Privacy Notice

1. Introduction

IceCure Medical Ltd., (“IceCure Medical” “we” or “us”) has created this Privacy Notice to demonstrate our firm commitment to secure and trustworthy internet commerce and the individual’s right to privacy. This Privacy Notice sets IceCure Medical’s privacy policies and practices in relation to information that is collected by us through [www.icecure-medical.com], and any web-pages included thereto (collectively: the “Website”).

We strongly urge you to read this Privacy Notice and make sure that you fully understand and agree to it. If you do not agree to this Notice, please discontinue and avoid Browsing and/or make any other use of the website.

Please review Section ‎4 below to understand what kind of Personal Data we collect.

• What is Personal Data?

As between our relations with you in connection with your use of the Website, “Personal Data” means any data, which may enable the identification of a specific person, or is otherwise linked to such potentially identifying data.

2. Your Consent

You do not have a legal duty to provide Personal Data and providing it is subject to your unconditional consent. Certain services (such as online inquiries) on our Website will not be available to those choosing not to provide the applicable Personal Data requested – regarding which you will be specifically prompted to provide the applicable information.

3. For What Purposes Do We Use Your Data?

We will use your Personal Data in the scope and manners to which we receive your consent; for complying with applicable law; and based on our legitimate interests in maintaining and improving our Website and the content included thereto, understanding how our Website is used, improving our customer service and support operations, and protecting and securing our users, ourselves and our Website, responding to your inquiries.

Accordingly, subject to receiving your consent, we use Personal Data in order to contact our users via e-mail with general and/or service-related messages, to respond to your inquiries, and assess suitability of your potential candidacy for open position with IceCure Medical.

Further Uses. For the removal of doubt, we may process your Personal Data in additional manners, pursuant to your explicit approval, if we are legally obligated to do so, or if we have successfully rendered such data non-personal and anonymous.

Non-Personal Data. We may share or otherwise use non-Personal Data in our sole discretion and without the need for further approval.

4. How Do We Collect Your Data?

We collect two main categories of Personal Data:

• Data Automatically Collected or Generated. When you visit, interact with or use our Website, including any e-mail sent to you by us, we may collect or generate technical data about you. We collect or generate such data either independently or with the help of third party services, including through the use of “cookies” and other tracking technologies (as further detailed in our cookies policy.

Such data consists of connectivity, technical or aggregated usage data, such as IP address, non-identifying data regarding the device, operating system, browser version locale and language settings used, the cookies and pixels installed on such device, and the activity (clicks and other interactions) of users of our Website.

We do not use such data to learn a person’s true identity or contact details, but mostly to have a better understanding on how our users typically use browse our Website. The use of such technical and device data also helps us and our partners to deliver contextual or otherwise more effective advertisements and content; to optimize our ad management and our users’ viewing experience, and to improve the overall user experience and functionality of our Website.

• Data Received From You

You may provide us Personal Data voluntarily, such as your name, e-mail address, phone number, location, position, business information, when you contact us.

Specifically, we will collect and store data you deliver us when applying to open positions via the Site (including your CV, in case you elect to share it with us) (“Candidate Data”).

If you choose to give us your e-mail address, we will communicate with you via e-mail. We do not share your e-mail address with others outside of IceCure Medical. Depending on how your email application is set up, information about your actions, use of the email sent by us, may be transmitted automatically when you receive, open and/ or click on an e-mail from IceCure Medical. In any event, you may opt out from receipt of any additional e-mails from IceCure Medical, at any time.

User Communications. The Website is not intended to serve as a platform for collection of medical or other related sensitive information about you. Thus, we urge you not to share any such information with us when communicating with us. Regardless of our data retention policies, we may remove from our records, at any time, any such sensitive information.

5. How Do We Retain and Store Your Data?

IceCure Medical Ltd. is located and operates under the jurisdiction of the State of Israel, which has been declared by the European Commission, on the basis of Article 45 of Regulation (EU) 2016/679 as a country outside the EU which offers an adequate level of data protection.

While privacy laws may vary between jurisdictions, IceCure Medical has taken reasonable steps to ensure that your Personal Data is treated by its affiliates and Service Providers in a secure and lawful manner, and in accordance with common industry practices, regardless of any lesser legal requirements that may apply in their jurisdiction.

In general, we retain your Personal Data for a period of 60 months; however, we may inform you via email of extending such period from time to time. However, Candidacy Data is retained by us for 9 months from receipt,.

Please note that except as required by applicable law, we will not be obligated to retain your data for any particular period and are free to securely delete it for any reason and at any time, with or without notice to you.

6. With Whom Do We Share Data?

We may share your data (including Personal Data) with certain third parties, including law enforcement agencies, our service providers and our affiliates – but only in accordance with this Privacy Notice:

• Compliance with Laws, Legal Orders and Authorities. We may disclose or allow government and law enforcement officials access to certain Personal Data, in response to a subpoena, search warrant or court order (or similar requirement), or in compliance with applicable laws and regulations, including for national security purposes. Such disclosure or access may occur with or without notice to you, if we have a good faith belief that we are legally compelled to do so, or that disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing.

• Service Providers and Business Partners. We may engage selected third party companies and individuals to perform services complementary to our own (hosting services, data analytics services, media sources, e-mail distribution and monitoring services, and our business, legal, financial and compliance advisors) (collectively: “Service Providers”). These Service Providers may have access to your Personal Data, depending on each of their specific roles and purposes in facilitating the purposes of our Website, and may only use it for such purposes.

A list of the Service Providers we currently engage that has access to your Personal Data can be viewed in the IceCure Cookie Policy, Last updated: November 8, 2021

• Protecting Rights and Safety. We may share your Personal Data with others, if we believe in good faith that this will help protect the rights, property or personal safety of IceCure Medical, any of our users or any members of the general public.

7. Security Measures

IceCure Medical maintains physical, electronic and procedural safeguards to help guard your Personal Data. We restrict access to personally identifiable information to those persons who need to know that information to provide products or services to you and any persons you have authorized to have access to such information. While we strive to protect your Personal Data, we cannot guaranty the security of any information you transmit to us.

8. Transfer of Personal Data Between the IceCure Medical LTD Entities / Service Providers

We may allow access to your Personal Data for the uses prescribed in this Privacy Notice, internally, between our group entities. In instances where Personal Data is collected from individuals within the EU, we will make sure that transfer outside EU borders (a) an EU Commission Adequacy Decision is in place, or (b) we have a legitimate interest of such transfer, and the recipient entity is bound by similar security measures that we apply, and further subject to the provisions of Section 5.

9. Your Rights Regarding Your Personal Information under GDPR

Please note that you may have certain rights regarding the manner of collection, processing and usage of your personal information pursuant to applicable privacy laws such as the EU General Data Protection Regulations (“GDPR”). Under the GDPR (to the extent it applies to you) you may be eligible for the following rights:

• Right to Access. You have a right to access your personal data that we process and receive a copy of it, by sending the request to the following e-mail address: DPO@icecure-medical.com

• Right to Rectification. You have the right to ask us to rectify inaccurate personal data concerning you and to have incomplete personal data completed.

• Right to Data Portability. You have a right to receive the personal data that you provided to us, in a structured, commonly used and machine-readable format. You have the right to transmit this data to a third party. Where technically feasible, you have the right that your personal data be transmitted directly from us to a third party you designated.

• Right to Withdraw Consent. You have the right to withdraw your consent for processing your personal data at any time. If you do that, we will not collect any further personal data, but we will further process the data we already collected for reasons described in this Policy. Withdrawing your consent will not affect the lawfulness of data processing we carried out based on your consent before such withdrawal.

• Right to Object. If you previously agreed that your personal data may be used for other purposes other than registering and/or placing an order, you may have a right to object to the use of your personal data for such additional purposes.

• Right to Restrict. You have the right to restrict processing of your Personal Data (except for storing it) if you contest the accuracy of your Personal Data, for a period enabling us to verify its accuracy; if you believe that the processing is unlawful and you opposes the erasure of the personal data and requests instead to restrict its use; if we no longer need the personal data for the purposes outlined in this Policy, but they are required by you to establish, exercise or defence relating to legal claims, or if you object to processing, pending the verification whether our legitimate grounds for processing override yours.

• Right to be Forgotten. Under certain circumstances, such as when you withdraw your consent, you have the right to ask us to erase your personal data. However, we may still process your personal data if it is necessary to comply with a legal obligation we are subject to under laws in EU Member States.

Please note that the above list contains a summary of the main rights you may have under the GDPR. Under no circumstances shall the above be deemed as an exhaustive list, nor should you rely on it in terms of fully understanding all of your rights under the GDPR.

Additional Information for users entitled to rights under GDPR:

Controller. IceCure Medical Ltd. is the data controller for the purposes of the personal data we collect via the Website and for the performance of the services offered through the Website.

10. Children

This Website is directed towards and designed for use by persons aged 16 and older. We do not solicit or knowingly collect Personal Data from children under the age of 16. If we nevertheless receive Personal Data from an individual who indicates that he or she is, or whom we otherwise have reason to believe is, under the age of 16, we will delete such information from our systems.

11. Links to Third Party Websites

The Website may contain links to other websites. While we try to link only to websites that share our respect for privacy, please be aware that IceCure Medical is not responsible for the privacy practices or the content of other websites. Websites that are accessible by hyperlinks from the Website may use “cookies.” We encourage you to read the privacy statements provided by other websites before you provide personally identifiable information to them.

12. Changes to this Privacy Notice

This Privacy Notice may change over time as we modify or expand our service. If we decide to change our Privacy Notice, we will prominently post those changes on this page. Your continued use of the Website after we post such notice constitutes your agreement to any such changes.

13. Contacting Us

If you have any questions about this Privacy Notice, or in the event that you wish to exercise certain rights you are eligible for with respect to your Personal Date, please contact us via the below online contact for. We welcome your questions and suggestions about our Privacy Notice.

Contact Information:

By mail: Ha’Eshel St, PO BOX 3163, Caesarea, 3079504, Israel

By email: icecuresupport@icecure-medical.com (kindly state the nature of your inquiry at the subject line of the email)

Physical address: Ha’Eshel St, Caesarea, 3079504, Israel