Introduction

Mellow Software, Inc. and its affiliates (together - "Mellow", "Company", "We") operates the website https://www.clarahealth.co and its related services and features (“Website”, collectively – the “Services”).

We are dedicated to protecting your privacy rights and making our practices regarding the processing of your personal data more transparent and fairer. This Privacy Policy (“Policy”) was designed to help you understand the information we collect, store, use and share, and it applies whenever you visit, install, or interact with our Services. Please note that parts of this Policy may not be applicable to you, depending on the jurisdiction in which you reside and the applicable laws.

Scope: This Policy applies only to the information we collect in connection with your use of the Website, including when you register to receive more information about our Services or when you provide it to our representatives via the phone or any other communication methods.

This Privacy Policy supplements and shall be read in conjunction with our Website Terms of Use (the “Terms”), and may be supplemented by additional privacy statements, terms or notices provided to you.

We strongly urge you to read this Policy and make sure that you fully understand and agree to it. If you do not agree to this Policy, please discontinue and avoid using our Services. You have the right to cease using our Services at any time, pursuant to this Policy and our Terms. You are not legally required to provide us with any personal data, but without it we will not be able to provide you with the best experience of using our Services.

Specifically, this Policy describes–

1. WHAT TYPES OF DATA WE COLLECT?

2. TRACKING TECHNOLOGIES

3. WHY WE PROCESS YOUR PERSONAL DATA?

4. WITH WHOM WE SHARE YOUR PERSONAL DATA?

5. MARKETING AND ADVERTISING

6. YOUR RIGHTS

7. TRANSFER OF PERSONAL DATA

8. DATA SECURITY

9. MINORS

10. RETENTION

11. EXTERNAL LINKS

12. UPDATES TO THIS POLICY

13. CONTACT US

1. WHAT TYPES OF DATA WE COLLECT?

We collect personal data from you, meaning any information which potentially allows, alone or together with other data, the identification of an individual with reasonable means (for example, email address or name, collectively "Personal Data"). This section sets out how and when we collect and process Personal Data about you. 

1.1. Information received directly from you:

We collect information which you provide us voluntarily. For example, when you request to receive communications from us or when you otherwise contact us directly via the Website:

• Communication Information:

When you send us an email, or contact us via the Website, we collect the personal data you provide us. This includes your name, email address and any other information you choose to provide.

• Personal details that you provide us in connection with your request to receive further information, or to receive our communication and updates;  

• In addition, phone calls, live chats and other communications with potential customers may be automatically recorded, tracked and analyzed, for purposes of business quality control and improvements, sales and marketing, and record-keeping purposes.  

• User Data received from you: If you choose to receive a Service that requires to log-in to your account via the Website, we may collect your personal data in respect of your engagement with the respective Service, such as your user account credentials, your business needs and preferences. 

1.2. Information we collect when you are using the Website: 

When you visit or access our Websites we may automatically receive and record information through the use (and authorize 3rd parties to use) of pixels, cookies and other tracking technologies as further detailed under the "Tracking Technologies" section below: 

Usage and Technical Information: 

When you use our Services and access our Website, we collect technical information about your interaction with our Services. Such information includes technical information about your interaction with our Services, geolocation data, IP address, unique identifiers (e.g. MAC address and UUID), your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our Website, methods used to browse away from the Website, as well as other information which relates to your activity in the Services. 

The information collected (including your IP address) may be disclosed to or collected directly by our third-party web analytics service providers such as Google Analytics, as further detailed under the "Tracking Technologies" section below.

1.3. Aggregated data: We may also collect aggregated or technical data generated when you use our Services, relating to how you use them, so we could learn how users and customers use our Services and improve them and our users’experience. Aggregated data may be derived from your personal data but is not considered personal data as this data does not directly or indirectly reveal your identity.

1.4. Sensitive Personal Data: We do not intentionally collect sensitive Personal Data (for example, information revealing race, ethnic origin, political opinions, religion, etc.) and we ask you not to provide us with such information.

2.      TRACKING TECHNOLOGIES

When you visit or access our Services, we use cookies, pixels, beacons, local storage and similar technologies ("Tracking Technologies"). 

Cookies: a cookie is a small data file that is downloaded and stored on your computer or mobile device when you visit our Website. 

We use "First Party Tracking Technologies" and also "Third Party Tracking Technologies" that are stored by other third parties. Third-party cookies are aimed at collecting certain information (including Personal Data you provided us via the Website) to deliver our targeted advertisements based on user's online activity and interests.  

These Tracking Technologies allow us to automatically collect information about you, your device, and your online behaviour, in order to enhance your navigation in our Services, improve our Services' performance, perform analytics, customize your experience and offer you, for example, tailored content and personalized advertisements that better correspond with your interests. 

For example, these technologies enable us to: (i) keep track of our users’ preferences and authenticated sessions, (ii) secure our Website by detecting abnormal behaviours, (iii) identify technical issues and improve the overall performance of our Website, and (iv) create and monitor analytics. 

You can learn more about our use of these technologies on the Cookie clause below.

You can delete cookies in your browser. If you turn cookies off, some of the features that make the Website’s experience more efficient may not function properly.  

WHY WE PROCESS YOUR PERSONAL DATA?

This section explains for what purposes we use your personal data:

• Provision and operation of our Services; Support. We use your personal data, such as your name and email address, to provide you with our Services and provide customer support. This includes, for example, responding to your inquiries.

• Communicate with you, notably when you contact us or submit a request to us.

• Improve our Services. We collect and analyse personal data about you and your usage of our Services for the purposes of usability, quality, functionality and effectiveness of our Services and their user experience.

• Anonymize or de-identify your Personal Data, create cumulative data that is non-personal, which we might make use in order to operate and improve our Services, and for research purposes.

• Marketing and Advertising. We use your personal data in order to provide you with advertisements, updates, notices, notifications, newsletters and additional information when you visit our Services, including personalized and non-personalized advertising.

• Integrity. We process certain information about you and your usage of our Services in order to keep the integrity and security of our Services, identify your identity and enforce our policies.

• Compliance with applicable laws; assistance to law enforcement agencies; response or defend against legal proceedings. We process your personal data in order to comply with our legal obligation under applicable laws.

• Protect and enforce our rights, privacy and security, prevent fraud or other illegal activity, safety of our systems, users and property, or those of other persons or entities, conduct audits, defend legal claims and resolve disputes.

3. WITH WHOM WE SHARE YOUR DATA?

We disclose your personal data as described below:

1. Service providers: 

Our service providers that serve in facilitating and enhancing our Services, work on our behalf and may need access to certain personal data in order to provide their services to us. These companies include, but are not limited to, hosting services, analytics services, Website functionality and operation services, marketing services, identity verification providers, etc. These service providers are authorized to use your personal data as necessary to provide these services or as otherwise authorized by us. 

2. Third party advertisers: 

We partner with third parties to either display or to manage our advertising on other websites or apps. Our third-party advertisers use Tracking Technologies to gather information about your activities on our Services and other websites and apps in order to provide you advertising based upon your browsing activities and interests.

3. Compliance with laws and assistance to law enforcement agencies: 

We may disclose your personal data to government or law enforcement officials or private parties. The disclosure will be made in our sole discretion, as we believe it necessary or appropriate to respond to claims and legal procedures (including but not limited to subpoenas), to protect our or a third party’s property and rights, to protect the safety of the public or any person, or to prevent or stop any activity we consider to be, or to pose a risk of being, illegal, unethical, inappropriate or legally actionable. We also may be required to disclose an individual’s personal data in response to a lawful request by public authorities, including meeting national security or law enforcement requirements. 

4. Auditors and advisers: 

We may share your personal data with our external auditors, advisors and professional service providers (e.g. lawyers, accountants, insurers etc.) for ensuring our compliance with regulatory requirements and industry standards, auditing, managing disputed etc.

5. Protecting our rights and safety:

We may share your personal data to enforce this Privacy Policy or the Terms of Use, including investigation of potential violations thereof; to detect, prevent, or otherwise address fraud, security or technical issues; or otherwise if we believe in good faith that this will help protect the rights, property or personal safety of any of our users, or any member of the general public.

6. Affiliated companies, mergers and acquisitions: 

We may share your personal data with our affiliated companies. In addition, we may transfer or share your personal data in case of entering into a business transaction (including during negotiations) such as a merger, acquisition, reorganization, bankruptcy, or sale of some or all of our assets, with the parties involved in such event. Such disclosure shall be subject to the terms of this Privacy Policy. 

For avoidance of doubt, we may share anonymized or de-identified information with any other third party, at our sole discretion.

4. MARKETING AND ADVERTISING

We use your personal data ourselves or by using our third-party subcontractors for the purpose of providing you with promotional materials, ads, products, services, websites and applications which relate to our affiliated companies or our business partners (collectively: “Marketing Affiliates”), which we believe may interest you.

You can decline receiving further marketing offers from us or from our business partners and Marketing Affiliates at any time, by contacting us at hello@clarahealth.co. Please note that even if you unsubscribe from our marketing-mailing list, we can continue to send you service-related updates and notifications.

5. COOKIES

When you visit or access our Services we use Tracking Technologies. Those allow us to automatically collect information about you, your device and your online behavior, in order to enhance your navigation in our Services, improve our Services’ performance, perform analytics and customize your experience. We store Tracking Technologies when you visit or access our Services. These are called "First Party Tracking Technologies". In addition, Tracking Technologies are stored by other third parties (for example our analytics service providers, business partners and advertisers) – these are called "Third Party Tracking Technologies". Both types of Tracking Technologies may be stored either for the duration of your visit on our Services or for repeat visits.

Our Platform may use the following types of cookies:

• Essential/Strictly Necessary Cookies: These cookies are necessary for the Services to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the Sites will not then work.

• Analytics/Performance Cookies: These cookies allow us to count visits and traffic sources, so we can measure and improve the performance of our Services. They help us know which pages are the most and least popular and see how visitors move around the Sites.

• Targeting/Advertising Cookies: These types of cookies may be set by our advertising partners. These cookies may be used by those advertising partners to build a profile of your interests and to show you relevant adverts on other websites. You may opt-out of certain sharing of information through these cookies, by sending a request as explained under your privacy rights below

• Analytics Services: We may use third-party web analytics services (such as Google Analytics) and other technologies on our Services to: collect and analyze usage information through cookies and similar tools; engage in activities such as auditing, research, or reporting; and provide certain features to you. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-out Browser Add-on 
  
  

How to Manage Your Tracking Technologies Settings

There are various ways in which you can manage and control your Tracking Technologies settings. By deleting or blocking Tracking Technologies, some of the features of the Services may not work properly or as effectively

• Below are some links to some commonly used web browsers. Information about cookies is usually found in the "Help" section of the web browser.

  • Google Chrome

  • Internet Explorer

  • Mozilla Firefox

  • Safari (Desktop)

  • Safari (Mobile)

  • Android Browser

  • Opera

  • Opera Mobile

For other browsers, please consult the documentation that your browser manufacturer provides.

Mobile Devices - You can-opt out of certain types of interest-based advertising (or “cross-app” advertising), by accessing the “settings” on your device.  

 You can also turn off certain third party targeting and advertising cookies by visiting the following link: Network Advertising Initiative and http://optout.aboutads.info/#!/.

6. YOUR RIGHTS 

Depending on the jurisdiction in which you reside, you may have certain rights under relevant applicable laws regarding the collection and processing of your personal data. To the extent these rights apply and concern you, you can contact us via the contact details available below and ask to exercise the following rights (which may be subject to certain exemptions or derogations):

If you wish to exercise your rights under applicable law, such as the right to request access to, and rectification or erasure of your personal data held with Mellow, or to restrict or object to such personal data’s processing, or to port such personal data, or the right to equal services and prices (each to the extent available to you under the laws which apply to you) – please contact us by e-mail at hello@clarahealth.co. Please note that once you contact us by e-mail, we may require additional information and documents, including certain personal data, in order to authenticate and validate your identity and to process your request. Such additional data will be then retained by us for legal purposes (e.g. as proof of the identity of the person submitting the request).

7. SPECIFIC PROVISIONS FOR US RESIDENTS

This section of the Policy applies to you, if you are a US resident in a state with an applicable privacy law or regulation.

During the last twelve (12) months we may have collected the following categories of personal information from users:

• Information that you chose to upload or otherwise provided by you to Mellow, which may include: (i) Identifiers and personal information, such as name, postal addresses, phone number, online identifiers, email addresses; (ii) characteristics of protected classifications, such as gender; audio, electronic or similar information; (iii) professional or employment-related information, and any other personal information voluntarily shared with us by you, including content of your interaction with our representatives.

• Information we collect when you use the Services, including (i) technical identifiers and personal information, such as online identifiers, internet protocol (IP) addresses, access device and connection information such as browser type, version, and time zone setting and browser plug-in types and versions; (ii) Internet or other electronic network activity information relating to your activity on our Website, including, log-in and log-out time, the duration of sessions, the content uploaded and downloaded, viewed web-pages or specific content on web-pages, activity measures; (iv) Geolocation information.

1. Sources of Personal Information: The sources from which we obtain Personal Information are (a) Directly from our users (either actively, when you contact us online via any digital form, via the Website, via phone conversations, or through monitoring of use of the Services by cookies and other tracking technologies); (b) Third Parties such as our advertising partners, data analytics providers.

We use the personal information that we collect or receive for the business purposes as described above under the Section titled “WHY WE PROCESS YOUR PERSONAL DATA?”.

Sharing or Selling personal information: We may disclose the above listed categories of personal information to third parties for business purposes as described above under the Section titled “WITH WHOM WE SHARE YOUR PERSONAL DATA?” in the Policy. 

In the preceding twelve (12) months, we may have disclosed all the categories of personal information detailed above for business purposes.

While we do not sell or share your personal information for monetary compensation, we may share your personal information with our marketing partners, to tailor and personalize our offers, ads, and content to suit your preferences while you're browsing other sites. This process may constitute selling or sharing of personal information under certain US state privacy laws. You can ask us not to use or disclose your personal information for such targeted advertising by sending an email to: hello@clarahealth.co. 

Please note that you may still see generalized Mellow ads after opting out of targeted advertising.

Your rights: You may have the following rights subject to certain exceptions, in relation to personal information related to you:

• a right to request access to the personal information we have collected about you over the past 12 months, including: (i) the categories of personal information we collect about you; (ii) the categories of sources from which the personal information is collected; (iii) the business or commercial purpose for collecting your personal information; (iv) the categories of third parties with whom we have shared your personal information; (v) the specific pieces of personal information that we have collected about you.

• a right to request that we delete personal information related to you that we collected from you under certain circumstances and exceptions.

• a right to correct the personal information you provided us with.

• a right to opt out of selling your personal information.

• a right to opt out of targeted advertisement. 

• a right not to be discriminated against for exercising your rights.

• a right to submit your request via an authorized agent. If you use an authorized agent to submit a request to access or delete your personal information on your behalf, the authorized agent must: (1) be a person or business entity registered with the relevant Secretary of State to conduct business in relevant state; (2) provide proof of such registration; and (3) provide documentation or other proof indicating that they are authorized to act on your behalf. We may also require you to verify your identity directly with us, and directly confirm with us that you provided the authorized agent permission to submit the request.

• Right to lodge a complaint and appeal our decisions: 

All requests, complaints or queries may be addressed to the Company to the following email address: hello@clarahealth.co. 

We will verify your request using the information associated with your account, to identify you (or your authorized representative). 

We will consider any requests, complaints or queries and provide you with a reply in a timely manner. We take our obligations seriously and we ask that any concerns are first brought to our attention, so that we can try to resolve them. To the extent you feel unsatisfied with our response to your request to exercise your rights, you may choose to send us a request to appeal our decision. If you are unsatisfied with our response, you can lodge a complaint with the applicable data protection supervisory authority.

Please note that these rights are not absolute, and may be subject to the relevant applicable laws, our own legitimate interests and regulatory requirements. 

Authorized agent

1. You can use an authorized agent to make a request to exercise your right under applicable laws on your behalf if:

   1. The authorized agent is a natural person or a business entity; and

   2. You sign a written declaration that you authorize the authorized agent to act on your behalf. If you use an authorized agent to submit a request to exercise your right, please provide us with a certified copy of your written declaration authorizing the authorized agent to act on your behalf using the contact information below.

2. The request must:

   1. Provide sufficient information to allow us to reasonably verify you are the person about whom we collected Personal Data or an authorized agent. We cannot respond to your request or provide you with Personal Data if we cannot verify your identity or authority to make the request and confirm the Personal Data relates to you; and

   2. Describe your request with sufficient details to allow us to properly understand, evaluate, and respond to it.

3. We will only use Personal Data provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

8. DATA SECURITY

We have implemented industry-standard administrative, technical, and physical safeguards to reduce the risk of unauthorized access, use, or disclosure of your personal data. Your information is stored on secure servers and is not publicly available. 

We limit access of your personal data only to those employees, or third-party service providers on a “need to know” basis.

Despite these measures, Mellow cannot provide absolute information security or eliminate all risks associated with personal data, and security breaches may happen.  

9. TRANSFER OF DATA OUTSIDE YOUR TERRITORY

​​We may store and process information in various locations throughout the globe, including through cloud services. In such cases, we will take steps to ensure a proper level of protection of personal data as required by applicable law. You agree to the transfer of your personal data to such other countries for the purpose of the processing as described in this Policy, including through cloud services.

10. MINORS 

We do not knowingly sell or share personal information of users under the age of 18.

We do not knowingly collect or solicit Personal Data from Minors (as determined under the applicable laws where the individual resides; “Minors”). By accessing, using or interacting with our Services, you certify to us that you are not a Minor. If you believe that we might have any information from or about a Minor without verification of parental consent, then please contact us through the contact details available below.

11. RETENTION 

We will retain your personal data for as long as necessary to provide our Services, and as necessary to comply with our legal obligations, resolve disputes, and enforce our policies. Retention periods will be determined taking into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time.

12. EXTERNAL LINKS

While our Service may contain links to other websites or services, we are not responsible for their privacy practices. We encourage you to pay attention when you leave our Service for the website or application of such third parties, and to read the privacy policies of each and every website and service you visit. This Privacy Policy applies only to our Service. 

13. UPDATES TO THIS POLICY 

We reserve the right to change this Policy at any time. The most current version will always be posted through our Services (as reflected in the “Last Updated” heading). You are advised to check for updates regularly. In the event of material changes, we will provide a notice via the Services or by other means. By continuing to access or use our Services after any revisions become effective, you agree to be bound by the updated Policy.

14. CONTACT US

If you have any further questions, please contact us by email at: hello@clarahealth.co. 

Address: 8 Yohanan Horkanos St, Apt 9, 6249308, Tel Aviv, Israel.