Privacy Policy

Introduction

We, Silla Health Ltd ("Silla"), are committed to protecting the privacy of our users. We gather certain information and/or data about users when they interact with our websites/apps (the "Service") and this Privacy Policy explains what information is gathered, how it is used, Silla's commitment to protecting it and more.

This Privacy Policy applies to all Information (as defined below) gathered through the Service by whatever means and for whatever reason the Service is used, irrespective of how the Service is accessed.

This policy will remain in full force and effect even if your use of the Services terminates, expires, ceases, is suspended or deactivated for any reason.

If you do not agree with this Privacy Policy, please do not use the Service.

Information Collected

We collect Personal Information from the individuals who use the Service, either as visitors, registered users ("Silla Clients") or patients that are invited to particpate in the surveys that we manage on behalf of Silla Clients ("Survey Participants").

We may contact you as a Survey Participant on behalf of Silla Clients, using their branding and email addresses. In such cases, Silla has been permitted by the Silla Client to contact you and Silla acts as the Data Processor ("Data Processor") on behalf of the Silla Client ("Data Owner").

When we use the term "Personal Information" we mean information that would let someone identify you or contact you, such as your full name, postal address, e-mail address or telephone number. When we use the term "Other Information", we mean any information other than Personal Information that may be collected about you, including, but not limited to, Tracking Technologies (as that term is defined below). Any Personal Information that is modified to remove or anonymize your contact information and other information that identifies you shall not be treated as Personal Information but shall be treated as Other Information after such modification. On the other hand, when we combine Other Information with Personal Information, we shall treat the combined Information as Personal Information for purposes of the sharing or disclosure of such combined Information. (Personal Information and Other Information, together, the "Information").

Information that You Provide to Us

To the extent we offer user registration on the website, you may be required to select a username and/or password ("Login Credentials") and may be required to also provide other Information, such as your email address and date of birth. Additional Information may be requested during the registration process (but not required).

We may also provide you with access to certain features or functions that we may offer on the website, such as the option to subscribe to newsletters, marketing or promotional emails and other periodic information, chat rooms, message boards, shopping and member profile pages. To sign up for or participate in these features or functions, you may be required to provide us with certain Information about you in order for us to personalize and/or let you use such features and functions.

There may be a separate registration process to enter promotions which may require Personal or Other Informaiton. The promotion's entry page and/or rules shall provide the specific requirements.

Information Collected Through Tracking Technologies

The website and/or third parties may use "cookies", "web beacons", Flash local shared objects and other similar tracking technologies (collectively, "Tracking Technologies") to collect Other Information automatically as you browse the website and the web.

We use Tracking Technologies to help tailor our content, let users move between associated sites without logging into each website, understand website and internet usage, improve or customize the content, offerings or advertisements on this website, personalize your experience on this website (for example, to recognize you by name when you return to the website, to store your selected country, and to display your recent website search results), save your password in password-protected areas, save your settings, help us offer you products, programs or services that may be of interest to you (for example, to understand your interactions with email messages such as the links clicked on and whether the messages were opened or forwarded), maintain and administer the website and for other purposes described below. These Tracking Technologies collect "click stream" data and additional Other Information regarding your visits to the website, such as your visits to the website's webpages, type of browser use, type of operating system used, date and time of viewing, use of our features, and purchasing history or preferences. Through these Tracking Technologies, we may collect Other Information across multiple sessions on this website and other websites, applications or other interactive services offered by third parties and may also collect your IP address (which is automatically assigned to any Device(s) and/or Device and Internet browser combination you use to access the website) and/or set some other identifier unique to the Device(s) and/or Device-Internet browser combination you use to access the website ("Identifier"). Your Personal Information is not collected as part of this process, but we may combine any or all of the Other Information we collected using Tracking Technologies and associate it and/or Identifiers with your Personal Information.

We use Tracking Technologies to enable us to collect and then use Information as described in the "How Is Collected Information Used" section below.

This website may additionally use a variety of third party data exchanges, data management platforms, supply side platforms, ad exchanges, traffic or audience measurement service providers, marketing analytics service providers, operational service providers (as defined below) and other third parties (collectively, "Third Party Service Providers") to, for example, facilitate targeting of content ("Targeting Services") and/or measure and analyze effectiveness and/or traffic on the website. Targeting Services enable us to, among other things, help deliver content to you for products and services that you might be interested in based on your visits to the website and other websites, application or other interactive services you have visited.

Third Party Service Providers may themselves set and access their own Tracking Technologies on your Device subject to your choices about those Tracking Technologies and/or they may otherwise collect or have access to Information about you and your online activities over time and across different websites when you use the website.

We may also enlist the assistance of Third Party Service Providers so that the website may set Tracking Technologies.

Except to the extent necessary to provide services to the website, Third Party Service Providers do not have access to Tracking Technologies set by the website, but we may provide to Third Party Service Providers certain Other Information collected by Tracking Technologies set by the website in order for the website to provide Targeting Services or in order for the Third Party Service Providers to provide other services to the website, such as measuring or analyzing content effectiveness or traffic on the website. For example, in order to analyze traffic on the website, we may provide to our Third Party Service Providers certain information we collect about your interaction with the website along with an Identifier so that the Third Party Service Provider may provide analytics services to the website.

How Collected Information Is Used

As set forth in this Privacy Policy, we may share Information with other parties (including Affiliates).

Personal Information

We use the Personal Information we collect from you in a variety of ways, including:

Processing your registration with the website, such as verifying that your email address is active and valid;
Contacting you regarding the administration of your account, any services, features or functions you have enrolled in or registered to use, any Promotions you have participated in or have entered, any goods and/or services you have ordered or any other transactions you have undertaken with the website;
Allowing you to participate in various areas/features of the website;
Responding to your questions or other requests;
Contacting you regarding your use of the website, for informational purposes related to the website or, in our discretion, regarding changes to the website's policies;
Improving the website or our services and for internal business purposes;
Tailoring your experience on the website and/or otherwise customizing what you see when you visit the website;
Sending newsletters, marketing or promotional emails relating to goods/services that may be of interest to you, whether provided by us or third parties;
Saving your login credentials or other Personal Information, so you don't have to re-enter it each time you visit the website;
Otherwise to maintain and administer the website and
For other purposes disclosed at the time you provide the Personal Information (for example, as set forth in the Rules for any Promotions you enter).

Other Information Collected by Us

We use the Other Information we collect from you in a variety of ways, including:

Accumulating and reporting aggregate, statistical information in connection with the website and user activity;
Determining which features, webpages, products and services users like best to, among other things, help us operate the website, applications or other interactive services, enhance and improve our services and the website and/or other websites, application or other interactive services and marketing information;
Preparing statistics reports;
Allowing you to participate in various areas/features of the website;
Improving our services, the website, application or other interactive services and for internal business purposes (for example, to assess the appeal of certain content to our general website audience and to understand your interactions with email messages we send, such as the links clicked on within marketing and promotional emails we send and whether such messages were opened or forwarded);
Personalizing your experience on, and/or otherwise customizing what you see when you visit, the website, application or other interactive services and/or third party sites, applications or other interactive services (e.g. to provide recommendations on content of more interest to you);
Saving certain Other Information for use on your return visits to the website and making your experience on this website more convenient for you (e.g. to apply certain settings or preferences you have identified, to store your selected country and to display your recent website search results);
Using characteristics that you enter about yourself, such as age or gender, for personalizing the content that you see when you visit the website, applications or other interactive services or third party websites, applications or other interactive services, whether alone or in combination with other Information;
Maintaining and administering the website;
For the uses described for "Personal Information" above and
For other purposes disclosed at the time you provide the Other Information.

Other Information Collected by Third Party Service Providers.

The use of Tracking Technologies by Third Party Service Providers is within their control and not ours. Even if we have a relationship with the Third Party Service Provider, we do not control their websites, applications or other interactive services or their policies and practices regarding your Information and you should be aware that different rules might apply to the collection, use or disclosure of your Information by third parties in connection with their advertisements or promotions and other sites, applications or other interactive services you encounter on the Internet. This Privacy Policy does not cover any use of Information that a Third Party Service Provider may directly collect from you. Use of Third Party Service Providers' Tracking Technologies is governed by the Third Party Service Providers' own specific privacy policies and not this Privacy Policy. However, please see the "Your Choices" section for more information on how to opt-out of the collection and/or use of Information collected by certain Third Party Service Providers.

Your Choices

You may opt out of receiving newsletters, marketing or promotional emails from the website at any time by using the opt-out mechanism that is contained in each such email and by any other additional methods that the website may provide.

Please note that, if you deactivate your registration as a member of the website, you shall continue to receive newsletters, marketing and promotional emails from the website unless you subsequently exercise your opt-out options above.

However, even if you exercise your opt-out rights above, we may continue to contact you for the other purposes described in the "How Collected Information Is Used" Section above, such as for maintenance and administrative purposes.

With respect to the Tracking Technologies set by the Website or Third Party Service Providers, we do not have any way for you to opt-out of them individually. You can, however, prevent the use of certain Tracking Technologies for a particular Device and/or Internet browser by using the controls provided by the Device and/or Internet browser.

Note that your choices shall only apply to the specific Device and Internet browser combination. For example, if you disable browser cookies on Internet Explorer 9 on one Device, this choice shall not disable browser cookies when you use Mozilla Firefox on the same Device or on a different Device using Internet Explorer 9.

Some Device manufacturers and/or browsers may preset their browser to automatically disable browser cookies from websites, applications or other interactive services other than those you visit directly (sometimes referred to as third party cookies) and, if so, the opt-out choices you have exercised with regard to third parties may not function and you may need to enable third party cookies in order for your opt-out choices to function.

Web beacons cannot be deleted or disabled using the above opt-out options, but may be affected if such web beacons rely on browser cookies or other deleted or disabled Tracking Technologies to track your activities.

In addition to the above, if you delete or disable Tracking Technologies set by the website, unless we offer alternative means to enable such functionality, the website may no longer be able to offer certain features or functionality to you, potentially making such features/functionality inoperable.

Some web browsers may transmit "do-not-track" signals to the websites with which the browser communicates. Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they even are aware of them. There currently is disagreement, including among participants in the leading Internet standards-setting organization, concerning what, if anything, websites should do when they receive such signals.

We currently do not take action in response to these signals, but, if and when a final standard is established and accepted, we may reassess how to respond to these signals.

Sharing and Disclosure of Information

With the exception of the following circumstances, we do not sell, rent, lease or disclose your Personal Information to third parties:

To administer and maintain the website's services, features, functions and operations. We refer to these third parties as "operational service providers" and we use them to efficiently provide the full range of content, activities, services, features and functions we bring you and we disclose your Information to operational service providers for the purpose of providing services to us.
When we are compelled to do so by a governmental agency, court or other entity (e.g., to respond to subpoenas, court orders or legal process) or if requested by a governmental agency or other authority as part of an investigation;
If we believe your actions violate any law, rule, regulation and/or the Terms of Service, including, without limitation, this Privacy Policy or Additional Terms;
In connection with Promotions, as necessary to administer the Promotion or as required by applicable laws, rules or regulations (for example, to provide winners' lists or make required filings as appropriate);
If you opt-in or otherwise agree to have your Personal Information shared with or otherwise disclosed to a third party for marketing or other purposes, in which case the third party's use of your Information is subject to the third party's own privacy policy;
If, in our sole discretion, we believe such disclosure to be necessary or appropriate: to investigate or resolve possible problems or inquiries; to protect our business and assets or the rights, property, or any of our operational service providers, licensors, suppliers, advertisers, customers, users, or any other party; to limit our legal liability; to defend our interests; to enforce this Privacy Policy or the Terms of Service and/or to comply with our legal, regulatory, audit and compliance obligations or requests by law enforcement or other governmental agencies or authorities and/or
In the event of a bankruptcy, merger, acquisition, sale, transfer of control, joint venture or other business combination involving us.
if you consent to such disclosure at the time you provide the Personal Information or as described in this Privacy Policy

We may share Other Information with or otherwise disclose Other Information to third parties, but we do not disclose Personal Information to them except as described in this Privacy Policy.

Reviewing, Updating or Deleting Information

Generally, you may review, update or delete certain Information collected by the website, if you are a registered user of the website and logged into the website. Some Personal Information, however, that is necessary to check eligibility, such as date of birth or age, cannot be deleted, but may be modified with sufficient verification of the correct information. We will let you change the password portion of your login credentials, as well as certain other Information you have given us in order to keep your information current.

If the burden or expense of providing access to your Information is disproportionate to the risks to your privacy or if the legitimate rights of others would be violated, we may decide not to provide access to such Information in accordance with the Data Protection Act. In such cases, we will provide to you an explanation of why access cannot be provided and contact information for further inquiries.

If we, inadvertently send an email or text message to a person that does not meet the age and other eligibility requirements of the website, such as a child (a person under the age of 13) or others who do not meet the greater age requirements of the website or certain features of this website ("Ineligible Teenagers"), the child (or Ineligible Teenager) or the child's (or Ineligible Teenager's) parent or legal guardian (the "Parent") always has the right to unsubscribe (opt-out) from receiving future emails or text messages via the unsubscribe mechanism contained in the email or message. The same unsubscribe process is available to a parent or legal guardian of a minor (a person under the age of 18, or the age of majority in your state or country). In addition, Parents of children or Ineligible Teenagers who wish to terminate their child's or Ineligible Teenager's membership can do so by contacting us.

We will not allow direct access to a user's account and Personal Information by any person without the user's login credentials.

Protection of Information

While no data transmission over the Internet is 100% secure from intrusion, we maintain commercially reasonable physical, electronic and procedural safeguards to protect your Information. However, regardless of our efforts and the Device you use to access the website, it is possible that third parties may unlawfully intercept or access transmissions or private communications over an unsecured transmission. While no data transmission over the Internet is 100% secure from intrusion, we conduct financial transactions via secured transmissions but may not always secure other parts of the website. We also limit our employees' access to Information collected by the website to those individuals who are authorized for the proper handling of such Information and any employee found violating our standards of security and confidentiality shall be subject to our disciplinary processes. We expect the same from our operational service providers.

WE DO NOT SEND EMAILS ASKING YOU TO PROVIDE OR CONFIRM CREDIT CARD NUMBERS, SOCIAL SECURITY NUMBERS OR LOGIN CREDENTIALS!

If you receive such email communication, contact us immediately. These are 'spoofed' e-mails which lead consumers to counterfeit websites designed to trick recipients into divulging Information such as credit card numbers, account usernames, passwords and social security numbers.

Changes to this Privacy Policy and Notice

We reserve the right to revise this Privacy Policy at any time by posting an updated Privacy Policy without advance notice to you. Such revisions shall be effective immediately upon posting. Notice of material changes may be posted on the website's homepage and/or may be provided by e-mailing you or notifying you upon login about these changes; the form of such notice is at our discretion. However, we encourage you to check this Privacy Policy and Terms of Service often for updates.

U.K. Governing Law

The Service is governed by and operated in accordance with the laws of the United Kingdom. We make no representation that this website is operated in accordance with the laws or regulations of, or governed by, other nations. By using the Service, you certify that you meet the age and other eligibility requirements for this website as set forth in our Terms of Service. If you do not meet the age and other eligibility requirements, please discontinue using the website immediately as your continued use of the website indicates that you are agreeing to the collection, use, disclosure, transfer, processing, management and storage of your Information as described in this Privacy Policy.

If you are located outside of the EEA and Switzerland, you use this website at your own risk and initiative and you, not us, are responsible for compliance with any applicable local and national laws. Please be aware that any Personal Information and Other Information you provide to us or we obtain as a result of your use of this website shall be collected in the U.K. and/or transferred to the U.K. and subject to U.K. law. By using this website, participating in any website activities and/or providing us with your Personal Information and Other Information, you (a) consent to the transfer and/or processing of any Information to and in the U.K, (b) acknowledge that U.K law may provide a lower standard of protection for personal data than the laws of your location and (c) understand that we will collect, transfer, store, process and/or deal with your Information in accordance with this Privacy Policy and U.K law. Consequently, to the full extent permitted by law, you hereby waive any claims relating to the processing of your Personal Information or Other Information in accordance with this Privacy Policy that may arise under the laws and regulations that apply to you in or of any other country or jurisdiction.

Miscellaneous

Accuracy and Confidentiality

It is your responsibility to give us current, complete, truthful and accurate information, including Personal Information, and to keep such information up to date. We cannot and will not be responsible for any problems or liability that may arise if you do not give us accurate, truthful or complete information or Personal Information or you fail to update such information or Personal Information. We will reject and delete any entry that we believe in good faith to be false, fraudulent or inconsistent with this Privacy Policy.

You are solely responsible for maintaining the strict confidentiality of your login credentials, if applicable, and for any charges, costs, expenses, damages, liabilities and losses we incur or may suffer as a result of your failure to do so. You, and not us, are solely responsible and liable for the activity, behavior, use and conduct on the website under your login credentials (whether used by you or any others who use your login credentials), unless and until you notify us that your login credentials may have been compromised, misappropriated or improperly taken or used by another party. We reserve the right to deny access, use and registration privileges to any user, including without limitation, a registered user, of any services, features or functions of the website if we believe there is a question about the identity of the person trying to access the user's account or any services, features or functions.

Further, if you use any of the Communities features and functions made available on or through the website, please remember that any Information disclosed in these venues is automatically made public and please use caution when disclosing any Personal Information in the Communities, as you do not know who may access and use your Personal Information or for what purposes. We are in no way responsible for the accuracy, use, or misuse of any information, including Personal Information, that you disclose or receive through these venues and you should assume that any disclosure you do make in these venues will be available publicly, even without your knowledge or authorization.

Questions

If you have questions about this Privacy Policy, if you do not understand any information about how we collect, maintain, use or share your Personal Information or Other Information or if you would like more information about the Personal Information the website collects about you, please contact us using the contact options provided on our website using "Privacy Request" in the subject of the message. We shall not accept requests via postal mail, telephone or facsimile. We are not responsible for notices that are not labeled or sent properly, or may not be able to respond if you do not provide complete information.

Sole Statement

This document is the sole statement of the website's Privacy Policy and no summary, restatement or other version thereof, or other privacy statement or policy, in any form, including, but not limited to, machine-generated, is valid.

Other

If you have not yet done so, please review our Terms of Service which governs your use of the website. Any terms that are not defined in this Privacy Policy shall have the meaning given in the Terms of Service Agreement. In the event of any conflict, the order of precedence shall be the Terms of Service and then the Privacy Policy