This site is O&O by Shinez.io LTD
Ibn Gvirol 30, Tel Aviv, Israel.
- General
We atpenguinmd (the “Company“, “We“, “Us” or “Our“), are committed to protecting the privacy of Our users (“You“). As part of this commitment, it is important for Us to be transparent about how We handle the Data that We (or others on Our behalf) collect about Our users, when We collect Data about them, and how We use such Data.
This privacy policy (the “Policy“) provides You with information regarding the Data collected, processed, used by the website We operate at: https://penguinmd.com (“the “Website“).
This Policy is part of and should be read in conjunction with our Terms of Use. https://penguinmd.com/terms_and_conditions/
In this Policy, any reference to “Personal Data” is to any Data relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or in combination with additional Data that We have or that We have access to.
- When do We collect Data about You?
- We may collect Personal Data about You in the following circumstances:
- When You access or use the Website;
- When You interact with Us in any manner, including by sending us emails or messages via third party social media Websites such as Meta (Facebook) or in any other manner.
- You are under no legal obligation to furnish any Data about You, and the furnishing thereof is at Your discretion and of Your own free will. However, if You do not furnish certain Data about You, We shall not be able to provide You with some of the Services or certain sections on the Website.
- We do not knowingly process Data about minors. Any person who provides the Data to Us (or to others on our behalf) in connection with the Services represents to us that they are 16 (sixteen) years of age (or such other lawful age – where higher than 16) or older. It is Our policy to try and uncover attempts by minors to access the Services, and this may require having to access and verify Your Personal Data. We will not accept and take actions to remove from Our records any Data which we discover is or was submitted by a minor.
- We may collect Personal Data about You in the following circumstances:
- What types of Data do We collect?
- We (or others on Our behalf) may collect the following types of Personal Data about You:
- Communication Data – when You contact Us, though any channel whatsoever, including social media networks, You may provide Us with Your name, certain contact Data (such as email address) and the content of Your communication with Us.
- Website usage Data – this Data includes online activity log, traffic Data (including, without limitation, IP address, time of access, date of access, web and mobile page(s) visited, language used, operating system Data, Your device Data, crash reports and type of browser used, Data regarding the device You used, including the hardware model, operating system and version, the website You visited before entering our Website and other device identifiers. Some of this Data may not identify You personally, and therefore does not constitute Personal Data.
- Website activity Data – whenever You use the Website, We monitor Your use of the Services and record Your activity. The Data that We gather about You in this context includes any activity that You perform in the Website, such as dates and times on which You will use the Website, the length of time You will be watching content on the Website, Your interaction with content in the Website, etc.
- You are responsible for ensuring the accuracy of the Data that You provide Us (or others on Our behalf) with. Inaccurate Data will affect Our ability to provide You with some of the Services, as well as Our ability to contact You as contemplated in this Policy.
- We (or others on Our behalf) may collect the following types of Personal Data about You:
- The Purposes Of The Processing Of Personal Data And Their Legal Basis
- The Company will not process Personal Data about You unless there is a legal basis for such processing.
- The legal bases according to which We may process Personal Data about You are as follows:
- Your consent that the Company will process Personal Data about You for one or more specific purposes. By way of example, for the purpose of operating the Website. Where the legal basis for the processing of the Personal Data about You is consent, You may at any time withdraw Your consent for the purposes for which You provided Your consent by sending a notice free of charge to the following email address: [email protected].
Where You withdraw Your consent for the processing of Personal Data about You, We might not be able to provide You with some or all of the Services You requested or in the form intended to be provided to You, and You will have no claim in respect of that.
- Processing is necessary for the performance of a contract to which You are party or in order to take steps at Your request prior to entering into a contract. This refers to all the Data required for us to provide You with the Services and grant You access to the Website and the various Services offered in connection therewith.
- Processing is necessary for the purposes of the legitimate interests pursued by the Company or by a third party. By way of example, for the purpose of improving Our Services, or for the exercise or defense of legal claims.
- At any time, You may approach Us by sending a notice to the email address [email protected], in order to receive Data concerning the review performed by Us. This is so You can conclude that We may process the Personal Data about You on account of such processing being necessary for the purposes of the legitimate interests pursued by the Company or by a third party.
- How do We use Personal Data?
We may use Personal Data about You for the following purposes:
- To operate the Website and provide the Services.
- To contact You for the purpose of operational requirements.
- To personalize content and/or offers to You.
- To respond to Your queries, requests and/or complaints.
- To send You materials regarding services, events and other Data we think will be of interest to You, subject to Your consent.
- To analyze and improve the Services, as well as to develop and offer new ones.
- To analyze and track usage to determine the usefulness or popularity of certain content and to better understand the online activity of the Website users.
- Monitor and analyze trends, usage and activities in connection with the Website and the Services.
- To perform and maintain various activities supporting the offering and provision of the Services, including, but not limited to, the Website (such activities include back office functions, business development activities, strategic decision making, financing management, etc.).
- To protect Our and third parties’ interests, rights and assets, including detecting, investigating and preventing fraudulent transactions or unauthorized or illegal activities and initiation or exercise or defense of legal claims and preventing.
- To fulfill Our legal or regulatory requirements.
- Sharing of Personal Data
- We will not disclose Personal Data about You to third parties except as detailed in this Policy.
- We may transfer Personal Data to entities that control Us, entities that are under Our control and/or to entities under common control or ownership with Us, as shall be from time to time (collectively the “Group”). Such entities may use the Personal Data to support the needs of the Group.
- When You are transferred to Our Website from another third party Business partner, We may transfer Your Personal Data that You have provided to Us to that third party Business partner;
- We may transfer Personal Data to Our Affiliates;
- In the event that We will be subject to an audit or a Due diligence process;
- In the event that We sell, assign or transfer some or all of Our business or assets to a successor or acquirer, or if We are acquired by or merge with a third party, or if We file for bankruptcy or become insolvent, or any other situation where Personal Data may be sold, assigned or transferred to a successor or acquirer;
- To protect Our rights, property and interest or those of third parties;
- To fulfill Our legal or regulatory requirements or to comply with a court order;
- Upon Your consent or instruction;
- In addition, We may share Personal Data about You with the following third parties providing Us the following services:
- Storage and hosting providers, including cloud computing services and data security services;
- IP address Data;
- Analysis of user experience;
- Support;
- Marketing;
- Advertisements services;
- CRM data management;
- Accounting and legal services; and
- Research, analytical, technical, and diagnostic services.
- Transfer of Personal Data abroad
- We may transfer Personal Data about You outside the jurisdiction which You are a resident of and store it in other jurisdictions and countries; the data protection and other laws of these jurisdictions or countries may not be as protective to Personal Data as those in the jurisdiction which You are resident – in these instances, We will take steps to ensure that an appropriate level of protection is given to Your Personal Data.
- You may request that the Company provide You with details concerning the safeguards employed by it to protect the Personal Data about You that are transferred to a third country or an international organization, by sending an email to the following address: [email protected].
- Retention of Personal Data
We will retain Personal Data about You only for as long as necessary for the fulfillment of the purposes for which such Personal Data is collected. We may retain Personal Data about You for longer periods, if We find it necessary to comply with legal requirements applicable to Us.
- Cookies and Trackers
- We may use certain third party services, such as analytics companies or companies delivering advertisements, which may also use cookies or other technologies, and those practices and providers are subject to their own policies.
- Cookie (which is a small text file) is installed on the device via which You visit or access the Website. The cookies allow Us to collect information about You and Your behavior, in order to improve Your user experience, to remember Your preferences and settings, and to customize and offer You products and services that may interest You. Cookies are also used to collect statistics and perform analytics.
- Some of the cookies We use are session cookies, which are downloaded temporarily to Your device and last until You close Your web browser, while others are persistent cookies, which last on Your device after You cease browsing the Service and are used to help the Service remember You as a returning visitor when You return to the Service.
Types of cookies:
The cookies We may use have been classified according to their functionality, as follows:
Type of Cookie | Purpose | Additional Information |
Strictly Necessary Cookies | These cookies are strictly necessary to enable You to navigate the Website and use features You have requested. They are used to provide You with Our content, products, and Website that You have requested. Such cookies are essential to help Your device download or stream information so that You can navigate around the Website, use its features, and return to pages You have previously visited. | These cookies collect Personal Data about You, such as user name and last login date, and identify You as being logged in to the Website. These cookies are deleted when You close Your web browser (session cookies). |
Functionality Cookies | These cookies are used to recognize You when You return to the Website and allow Us to remember Your choices and preferences and measure how You use our website. | These cookies survive the closing of Your web browser, and last until their applicable expiry time. |
Performance Cookies | These cookies are used to provide aggregated statistics in respect of the performance of the Website and to test and improve such performance, in order to provide better user experience. In addition, they allow Us to carry out analytical functions on the Website. | These cookies collect anonymized data that is not related to an identified or identifiable natural person. These cookies are valid for varying periods; some are deleted once You close Your browser, while others have an indefinite validity period. |
Third Party Marketing/Targeting Cookies | These cookies are used to deliver ads and marketing communications, and to display the Website in a manner that is more relevant to You. They are also used to measure the effectiveness of an advertising campaign. These cookies record Your visit to the Website and the pages You have visited. | Some of these cookies are provided and used by third parties. These cookies are valid for varying periods; some are deleted once You close Your browser, while others have an indefinite validity period. |
The Cookies incorporated in our Website are as follows:
Third Party | Name | Retention | Type | Function |
No | penguinmd.com | 1 week | Essential, Functionality and Performance. | User experience statistics, values needed for technical optimization |
Yes | Google Products | 13 months (max) | Essential, Functionality, Performance and Targeted Advertising | https://business.safety.google/adscookies/ |
Yes | GeoEdge | Operation and Security | https://www.geoedge.com/privacy | |
Yes | Cloudflare | 30 minutes | Operation and Security | https://developers.cloudflare.com/fundamentals/reference/policies-compliances/cloudflare-cookies/ |
Yes | Facebook Pixel | 3 months and 1 week. | Targeted Advertising | https://www.facebook.com/business/help/471978536642445?id=1205376682832142 |
Blocking and removal of cookies:
You can change Your browser settings to block and delete some or all cookies. Please see below links to instructions on how to do this in respect of some of the most popular web browsers:
- Firefox: https://support.mozilla.org/en-US/kb/cookies-information-websites-store-on-your-computer?redirectslug=Cookies&redirectlocale=en-US
- Edge: https://support.microsoft.com/en-us/microsoft-edge/delete-cookies-in-microsoft-edge-63947406-40ac-c3b8-57b9-2a946a29ae09
- Internet Explorer: https://support.microsoft.com/en-gb/windows/delete-and-manage-cookies-168dab11-0753-043d-7c16-ede5947fc64d
- Google Chrome: https://support.google.com/chrome/answer/95647?hl=en
- Safari: https://support.apple.com/en-ph/guide/safari/sfri11471/mac
Please note, however, that if You do so, some or all of the Service’s features and functionalities might not perform as intended.
ONLINE TRACKING NOTICE
AT THIS TIME, THIS SERVICE DOES NOT SUPPORT DO-NOT-TRACK SIGNALS.
- Security
We have implemented suitable security policies, rules and technical measures to protect and safeguard the Personal Data under Our control from unauthorized access, improper use or disclosure, unauthorized modification, or unlawful destruction.
- Links to Other Websites
- The Website may contain links to websites and/or applications of third parties. Other websites and applications may also reference or link to Our Website. We do not control such websites and applications, nor the collection and/or processing of Personal Data about You by such websites and applications, and thus We are not responsible for the privacy practices. This Policy does not apply to any actions taken via such websites and/or applications.
- Whenever You access such third parties’ websites and/or applications, We recommend that You carefully review their privacy policies prior to using such websites and/or applications and prior to disclosing any Personal Data about You.
- Your rights in respect of the Personal Data about You
- Generally, You have the right to request that We provide You with confirmation as to whether Personal Data about You is being collected by Us, to ask to review such data, to rectify the Personal Data if applicable and to erase the Personal Data no longer required by Us.
- Where the legal basis for the processing of the Personal Data about You is consent, You may at any time withdraw Your consent for the purposes for which You provided Your consent by sending a notice free of charge to the following email address: [email protected].
- Where You withdraw Your consent for the processing of Personal Data about You, We might not be able to provide You with some or all of the Services You requested or in the form intended to be provided to You, and You will have no claim in respect of that.
- At any time, You may approach Us by sending a notice to the email address [email protected], in order to receive information concerning the review performed by Us. This is so You can conclude that We may process the Personal Data about You on account of such processing being necessary for the purposes of the legitimate interests pursued by the Company or by a third party.
- The Company may provide You with offers that are tailored for You specifically, in order to connect You to brands, products and services in ways that are important to You. This may include ads, offers and other sponsored content related to products and services of Our’s or of third parties. This is done following the processing of Personal Data about You, in order to adjust the materials presented to You, on the basis of Your preferences, behavior, characteristics and interests.
If You reside in the U.S.A, please read below with respect to the California Consumer Privacy Act (CCPA), California Privacy Rights Act (CPRA), the Virginia Consumer Data Protection Act (VCDPA), and the Colorado Privacy Act (CPA)) rights You might have:
Right | Scope | |
1 | Right to know | You have the right to receive the following information: The specific pieces of Personal Data We have collected about You.What types of Personal Data collected;categories of personal data collected;What are the types of sources of the Personal Data collected;the purpose of collecting the Personal Data;Types of third parties with whom We share Personal Data, if any; and |
2 | Right of Erasure | You may ask Us to delete Your Personal Data and direct Our service providers to do so. Please note that We may not delete Your Personal Data if it is necessary to complete Our legal obligation to You to provide the Website or Services otherwise protect Our legal rights, comply with an existing legal obligation; or use Your Personal Data, internally, in a lawful manner that is compatible with the context in which You provided the information. |
3 | Right to non selling or sharing | You may ask Us to not sell or share Your Personal Data. |
4 | Right to Non-Discrimination for the exercise of Your privacy rights | You have the right to not be discriminated by Us because You exercised any of Your rights under the CCPA. |
5 | Right to designate an authorized agent to submit CCPA requests on Your behalf | You may designate an authorized agent to make a request under the CCPA on Your behalf. To do so, You need to provide the authorized agent written permission to do so and the agent will need to submit to Us proof that such agent has been authorized by You. We will also require that You verify Your own identity, as explained below. |
In order to exercise Your rights, please contact us using the following details: [email protected].
If You are an EEA resident, please read this section below:
- You are entitled to the following rights in respect of the Personal Data about You. To exercise such rights, You may send a request to exercise Your rights to the following email address: [email protected].
- We will grant Your right to receive information how Personal Data about You is processed by Us; to rectify any inaccuracy in Your Personal Data; to erase Your Personal Data processed and stored by Us; to restrict the processing thereof or object thereto if applicable under the circumstances; the right to receive the Personal Data about You, which You have provided to the Company, in a structured machine readable manner and the right to withdraw Your consent when such is the legal basis of our processing.
- We may reject Your requests where the request harms the rights and freedoms of others or comply with legal requirements applicable to Us. We may also charge a reasonable fee where applicable.
- You will also have the right to lodge a complaint with a supervisory authority established by a Member State to protect the fundamental rights and freedoms of natural persons in relation to the processing of Personal Data within the European Union.
- Please note that We may need to receive Personal Data from You in order to verify Your identity prior to allowing You to exercise Your rights.
- Transfer of Personal Data
- Personal Data about You may be transferred to a third country (i.e. jurisdictions other than the one You reside in) or to international organizations. In such circumstances, the Company shall take appropriate safeguards to ensure the protection of Personal Data about You and to provide that enforceable data subject rights and effective legal remedies for data subjects are available.
- If You are an EEA resident, please note that these safeguards and protection will be available if any of the following are met:
- The transfer is to a third country or an international organization that the EU Commission has decided provides an adequate level of protection to the Personal Data that is transferred to it pursuant to Article 45(3) of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (“GDPR“);
- The transfer is according to a legally binding and enforceable instrument between public authorities or bodies pursuant to Article 46(2)(a) of the GDPR; or
- The transfer is in accordance with standard data protection clauses adopted by the EU Commission pursuant to Article 46(2)(c) of the GDPR.
You may request that the Company provide You with details concerning the safeguards employed by it to protect the Personal Data about You that are transferred to a third country or an international organization, by sending an email to the following address: [email protected].
- Changes to the Policy
We may change this Policy in Our sole discretion at any time. Any revisions to this Policy will be posted as an updated version accessible via the Website home page. We recommend that You revisit this Policy regularly so as to be kept apprised of any such changes.
- Contact Us
For any queries relating to this Policy and data protection, please contact Us at [email protected].
This site is O&O by Shinez.io
Last updated: December 2023.