Privacy Policy

Last Updated: August 27, 2020

In order to ensure transparency and give you more control over your Personal Data, this privacy policy (“Privacy Policy”) governs how we, Immunai Inc. and its affiliates and subsidiaries  (together, “Immunai” “we”, “our” or “us”) use, collect, and store Personal Data we collect or receive from or about you (“you”) such as in the following use cases:

  1. When you browse or visit our website, https://www.immunai.com (“Website”);
  2. When you make use of, or interact with, our Website
  1. When you contact us (e.g. customer support, partnership, need help, submit a request)
  1. When you attend a marketing event and provide us with your Personal Data and/or you give us your business card 
  2. When we use the Personal Data of our customers (e.g. contact details) 
  3. When we use the Personal Data of our partners, collaborators, doctors, researchers (e.g. contact details) 
  4. When we use the Personal Data of our service providers, consultants, vendors, finders, agents (e.g. contact details)  
  5. When you interact with us on our social media profiles (e.g., Twitter, LinkedIn) 

We greatly respect your privacy, which is why we make every effort to provide a platform that would live up to the highest of user privacy standards. Please read this Privacy Policy carefully, so you can fully understand our practices in relation to Personal Data. “Personal Data” or “Personal Information” means any information that can be used, alone or together with other data, to uniquely identify any living human being. Please note that this is a master privacy policy and some of its provisions only apply to individuals in certain jurisdictions. For example, the legal basis in the table below is only relevant for GDPR-protected individuals.

Important note: Nothing in this Privacy Policy is intended to limit in any way your statutory right, including your rights to a remedy or means of enforcement. 

Table of contents

  1. What information we collect, why we collect it, and how it is used
  2. How we protect and retain your Personal Data
  3. How we share your Personal Data
  4. Additional information regarding transfers of Personal Data
  5. Your privacy rights
  6. Use by children
  7. Interaction with third party products
  8. Log files 
  9. Analytic tools
  10. Specific provisions applicable under California privacy law
  11. Contact us

This Privacy Policy can be updated from time to time and, therefore, we ask you to check back periodically for the latest version of this Privacy Policy.  If we implement significant changes to the use of your Personal Data in a manner different from that stated at the time of collection, we will notify you by posting a notice on our Website or by other means.

  1. WHAT INFORMATION WE COLLECT, WHY WE COLLECT IT, AND HOW IT IS USED


Specific Personal Data we collect


Why is the Personal Data collected and for what purposes?


Legal basis (GDPR only, if applicable)


Third parties with whom we share your Personal Data 

Consequences of not providing the Personal Data

When you browse or visit our Website

Cookies, analytic tools and log files


For more information, please read our cookies policy https://www.immunai.com/cookie-notice




To operate, monitor and analyze the Website, to improve the Website, and provide you with certain  functionalities on the Website 


Consent


Legitimate interest (e.g. essential cookies)


3rd party platforms such as for the following purposes:


For more information, please read our cookies policy https://www.immunai.com/cookie-notice


Certain Website features may not be available 


Read more about the purposes of each cookie here https://www.immunai.com/cookie-notice


When you make use of, or interact with, our Website

When you contact us

  • Full name
  • Email address
  • Country of resident
  • Message / comments
  • Any other information that you decide to provide/supply us with

 



  • To process and answer questions
  • To process and answer commercial inquiries
  • To provide you support (e.g., bug issues)



Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract


Legitimate interest (e.g., to answer your query)


3rd party platforms such as for the following purposes:


  • Google – Email provider
  • Webflow – Website host

Cannot process, assist and answer  your  query


Cannot process and answer your commercial questions


Cannot provide you support

When you attend a marketing event and provide us with your Personal Data and/or you give us your business card

  • Full Name
  • Email address
  • Phone number
  • Company name
  • Any other information that you decide to provide/supply us with



  • To establish a business connection


Consent 


Legitimate interest (e.g. certain B2B discussions)


3rd party platforms such as for the following purposes:

  • Google cloud platform - cloud provider
  • Google – Email provider


Cannot establish a business connection 

When we use the Personal Data of our customers (e.g., contact details)

  • Full Name
  • Business email
  • Company name
  • Job title
  • Phone number
  • Number of employees
  • Any other data you decide to provide/supply us with 



  • To provide our products and services


  • To perform the applicable agreement


  • To comply with legal requirements 


  • To communicate with our customers


Processing is necessary for the performance of a contract to which our customer is a party.


Compliance with a legal obligation (e.g. tax laws, bookkeeping laws, etc.).


Legitimate interest (e.g. send you contract-related communications)

3rd party platforms such as for the following purposes:


  • Google cloud platform - cloud provider
  • Google – Email provider

Cannot provide the services and/or our products


Cannot perform the agreement


Cannot comply with relevant legal requirements


Cannot communicate with you


When we use the Personal Data of our partners, collaborators, doctors, researchers (e.g., contact details) 

  • Full name
  • Email address
  • Company or institute/organization  name
  • Role/position
  • Any other Information you decide to provide/supply us with



  • To perform the applicable agreement


  • To comply with legal requirements 


  • To communicate with our customers



Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract


Compliance with a legal obligation (e.g. tax laws, bookkeeping laws, etc.).


Legitimate interest (e.g. send the reseller, distributor, agent and/or finder contract-related communications)

3rd party platforms such as for the following purposes:

  • Google cloud platform - cloud provider
  • Google – Email provider



Cannot perform the agreement


Cannot comply with relevant legal requirements


Cannot communicate with you


When we use the Personal Data of service providers, consultants, vendors, finders, agents (e.g., contact details)  

  • Full name
  • Email address
  • Company or institute/organization  name
  • Role/position
  • Any other Information you decide to provide/supply us with



  • To contact our service providers


  • To perform the applicable agreement



Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract


Compliance with a legal obligation (e.g. tax laws, bookkeeping laws, etc.).


Legitimate interest (e.g. send the reseller, distributor, agent and/or finder contract-related communications)

3rd party platforms such as for the following purposes:

  • Google cloud platform - cloud provider
  • Google – Email provider



Cannot communicate with you


Cannot perform the agreement

When you interact with us on our social media profiles (e.g., Twitter, LinkedIn)

  • Full name
  • Any other data you decide to provide/supply 


  • To reply and/or respond to your request or question


Legitimate interest (e.g. to respond your questions)

3rd party platforms such as for the following purposes:

  • Google cloud platform - cloud provider
  • Google – Email provider

Cannot reply or respond to your request


Finally, please note that some of the abovementioned Personal Data will be used for detecting, taking steps to prevent, and prosecution of fraud or other illegal activity, to identify and repair errors, to conduct audits, and for security purposes. Personal Data may also be used to comply with applicable laws, with investigations performed by the relevant authorities, law enforcement purposes, and/or to exercise or defend legal claims. In certain cases, we may or will anonymize or de-identify your Personal Data. “Anonymous Information” means information which does not enable identification of an individual user, such as aggregated information about the use of our services. We may use Anonymous Information and/or disclose it to third parties without restrictions (for example, in order to improve our services and enhance your experience with them). 

  1. PERIOD OF STORAGE OF COLLECTED PERSONAL DATA 


  1. Personal Data. Your Personal Data (as described above) will be stored until we no longer need the information and proactively delete it or you send a valid deletion request. Please note that we will retain it for a longer or shorter period in accordance with data retention laws. We have an internal data retention policy to ensure that we do not retain your Personal Data perpetually.


  1. Cookies. This depends on the cookie in question. Some cookies (e.g. essential cookies) cannot be disabled. You may also control and delete these cookies through your browser settings. Read more in our cookie policy privacy@immunai.com.


  1. HOW WE PROTECT AND RETAIN YOUR INFORMATION 


  1. Security. We have implemented appropriate technical, organizational and security measures designed to protect your Personal Data. However, please note that we cannot guarantee that the information will not be compromised as a result of unauthorized penetration to our servers. As the security of information depends in part on the security of the computer, device or network you use to communicate with us and the security you use to protect your user IDs and passwords, please make sure to take appropriate measures to protect this information.


  1. Retention of your Personal Data. In addition to the retention periods mentioned above, in some circumstances we may store your Personal Data for longer periods of time, for example (i) where we are required to do so in accordance with legal, regulatory, tax or accounting requirements, or (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, or (iii) if we reasonably believe there is a prospect of litigation relating to your Personal Data or dealings. We have an internal data retention policy to ensure that we do not retain your Personal Data perpetually. Regarding retention of cookies, you can read more in our cookie policy https://www.immunai.com/cookie-notice


  1.  HOW WE SHARE YOUR PERSONAL DATA 


In addition to the recipients described above, we may share your Personal Data as follows:


  1. With our business partners with whom we jointly offer products or services. We may also share Personal Data with our affiliated companies. 
  2. To the extent necessary, with regulators, courts or competent authorities, to comply with applicable laws, regulations and rules (including, without limitation, federal, state or local laws), and requests of law enforcement, regulatory and other governmental agencies or if required to do so by court order;
  3. If, in the future, we sell or transfer, or we consider selling or transferring, some or all of our business, shares or assets to a third party, we will disclose your Personal Data to such third party (whether actual or potential) in connection with the foregoing events;
  4. In the event that we are acquired by, or merged with, a third party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer, disclose or assign your Personal Data in connection with the foregoing events; and/or 
  5. Where you have provided your consent to us sharing or transferring your Personal Data (e.g., where you provide us with marketing consents or opt-in to optional additional services or functionality).

If you want to receive the list of the current recipients of your Personal Data, please make your request by contacting us to privacy@immunai.com


  1. ADDITIONAL INFORMATION REGARDING TRANSFERS OF PERSONAL DATA 

 

  1. Storage: Google cloud – North Virginia – US 

  1. Access from Israel: Access from Israel is covered by the European Commission’s Adequacy Decision regarding Israel. You can read more here: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en.


  1. Internal transfers: Transfers within the Immunai group will be covered by an internal processing agreement entered into by members of the Immunai group (an intra-group agreement) which contractually obliges each member to ensure that Personal Data receives an adequate and consistent level of protection wherever it is transferred to. 


  1. External transfers: Where we transfer your Personal Data outside of EU/EEA (for example to third parties who provide us with services), we will obtain contractual commitments from them to protect your Personal Data. Some of these assurances are well recognized certification schemes for the protection of Personal Data transferred from within the EU to the United States.


  1. YOUR PRIVACY RIGHTS. 


  1. Rights: The following rights (which may be subject to certain exemptions or derogations) shall apply to certain individuals (some of which only apply to individuals protected by the GDPR):
  • You have a right to access Personal Data held about you. Your right of access may normally be exercised free of charge, however we reserve the right to charge an appropriate administrative fee where permitted by applicable law;
  • You have the right to request that we rectify any Personal Data we hold that is inaccurate or misleading;
  • You have the right to request the erasure/deletion of your Personal Data (e.g. from our records). Please note that there may be circumstances in which we are required to retain your Personal Data, for example for the establishment, exercise or defense of legal claims;
  • You have the right to object, to or to request restriction, of the processing;
  • You have the right to data portability. This means that you may have the right to receive your Personal Data in a structured, commonly used and machine-readable format, and that you have the right to transmit that data to another controller;
  • You have the right to object to profiling;
  • You have the right to withdraw your consent at any time. Please note that there may be circumstances in which we are entitled to continue processing your data, in particular if the processing is required to meet our legal and regulatory obligations. Also, please  note that the withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal;
  • You also have a right to request certain details of the basis on which your Personal Data is transferred outside the European Economic Area, but data transfer agreements and/or other details may need to be partially redacted for reasons of commercial confidentiality;
  • You have a right to lodge a complaint with your local data protection supervisory authority (i.e., your place of habitual residence, place or work or place of alleged infringement) at any time or before the relevant institutions in your place of residence. We ask that you please attempt to resolve any issues with us before you contact your local supervisory authority and/or relevant institution.


You can exercise your rights by contacting us at privacy@immunai.com. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly in accordance with applicable law or inform you if we require further information in order to fulfil your request. When processing your request, we may ask you for additional information to confirm or verify your identity and for security purposes, before processing and/or honoring your request. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive. In the event that your request would adversely affect the rights and freedoms of others (for example, would impact the duty of confidentiality we owe to others) or if we are legally entitled to deal with your request in a different way than initial requested, we will address your request to the maximum extent possible, all in accordance with applicable law. 

  1. USE BY CHILDREN 


We do not offer our products or services for use by children and, therefore, we do not knowingly collect Personal Data from, and/or about children under the age of eighteen (18). If you are under the age of eighteen (18), do not provide any Personal Data to us without involvement of a parent or a guardian. For the purposes of the GDPR, we do not intend to offer information society services directly to children. In the event that we become aware that you provide Personal Data in violation of applicable privacy laws, we reserve the right to delete it. If you believe that we might have any such information, please contact us at privacy@immunai.com

  1. INTERACTION WITH THIRD PARTY PRODUCTS 


We enable you to interact with third party websites, mobile software applications and products or services that are not owned or controlled by us (each a “Third Party Service”). We are not responsible for the privacy practices or the content of such Third Party Services. Please be aware that Third Party Services can collect Personal Data from you. Accordingly, we encourage you to read the terms and conditions and privacy policies of each Third Party Service.


  1. LOG FILES  

We use log files. The information inside the log files includes internet protocol (IP) addresses, type of browser, Internet Service Provider (ISP), date/time stamp, referring/exit pages, clicked pages and any other information your browser may send to us. We use such information to analyze trends, administer the Website, track users’ movement around the Website, and gather demographic information.

  1. ANALYTIC TOOLS  
  • Google Analytics. The Website uses a tool called “Google Analytics” to collect information about use of the Website. Google Analytics collects information such as how often users visit this Website, what pages they visit when they do so, and what other websites they used prior to coming to this Website. We use the information we get from Google Analytics to maintain and improve the Website and our products. We do not combine the information collected through the use of Google Analytics with Personal Information we collect. Google’s ability to use and share information collected by Google Analytics about your visits to this Website is restricted by the Google Analytics Terms of Service, available at https://marketingplatform.google.com/about/analytics/terms/us/, and the Google Privacy Policy, available at http://www.google.com/policies/privacy/. You may learn more about how Google collects and processes data specifically in connection with Google Analytics at http://www.google.com/policies/privacy/partners/. You may prevent your data from being used by Google Analytics by downloading and installing the Google Analytics Opt-out Browser Add-on, available at https://tools.google.com/dlpage/gaoptout/

We reserve the right to remove or add new analytic tools.

  1. SPECIFIC PROVISIONS APPLICABLE UNDER CALIFORNIA PRIVACY LAW
  1. Our California Do Not Track Notice: Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
  2. California Privacy Rights: California Civil Code Section 1798.83 permits our customers who are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please send an email to privacy@immunai.com. Please note that we will respond to one request per customer each year, unless otherwise required by law.
  3. Deletion of Content from California Residents: If you are a California resident under the age of 18 and a registered user, California Business and Professions Code Section 22581 permits you to remove content or Personal Information you have publicly posted. If you wish to remove such content or Personal Information and you specify which content or Personal Information you wish to be removed, we will do so in accordance with applicable law. Please be aware that after removal you may not be able to restore removed content. In addition, such removal does not ensure complete or comprehensive removal of the content or Personal Information you have posted and that there may be circumstances in which the law does not require us to enable removal of content.


  1. CONTACT US


If you have any questions, concerns or complaints regarding our compliance with this notice and the data protection laws, or if you wish to exercise your rights, we encourage you to first contact us at privacy@immunai.com.