Privacy Policy - SoniVie

SoniVie Privacy Policy

Last updated: January 2025

This Privacy Policy describes how SoniVie Ltd. (together with its affiliates – “SoniVie”, “we”, “our” or “us”) processes information about an identified or identifiable individuals (“personal data” and “data subjects”, respectively). Specifically, this policy covers our processing of personal data relating to the following categories of data subjects:

Individuals who visit or otherwise interact with our website, available at www.sonivie.com, or any other website, webpage, e-mail, text message or online ad under our control (“Visitors” and “Sites”, respectively);
Individuals who interact with us, whose personal data (such as their contact details) is processed by us as a part of our business relationship or engagement. This includes, for example, staff of hospitals who host our clinical trials or personnel of our service providers who engage with us (“Business Contacts”);

The activities described above are the “Services” to which this Privacy Policy applies. If you are a participant (or a prospective participant) in any of our clinical trials, who has been already accepted to participate in a clinical trial, please refer to your Informed Consent Form. If you are a prospective clinical trial participant, please refer to the specific privacy policy applicable to you. You can contact us at privacy@sonive.com for more information.

Please read this Privacy Policy and make sure that you fully understand and accept it. If you object to this policy, please avoid or discontinue using our Services.

You are not legally required to provide us with any personal data, and may do so (or avoid doing so) on your own free will. If you do not wish to provide us with your personal data, or to have it processed by us or any of our Service Providers (as described in Section 3 below), please avoid any interaction with us or any use of our Services.

This Privacy Policy describes our practices regarding –

Collection of your Personal Data
Use of your Personal Data
Data Disclosure
Data Retention and Location
Tracking Technologies and Cookies
Security of your Personal Data
Communications
Data Subject Rights
Data Controller/Processor
Additional Notes

1. Collection of your Personal Data

We collect various types of personal data regarding Visitors and Business Contacts. Such data is typically collected or generated through your interaction with us or our Services, through automatic means, directly from you or through third parties. We and our Service Providers collect and process the following categories of personal data:

Personal details of Visitors and Business Contacts, such as names, company, position, contact details, professional experience, preferences, and interests. We may collect such data directly from you or from third parties (for example, if you participate in an event, webinar, or promotion that we sponsor or participate in, we may receive your personal data from its organizers). We may also receive your personal details described above from our business partners or Service Providers (as described in Section 3 below), and through the use of tools and channels commonly used for connecting between companies and individuals in order to explore potential business and employment opportunities, such as LinkedIn and other similar platforms.

Usage data which is collected automatically when you use our Services. Usage data may include information such as your device’s Internet Protocol address (i.e. IP address), browser type, browser version, operating system, the type of device used, the pages of our Site that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data. We may also collect information that your browser sends whenever you visit our Sites or when you access them by or through a mobile device. Such data may be collected through the use of analytics tools (e.g., Google Analytics) or cookies, as described below in Section 5 below.

2. Use of your Personal Data

We use personal data as necessary for the following purposes, and in reliance on the lawful bases noted below:

Purpose	Lawful Bases
To provide and maintain our Services.	Legitimate Interest
To monitor, study and analyze the use of the Services, and to gain a better understanding of how individuals use and interact with our Services, and how we could improve their user experience and the overall performance of our Services.	Legitimate Interest
To contact you by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application’s push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation. To contact you with general or personalized service-related messages, as well as promotional messages that may be of specific interest to them.	Legitimate Interest Performance of a Contract (to the extent applicable) Consent (for sending promotional messages, to the extent applicable)
To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information.	Legitimate Interest
To attend and manage your requests to us, including the provision of support.	Legitimate Interest
To support and enhance our data security measures, including ‎for purposes of preventing and mitigating the risks of fraud, ‎error, or any illegal or prohibited activity.‎	Legitimate Interest Performance of a Contract (to the extent applicable) Compliance with legal obligations
To comply with court orders and warrants, and prevent misuse of ‎the Services, and take any action in any related legal dispute ‎and proceeding.‎	Legitimate Interest Performance of a Contract (to the extent applicable) Compliance with legal obligations
To comply with applicable laws and regulations.	Compliance with legal obligations

We do not sell your personal information for the purposes of the California Consumer Privacy Act (CCPA). If you reside or are interacting with the Services in a territory governed by privacy laws under which “consent” is the only or most appropriate legal basis for processing personal data (in general, or specifically with respect to the types of personal data you choose to provide via the Services), your acceptance of our Terms of Use and of this Privacy Policy will be deemed as your consent to the processing of your personal data for all purposes detailed in this Privacy Policy. If you wish to revoke such consent, please contact us by e-mail at privacy@sonive.com.

3. Data Disclosure

We may disclose your personal data in the following situations:

With Service Providers: We may disclose your personal data to selected third-party companies and individuals to perform services complementary to our own. Such service ‎providers include hosting and server co-location services, communications, and content ‎delivery networks (CDNs), data and cyber security services, billing and payment processing ‎services, fraud detection and prevention services, web analytics, e-mail distribution, marketing ‎and monitoring services, session or activity recording services, remote access services, ‎performance measurement, data optimization and enrichment services, social and advertising ‎networks, content providers, e-mail, voice-mails, support and customer relation management ‎systems, and our legal, compliance and financial advisors (collectively, “Service Providers“). ‎
For business transfers: We may disclose or transfer your personal data in connection with, or during negotiations of, any merger, sale of our assets, financing, or acquisition of all or a portion of our business to another company. If the Company is involved in a merger, acquisition or asset sale, your personal data may be transferred. We will provide notice before your personal data is transferred and becomes subject to a different Privacy Policy
With affiliates: We may disclose your personal data to our affiliates, which will be required to use only in accordance with the data processing agreements we have with them. Affiliates include our parent company and any other subsidiaries, joint venture partners or other companies that we control or that are under common control with us.
With business partners: We may share your information with our business partners to offer you certain products, services or promotions.
With other users: when you share personal data or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside. If you interact with other users or register through a Third-Party Social Media Service, your contacts on the Third-Party Social Media Service may see your name, profile, pictures and description of your activity. Similarly, other users will be able to view descriptions of your activity, communicate with you and view your profile.
Law enforcement: Under certain circumstances, SoniVie may be required to disclose your personal data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
Other legal requirements: SoniVie may disclose your personal data in the good faith belief that such action is necessary to: comply with a legal obligation, protect and defend the rights or property of SoniVie, prevent or investigate possible wrongdoing in connection with the Services, protect the personal safety of individuals using the Services or the public, or protect against legal liability.

4. Data Retention and Location

Data Retention. SoniVie will retain your personal data only for as long as is necessary for the purposes set out in this Privacy Policy and to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies. SoniVie will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Services, or we are legally obligated to retain this data for longer time periods.

Data Location. Your personal data is processed by SoniVie and our Service Providers in Israel and USA and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.

SoniVie is headquartered in Israel, a jurisdiction which is considered by the European Commission as offering an adequate level of ‎protection for the personal data of EU Member State residents. ‎

While privacy laws may vary between jurisdictions, SoniVie and its affiliates and Service ‎Providers are each committed to protecting personal data in accordance with this Privacy ‎Policy and customary industry standards, and such appropriate lawful mechanisms and ‎contractual terms requiring adequate data protection, regardless of any lesser legal ‎requirements that may apply in their jurisdiction. For data transfers from the European ‎Economic Area (EEA), the UK, or Switzerland to countries that are not considered to be ‎offering an adequate level of data protection, we and the relevant data exporters and importers ‎have entered or will enter into standard contractual clauses as approved by the European Commission, the ‎UK, or Switzerland. You are entitled to request a copy of the standard contractual clauses used ‎in these cases, and may do so by contacting us at privacy@sonivie.com. ‎

SoniVie will take all steps reasonably necessary to ensure that your personal data is treated securely and in accordance with this Privacy Policy and no transfer of your personal data will take place to an organization or a country unless there are adequate controls in place including the security of your personal data.

5. Tracking Technologies and Cookies

The website utilizes certain web monitoring and tracking technologies (i.e., cookies), which are used to maintain, provide, improve and analyze our website and services. Cookies are small files containing a string of characters that are stored on your computer or mobile device through the browser. Such cookies collect information such as your IP address, geolocation, type of device, browser, operating system, screen resolution, browsing origin, time and duration of visit, pages visited, and the number and frequency ‎of your visits. Cookies may be set up for the duration of your visit (session cookies) or for longer periods (persistent cookies). The length of time a persistent cookie stays on your device varies between cookies, depending on their functionality. They may be set up by us (first-party cookies) or by third-party providers who work with us (third-party cookies). Please note that our access to and control over such third-party cookies, beyond the scope of our services, is limited and subject to such other websites, services and providers’ own terms and policies. You are not obligated to accept all cookies in order to use our services. However, enabling cookies may allow for a more personalized browsing experience and is required for most of our Services to work properly

We use cookies of the following categories:

Necessary / Essential Cookies: These cookies are necessary to provide you with our services, and cannot be disabled through our cookie management tools. Without them, the basic functions of our services will not work.
Analytics: These cookies are used for gathering analytics data on how you interact with our services so that we can improve their performance accordingly. Without these cookies, our ability to improve your user experience and that of others will be reduced. You can choose not to enable analytics cookies through our cookie management tool on our website. Our analytics cookies are utilized by Google Analytics. They help us understand users’ behavior on our website, including by tracking page content, and click/touch, movements, scrolls and keystroke activities. Further information about the privacy practices of Google Analytics is available at: google.com/policies/privacy/partners/. Further information about your option to opt-out of Google Analytics is available at: https://tools.google.com/dlpage/gaoptout.

Please note that if you get a new device, install a new browser, erase or otherwise alter your browser’s cookie file (including upgrading certain browsers), you may also clear the opt-out cookies installed once you opt-out, so an additional opt-out will be necessary to prevent additional tracking.

To learn more about the specific cookies we use, please click the ‘Consent Preferences’ widget available on our website’s footer. You can always withdraw your consent to the use of non-necessary cookies (e.g., analytics cookies) by re-opening the cookie banner using the widget and modifying your selection.

6. Security of your Personal Data

The security of your personal data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal data, we cannot guarantee its absolute security.

7. Communications

We and may use your personal data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt-out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send or by contacting us at privacy@sonivie.com.

8. Data Subject Rights

If you wish to exercise your rights under laws applicable to you, including the EU or UK General Data Protection Regulation (GDPR), such as the to request access to, and rectification or erasure of your personal data held with SoniVie, and the right to object at any time to processing of personal data concerning you which is based on our legitimate interests as detailed in Section 2 above (each to the extent available to you under the laws which apply to you) – please contact us by e-mail at privacy@sonivie.com.

Please note that once you contact us by e-mail, we may require additional information and documents, including certain personal data, in order to authenticate and validate your identity and to process your request. Such additional data will be then retained by us for legal purposes (e.g., as proof of the identity of the person submitting the request), in accordance with Section 3 above. If you make a request, we will try our best to respond to you as soon as possible.

If you are a GDPR-protected individual, you also have the right to lodge a complaint with the relevant supervisory authority in the EU or UK (as applicable to you).

9. Data Controller/Processor

Certain data protection laws and regulations, such as the GDPR or the CCPA, typically ‎distinguish between two main roles for parties processing personal data: the “data controller” or “business”, ‎who determines the purposes and means of processing; and the “data processor” or “service provider”, who ‎processes the data on behalf of the data controller. Below we explain how these roles apply to ‎our Services, to the extent that such laws and regulations apply.‎

SoniVie is the “data controller” of personal data relating to its Visitors and Business Contacts. With respect to such data, we assume the responsibilities of data ‎controller (solely to the extent applicable under the law), as set forth in this Privacy Policy. In ‎such instances, our Service Providers processing such data will assume the role of “data ‎processor”. ‎

10. Additional Notices

Links to Other Websites. Our Services may contain links to other websites that are not operated by us. If you click on a third party link, you will be directed to that third party’s site. We strongly advise you to review the privacy policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Changes to this Privacy Policy. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page. If we make material changes to this Privacy Policy which in our discretion may affect your personal data, we will notify you as appropriate under the circumstances.

Our Services are not designed to attract children who are minors. We do not knowingly collect personal data from children and do not wish to do so. If we learn that a person who is to be considered as a minor, according to the applicable law, we will attempt to prohibit and block such use and will make efforts to promptly delete any personal data stored with us with regard to such minor. If you believe that we might have any such data, please contact us at privacy@sonivie.com.

Contact Us. If you have any questions about this Privacy Policy, you can contact us via email at privacy@sonivie.com.

Data Protection Officer: SoniVie has appointed PrivacyTeam Ltd. as its Data Protection Officer (DPO), for monitoring and advising on SoniVie’s ongoing privacy compliance and serving as a point of contact on privacy matters for data subjects and supervisory authorities. If you have any comments or questions regarding our Privacy Policy, if you have any concerns regarding your privacy, or if you wish to make a complaint about how your personal data is being processed by SoniVie, you can contact dpo@sonivie.com.

EU Representative. SoniVie International SAS has been designated as SoniVie’s representative in the European Union for data protection matters pursuant to Article 27 of the GDPR. SoniVie International SAS may be contacted only on matters related to the processing of personal data of EU residents. To make such an inquiry, please contact SoniVie International SAS by email at [dpo@sonivie.com ], or by post at [SONIVIE INTERNATIONAL SAS, 2 Place de Rio de Janeiro – 75008 Paris – France].