Privacy Notice

We at Shamaym Improv Ltd. and our affiliate Shamaym – Social Business US Inc. ("Shamaym" or "we" or "our") recognize and respect the importance of maintaining the privacy of our customers and visitors to our Site. This Privacy Notice describes the types of information we collect from you when you visit our Site or use our Services. This Privacy Notice sometimes distinguish between two different Services we provide: our Original Shamaym Services and our MedInsight.ai Services. This Privacy Notice also explains how we process, transfer, store and disclose the information collected, as well as your ability to control certain uses of the collected information. If not otherwise defined herein, capitalized terms have the meaning given to them in the Terms of Service, available at www.shamaym.com/terms.

If you are an individual located in the European Union, some additional terms and rights may apply to you, as detailed herein. Certain data protection laws, including the laws in the EU, differentiate between a party that determines why and how personal data is processed (called a "controller") and a party that processes personal data solely on the controller's behalf and according to the controller's instructions (called a "processor"). Shamaym Improve Ltd. is the data controller in respect of the processing activities outlined in this Privacy Notice. Our registered office is 9 Jabotinsky St, Bnei Brak, Israel, and our registration number is 515181014. Shamaym Social Business US, Inc., a company incorporated under the laws of the State of Delaware, serves as a joint controller of your Personal Data. That said, in respect of certain personal data, we serve as a processor. Please see the section below on Personal Data We Collect as a Processor for more information. For further details regarding our arrangement with Shamaym Social Business US Inc. or if you have questions about your privacy or want to exercise your rights, please contact our data protection officer at help@shamaym.com.

"Personal Data" means any information that refers, is related to, or is associated with an identified or identifiable individual or as otherwise may be defined by applicable law. This Privacy Notice details which Personal Data is collected by us in connection with provision of the Site and Services.

Privacy Notice Key Points

The key points listed below are presented in further detail throughout this Privacy Notice. You can click on the headers in this section in order to find out more information about any topic. These key points do not substitute the full Privacy Notice.

• Personal Data We Collect, Uses and Legal Basis.
• Automated Decision-Making.
• Sharing the Personal Data We Collect.
• International Transfer.
• Security.
• Your Rights.
• Data Retention.
• Use of Cookies and Similar Technologies.
• Children.
• Third-Party Applications and Services.
• Communications.
• Changes to the Privacy Notice.
• Comments and Questions.

Personal Data We Collect, Uses and Legal Basis

Depending on your usage, we collect different types of data and we and any of our third-party sub-contractors and service providers use the data we collect for different purposes, as specified below. It is your voluntary decision whether to provide us with certain Personal Data, but if you refuse to provide such Personal Data, we may not be able to register you to the Site and/or provide you with the Services or part thereof.

• Contact Information – When you request information from us, or contact us for any other reason, we will collect any data you provide, such as your name, company, phone number, email address and the content of your inquiry.

How we use this data: To respond to your request or inquiry and to provide you with newsletters.

Legal Basis: We process this Personal Data based on performance of a contract when we respond to your inquiry and based on our legitimate business interests when we provide you with newsletters.

• Automatically Collected Data – When you visit the Site, we automatically collect information about your computer or mobile device, including non-Personal Data such as your operating system, and Personal Data such as IP address, device ID, as well as your browsing history and any information regarding your viewing and purchase history on our Site. For more information about the cookies and similar technologies we use and how to adjust your preferences, please see the section “Cookies and Similar Technologies” below.

How we use this data: (1) to review usage and operations, including in an aggregated non-specific analytical manner, develop new products or services and improve current content, products, and Services; (2) to prevent fraud, protect the security of our Site and/or Services, and address any problems with the Site and/or Services; (3) to provide you with customized content, and advertising related to our products and Services. Legal Basis: We process this Personal Data for our legitimate interests to develop and improve our products and Services, review usage, perform analytics, prevent fraud, for our recordkeeping and protection of our legal rights and to market our own products and services. Additional information regarding direct marketing is provided below.

Additional Uses

Statistical Information and Analytics

We and/or our service providers use analytics tools, including “Google Analytics” to collect and analyze information about the use of the Site and/or Services, such as how often users visit the Site, what pages they visit when they do so, and what other sites and mobile applications they used prior to visiting the Site. By analyzing the information we receive, we may compile statistical information across a variety of platforms and users, which helps us improve our Site and Services, understand trends and customer needs and consider new products and services, and tailor existing products and services to customer desires. The information we collect is anonymous and aggregated and we will not link it to any Personal Data. We may share such anonymous information with our partners, without restriction, on commercial terms that we can determine in our sole discretion. You can find more information about how Google collects information and how you can control such use at https://policies.google.com/technologies/partner-sites.

Statistical Information and Analytics

As described above, we may use Personal Data to let you know about our products and Services that we believe will be of interest to you. We may contact you by email or through other communication channels. In all cases, we will respect your preferences for how you would like us to manage marketing activity with respect to you. To protect privacy rights and to ensure you have control over how we manage marketing with you:

• We will take steps to limit direct marketing to a reasonable and proportionate level and only send you communications which we believe may be of interest or relevance to you.
• You can ask us to stop sending email marketing by following the "unsubscribe" link you will find on all the email marketing messages we send you. Alternatively, you can contact us at info@shamaym.com.
• You can change the way your browser manages cookies, which may be used to deliver online advertising, by following the settings on your browser as explained below. If our marketing activities are based upon your consent, you may withdraw this consent at any time.

Personal Data We Collect As Processor.

• We process certain personal data about our customers' end users, clients, customers, team members, or employees ("End User Data Subject") when we provide services to our customers. In that case, we serve as a processor and our customer serves as a controller. We process that data on behalf of the relevant customer and according to its instructions. If you are an End User Data Subject of one of our customers, we may process personal data about you that includes name, email address, or (for Medinsight.ai customers) medical records. We may share this data with the relevant customer. To learn more about our processing activities in this capacity or to exercise your privacy rights regarding them, please contact the applicable customer directly.
• Incident Description – On our Medinsight.ai platform, we receive descriptions of safety incidents from healthcare providers.

How we use this data: We use this data to send analyze specific event or aggregated events, including through third party gen-ai platforms and incident reports to local health authorities at our customers’ direction.

Legal Basis: We process this Personal Data based on performance of a contract when we provide you with services.

• Medical Records – Some of our MedInsight.ai customers may subscribe to an optional functionality which includes a dedicated API integration to electronic medical records systems. For customers that use this use-case, we receive pseudonymized medical records from healthcare providers which can only be linked to the individual using the unique identifier or ‘key’ provided to us by the healthcare provider. Our Shamaym product and services do not process medical records, and any reference to medical records in this Privacy Notice only applies to MedInsight.ai customers who opt-in to the aforementioned functionality.

How we use this data: We will only use these records when the data subject grants consent for us to do so, and then we will show the data subject the data in order to provide further Services.

Legal Basis: We process this pseudonymized data without any link to the data subject based on performance of a contract with the healthcare provider, and only link data to the data subject when provided consent by the individual data subject.

Automated Decision-Making. We process certain Personal Data using artificial intelligence algorithms in order to provide incident analysis, to improve our services, and to develop new products and services. We use generative AI in order allow our customers to ask questions about their data, analyze and automate the medical incidents reporting process (for customers who enable the specific Solution functionality), and provide insights. We may process pseudonymized medical records which we obtained from MedInsight.ai customers with these algorithms. We process names and ID numbers only for certain Original Shamaym Services users whose administrators have opted-in to provide this information. Third-party service providers such as AI-model providers may have access to such Personal Data.

Sharing the Personal Data We Collect

We share your information, including Personal Data, as follows:

We share information, including your Personal Data, with our subsidiary, Shamaym Social Business US Inc., who serves as a joint controller of your Personal Data, for the purpose of management of our business and to provide you with our Services.

We disclose information, including Personal Data we collect from and/or about you, to our trusted service providers and subcontractors, who have agreed to confidentiality restrictions and who use such information solely on our behalf in order to: (1) help us provide you with the Site and/or Services (including, as relevant, with AI capabilities); (2) aid in their understanding of how users are using our Site and/or Services; (3) for the purpose of direct marketing (see above for more details). Such service providers and subcontractors provide us with IT and system administration services, data backup, security, and storage services, data analysis and help us serve advertisements and provide other marketing services. We use third-party AI platforms belonging to OpenAI, Google, Twilio, Microsoft, and other LLMs and other providers to power our generative AI services. These vendors may process your Personal Data according to their own privacy policies. We recommend reviewing their privacy policies to better understand how your Personal Data may be used by these third parties.

Your Personal Data may be disclosed as part of, or during negotiations of, any merger, sale of company assets or acquisition (including in cases of liquidation). In such case, your Personal Data shall continue being subject to the provisions of this Privacy Notice.

We may share your Personal Data with third parties: (i) if we believe in good faith that disclosure is appropriate to protect our or a third party’s rights, property or safety (including the enforcement of the Terms and this Privacy Notice); (ii) when required by law, regulation subpoena, court order or other law enforcement related issues, agencies and/or authorities; or (iii) as is necessary to comply with any legal and/or regulatory obligation.

We may use your Personal Data as required or permitted by any applicable law, for example, to comply with audit and other legal requirements.

International Transfer

We use subcontractors and service providers and have affiliates who are located in countries other than your own, such as the US, and send them information we receive (including Personal Data). We conduct such international transfers for the purposes described above. We will ensure that these third parties will be subject to written agreements ensuring the same level of privacy and data protection as set forth in this Privacy Notice, including appropriate remedies in the event of the violation of your data protection rights in such third country. Whenever we transfer your Personal Data to third parties based outside of the European Economic Area ("EEA"), we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your Personal Data to countries that have been deemed to provide an adequate level of protection for Personal Data by the European Commission.
• Where we use certain service providers not located in countries with an adequate level of protection as determined by the European Commission, we may use specific contracts approved by the European Commission which give Personal Data the same protection it has in the EEA.
• Where we use service providers based in the US, we may transfer Personal Data to them if they have been certified by the EU-US Privacy Shield, which requires them to provide similar protection to Personal Data shared between the EU and the US or any other arrangement which has been approved by the European Commission or other body having jurisdiction to approve such arrangement.

Please contact us at help@shamaym.com if you would like further information on the specific mechanism used by us when transferring your Personal Data out of the EEA.

Security

We have implemented and maintain appropriate technical and organization security measures, policies and procedures designed to reduce the risk of accidental destruction or loss, or the unauthorized disclosure or access to Personal Data appropriate to the nature of such data. The measures we take include:
Safeguards – The physical, electronic, and procedural safeguards we employ to protect your Personal Data include secure servers, firewalls, antivirus, and SSL encryption of data.
Access Control – We dedicate efforts for a proper management of system entries and limit access only to authorized personnel on a need to know basis of least privilege rules, review permissions quarterly, and revoke access immediately after employee termination.
Internal Policies – We maintain and regularly review and update our privacy related and information security policies.
Personnel – We require new employees to sign non-disclosure agreements according to applicable law and industry customary practice.
Encryption – We encrypt the data in transit using secure protocols.
Database Backup – Our databases are backed up on a periodic basis for certain data and are verified regularly. Backups are encrypted and stored within the production environment to preserve their confidentiality and integrity, are tested regularly to ensure availability, and are accessible only by authorized personnel.
However, no method of transmission over the Internet or method of electronic storage is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security. As the security of information depends in part on the security of the computer you use to communicate with us and the security you use to protect user IDs and passwords, please take appropriate measures to protect this information.

Your Rights – How to Access and Limit Our Use of Certain Personal Data

Subject to certain exemptions, and in some cases dependent upon our processing activities, you have certain rights in relation to the Personal Data that we or our joint controllers hold about you, as detailed below. We will investigate and attempt to resolve complaints and disputes and make every reasonable effort to honor your wish to exercise your rights as quickly as possible and, in any event, within the timescales provided by applicable data protection laws. We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any information and/or comply with any of your requests, as detailed below:

• Right of Access. You have a right to know what Personal Data we collect about you and, in some cases, to have such Personal Data communicated to you. Subject to applicable law, we may charge you with a fee. Please note that we may not be able to provide you with all the information you request, and, in such case, we will endeavor to explain to you why.
• Right to Data Portability. If the processing is based on your consent or performance of a contract with you and processing is being carried out by automated means, you may be entitled to (request that we) provide you or another party with a copy of the Personal Data you provided to us in a structured, commonly-used, and machine-readable format.
• Right to Correct Personal Data. Subject to applicable law, you may request that we update, complete, correct or delete inaccurate, incomplete, or outdated Personal Data.
• Deletion of Personal Data (“Right to Be Forgotten”). You have a right to request that we delete your Personal Data if either: (i) it is no longer needed for the purpose for which it was collected, (ii) our processing was based on your consent and you have withdrawn your consent, (iii) you have successfully exercised your Right to Object (see below), (iv) processing was unlawful, or (v) we are required to erase it to comply with a legal obligation. We cannot restore data once it has been deleted. To ensure that we do not collect any further Personal Data, you should clear our cookies from any browse where you have visited our Site. We may retain certain Personal Data (including following your request to delete) for audit and recordkeeping purposes, or as otherwise permitted or required under applicable law.
• Right to Restrict Processing. You can ask us to limit the processing of your Personal Data if either: (i) you have contested its accuracy and wish us to limit processing until this is verified; (ii) the processing is unlawful, but you do not wish us to erase the Personal Data; (iii) it is no longer needed for the purposes for which it was collected, but we still need it to establish, exercise, or defend of a legal claim; (iv) you have exercised your Right to Object (below) and we are in the process of verifying our legitimate grounds for processing. We may continue to use your Personal Data after a restriction request under certain circumstances.
• Direct Marketing Opt Out. You can change your mind at any time about your election to receive marketing communications from us and/or having your Personal Data processed for direct marketing purposes. If you do, please notify us by contacting us at info@shamaym.com. We will process your request as soon as reasonably possible, however it may take a few days for us to update our records before any opt out is effective.
• Right to Object. You can object to any processing of your Personal Data that is based on our legitimate interests, if you believe your fundamental rights and freedoms outweigh our legitimate interests. If you raise an objection, we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms.
• Withdrawal of Consent. You may withdraw your consent in connection with any processing of your Personal Data based on your consent. This will not affect the lawfulness of any processing prior to such withdrawal.
• Right to Lodge a Complaint with Your Local Supervisory Authority. You may have the right to submit a complaint to the relevant supervisory data protection authority if you have any concerns about how we are processing your Personal Data. We ask that, as a courtesy, you please attempt to resolve any issues with us first.

Data Retention

Subject to applicable law, we retain Personal Data as necessary for the purposes set forth above. We may delete information without notice to you once we deem it is no longer necessary for these purposes. Retention by our processors may vary in accordance with the processor’s retention policy.
In some circumstances, we may store your Personal Data for longer periods of time, for instance where we are required to do so due to legal, regulatory, tax, audit, or accounting requirements and so that we have an accurate record of your dealings with us in the event of any complaints or challenges, or if we reasonably believe there is a prospect of litigation relating to your Personal Data or dealings. To determine the appropriate retention period, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data, and whether those purposes can be achieved through other means, as well as applicable legal requirements. Please contact us at info@shamaym.com if you would like details regarding the retention periods for different types of your Personal Data.

Cookies and Similar Technologies

We use cookies and similar technologies for a number of reasons, including to help personalize your experience. Third parties through which we provide the Services and/or our business partners may be placing and reading cookies on your browser or using web beacons to collect information in the course of advertising being served on different websites. When visiting this Site, you shall be notified of the use of and placement of cookies and other similar technologies on your device.

A cookie is a small piece of text that is sent to a user’s browser or device. The browser provides this piece of text to the device of the originating user when this user returns.

• A "session cookie" is temporary and will remain on your device until you leave the Site.
• A "persistent" cookie may be used to help save your settings and customizations across visits. It will remain on your device until you delete it.
• First-party cookies are placed by us, while third-party cookies may be placed by a third party. We use both first- and third-party cookies.

• We may use the terms “cookies” to refer to all technologies that we may use to store data in your browser or device or that collect information or help us identify you in the manner described above, such as web beacons or “pixel tags”.

We use cookies and similar technologies for a number of reasons as specified below. The specific names and types of the cookies, web beacons, and other similar technologies we use may change from time to time. However, the cookies we use generally fall into one of the following categories:

We use cookies of the following third parties on the Site:

Most Web browsers are initially configured to accept cookies, but you can change this setting so your browser either refuses all cookies or informs you when a cookie is being sent. In addition, you are free to delete any existing cookies at any time. Please note that some features of the Services may not function properly when cookies are disabled or removed.
By changing your device settings, you can prevent your device’s ad identifier being used for interest-based advertising, or you can reset your device’s ad identifier. Typically, you can find the ad identifier settings under “privacy” or “ads” in your device’s settings, although settings may vary from device to device. Adjusting these preferences does not mean you will no longer receive advertisements, it only means the advertisements that you do see will be less relevant to your interests.

Third-Party Applications and Services

All use of third-party applications or services is at your own risk and subject to such third party’s terms and privacy policies.

Children

We do not knowingly collect Personal Data from children under the age of sixteen (16). However, we note that our customers may provide us with personal data for our processing that may include information of End User Data Subjects who are children. In the event that you become aware that an individual under the age of sixteen (16) is directly using the Services without parental permission, please advise us immediately.

Changes to the Privacy Notice

We may update this Privacy Notice from time to time to keep it up to date with legal requirements and the way we operate our business, and we will place any updates on this page. Please visit this page every now and then to make sure you are familiar with the latest version. If we make material changes to this Privacy Notice, we will seek to inform you by notice on our Site or per email.

Comments and Questions

If you have any comments or questions about this Privacy Notice or if you wish to exercise any of your legal rights as set out herein, please contact us at info@shamaym.com.

Last updated: December 2024