment service provider for the purpose of processing your payment and will not be available to us.
When you contact us, or when we contact you, we will receive and process any personal information that you choose to provide us. At your sole discretion, you may choose to provide us with information regarding your use of the Device and App when you contact us.
We will combine personal information related to you which we collect through various sources (including through the Services).
2. The Personal Information Related to You That We Collect
We will collect, including by using third parties' web analytics and session replay services, usage information about the time, type and manner of your use of the Services. This information may include, for example: information regarding the Internet Protocol (IP) address and Geo-IP parameters, your activity events, non-personal usage statistics (e.g., time of usages, number of clicks on each link, etc.), crash reports, diagnostic logs, information regarding your browsing history and web activities, and other information regarding the use of the Services.
When you use the App it might record and collect information as received from the Device, and subject to your permission from your mobile regarding your use of the Device and App.
Like many websites, we use automated data collection tools such as “cookies”, clear gifs and/or similar technologies. For further information, please see the ‘Cookies and Other Tracking Technologies’ section of this policy.
3. The Personal Information Related to You That You Upload
The content you share or import to the Services, from third-party devices and services, for example from Facebook (“Data Source”), including any data, text, graphic, audio and audio-visual files, can include personal information. Such content that you import will be stored by us to make such third-party data available to you through the Services.
Please use caution when sharing such content and avoid any involuntary disclosure of personal information related to you, or disclosure of’ personal information related to others without their consent.
4. What Do We Do with Personal Information Related to You?
We use the personal information we collect and receive for the following purposes:
to provide you and others with the Services.
To enable the Services’ tools and features.
To enhance users’ experience with the Services.
to study and analyse the functionality of the Services and users’ activities.
to maintain the safety and security of the Services, to protect users’ health, and for training, administrative and legal purposes.
to analyse your use of the Services and to match such information with other information, for statistical and market analysis purposes.
for advertising and marketing purposes.
to provide support, customer care and to help us in any future dealings with you, for example by identifying your requirements and preferences.
to provide automatic updates of new versions of the Services.
where required by law or in connection with legal proceeding or disputes; and,
to maintain, test, research, and continue developing the Services.
We will use your email address to contact you, when necessary, to send you reminders and to provide you with information and notices about the Services. We will include commercial and marketing information about our Services in such communications.
We obey the law and expect you to do the same. If necessary, we will use personal information related to you to enforce our terms, policies and legal agreements, to comply with court orders and warrants, and assist law enforcement agencies, to collect debts, prevent fraud, misappropriation, infringements, identity thefts and any other misuse of the Service, and to take any action in any legal dispute and proceeding.
5. Sharing Personal Information with Others
5.1. Information We Share with Our Service Providers.
We do not sell, rent or lease personal information related to you. We will share personal information related to you with service providers and other third parties, if necessary to fulfill the purposes for collecting the information. Any such third party will be contractually bound to keep personal information related to you confidential and appropriately secure.
For example, we will use a service provider to manage our email messages transmission. We will also share necessary details with our ticketing service providers, and use a session replay service, to support and enhance your experience with the Services.
5.2. Information We Share at Your Request.
You can choose to download, copy and distribute data through the Services. You acknowledge sole responsibility for and assume all risk arising from your download, copy and distribution of such information. We will not be responsible for any consequences of any use or disclosure of personal information related to you by you or any third parties to whom you provide personal information.
If personal information related to you or other information you share through the Services contains information about other individuals (such as your family or friends), including personal information (such as names or photos), please ensure that you have the consent of those individuals before you share personal information related to them or provide it to us.
5.3. Information We Share with Our Affiliates.
We will also share personal information related to you with our affiliates. These mean companies within the Everysight group and include subsidiaries, sister-companies and parent companies, with the express provision that their use of personal information related to you will comply with this policy.
5.4. Information We Disclose for Protection.
We will report any content that you upload and share such personal information, if we believe, in our sole discretion that such content is unethical, illegal or abusive or may violate any third-party rights;
5.5. Information We Disclose in Connection with a Structural Change
Additionally, a merger, acquisition or any other structural change will require us to transfer personal information related to you to another entity, as part of the structural change, provided that the receiving entity will comply with this policy.
6. Disclosure of Information to Authorities
We will need to disclose personal information related to you, as we believe to be necessary or appropriate for the following purposes:
if required under applicable law, including laws outside your country of residence.
to comply with legal process.
in response to lawful requests by public authorities, including to meet national security or law enforcement requirements, or if such disclosure is required in order to respond to claims, legal process (including subpoenas).
to enforce our terms and conditions.
to protect our property, rights privacy, safety, interests or safety, or that of our affiliates, you or others.
to protect our operations or those of any of our Affiliates.
if we are involved in any discussions related to our corporate reorganization that require such disclosure ; and,
to allow us to pursue available remedies or limit the damages that we may sustain.
We will share personal information related to you only subject to the terms of this policy, or subject to your prior consent.
7. Aggregated and Analytical Information
We use standard analytics tools. The privacy practices of these tools are subject to their own privacy policies, and they use their own cookies to provide their service (for further information about cookies, please see the 'Cookies' section in this policy).
Opt-out of Ad Tracking. You can opt out of the collection and use of information for ad targeting by going to http://www.aboutads.info/choices or http://www.youronlinechoices.eu/ to limit collection through the Sites or by configuring the settings on your mobile device to limit add tracking.
We will also de-identify information related to you, so it may not be used to identify you we will use, shared and transfer such anonymous, statistical or aggregated information for legitimate business purposes. It has no effect on your privacy, because there is no reasonable way to extract data from such information that we or others can associate specifically to you.
8. Your Choice
We will give you choices about the ways we use and share personal information related to you, and we will respect the choices you make. At any time, you can unsubscribe our mailing lists or newsletters, by either clicking the ‘unsubscribe’ link within the emails you receive from us or by contacting us.
We collect and receive personal information related to you that we need for the purposes described in this policy. At any time, you can stop using the Services. Termination is subject to Terms of Service.
At any time, you can exercise your following rights options:
you can object to the disclosure of personal information related to you to a third party, other than to third parties who act as our agents to perform tasks on our behalf and under our instructions.
you can object to the use of personal information related to you for a purpose that is materially different from the purposes for which we originally collected such information, pursuant to this policy, or you subsequently authorized such use. You can exercise your choice by contacting us.
You can request that your account be terminated, and that personal information related to you be deleted by contacting us. Any termination of your account will involve deletion of your account information from our live databases and all the information and data stored for such account in the Services.
you may request a copy of the personal information that we store about you by contacting us.
When we delete personal information related to you that we have collected from or about you, it will be deleted from our active databases, but we will keep a reasonable number of copies in our archives. Although we will deactivate your account, we will continue to retain the personal information related to you for legitimate business purposes as set forth above.
We request and collect personal information that we need for the purposes that we describe in this policy. Following the termination or expiration of the Services, we will stop collecting any personal information from or about you. However, we will store and continue using or making available personal information related to you according to our data retention section in this policy.
Some web browsers offer a “Do Not Track” (“DNT”) signal to indicate your preference for tracking your activities on the Services or through cross-site online activities. These features are varied with no uniform or common standard adopted yet by industry groups or regulators. Therefore, our Services do not currently respond to DNT signals. We continue to monitor developments around DNT technology and the implementation of a standard.
If you wish to exercise any of your rights in relation to personal data related to you, including exercising your choices or opt-out rights, please send us an email to: firstname.lastname@example.org.
9. Accessing Personal Information Related to You
If you find that the information on your account is not accurate, complete or up-to-date, please provide us the necessary information to correct it.
At any time, you can contact us at: email@example.com and request to access the personal information related to you that we keep. We will ask you to provide us certain credentials to make sure that you are who you claim to be and will make good-faith efforts to locate personal information related to you that you request to access.
Under your right of access, you can obtain confirmation from us of whether we are processing personal information related to you, receive a copy of that data, so that you could:
verify its accuracy and the lawfulness of its processing.
request the correction, amendment or deletion of personal information related to you if it is inaccurate or if you believe that the processing of personal information related to you is in violation of applicable law.
We will use judgement and due care to redact from the data which we will make available to you, personal information related to others.
10. Specific Provisions for U.S. Residents
This section applies solely to all users and others who reside within the United States of America (U.S.). We adopted this section to comply with U.S. state privacy laws (“U.S. Privacy Laws”), and any terms defined under U.S. state privacy laws will have the same meaning when used in this section. This chapter supersedes any contradicting provisions under the other sections of this policy.
We have collected the personal information related to you which is described above under the sections 1-2 of this policy. Such information consists of the following categories:
Identifiers and personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with the Sites.
Commercial information, including products or Services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Geolocation data, namely your physical location or movements.
Inferences drawn from any of the above-mentioned information.
We obtain the categories of personal information related to you listed above from the following categories of sources:
Directly and indirectly from you and your activity on the Sites.
Third parties such as reliable service providers.
We use the personal information related to you that we collect or receive for the purposes mentioned under section 4 of this policy.
We disclose personal information related to you to third parties for business purposes as described above under sections 5-6.
Selling and Sharing Personal Information
We do not sell or share personal information. However, we engage third parties to provide us with services such as analytics, marketing automation and user experience and allow them to collect personal information on our Sites and Services.
We do not knowingly sell or share personal information of consumers who are under 16 years of age.
The categories of personal information collected by these third-parties in the preceding 12 months include identifiers, online activities and inferences drawn from such activities.
These third-parties do not pay us for collecting such information, but the right granted to them to collect personal information may be considered as disclosure for the purpose of sale or sharing for cross-context behavioral advertising. At any time, you can opt-out of the collection of personal information by our service providers by contacting us.
Your rights as a U.S. Resident
In addition to your rights under other sections under this policy, if you are a resident of the U.S., you are also entitled to the following specific rights under U.S. Privacy Laws, regarding personal information related to you:
Access to specific personal information and data portability rights – you have the right to request that we disclose certain information to you about our collection and use of personal information related to you over the past 12 months. Upon verification of your request, we will disclose to you:
The categories of sources for the personal information we collected about you.
Our business or commercial purpose for collecting that personal information.
The categories of personal information that we disclosed for a business purpose, and the categories of third parties with whom we disclosed that particular category of personal information.
The specific pieces of personal information that we collected about you.
If we disclosed personal information related to you for a business purpose, we will provide you with a list which will identify the personal information categories that each category of recipient obtained.
The categories of personal information we collected about you.
Deletion rights – you have the right to request that we delete any portion of personal information related to you. Upon confirmation of your request, we will delete such personal information related to you from our records, unless an exception under U.S. Privacy Laws applies.
Non-discrimination – you also have the right not to be discriminated against for exercising your rights under the CPRA.
Exercising Your Rights
To exercise the rights described above, please submit your request to us by sending an email message to: firstname.lastname@example.org. Only you or a person authorized to act on your behalf, may make a request related to personal information related to you. A request for access can be made by you only twice within a 12-month period.
The verifiable consumer request must provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative and describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with the requested personal information if we cannot verify your identity or authority to make the request and confirm the personal information related to you. We will only use the personal information provided in your request to verify your identity or authority to make the request.
We will do our best to respond to your request within 30 days of its receipt. If we require more time (up to additional 30 days), we will inform you of the reason and extension period in writing. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
Any disclosures we provide will only cover the 12-month period preceding receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable.
We do not charge a fee to process or respond to your request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will inform you of the reasons for such decision and provide you with a cost estimate before completing your request.
We will not require that you create an account in order to exercise your rights under this policy and we will not increase the cost, or decrease the availability, of our Services based solely on the fact that you have chosen to exercise one of your rights under U.S. Privacy Laws.
After receiving our reply, you may appeal our decision by contacting us. We will review your appeal and provide you with our answer and our explanation of the reasons for our decision(s) within 60 days of receiving it. We will also provide you with a link (to the extent available) where you may submit a complaint with the relevant Attorney General.
11. Specific Provisions for EU Residents
If EU data protection laws apply to the processing of personal information related to you by us, then the following terms apply:
Personal information as used under this chapter will also include “personal data”, as such term is defined under EU data protection laws.
We process personal information related to you for the following lawful grounds:
All processing of personal information related to you which are not based on the lawful grounds indicated below, are based on your consent.
We process your account and payment details to perform the contract with you.
We will process personal information related to you to comply with a legal obligation and to protect your and others' vital interests.
We will further rely on our legitimate interests, which we have good-faith belief that they are not overridden by your fundamental rights and freedoms, for the following purposes:
Communications with you, including direct marketing where you are our client or a user of our client, or where you contact us through our Sites and/or other digital assets.
Support, customer relations, service operations.
Enhancements and improvements to yours and other users' experience with our Services.
Fraud detection and misuse of the Services.
In addition to your rights under other sections in this policy, you have the following rights:
AT AMY TIME, CONTACT US IF YOU WANT TO WITHDRAW YOUR CONSENT TO THE PROCESSING OF PERSONAL INFORMATION RELATED TO YOU. PLEASE NOTE HOWEVER, THAT EXERCISING THIS RIGHT WILL NOT AFFECT THE LAWFULNESS OF PROCESSING BASED ON CONSENT BEFORE ITS WITHDRAWAL.
Request to delete or restrict access to personal information related to you. We will review your request and use our judgment, pursuant to the provisions of the applicable law, to reach a decision about your request.
If you exercise one (or more) of the above-mentioned rights, in accordance with the provisions of applicable law, you may request to be informed that third parties that hold personal information related to you, in accordance with this policy, will act accordingly.
You may ask to transfer personal information related to you in accordance with your right to data portability.
You may object to the processing of personal information related to you for direct marketing purposes. Additional information about this right is available under the Choice section in this policy.
You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affecting you.
You have a right to lodge a complaint with a data protection supervisory authority of your habitual residence, place of work or of an alleged infringement of the General Data Protection Regulation (EU) 2016/679 (“GDPR”).
A summary and further details about your rights under EU data protection laws, is available on the EU Commission's website at: https://ec.europa.eu/info/law/law-topic/data-protection/reform/rights-citizens_en.
Note that when you send us a request to exercise your rights, we will need to reasonably authenticate your identity and location. We will ask you to provide us credentials to make sure that you are who you claim to be and will ask you further questions to understand the nature and scope of your request.
If we need to delete personal information related to you following your request, it will take some time until we completely delete residual copies of personal information related to you from our active servers and from our backup systems.
Please note, however, that if we delete certain personal information related to you or if you object to the processing of personal information related to you, you may not be able to access all portions or features of the Services.
If you have any concerns about the way we process personal information related to you, you are welcome to contact our privacy team at: email@example.com. We will investigate your inquiry and make good-faith efforts to respond promptly.
If you are located in the EEA, please note that we have authorized the following party as our designated representative:
Our EU-GDPR representative according to Art. 27 of the GDPR is Rickert Rechtsanwaltsgesellschaft mbH, at Colmantstraße 15, 53225 Bonn, Germany and may be reached at firstname.lastname@example.org.
12. Data Retention
We retain different types of personal information for different periods, depending on the purposes for processing the information, our legitimate business purposes as well as pursuant to legal requirements under the applicable law.
For example, we will need to keep limited information about the payment transactions that you made for several years due to tax related requirements, for accounts settling, record keeping, archiving and legal issues.
We will maintain your contact details, to help us stay in contact with you. At any time before or after the termination of your account, you can contact our privacy team at: email@example.com and request to delete your contact details. Note that we may keep your details without using them unless necessary, and for the necessary period, for legal matters.
We will keep aggregated non-identifiable information without limitation, and to the extent reasonable we will delete or de-identify potentially identifiable information, when we no longer need to process the information.
In any case, as long as you use the Services, we will keep information about you, unless the law requires us to delete it, or if we decide to remove it at our discretion, according to the terms of this policy.
13. Transfer of Data Outside Your Territory
The Services are web-based Services. We store and process information in, Israel, the US and the EU. From time to time, we will make operational decisions which will have an impact on the sites in which we maintain personal information. We make sure that our data hosting service providers, provide us with adequate confidentiality and security commitments.
If you are a resident in a jurisdiction where transfer of personal information related to you to another jurisdiction requires your consent, then you provide us your express and unambiguous consent to such transfer. You can contact our privacy team at: firstname.lastname@example.org for further information about data transfer.
If you are located in the European Economic Area (EEA), note that we will transfer personal information related to you to other jurisdictions, which are not deemed to provide an adequate level of data protection. In such case, we will use appropriate safeguards, in particular, by way of entering into the European Union (EU) Standard Contractual Clauses as amended from time to time with the relevant recipients, or by adhering to equivalent data transfer regulations to protect the security and confidentiality of such personal information. You can obtain a copy of the suitable safeguards that we use when transferring personal information as described above or receive further information about data transfer by contacting us at: email@example.com.
We make sure that our third-party service providers provide us with adequate confidentiality and security commitments and we will take all steps reasonably necessary to ensure that personal information related to you is treated securely and in accordance with this policy.
14.. Cookies and Other Tracking Technologies
15. Information Security
We and our hosting services implement systems, applications and procedures to secure personal information related to you, to minimize the risks of theft, damage, loss of information, or unauthorized access or use of information.
These measures provide sound industry standard security. However, please understand that no security system is impenetrable, and although we make efforts to protect your privacy, we cannot guarantee that the Services will be immune from any wrongdoings, malfunctions, unlawful interceptions or access, or other kinds of abuse and misuse.
16. Changes to this Policy
From time to time, we will update this policy.
If the updates have minor (if any), consequences, they will take effect 10 days after we post a notice on the Sites. Substantial changes will be effective 30 days after our we initially posted the notice.
Until the new policy takes effect, if it materially reduces the protection of your privacy right under the then-existing policy you can choose not to accept it and terminate your use of the Services. Continuing to use the Services after the new policy takes effect means that you agree to the new policy. Note that if we need to adapt the policy to legal requirements, the new policy will become effective immediately or as required by law.
17. Contact Us
Please contact our Privacy Team at: firstname.lastname@example.org for further information.