Eye-Net^TM
Privacy Policy

Valid as of: 28 September 2022

Welcome to Eye-Net’s Privacy Policy.

Eye-Net Mobile Ltd. and anyone on our behalf (herein “we” or “us“) respect your privacy and are committed to protecting your personal data.

The Eye-Net SDK and the Eye-Net SDK Reference App (herein – the “Service“) offer you notifications for certain instances, which are detailed in our documentation and in any other relevant platform on our Service or website.

This Privacy Policy will help you understand what types of personal and non-personal information we collect, how we collect it, how we process it, and how we anonymize it. It further explains why we cannot update, manage, or delete it due to anonymization, and how you can contact us regarding any privacy issue.

This policy is incorporated and considered as part of our Terms of Use. Your use of the Service is subject to said Terms of Use and this Privacy Policy, and your use of the Service indicates your consent to these respective terms.

1. THE PERSONAL DATA WE COLLECT

The term Personal Data in this Policy means any information that you supply by which you may be identified.  It does not include data where the identity has been removed (anonymous data), statistical data, or aggregated data.

When you operate our Service, we generate a random unique identifier which remains valid until you uninstall the Application. We do not collect your name, phone number, email, or any other data that identifies you.

We may collect, use, store, and transfer different kinds of personal data which we have grouped together subject to our interaction. The information outlined below will be connected only to the unique identifier and not to any other personal data:

• IP address: which is the internet protocol address.
• Technical Data: such as device type, operating system version, time zone setting and localization, and similar information.
• Location Data:such as GPS and similar location data from your relevant device. Depending on your application specification and/or your selected device settings, we may collect information about your location while the application is running in the background.
• Activity data: such as speed or type of movement and various device sensors’ data, including accelerometer, gyro, magnetometer, etc.
• Interactions with us: If at any time you contact us or interact with us, this data is collected and saved in order to better serve you. We also monitor all communications with our servers.

We collect Data only if it is specifically required to do so in order to provide you with our Service.

2. PURPOSES FOR COLLECTION OF DATA

Your Personal Data will be used only for the following purposes:

• Delivering our Services to you and our users, mainly to improve road safety for you and other road users. This may also include any integration with third party devices or programs (such as navigation applications, car-manufacturers’ application, and similar third-party applications).
• Maintaining and improving our Service and handling any malfunction.
• Communicating with you as needed.
• Big data processing or statistical analysis, in aggregate, de-identified, form. 

We may also use your Personal Data in order to: (i) enforce our Terms of use, (ii) contact you, (iii) comply with law agencies or court decisions, (iv) detect abuse or fraud, and (v) in order to take action in any relevant legal dispute or proceedings.

We have set out below a description of the ways we may use your Personal Data, and which legal bases we rely on. Where appropriate, we have also identified what our legitimate interests are.

Consent means you have been given notification of the collection and its scope for each purpose detailed upon collection, and you agree to anything herein by accepting this Privacy Policy.

Our legitimate interest may include any of the following: providing and improving our services, developing new services, understanding the use of our Service and services, customizing our services, marketing our services, detecting and preventing fraud or misuse, protecting our users from harm of any manner, performing research based on our data and aggregated data, fulfilling our obligations to our third party partners (such as vehicle manufacturers, navigation applications, developers, right holders, etc.), enforcing our Terms of use or any other legal action or proceedings.

Performance of a contract means performing the service we undertook to perform on our Terms of use.

Protecting your vital interest may include any notification of an irregularity we may decide at our own discretion that is significant.

3. HOW DO WE COLLECT YOUR PERSONAL DATA?

We collect your personal data through the device you use our Service with or from third parties (such as the applications our Services may be embedded within).

We may also record and save any correspondence or connection by email, telephone, customer’s service, etc.

4. DISCLOSURES AND SHARING OF YOUR PERSONAL DATA

Where Eye-Net is a standalone application, we do not share your Personal Data with anyone except ourselves (employees and contractors).

Where our Service is not a standalone application, but is embedded in an application or product, we may share your Personal Data with the application operator, and the use of your Personal Data will be further subject to their privacy practices and policies.

Except for the above, If we share data, no personal data will be shared. However, statistical, aggregated, or anonymized data may be shared.

We store your Personal Data on cloud platforms such as Google cloud, Mongo DB, Cassandra DB, Elasticsearch, or other services which may replace them. We also use third parties to analyze the collected data, primarily but not solely in a statistical manner.

For the purposes set out in the table in Paragraph 2, we may have to share or disclose your Personal Data with the following parties:

• Employees of our company and third-party suppliers or processors, in order to achieve the Purpose per each specific data. For example, we may give you notification through the application in which our Service is embedded within, the identity controlling such application will be receiving our notice.
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your Personal Data in the same way as set out in this Privacy Policy.
• Third parties that operate their servers as controllers of our collected Personal Data, subject to an agreement that protects your privacy.
• The third-party application or product which offers the Eye-Net SDK as an embedded service.
• We require all third parties to respect the security and privacy of your Personal Data and to treat it in accordance with the law. We do not allow our third-party service providers to use your Personal Data for their own purposes, and only permit them to process your Personal Data for specified purposes in accordance with our instructions.

5. CONTROLLING YOUR PERSONAL DATA

Please note: Your Personal Data is not linked to you personally, but only with a random unique identifier generated when you first use the Service. This means that if you use different devices, remove the Service (by removing the application, or an application in which it is embedded) from your device, or clear the data on your device, the data will cease to be associated with the identifier.

Additionally, we remove the connection between the unique identifier and the Personal Data within thirty (30) days after its collection, thus anonymizing the Personal Data.

6. AGGREGATED DATA

We use anonymous, statistical, or aggregated information (including anonymous location information) in various ways, such as to operate our services and improve them to better serve you and other users. Such data may also be shared with third parties at our discretion. For example, aggregated location data may be used to alert all our users that a certain route may be backed-up and they should consider other routes.

7. THIRD-PARTY LINKS

We cannot and have not reviewed all third-party links which may be connected to our Service and therefore cannot be liable for their content. Use links to other Websites or applications at your own risk and use such sites according to their terms and conditions of use. 

8. INTERNATIONAL TRANSFERS

We store our information and data on cloud-servers located in various countries such as the Netherlands, so your personal information may be located outside your country. As privacy and protection of data laws may vary in different countries, we have adopted a unified approach that shall protect all of our data bases and transfers. We will transfer your Personal Data while using appropriate and suitable safeguards, while using a variety of legal mechanisms, including contracts, to ensure your rights and protections travel with your data.

9. DATA SECURITY

We consider the security of our data a top priority. Therefore, we use appropriate security measures in order to prevent your Personal Data from being accidentally lost, used, altered, disclosed, or accessed in an unauthorized way.

In addition, we limit access to your Personal Data (as our data bases are password protected) only to employees, agents, contractors and other third parties who may need access for the Purpose stated herein. They will only process your Personal Data upon our instructions, subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

However, please note that these security measures cannot provide absolute assurance that mishaps will not happen. We cannot guarantee that our database will be protected from any wrongdoers, malfunctions, improper access or any other kind of misuse or abuse.

10. DATA RETENTION

HOW LONG WILL YOU KEEP AND USE MY PERSONAL DATA FOR?  

As to the information we collect, your IP address will be deleted after seven (7) day period of their collection. Location and sensors data will be deleted after a period of one (1) year after its collection.

The rest of the information we collect will be disconnected from your unique identifier thirty (30) days after you cease using our Services or delete our Service (or the application it is embedded in) from your device.

Please note that when the data is turned into statistical or aggregated data, we do not delete it and we may sell it, without identifying data.

11. YOUR LEGAL RIGHTS

You have the right at any time to request to access or modify your information. To exercise these options, please contact us at support@eyenet-mobile.com .

In some jurisdictions, in particular those located within the European Union (the “EU”) or within the European Economic Area (the “EEA”), you may be afforded specific rights regarding your Personal Data. Subject to such eligibility, you may have the following rights to:

• Request access to your personal data.
• Request correction of your personal data.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Right of personal data portability.
• Right to withdraw consent.

Please note that we highly respect your privacy rights. For this purpose, we have designed our service with your privacy on our minds (“Privacy by Design”). Thus, on an ongoing and repetitive basis, we anonymize your Personal Data and disconnect it from your unique identifier within thirty (30) days of its collection.

Additionally, we supply this service without registration or the requirement of other identifying data. This protects your privacy and your personal data and does not enable us to identify specific users and respond to such SARs.

Due to these choices to protect your privacy, we will most likely be unable to exercise your rights above, but only because we will hold no such personal information within thirty (30) days of its collection. At that time, all the information we hold will not be connected with your unique identifier.

For further review of privacy rights under the GDPR, click on the link below: https://gdpr-info.eu/chapter-3/.

We will not charge fees as you exercise your rights. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

TIME LIMIT TO RESPOND  

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. Please note that at the time of the response, we may no longer hold any personal information.

12. PERSONAL DATA OF CHILDREN

We do not knowingly collect or solicit Personal Data from anyone under the age of 16. If you are under 16, please do not attempt to use the Service or the Services. If we learn that we have collected Personal Data from a child under age 16, we will delete that information as quickly as possible. If you believe that a child under 16 may have provided us Personal Data, please contact us at dpo@eyenet-mobile.com.

13. Controller of Personal Information

Eye-Net Mobile Ltd. With its address at5  Golda Meir St., Ness Ziona, Israel, is the data controller of personal information collected or processed through the Eye-Net Offering.

14. CONTACT US

If you have any questions regarding your personal data or concerns about this Policy, feel free to contact us at our email address dpo@eyenet-mobile.com  by telephone No.: 972-74-7745745. Any requests, complaints, or questions may be sent to support@eyenet-mobile.com .  

You may also contact us to change or delete any inaccurate data we may hold. We will do our best to deal with your questions or complaints in a swift and friendly manner.