Privacy Policy

This is the privacy policy (“Privacy Policy”) that governs how we, SaverOne 2014 Ltd. (“SaverOne”, “we”, “our” or “us”), use Personal Information (defined below) that we collect, receive and store about individuals such as our customers or potential customers, customers’ end-users, employees and service providers and the users of the Site, in connection with the use of: (i) the website https://www.saver.one, and any other website that we operate (each, together with its sub-domains, content and services, a “Site”); (ii) the SaverOne Protection System (“Product”); and (iii) the SaverOne mobile software application (the “App”). The Site, Product, and the App are individually and collectively referred to herein as the “Services”.

1. We have implemented this Privacy Policy because your privacy, and the privacy of other users, is important to us. This Privacy Policy explains our online information practices and the choices you can make about the way your Personal Information is collected and used in connection with the Services. This Privacy Policy sets forth our policy with respect to:
   • Information that can be associated with or which relates to a person and/or could be used to identify person, such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person, all as defined by the General Data Protection Regulation (GDPR) (EU) 2016/679 (“Personal Information”).
   • As it refers to California’s consumers or individuals where their data is collected in the state of California, this Privacy Policy sets forth our policy with respect to Information,
     • That identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or California household such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers; and /or
     • hat identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, their name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.

All as defined by the California Consumer Privacy Act of 2018 (“CCPA”).

• “Non-Personal Data” or “Anonymous Information” as used in this Privacy Policy, is therefore any information that does not relate to a person, cannot be used to identify a person, and /or refers to information collected in the state of California Publicly Available Information. The limitations and requirements in this Privacy Policy on how we gather, use, disclose, transfer, and store/retain Personal Data do not apply to Non-Personal Data. We may use Anonymous Information or disclose it to third party service providers in order to improve our Services and enhance your experience with the Services. We may also disclose Anonymous Information (with or without compensation) to third parties, including advertisers and partners.

2. This Privacy Policy forms part of the App’s End User License Agreement which can be viewed from within the App and which you accepted prior to, installing and/or using the App for the first time (“EULA”). Any capitalized but undefined term in this Privacy Policy shall have the meaning given to it in the EULA.
3. Consent and Modification.
   • You are not legally obligated to provide us Personal Information, and you hereby confirm that providing us Personal Information is at your own free will. By using the Services, you consent to the terms of this Privacy Policy and to our collection, processing and sharing of Personal Information for the purposes set forth herein. If you do not agree to this Privacy Policy, please do not access or otherwise use the Services.
   • We reserve the right, at our discretion, to change this Privacy Policy at any time. Such change will be effective ten (10) days following posting of the revised Privacy Policy on the App, and your continued use of the Services thereafter means that you accept those changes.
   • This Privacy Policy does not apply to any Personal Information that you provide to third parties. This Privacy Policy applies only to our Product and Site. It does not apply to third party’s websites or services, even if they link to our Site or Product. The existence of a link from a third party’s website or services does not imply that we endorse or have reviewed the third-party’s websites or services. We suggest contacting such third parties directly for information on their privacy policies. 
4. What Personal Information We Collect, How We Collect It and Why. We do not currently require you to provide Personal Information in order to have access to general information available on the Site. But we do receive and/or collect Personal Information from you in the following ways:
   • Registration. In order to use certain services that we offer via the Services, you may be required to register to the Service and will be required to provide us with certain information, such as your name, as well as a password that you will use in order to access the Services (“Registration Information”). We may send you a text message (SMS) to your mobile phone or any other electronic device with SIM to confirm your registration. If you choose not to register, you may not be able to access or use certain features of the Services.
   • User Validation. For the purpose of your mobile phone number or device validation as part of the application login process, we will transfer your mobile phone number or the device phone number alternatively to a third-party server which will send back a text message to your mobile phone or device. This text message will contain a temporary one-time-password (OTP) that will be sent during the log in process. Please note that this service is currently available for Android devices only. For more information regarding the third party’s privacy policy please visit: twilio.com/legal/privacy#twilio-privacy-statement.
   • Vehicle Information. You may also be required to provide information about the vehicle(s) on which the Product is installed and with which the Service will be used, including the manufacturer (make), model, year, and license number of the vehicle. We may also record, in connection with the use of the Services, the hardware and serial numbers and software version number of the Product installed on the vehicle being operated.
   • Use of the Services. During your use of the Services, we may collect personal information relating to your use of the Services, including with respect to the number of times you accessed to or try to access applications on your device while driving or operating a vehicle.
   • Remote Service Support. As part of our customer service, you can use our service to remotely support your device. The process will begin with your consent to allow access to the company representative for activating. As part of the service activate through the application, a one-time code (OTP) will appear on the screen of your device for continued remote support. This code will be sent through a third party for your connection to the service. Once the service starts, SaverOne may document a visual video of all displayed content on the screen for the purpose of supervision, legal defense and improving the service, documentation which will require your consent, due to the possibility of exposing sensitive visual information on your device. Once the support documentation is completed, SaverOne will not be able to access the above video and / or operate your device remotely. Please note that this video will be sent to a third-party server which will save documentation above for 7 days, after which it will be deleted. This service is currently available for Android devices only. For more information regarding the third party’s privacy policy please visit: https://cobrowse.io/terms-and-policies.
   • ‘Contact Us’ Information. If you send us a “Contact Us” request, whether by submitting an online form that we make available or by sending an email to an email address that we display, you may be required to provide us with certain information such as your name and email address.
   • Location Data. Certain features or functionality (“Features“) of the App use collect and dependent on data related to your geographic location (“Location Data“). You should be able to use the settings on your mobile device to turn off location-sharing features, note that if you should choose to do so, it may impar the Services. Sometimes the App will collect information about which state you are located at, this option is required and cannot be turned off.
   • Mobile Device Data. We may collect limited information from your mobile device in order to provide the App. Such information may include your mobile device type, mobile device ID, and date and time stamps of App use.
   • Processing and Analyzing. In order to provide the Services and operate our business, We may use the Personal Data for processing and analyzing purposes.
   • Specific Purpose. If you provide Personal Data for a specific purpose, We may use said Personal Information in connection with the purpose for which it was provided. For instance, if you contact Us by email, we will use the Personal Information you provide to answer your question or resolve your problem and will respond to the email address used to contact Us.
   • Internal Business. We may use your Personal Information for internal business purposes, including, without limitation, to help us improve Site content and functionality to better understand our Customers and Users, to improve our Services, to protect against, identify or address wrongdoing, to enforce our Contracts and this Privacy Policy, to provide you with customer service, and to generally manage and operate our business (e.g., pay salaries, etc.).
   • Statistics. We may use any Personal Information you provide us with to generate statistical reports containing aggregated information.
   • Security and Dispute Resolution. We may use Personal Information to protect the security of the Site and Services, to detect and prevent cyberattacks, fraud, phishing, identity theft, and data leaks, to verify genuine software licenses, to resolve disputes, and to enforce our agreements.
   • Cloud Services. We may need to share Personal Information with our cloud service. For example, to assist in protecting and securing the Site or Services the cloud service admin may need access to Personal Information to provide those functions. In such cases, the cloud service provider must abide by our data privacy and security requirements and is not allowed to use Personal Information they receive from us for any other purpose.
   • Development and Customer Service. For example, to provide customer service and support or assist in protecting and securing our systems and services our development and customer service team may require access to Personal Information. In such cases, our personnel must abide by our data privacy and security requirements and policy and are not allowed to use Personal Information for any other purpose.
   • Corporate Sale, Merger, Reorganization, Dissolution or Similar Event. Personal Information may be part of the transferred assets. You acknowledge and agree that any successor to or acquirer of the Company (or its assets) will continue to have the right to use your Personal Information and other information in accordance with the terms of this Privacy Policy.
   • Law Enforcement. In order to, for example, respond to a subpoena or request from law enforcement, a court or a government agency (including in response to public authorities to meet national security or law enforcement requirements), or in the good faith belief that such action is necessary to (a) comply with a legal obligation, (b) protect or defend our rights, interests or property or that of third parties, (c) prevent or investigate possible wrongdoing in connection with the Services, (d) act in urgent circumstances to protect the personal safety of users of the Site and Services or the public, or (e) protect against legal liability.
   • Other Purposes. If We intend to use any Personal Information in any manner not consistent with this Privacy Policy, you will be informed of such anticipated use prior to or at the time the Personal Information is processed.
   • Non-Personal Data. Since Non-Personal Data cannot be used to identify you in person, we may use such data in any way permitted by law.
5. Cookies. We use cookies and similar tracking technologies to track the activity on our Site and hold certain information. Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a Site and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyze our Site and Services. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Site. In order to manage Your permissions for our use of cookies please see our Cookie Policy.
6. Examples of cookies we use:

• Session cookies – for operating our Sites.
• Preference cookies – for remembering your preferences and various settings.
• Security cookies – for security purposes.

7. The Way We Use, Store and Transfer Personal Information. If you submit or we collect Personal Information through the Services, then we may use such Personal Information in the following ways:
   • We will use your Personal Information to provide and improve our Services and to identify and authenticate your access to the parts of the Services that you are authorized to access and in order to send you updates and information regarding changes or updates we may perform in the Services or the App.
   • We may transfer your Personal Information to our local or foreign subsidiaries or affiliated companies for the purpose of storing or processing such information on our behalf. Such information may be transferred to other countries. We require that these parties agree to process such information in compliance with our Privacy Policy and with applicable law.
   • We may share your Personal Information with our third-party service providers and partners to assist us with our business operations and to provide our Services to you and other users. Such information may be transferred to other countries. We transfer to such providers only the minimum data that is necessary for conducting our services. The data is transferred only to suppliers approved by us that allow compliance with the GDPR. Personal Data may be transferred stored and processed in countries outside the EU or European Economic Area (EEA). Such transfer to third countries may include countries that do ensure the same level of data protection laws as required by EU privacy laws. In such cases, we implement information security techniques and technical measures or third parties’ contractual obligations to maintain such Personal Information at the same security level as other Personal Data that SaverOne administers.
   • In addition to the many security and privacy controls that we have put in place, we also use the EU’s Standard Contractual Clauses as a valid transfer mechanism according to the GDPR when we need to transfer Personal Information outside of the EU or adequate level countries.
   • In order to provide our Services, manage and operate our business we use third parties’ cloud services such as:

• Microsoft office 365 (for Microsoft privacy policy see https://privacy.microsoft.com/en-us/privacystatement).
• SaverOne stores data on Microsoft AZURE cloud services. For Microsoft Azure Privacy policy and TOU see https://azure.microsoft.com/en-us/support/legal/ . SaverOne’s database storage location is in Ireland.
  • In order to deliver the Services and/or operate our business, Information, which may include Personal Information, may be processed by our third parties service providers (“Suppliers”). We transfer only the minimum data that is necessary for conducting the Services. The data is transferred only to suppliers approved by us that allow compliance with GDPR.
  • We may transfer Personal Data to our headquarters located in Israel and maintain it there. Israel has declared by the EU as have an adequate data protection law as to the EU law.
  • We may also share Personal Information with our partners that are the owners or operators of the vehicle fleet which includes the Vehicle, for the purpose of reporting the use and operation of the Services.
  • We may disclose your Personal Information or any information you submitted via the Services if we have a good faith belief that disclosure of such information is helpful or reasonably necessary to: (I) comply with any applicable law, regulation, legal process or governmental request; (ii) enforce our EULA, including investigations of potential violations thereof; (iii) detect, prevent, or otherwise address fraud or security issues; or (iv) protect against harm to the rights, property or safety of SaverOne, our users, yourself or the public.
  • Marketing: We may use any Personal Data you provide us with to contact you in the future for our marketing and advertising purposes, including, without limitation, to inform you about services we believe might be of interest to you, and to develop promotional or marketing materials and provide those materials to you.

IF YOU RECEIVE DIRECT MARKETING BY MISTAKE OR WITHOUT YOUR SPECIFIC CONSENT AND/OR YOU WISH TO OPT-OUT, YOU ARE REQUIRED TO CONTACT US ATsupport@saver.one.

• Merger, Sale or Bankruptcy. 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 or assign Personal Information in connection with the foregoing events.
• If we intend to use any Personal Information in any manner not consistent with this Privacy Policy, you will be informed of such anticipated use prior to or at the time the Personal Information is processed.
• We are not selling Personal Data to third parties.
• If you have a reasonable basis to assume or you know that any of the abovementioned is not met, you are required to promptly inform us, without delay, by sending us an email to support@saver.one.

8. Data Retention, Archives. We retain and archive Personal Information so long as it is necessary to operate our business and maintain our Services, meet contractual obligations, laws and regulations, and are subject to our retention policies and this Privacy Policy. Even if we delete your Personal Information, it may remain stored on backup or archival media for an additional period of time due to technical issues or for legal, tax or regulatory reasons, or for legitimate and lawful business purposes.
9. At all times, you may choose whether or not to provide or disclose Personal Information. If you choose not to provide mandatory by law and/or necessary data to provide the services you will not be able to use the App and the Services.
10. Children’s Privacy. We collect data from any person who has driver license, which may include minors (under the age of 18). Accordingly, we do not intend to collect Personal Information from anyone we know to be under the applicable legal age to have a driving license. If we learn that we have collected Personal Information from a child (under the age of 16) who does not have a driving license, we will delete that information as quickly as possible. If you believe that we might have any such information, please contact us at support@saver.one.
11. The security of Personal Information is important to us. We follow generally accepted industry standards, including the use of appropriate administrative, physical and technical safeguards, to protect the Personal Information submitted to us. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use reasonable acceptable means to protect your Personal Information, we cannot guarantee its absolute security or confidentiality. If you have any questions about security on the Services, you can contact us at support@saver.one. We recommend that you use, disclose and share your Personal Information with caution and do not give out Personal Information unless it is necessary, as we cannot guarantee the security of data over the internet and cannot control the actions of other users of the Services with whom you choose to share Personal Information.
12. Data subject/California Consumer rights: Accessing, Updating, Correcting, and Deleting Information, Restricting Information Processing.
    • You may have the right to request access to some of your Personal Data being stored by Us. California consumers (California residents) have the right to request that we disclose certain information to them about our collection and use of their personal information over the past 12

Once we receive and confirm your verifiable consumer or individual request, we will disclose to you, inter

           alia:

• The categories of Personal Information we collected about you.
• Our business or commercial purpose for collecting that Personal Information.
• The categories of third parties with whom we share that Personal Information.
• The specific pieces of Personal Information we collected about you (also called a data

portability request)

• You can also request to correct and update any inaccurate Personal Data or ask to delete Personal Data that we process about you. The foregoing is subject to our policies and the applicable laws and regulations. Once we receive and confirm your verifiable consumer/individual request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.
  • According to the CCPA, we may deny California consumer’s deletion request if retaining the information is necessary for us or our service providers to:
• Complete the transaction for which we collected the personal information, provide our services that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Debug products to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code §1546 seq.).
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with Us.
• Comply with a legal obligation.
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
  • In order to exercise these rights, you can contact Us at: support@saver.one or call us at: +18773951222 (Toll free number) Only you or other person that you authorize to act on your behalf, California resident or a person registered with the California Secretary of State that California resident authorize to act on its behalf, may make a verifiable individual or consumer request related to their Personal Information. California residents may only make a verifiable consumer request for access or data portability twice within a 12-month period.
    • The verifiable consumer or individual request must:
  • Provide sufficient information that allows Us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
  • We cannot respond to your request or provide you with Personal Information if We cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. We will only use Personal Information provided in a verifiable consumer/Individual request to verify the requestor’s identity or authority to make the request.
    • Response Timing and Format. We endeavor to respond to a verifiable consumer request within 45 days (by the CCPA) or 30 days (By the GDPR) of its receipt. If we require more time, We will inform you of the reason and extension period in writing. We will deliver our written response via email. For California residents, any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons We cannot comply with a request, if applicable. For data portability requests, We will select a format to provide your personal information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance.
    • We do not charge a fee to process or respond to your verifiable consumer or Individual request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

• Non-Discrimination. We will not discriminate against you for exercising any of your CCPA or GDPR rights. Unless permitted by the CCPA and GDPR, We will not: Deny you use of our Services and/or provide you a different level or quality of Services.
• We may retain your Personal Information for any period permitted or required under applicable laws. Even if we delete your Personal Information, it may remain stored on backup or archival media for an additional period of time due to technical issues or for legal, tax or regulatory reasons, or for legitimate and lawful business purposes.
• You may have the right to restrict processing if one of the following applies:
  • The accuracy of the Personal Information is contested by the data owner;
  • The processing is unlawful, and the data owner objects to having their Personal Information erased, instead requesting that its use be restricted;
  • Your service provider no longer needs the Personal Information for the purposes of the original processing, but the data is required by the data owner for establishing, exercising or defending legal claims;
  • The data owner has objected to processing pending verification of whether the legitimate grounds of your service provider override those of the data owner.
• You have a right to object to any processing based on our legitimate interests where there are grounds relating to your particular situation. There may be compelling reasons for continuing to process your Personal Information, and we will assess and inform you if that is the case. You can object to marketing activities for any reason. If you wish to object to processing, you are required to contact Us at support@saver.one.

13. We are committed to protecting your privacy. Protecting your privacy online is an evolving area, and we are constantly evolving our Services to meet these demands. If you have any comments or questions regarding our Privacy Policy, or your Personal Information that we may be storing and using, please contact us at support@saver.one.
14. Dispute Resolution. The laws of the State of Israel govern this Privacy Policy. The competent courts in the district of Tel Aviv in Israel have exclusive jurisdiction with regard to any dispute that may arise in connection with this Privacy Policy.
15. You also have the right to lodge a complaint to your national data protection authority. However, prior to doing so, you are welcome to contact us by email as set forth above in order to resolve the issue for the benefit of all parties.
16. Our supervisory authority is the Israeli Data Protection authority. Contact information for EU Supervisory Authorities is available here: https://edpb.europa.eu/about-edpb/about-edpb/members_en .

Our Contact details:

Address:

Em Hamoshavot Rd 94, Petah Tikva

POB: 3644

Tel: 972-36520770

Email: support@saver.one

Last updated:  April 2023