Privacy Policy​

Recently updated: November 24, 2021

This privacy policy (“Privacy Policy” or “Policy”), governs PolyPid Ltd.’s (“PolyPid,” “we,” “us,” or “our”) practices with respect to the processing (i.e., usage, storage, transferring, etc.) of certain data, including Personal Data and PHI (as both terms are defined below and as applicable) from our business partners (“Partners“), prospective Patients (as such term is defined below) (“Prospective Patients“) potential employees (“Potential Employees“), investors or shareholders (“Investors“) and individuals who access or use our website, available here (“Visitors“) (collectively, “you,” or “your”).

In the event you are a resident of California, the California Consumer Privacy Act (“CCPA”) may apply to you. Please review our CCPA Privacy Notice to learn more about our privacy practices with respect to the CCPA.

In the event you enroll in one of PolyPid’s clinical trials (“Patient“), we may collect and process additional information about you then what is listed in this Privacy Policy (“Patient’s Information“), which will be described in detail in the Informed Consent Form (“ICF”) that you will receive and review prior to your enrollment in the study. This Policy does not apply to the processing of such Patient’s Information. As a Patient you may be entitled to certain rights under applicable data protection laws, these rights are also explained in the ICF. Please contact your physician or the principal investigator of the applicable clinical trial for more information.

Please note, that our website may contain links to other websites, products or services offered by third parties, which are not governed by this Policy. In the event you click on any links to third party landing pages, registration pages or websites, their privacy practices may differ from ours, and are not under our control or responsibility, nor are we obligated to monitor them. We advise you to review the applicable privacy policy of these third parties, before interacting with such third party pages or websites.

• POLICY CHANGES AND UPDATES

We may update or revise this Policy from time to time. Modifications to this Policy will be posted on the website, and shall be effective as of the date reflected under the “Recently Updated” header above. We encourage you to periodically review this Policy in order to remain informed regarding our practices related to the collection and processing of your Personal Data.

• THE DATA WE COLLECT

Depending on your interaction with us, we may collect the following types of data:

• “Non-Personal Data”: means non-identifiable, aggregated data, that is mainly technical data which is transmitted to us by your device when you access and interact with our website, such as (without limitation) for example: types of browsers, type of operation system, type of device used, the time and date you accessed the website, how you navigated the website and the actions you took while on the website, your language preference, and country level location, etc. Non-Personal Data is used mainly for click stream analysis in order to provide, maintain, develop and enhance our website and the services that may be provided therein (if applicable), and is not used to identify individuals.
• “Personal Data”: means individually identifiable information which identifies or may identify, with reasonable effort, an individual, including online identifiers, such as your IP (internet protocol) address (i.e., a unique address that identifies your device on the internet or a local network). For the purposes of this Policy, Personal Data will also include Protected Health Information (“PHI“), which is information that may identify an individual and that relates to such individuals past, present, or future physical or mental health or condition, the provision of health care products and services to such individual or payment for such services, all as defined under the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”).

Personal Data Processed by us

We may collect the following Personal Data, and process it in accordance with the purposes and legal bases specified in the table below.

Data We Process From Visitors:

In addition to the Personal Data included in the Visitors table above, if you are an Investor or a Partner, we may also process the Personal Data included in the Investor and Partner table below.

Data We Process From Investors or Partners:

• HOW PERSONAL DATA IS COLLECTED

Certain Personal Data is collected automatically by using cookies and other similar tracking technologies, while other Personal Data is provided by you voluntarily and actively, for example, when you contact us.

• COOKIES & TRACKING TECHNOLOGIES

As stated above, when you access our website we or our third party’s service providers, may use “cookies” or other similar technologies or methods of web and mobile analysis to gather, store and track certain information related to your access, activity and interaction with our website.

A “cookie” is a small piece of information that a website assigns to your device while you access such website. Cookies are very helpful and may be used for a variety of different purposes. These purposes include, among other things, allowing you to navigate between pages efficiently, enabling automatic activation of certain features, remembering your preferences and making the interaction between you and our website quicker, easier and smoother. You can find out more information about cookies at www.allaboutcookies.org.

We use the following third-party cookies on our website:

Please click here for more information regarding our use of Google products.

Please note that most browsers will allow you to erase cookies from your device, block acceptance of cookies, or receive a warning before a cookie is stored through your device or browser settings. However, if you choose to disable cookies, some features of our services may not operate properly and your online experience may be limited.

• SHARING DATA WITH THIRD PARTIES

We will not share any Personal Data collected from you with third parties or any of our partners except under the following circumstances:

• Compelled Disclosures – To satisfy any applicable law, regulation, legal process, subpoena or governmental request;
• Enforcement of our Rights – To enforce this Policy and the terms of our agreements, including the investigation of potential violations thereof;
• Security Detections -To detect, prevent, or otherwise address fraud, security or technical issues;
• Business Transfers and Affiliated Companies – When it is undergoing any change in control, including by means of a merger, acquisition or purchase of all or substantially all of its assets or with our parent company, any subsidiaries, joint ventures, or other companies under common control with PolyPid solely if and when applicable or necessary for the purposes described in this Policy, or in the event of any of the corporate transactions listed herein;
• Service Providers and Legitimate Business Purposes – To collect, hold or manage your Personal Data through our authorized third-party service providers or clinical trial staff (including our CRO), as reasonable for our business purposes;
• Explicit Consent – If you provide us with your explicit approval to share your information prior to the disclosure.

• USER RIGHTS

We acknowledge that different people have different privacy concerns and preferences. Our goal is to be clear about what information we collect, so that you can make meaningful choices about how it is used. We provide you with the ability to exercise certain choices, rights and controls in connection with your information. Depending on your relationship with us and the applicable data protection and privacy laws that apply to you, you may exercise all or certain of the following rights:

• The right to access your Personal Data that we process;
• The right to ensure your Personal Data is accurate, complete and up to date;
• The right to have your Personal Data amended (by correcting, deleting or adding information);
• The right to object to the processing of your Personal Data, to the extent applicable;
• The right to send or “port” your Personal Data;
• The right to file a complaint with a supervisory authority in your jurisdiction;
• The right to withdraw consent, subject to legal or contractual restrictions and reasonable notice;
• The right to be informed;
• The right to Non-Discrimination.

You may exercise any or all of your above rights in relation to your Personal Data by filling out the Data Subject Request (“DSR”) form available here and sending it to our privacy team at: privacy@PolyPid.com or by clicking the “send” button on our online DSR form.

Where we are not able to provide you with the information for which you have asked, we will endeavor to explain the reasoning for this and inform you of your rights, including the right to complain to the supervisory authority (in the event that you are an EEA (as such term is defined below) resident). We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any such information in accordance with applicable law.

• DATA RETENTION

We retain the information we collect as long as it remains necessary for the purposes set forth above, all in accordance with applicable laws. We may at our sole discretion, delete or amend information from our systems, without providing any notice to you, once we deem it is no longer necessary for our purposes.

• SECURITY

We employ industry standard and implemented technical and administrative security measures to ensure the safety of your Personal Data and in order prevent unauthorized access or use of such Personal Data.  For more information regarding our security measures, please click here.

Please contact us at: privacy@PolyPid.com if you feel that your privacy was mistreated or treated in a way that is contrary to this Policy.

• CHILDREN

Our website is not intended for use by individuals who are under the age of eighteen (18). Therefore, PolyPid does not intend and does not knowingly collect any Personal Data directly from individuals who are considered to be children in their jurisdictions (i.e., under the age of sixteen (16) or as otherwise defined under applicable law in such jurisdiction), and does not wish to do so. If you are under 18, please be sure to read the terms of this Policy with your parents or legal guardian. If we obtain actual knowledge that you are considered a child under applicable law, we will take steps to immediately delete your Personal Data. We request that such individuals do not provide Personal Data through our website. Please contact us at: privacy@PolyPid.com if you become aware or have any reason to believe that a child has shared any Personal Data with us.

• DATA TRANSFER

We may store or process your Personal Data in in the EU, the United States or in other countries. Thus, any information you provide us may be transferred to and processed in countries other than the country from which you accessed our website. We will take appropriate measures to ensure that your Personal Data receives an adequate level of data protection upon its transfer. When Personal Data that was collected within the European Economic Area (“EEA”) is transferred outside the EEA, we will take necessary steps in order to ensure that sufficient safeguards are provided during the transferring of such Personal Data. You may exercise your rights, where applicable, to receive information regarding the transfer mechanism that was used during such transfer. Personal Data transferred outside the EEA that is transferred to a country which has not received an adequacy decision from the European Commission, will be transferred in all cases pursuant to the standard contractual clauses approved by the European Commission.

• CONTACT US

If you have any questions or concerns regarding privacy issues, or if you wish to be provided with any other information related to our privacy practices, please contact us at: privacy@PolyPid.com.

PolyPid Ltd. (Headquarters)

• 18 Hasivim Street, P.O Box 7126, Petach Tikva, Israel 4959376
• Phone: +972-74-719-5700

PolyPid Inc.

• 47 Maple St. Suit # 302A, Summit NJ 07901
• Phone: (908) 858-5995

Data Protection Officer:

Please contact our Data Protection Officer at: dpo@PolyPid.com if you have any requests regarding the Personal Data collected under this Policy, including without limitation, requests to remove, delete, amend, modify or transfer the data.

Please include your name, address and email address in any correspondence so that we can respond to your inquiry or request.

Data Protection Representative: Our Data Protection Representative is located in Romania and his contact information is as follows:

Name: Excellence Clinical Services SRL

Address: 3 Constantin Nottara Str., Bucharest 3^rd District, Romania

Email: dpr@excellencesmo.com

Supervisory Authority: The Romanian National Supervisory Authority for Personal Data Processing