Effectivate (“Effectivate”, “we”) is committed to maintaining the privacy of its users (“user”, “you”). The following information describes how Effectivate collects and processes information about you when you use our service through our website (the “Website”).

Our Privacy Policy explains:

• • What information we collect and why we collect it.
• • How we use that information.
• • Your rights with regard to the collection of such information.

By using our services through our Website, you agree to this Privacy Policy.

Effectivate provides an innovative platform, which combines digital exercise with artificial intelligence to create a designated personal cognitive training plan. We enable our users to strengthen their memory skills and develop their brains to their fullest potential (“service”).

Collecting Information

Please note that the scope of this Privacy Policy is limited only to information collected by Effectivate through your use of its service through the Website. Some information may be automatically collected, and some is collected when you interact with our Website. The type of information that may be automatically collected is non-personal information, which includes your session durations, the content you accessed on the Website, the frequency and scope of your use of the Website or service and information about your computer and internet connection including the operating system you use and browser type.

Information from which you can be personally identified may also be collected, including but not limited to your name, address, email address, telephone number and the location of the computer through which you used the Website (hereinafter: “Personal Information”). Personal Information shall be collected only if received voluntarily from you, including, without limitation, in the following methods:

1. a. Creating an account:

If you wish to use Effectivate’s services, you may contact us via the Website by submitting your name, phone number and email address and we will create an account for you (“Account”). After creating your Account, you will be required to choose a username and password that will enable your secured access to it.

1. b. Collecting information to be provided with the service:

When you wish to access your Account and use our service, you will be provided with a questionnaire regarding all the information we need to be able to create you your own cognitive exercise program. The information you will be requested to provide may include some health information and various habits you have, though we will only collect the information that you will chose to share with us.

1. c. Payment information:

We will collect your payment details to be able to provide you with our service. Such details will be kept secured and shall only be used for the purpose of the provision of the service.

1. d. Contacting us:

If you wish to contact us regarding any issue you may encounter with the Website or the service, we will collect the Personal Information included in your enquiry to be able to provide you with the support you require.

Use of Information

We use the Personal Information we collect from you for a range of different business purposes according to different legal bases of processing. We may use or process your Personal Information for the following purposes. One or more purposes may apply simultaneously.

1. 1. Providing the Requested Services:

• • We collect Personal Information to provide you with the service you contracted to receive. Such provision on service includes managing your personal cognitive program, making certain assessments and sending you relevant notifications regarding the operation of your Account and personal program.
• • Such collection of information will enable us to provide you with technical and professional assistance, with regard to the services you use or intend to use.

We process the Personal Information where it is necessary for the adequate performance of the contract for the provision of our services.

1. 2. Improvement and Development of the Services:

• • We collect Personal Information to improve and develop our Website and services and understand feedback on Effectivate’s Website and services.
• • We collect Personal Information for ongoing review and improvement of the information provided on our Website to ensure it is user friendly.
• • We collect Personal Information to improve the management and administration of our business and maintain compliancy with our internal policies and procedures.
• • We conduct surveys and research, test features in development, and analyze the information we have to evaluate and improve our services, develop new features, and conduct audits and troubleshooting activities.

We process this information in light of our legitimate interest in improving the Website and the service, to allow our users to have the best experience.

1. 3. Developing New Practices and Promoting Innovation:

• • We may collect non-personal Information for conducting research on cognitive behavior. Such non-personal information will be collected as aggregated, and the privacy of our users shall be maintained.
• • We will process such information to reach new conclusions, develop new practices and contribute to the progress of research development and innovation.

We process this information in light of our legitimate interest in improving our service by discovering new practices and promoting innovation in the field.

1. 4. Maintain a Safe and Secure Environment

We may use your information to detect and prevent fraud, abuse and security incidents in the following ways;

• • Verify and authenticate your identity and prevent unauthorized or illegal activity.
• • Enhance the safety and security of our Website and service.
• • Conduct security investigations and risk assessments.
• • Prevent or take action against activities that are, or may be, in breach of our terms of service or applicable law.

We process this information in light of our legitimate interest in improving our Website and service and enabling our users to browse in a secure environment.

1. 5. Personalize Content, Advertising and Marketing

• • If you have used Effectivate’s service in the past, we have a legitimate business interest for matching the data we collect with other data we had already collected.
• • This enables us to understand your needs and interests, optimize the content we send you and make it more suitable and relevant to your needs.
• • This also enables us to improve your experience on the Website by providing you with personalized content, recommendations, and features.

We process this information in light of our legitimate interest to personalize your experience and customize our content.

Disclosure of Information and Transfer of Data

Except as otherwise provided in this Privacy Policy, we reasonably attempt to ensure that we never intentionally disclose any of your Personal Information, to any third party without having received your permission, except as provided for herein or otherwise as permitted or required under law.

Third parties may be given access to your Personal Information when it is necessary to provide you with the services you requested to receive, or when such third parties are required to perform tasks on our behalf. We may share your Personal Information with our affiliates, subsidiaries or any third party companies and individuals to facilitate our services or any portion thereof, such as marketing, data management or maintenance services. In particular, we share your information with a cloud service provider, which enables us to save your data in a highly secured manner. We may also share your information with analytics service providers for analytics services. Such analytics service providers set their own cookies or other identifiers on your computer, through which they can collect information about your usage of our Website. This helps us compile aggregated statistics about the effectiveness of our Website and service.

The above mentioned third parties may be located in countries other than your own, and we may send them information we receive. When such third parties process your Personal Information on our behalf, we will assure that they comply with obligations similar to those which are set forth in this Privacy Policy. We will also assure that they will abide by our data privacy and security requirements and will be allowed to use the Personal Information solely for the purposes we set. We will transfer your Personal Information 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.

We may also transfer your information, including Personal Information, in connection with a corporate merger, consolidation, the sale of related assets or corporate division or other fundamental corporate changes. Furthermore, information about you may also be released in order to comply with any valid legal inquiry or process such as a search warrant, subpoena, statute or court order. We will also release specific information in special cases, such as if you use the Website or the service to perform an unlawful act or omission or take any act or omission that may damage Effectivate, its property and goodwill, or if there is an attempted breach of the security of the Website or a physical or property threat to you or others. The authority supervising such activities is the Israeli Privacy Protection Authority, and you have the right to file a complaint to it or any other relevant supervisory authority.

Your Rights

You have the right at any time to request to access or modify your information.

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 Information. Subject to such eligibility, you may have the following rights to:

1. 1. Request a rectification of your Personal Information where the information we hold about you is incorrect or incomplete.
2. 2. Object to the processing of your Personal Information for direct marketing purposes.
3. 3. Object to the processing of your Personal Information where our legal basis for that processing is that such processing is necessary for our legitimate interests.
4. 4. Object to an automated decision-making (including profiling) in certain circumstances.
5. 5. Request the erasure of your Personal Information in certain circumstances, such as where processing is no longer necessary for the purpose it was originally collected for, and there is no compelling reason for us to continue to process or store it;
6. 6. Receive your Personal Information or ask us to transfer it to another organization that you have provided to us, which we process by automated means, where our processing is either based on your consent or is necessary for the performance of a contract with you.

Generally, with regard to information collected on our Website, Effectivate is a “Data Controller”. Therefore, if you wish to exercise the above mentioned rights, please contact us, and we will make our best efforts to fulfill your request. If you wish to file a request regarding any of the above, you may contact us at: support@effectivate.org.

Cookies

We may use “cookies” and/or other technologies or files (collectively, “cookies”) to identify how visitors make use of this Website. This aggregated tracking information may be used to help us improve and enhance the Website experience for all of our visitors. In addition, cookies are used for adjusting the Website to your personal preferences. Cookies contain information such as the pages you visited, the length of time you stayed on the Website, the location from which you accessed the Website and more. If you would prefer not to have cookies stored on your computer, you may modify your browser settings to reject most cookies, or manually remove cookies that have been placed on your computer. However, by rejecting the cookies, you may be unable to fully access the offerings on this Website. To find out more about cookies, visit www.allaboutcookies.org.

Opt In or Opt Out

You are always in control of your data, and if you choose to receive information from us, or others, you can change your mind later. If, at any time, you would like to stop receiving such information or opt out of a feature, you may notify us by writing to support@effectivate.org. You should be aware, however, that it is not always possible to completely remove or modify information in our databases and servers, although we will always make reasonable efforts to do so upon your request.

Links to Other Websites

This Website may provide links to other websites. Please be aware that these other websites are not covered by our Privacy Policy. This Privacy Policy does not cover the information practices exercised by other providers of products or services, advertisers or other websites, companies or individuals, which are not owned or controlled by Effectivate. We suggest that when linking to another website, you always read that website’s privacy policy before volunteering any personally identifiable information.

Data Retention

Generally, Effectivate does not retain information longer than necessary to provide its services and for its reasonable business and lawful needs. If you withdraw your consent to us processing your data, we will erase your Personal Information from our systems, unless the data is required for Effectivate to establish, exercise or defend against legal claims or it is necessary for the performance of the requested services.

Children’s Privacy

The service is not intended for children under the age of 18. We do not, knowingly or intentionally, collect information about children who are under 18 years of age.

IF YOU ARE UNDER THE AGE OF 18 YOU MAY NOT USE THE SERVICE, UNLESS PARENTAL CONSENT IS PROVIDED ACCORDINGLY

Questions Regarding Our Privacy Policy

If you have any questions regarding this Privacy Policy or the practices described above, you are always welcome to contact us at support@effectivate.org.

Revisions and Modifications to our Privacy Policy

We reserve the right to revise, amend, or modify this Privacy Policy at any time. When changing the policy, we will update this posting accordingly. Please review this Privacy Policy often so that you will remain updated regarding our current policies.

Governing Law and Jurisdiction

This Privacy Policy will be governed and interpreted pursuant to the laws of the State of Israel without giving effect to its choice of law rules. You expressly agree that the exclusive jurisdiction for any claim or action arising out of or relating to this Privacy Policy shall be to the competent courts in Tel Aviv, Israel, to the exclusion of any other jurisdiction.

This page was updated on August 8, 2021.