Please read this Privacy Policy carefully and make sure that you fully understand it.

You are not legally required to provide us with any personal data. 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 (defined in Section 5 below), please avoid any interaction with us or with our Site, or submit a request to exercise your rights as further explained in Section 9 below.

1. Data Collection

We collect and generate the following types of personal data concerning our Visitors and Business Contacts:

· Site Usage Data: Connectivity, technical and aggregated usage data, such as user agent, IP addresses, device information (like type, OS, device ID, browser version, locale and language settings used), connectivity data, activity logs, communication and performance logs, session recordings, issues and bugs, and the cookies and pixels installed or utilized on our Site and/or your device;

· Business Contact Data: Data relating to individuals who are employed or engaged by our prospective or current business customers and partners, which we may collect in the following ways –

o Direct interactions and communications with us: Data you provide when submitting an online form on the Site, including the “Contact Us”, “Request a Demo” and support-related “Customer Community” forms (such as your name, title, medical specialty, e-mail address, phone number, country, and zip code), or when interacting with us through any other means, including surveys, feedbacks, transcripts, and analysis thereof. In this respect, please do not provide us with any personal data or sensitive data which is not required for us to process your request or inquiry;

o Data received from third parties: We may receive personal data concerning you from other sources. 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 contact and professional details (e.g., your name, company, position, country, contact details, professional experience, preferences and interests) from our business partners or Service Providers (defined in Section 5 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 data sources.

We collect such data either automatically, through your interaction with us or with our Site, or through third-party services, social media, analytics tools, events we organize or participate in, and other business initiatives.

2. Data Uses

We use Visitors and Business Contacts’ personal data as necessary for the following purposes and in reliance on the following legal basis:

Site Usage Data
Purpose	Legal basis for processing
To facilitate, operate and provide our Site.	▪ Legitimate Interests
To monitor, study and analyze use of the Site.	▪ Consent (where appropriate) ▪ Legitimate Interests
To gain a better understanding on how individuals use and interact with our Site, and how we could improve their and others’ user experience and continue improving our offerings and the overall performance of our Site.	▪ Consent (where appropriate) ▪ Legitimate Interests
To provide customer service and technical support.	▪ Performance of a Contract ▪ Legitimate Interests
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.	▪ Legal Obligations ▪ Legitimate Interests
To comply with court orders and warrants, prevent misuse of the Site, and take any action in any related legal dispute and proceeding.	▪ Legal Obligations ▪ Public Task ▪ Legitimate Interests
To comply with applicable laws and regulations.	▪ Legal Obligations ▪ Legitimate Interests
Business Contact Data
Purpose	Legal basis for processing
To authenticate the identity of our current customers’ users and allow them to access and use our Customer Community.	▪ Performance of a Contract
To provide technical support to our current customers who submit a request via the Customer Community.	▪ Performance of a Contract
To contact you with general or personalized Services-related messages, as well as promotional messages that may be of specific interest to them, as further described in Section 7 below.	▪ Performance of a Contract (where appropriate) ▪ Consent (where appropriate) ▪ Legitimate Interests
To facilitate and optimize our marketing campaigns, ad management and sales operations, and manage and deliver advertisements for our Products and related services more effectively, including on other websites and applications.	▪ Consent (where appropriate) ▪ Legitimate Interests
To explore and pursue growth opportunities by facilitating a stronger local presence and tailored experiences.	▪ Consent (where appropriate) ▪ Legitimate Interests
To facilitate, sponsor and offer certain events, contests, and promotions.	▪ Consent (where appropriate) ▪ Legitimate Interests
To create aggregated data, inferred non-personal data or anonymized or pseudonymized data (de-identified data), which we or our business partners may use to provide and improve our respective services, conduct research, or for any other purpose.	▪ Legitimate Interests
To comply with applicable laws and regulations.	▪ Legal obligations ▪ Legitimate Interests

We do not sell or share your personal information for the intents and purposes of the California Consumer Privacy Act (CCPA).

If you reside or are using the Site and its Services in a territory governed by privacy laws under which “consent” is the only or most appropriate legal basis for the processing of personal data as described herein (in general, or specifically with respect to the types of personal data you expect or elect to process or have processed by us), your acceptance of this Policy will be deemed as your consent to the processing of your personal data for all purposes detailed in this Policy. If you wish to revoke such consent, please contact us at [email protected].

3. Data Location

We and our authorized Service Providers (defined in Section 5 below) maintain, store and process personal data in the United States of America, the European Union, the United Kingdom, Israel, Japan and other locations, as reasonably necessary for the proper performance and delivery of our Site and its Services, or as may be required by law.

While privacy laws may vary between jurisdictions, Itamar Medical, its affiliates, and Service Providers engaged in processing hereunder, are each committed to protecting personal data in accordance with this Policy, 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 the jurisdiction to which such data is transferred.

To the extent we transfer Visitors and/or Business Contacts’ personal data originating from the European Economic Area (EEA), the United Kingdom (UK) or Switzerland elsewhere, we rely on appropriate data transfer mechanisms as established under applicable law, such as the standard contractual clauses adopted by the EU (available here) and the UK (available here).

4. Data Retention

We retain your personal data for as long as it is reasonably necessary in order to maintain and expand our relationship and provide you with our Site and offerings; in order to comply with our legal and contractual obligations; to pursue our legitimate business purposes; or to protect ourselves from any potential disputes (i.e., as required by laws applicable to log-keeping, records and bookkeeping, and in order to have proof and evidence concerning our relationship, should any legal issues arise following your discontinuance of use), all in accordance with our data retention policy.

Please note that except as required by applicable law or our specific agreements with you, we will not be obligated to retain your personal data for any particular period, and we are free to securely delete it or restrict access to it for any reason and at any time, with or without notice to you. If you have any questions about our data retention policy, please contact us by e-mail at [email protected].

5. Data Sharing

We may share your data with certain third parties, including law enforcement agencies, our Service Providers and our affiliates, in accordance with this Policy and as described below:

Legal compliance: We may disclose or allow government and law enforcement officials access to your personal data, in response to a subpoena, warrant or court order (or similar requirement), or in compliance with applicable laws and regulations. Such disclosure or access may occur if we believe in good faith that: (a) we are legally compelled to do so; (b) disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing; or (c) such disclosure is required to protect our legitimate business interests, including the security or integrity of our Site, Products, and Services.

Service Providers: We may engage selected third-party companies and individuals to perform services complementary to our own. Such service providers may include hosting and server co-location, communications and content delivery networks (CDNs), data security, fraud detection and prevention, web analytics, e-mail distribution and monitoring, session, call or activity recording and analysis, remote access services, performance measurement, inbound meeting scheduling automation, data optimization and marketing, social and advertising networks, content providers, e-mail, voicemail, support and customer relation management systems, and our legal, financial and compliance advisors (collectively, “Service Providers”). Our Service Providers may have access to your personal data, depending on each of their specific roles and purposes in facilitating and enhancing our Site and Services, and may only use the data for such limited purposes as determined in our agreements with them.

Protecting rights and safety: We may share personal data with others if we believe in good faith that this will help protect the rights, property, or personal safety of Itamar Medical, any of our Visitors, Business Contacts, End Users or customers, or any members of the general public.

Itamar Medical subsidiaries and affiliated companies; change of control: We may share personal data internally within our group, for the purposes described in this Policy. In addition, should Itamar Medical or any of its affiliates undergo any change in control or ownership, including by means of merger, acquisition, or purchase of substantially all or part of its assets, personal data may be shared with or transferred to the parties involved in such an event. If we believe that such change in control might materially affect your personal data then stored with us, we will notify you of this event and the choices you may have via e-mail or a prominent notice on our Site.

Additional sharing: For the avoidance of doubt, Itamar Medical may share personal data in additional manners, pursuant to your explicit approval, or if we are legally obligated to do so, or if we have successfully rendered such data non-personal, non-identifiable and anonymous.

6. Cookies & Tracking Technologies

Cookies: Cookies are small text files that are stored through the browser on your computer or mobile device (for example, Google Chrome or Safari) when you visit a website. Some cookies are removed when you close your browser session – these are the “session cookies”. Some last for longer periods and are called “persistent cookies”. We use both types of cookies to facilitate the use of the Services’ features and tools. While we do not change our practices in response to a “Do Not Track” signal in the HTTP header from a browser or mobile application, you can manage your cookies preferences, including whether or not to accept them and how to remove them, through your browser settings. Please bear in mind that disabling cookies may complicate or even prevent you from using the Site. For more information regarding cookies, you may find the following websites useful: www.allaboutcookies.org, www.youronlinechoices.co.uk.

To learn more about our cookie practices, please visit our Cookie Policy.

Google Analytics: we use Google Analytics to collect information about the use of our Site. Google Analytics collects information such as how often you visit the Site, which pages you visited when doing so, and which other sites you used prior to coming to our Site. We do not merge the information collected through the use of Google Analytics with personally identifiable information. Google’s ability to use and share information collected by Google Analytics about your visits to and use of the Site is restricted by the Google Analytics Terms of Service and the Google Privacy Policy. You can learn more about how Google collects and processes data specifically in connection with Google Analytics here. Further information about your option to opt-out of these analytics services is available here.

7. Communications

We may engage you in service and promotional communications through e-mail, phone, SMS and notifications. We may also notify you about new features, additional offerings, events, special opportunities, or any other information we think you will find valuable. We may provide such notices through any of the contact means available to us (e.g., phone, mobile or e-mail), through the Site, or through our marketing campaigns on any other sites or platforms.

If you do not wish to receive such promotional communications, you may notify Itamar Medical at any time by sending an e-mail to [email protected], or by following the “unsubscribe”, “stop”, “opt-out” or “change e-mail preferences” instructions contained in the promotional communications you receive.

8. Data Security

We implement industry-standard physical, procedural, and electronic security measures to secure your personal data held with us and our Service Providers, in order to minimize the risks of theft, damage, loss of information, or unauthorized access or use of personal data.

However, please be aware that regardless of any security measures used, we cannot and do not guarantee that our Site will be immune from any wrongdoing, malfunctions, unlawful interceptions or access, or other kinds of abuse and misuse.

9. Data Subject Rights

If you wish to exercise your privacy rights under any applicable law, including the EU General Data Protection Regulation (GDPR) or the California Consumer Privacy Act (CCPA), such as the right to know; the right to request access to, and rectification or erasure of, your personal data held with Itamar Medical; to restrict the processing of such data and to object to its processing; to port such data; or the right to equal services and prices (each to the extent available to you under the laws that apply to you) – you may do so by contacting us at [email protected].

Please note that we may require additional information, including certain personal data, in order to authenticate and process your request. Such additional information may 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 4 above. We may redact from the data which we will make available to you, any personal data related to other individuals.

Additionally, you have a right to lodge a complaint with a competent authority, such as the supervisory authority in the EU Member State of your habitual residence, place of work, or of the alleged GDPR infringement, the UK’s Information Commissioner’s Office, or your State’s Attorney General (as applicable).

10. Roles & responsibilities

Certain data protection laws and regulations, such as the GDPR and the CCPA, typically distinguish between two main roles for parties processing personal data: the “Data Controller” (or under the CCPA, “business”), who determines the purposes and means of processing; and the “Data Processor” (or under the CCPA, “service provider”), who processes the data on behalf of the Data Controller.

Itamar Medical is the Data Controller of its Visitors and Business Contacts’ personal data, and assumes the responsibilities of a Data Controller, solely to the extent applicable under law and as set forth in this Policy. In such instances, our Service Providers processing such data on our behalf will assume the role of Data Processor.

11. Additional Notices & Contact Details

Updates and Amendments: We may update and amend this Policy from time to time by posting an amended version on our Site. The amended version will be effective as of the date it is published. We will provide prior notice if we believe any substantial changes are involved via any of the communication means available to us. After such notice period, all amendments shall be deemed accepted by you.

External Links: While our Site may contain links to other websites or services, we are not responsible for their privacy practices. We encourage you to pay attention when you leave our Site for the website or application of such third parties, and to read the privacy policies of each and every website and service you visit. This Policy applies only to our Services.

Our Site is not designed for underage children: We do not knowingly collect personal data from children and do not wish to do so. If we learn that a person who is under age according to the law applicable to them is using the Site, we will attempt to prohibit and block such use and will make our best efforts to promptly delete any personal data stored with us with regard to such a child (except for data that must be retained for legal purposes). If you believe that we might have any such data, please contact us by e-mail at [email protected].

Data Protection Officer: Itamar Medical has appointed PrivacyTeam Ltd. as our Data Protection Officer (DPO), for monitoring and advising on Itamar Medical’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 this 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 Itamar Medical, you can contact our DPO at [email protected].

EU Representative: Arazy Group GmbH has been designated as Itamar Medical’s representative in the European Union for data protection matters pursuant to Article 27 of the GDPR. Arazy Group GmbH may be contacted on matters related to the processing of personal data of individuals in the EU. To make such an inquiry, please send an e-mail to one of the following email addresses: [email protected], [email protected].

UK Representative: Medes Limited has been designated as Itamar Medical’s representative in the United Kingdom for data protection matters pursuant to Article 27 of the UK GDPR. Medes Limited may be contacted on matters related to the processing of personal data of individuals in the UK. To make such an inquiry, please send an email to one of the following email addresses: [email protected], [email protected].

Questions, concerns, or complaints: If you have any comments or questions regarding this Policy, or if you have any concerns regarding your personal data held with us, please contact us at [email protected]. If you are a GDPR or UK GDPR-protected individual, you also have the right to lodge a complaint with an EU supervisory authority, or the UK’s Information Commissioner’s Office, as appropriate.