PANAX PRIVACY POLICY
Lastmodified: 19 September 2024
Panax Ltd. (collectively, “Panax”,"us", "our" or "we") iscommitted to respecting its clients and users’ privacy rights (collectively, “you”,“your” or “user”). This Privacy Policy applies to our website, www.thepanax.com and itsassociated subdomains, as well as our application, panax co-pilot(collectively, our “Service”).
This Privacy Policy (the "Policy") explains how wecollect, store and use your information. We encourage you to read this PrivacyPolicy carefully and use it to make informed decisions.
By accessing or using the Service and/or accepting our Terms of Service, you confirm that you have read,understood and agreed to the collection and use of your information as we haveoutlined in this Policy.
Capitalized terms used and not otherwise defined herein, shall have therespective meanings ascribed to them under our Termsof Service.
1. THE INFORMATION WE COLLECT
1.1. Panax collects information that identifies individuals or that may, withreasonable effort, identify individuals, including (the “PersonalInformation"):
1.1.1. Your name, gender,identification number, billing address and other information you may provide tous when you use the Service.
1.1.2. Your contact details;postal address telephone numbers (including mobile numbers) and e-mail address.
1.1.3. Your online browsingactivities through the Service (for example, device, software or hardware thatmay identify them, such as online identifiers, device unique identifiers (e.g.,UDID, MAC address), IP address and geolocation).
1.1.4. Your Account password(s)and usernames.
1.1.5. If you choose to set up anaccount when using the Service by logging through your Google, Facebook orother social network account (Single Sign On),we may receive personal information about you from the social network.
1.1.6. Your, preferences, feedbackand survey responses.
1.1.7. Your correspondence and communicationswith Panax.
1.2. Non-Personal Information. Panax also collectscertain unidentified, non-personal information that relates to youronline browsing activities through your use of the Services (the “Non-PersonalInformation”). Non-Personal Information is non-identifiable information that, when taken alone, cannot be used toidentify you. As such, we are not aware of the identityof the user from which the Non-Personal Information was collected. We alsocollect aggregate user data regarding your use of our Services. We mayanonymize or de-identify the information collected through the Service or viaother means so that the information cannot, on its own, personally identifyyou. Our use and disclosure of such aggregated or de-identified information isnot subject to any restrictions under this Policy, and we may disclose it toothers without limitation and for any purpose. For the avoidance of doubt, ifwe combine Personal Information with Non-personal Information (e.g., analyticaldata), the combined information will be treated as Personal Information so longas it remains combined.
2. HOW DO WE COLLECT YOUR PERSONAL INFORMATION?
2.1. Panax may collect Personal Informationand/or Non-Personal Information (collectively, “Information”) duringyour access and/or use of the Service, including through your interactions andcommunications with the Service, in thefollowing ways:
2.1.1. Information You Provide to Panax. Panax collects Information that you provide it, forexample, when you use the Services; when you answer questionnaires and surveys;send request customer support; or communicate with us for other purposes.Please be aware that the Information you choose to provide, may reveal, oridentify, information that is not expressly stated (for example, your name mayreveal your gender). Accordingly, you should carefully consider whichinformation you wish to share about yourself.
2.2. Information Collected Automatically. When you access or use the Services, we may automatically collect Information about you, including:
2.2.1. Usage Information. Panax monitors users’ activity in connection with theServices and may collect log information about you when you access and use theServices including your IP address, time of access, browser type and language,Internet Service Provider ("ISP"), informationabout the applications and features you use, the content you access, and anyactions taken in connection with the access and use of your content in theServices.
2.2.2. Device Information. If you access the Services from a mobile device, Panax maycollect information about the device, including the hardware model, operatingsystem and version, unique device identifiers, mobile network information (as allowed by the mobile network) or platform information(as allowed by the specific platform type).
2.2.3. Cookies and Other Tracking Technologies.
2.2.3.1. Like most websites and onlineplatforms, our Service uses “cookies” to collect Information. “Cookies” aresmall text files containing strings of letters and numbers that are downloadedonto your device (such as, computer, tablet or smartphone) when you use theService. These files allow to store Information about you. Some “cookies” willexpire when you exit the Service, and others will be saved in your device’smemory.
Ifyou want to disable or change your “cookies” settings, you will have to accessyour device’s browser settings. Please note that if you disable all cookies,some (or all) of the features and functionality of the Service may not beavailable to you.
2.2.3.2. Otherthan “cookies”, when you use our Service, you consent to our use (and authorizethird parties to use) of various technologies to collect Information, which mayinclude web beacons (also known as "tracking pixels"), events andother technologies (collectively, “Tracking Technologies”). SuchTracking Technologies allow us to automatically collect Information about you,your device and your online behavior, in order to enhance your navigation andimprove our Services’ performance, perform analytics and customize yourexperience. In addition, we may merge data we have with Information collectedthrough these Tracking Technologies and data we may obtain from other sourcesand, as a result, such combined data may constitute Personal Information.
3. HOW WE USE YOUR INFORMATION
3.1. Panax uses your Informationfor the limited purpose of providing the Service and related functionality andservices, or as otherwise specifically described in this Policy and aspermitted by applicable laws, all of which serve the legitimate interests ofPanax, including:
3.1.1. Providing,operating, maintaining, improving, promoting and auditing the Service (by Panaxor any third party acting on its behalf), from time to time.
3.1.2. Sendingyou transactional messages, technical notices, updates, security alerts andsupport and administrative messages.
3.1.3. Identifyingyou, so that we can interact with you, as well as providing and deliveringservices and features that you request, processing and completing transactions,and sending you related information.
3.1.4. Respondingto your comments, questions, and requests and provide customer service andsupport.
3.1.5. Communicatingwith you about services, features, surveys, newsletters, offers, promotions,contests and events, and provide other news or information about Panax and ourselect partners.
3.1.6. Personalizingthe Service, providing content, features, and/or advertisements that match yourinterests and preferences or otherwise customize the Services.
3.1.7. Monitoringand analyzing trends, usage, and activities in connection with the Services forresearch, marketing or advertising purposes.
3.1.8. Linkingor combining the Information with other information we receive from thirdparties to help understand your needs and provide you with better service.
3.1.9. Forcrime and fraud prevention, detection and related purposes.
3.1.10. Wherewe have a legal right or duty to use or disclose your information (for examplein relation to an investigation by a public authority or in a legal dispute).
3.1.11. Forcustomer relations, queries, complaints or disputes and Service’s operations.
3.1.12. Internalrecord keeping.
3.1.13. Formanaging insurance claims by our customers.
3.1.14. Cybersecurityneeds, fraud detection and misuse of our website.
3.2. Marketing(Promotional communications)
3.2.1. If you indicated youragreement to receive promotional materials from Panax, then we may use your email address to sendyou electronic mail for marketing purposes and update you about promotionaloffers, products and services which we think may be of interest to you as anindividual (the "Newsletters"), and by accepting the terms ofthis Privacy Policy you agree to Panax sending you such Newsletters, from timeto time.
3.2.2. Youare not obligated by law or otherwise to receive our Newsletters, and you havethe right to opt out of receiving such communications, at any time, by:
3.2.2.1. following the unsubscribe instructionsincluded in each Newsletter; or
3.2.2.2. contacting Panax via privacy@thepanax.com and request to be removed from our mailing list.
3.2.3. Nonetheless,please note that even if you choose to unsubscribe from our mailing list, we may continue sending you notices (a) to update you onrevisions made to this Privacy Policy or our Termsof Service; and (b) related to the ongoing Service, for example,promotions regarding products and services used by you, notices concerning youraccounts and any additional operational notices as required.
3.3. Sharing your Information with Third Parties
3.3.1. Wemay use and share your Information with certain third parties that help usoperate our Service, (e.g., deliver customer support, monitor and analyze theperformance of our Services, such as newsletter distribution and other service providers). When Panax uses such thirdparties, it restricts them from using or disclosing Personal Information,except as required to perform the services on behalf of Panax or to comply withlegal requirements. Specifically, we do not permit such third parties to useany Personal Information we share with them for their own marketing purposes orfor any purpose other than in connection with the services they provide to us.Third parties with which we may share your Information will be required to meetour standards on processing information and security. Personal Information weprovide them will only be provided in connection with the performance of theirfunction.
3.3.2. We may also share yourInformation with:
3.3.2.1. credit reference agenciesand payment card issuers (such as Visa, Mastercard and American Express) wherenecessary for card payments.
3.3.2.2. governmental bodies,regulators, law enforcement agencies, courts/tribunals and insurers where weare required to do so (a) to comply with our legal obligations; (b) to exerciseour legal rights (for example in court cases); (c) for the prevention,detection, investigation of crime or prosecution of offenders; and (d) for theprotection of our employees and customers.
3.3.2.3. If Panax becomes involvedin a merger, acquisition, or any form of sale of some or all of its assets, itmay transfer all the Information that was collected from users in connectionwith such a transaction.
3.3.3. Our cloud service providers. Theserver(s) on which the Service are hosted are within the United States. Pleasenote that some of the Information may be managed by third parties, including, Amazon Web Service (AWS)technology, whose mailing address is Amazon Web Services, Inc., 410 Terry AvenueNorth, Seattle, WA 98109-5210, ATTN: AWS Legal. You can find more details onAWS' Privacy Policy here. We have configured ourdata to be stored in Northern Virginia (US-EAST-1).
3.4. International Transfer ofInformation. To provide you with our Service, it may be necessary for Panax togrant third parties fromjurisdictions outside of your country of residency, with access to yourInformation. By agreeing to the terms of this Privacy Policy, you agree to Panaxsharing your Information outside of your country of residency.
3.5. We reserve the right todisclose your Information as required by law and when we believe thatdisclosure is necessary to protect our rights and/or comply with a judicialproceeding, or court order.
3.6. Also, please note that wemay disclose general, aggregated, non-personal and non-identifiable informationabout our users to potential business partners, investors, or the public.
4. HOW LONG DO WE KEEP YOUR INFORMATION?
4.1. Panax will retain yourInformation for as long as needed to provide you and our clients with ourService, or to comply with legal and regulatory obligations (e.g., audits,accounting and statutory retention terms), enforcing our Terms of Service, dispute resolutions and for theestablishment, exercise or defence of legal claims in the countries where we dobusiness. This isalso the case for any third party with which we share your Information whenthey carry out services on our behalf.
4.2. While different retentionperiods may apply with respect to different types of data, the longest we willnormally hold Personal Information is ten (10) years. When we no longer needyour Personal Information and there is no need for us to keep it to fulfil thepurposes described in this Privacy Policy, we will either remove it from oursystems or anonymize such Information so that it cannot identify you.
4.3. When you send an email orother communication to privacy@thepanax.com, or any other correspondence that you havewith us, we may retain those communications in order to process and respond toyour requests and improve our Service.
4.4. Please DO NOT sendus any communication which contains confidential or sensitive information,since we are unable to evaluate whether your content constitutes asconfidential or sensitive information, or not, and we may retain or use suchcommunication as described hereinabove, and such retention or use shall not bedeemed as a breach of any of our obligations pursuant to this Policy.
5. INFORMATION SECURITY STANDARD
5.1. Because we value yourprivacy, Panax uses industry standard measures to protect against unauthorizedaccess to, or unauthorized alteration, disclosure or destruction of data whichis stored in our records. These measures include internal reviews of our datacollection, storage and processing practices and standard measures, sensitiveinformation is transmitted via Secure Socket Layer (SSL) technology, making oursystems accessible only by those authorized with special access rights to suchsystems, and are required to keep the information confidential.
5.2. Nonetheless, we cannotguarantee a perfect and absolute security of your Information, as no method oftransmission over the Internet and or electronic storage is perfectly secure orinvulnerable. However, should we become aware of a security breach, we willnotify any affected user, so that they can take appropriate protective steps. Such notifications shall beissued by Panax in accordance with the applicable (local) laws and regulations,as well as Panax's internal policies.
5.3. Physical Standard. Panax follows Amazon’sPrivacy and Security Policy security standards with respect to physical access. You canread more about it here.
6. HOW CAN YOU HELP TO PROTECT YOUR DATA?
6.1. First, please remember thatPanax will never ask you for any password, bank account or credit card details.If you receive such communicating asking you to provide such information,please ignore it and do not respond. You can let us know that you havereceived such communication viaprivacy@thepanax.com.
6.2. If you are using yourdevice in a public location, we highly recommend that you always log out andclose the browser after completing your session.
7. WHAT RIGHTS YOU HAVE IN CONNECTION WITH YOUR INFORMATION?
7.1. You have the right to ask that Panax will provide you with a copy of anyPersonal Information that we keep about you.
7.2. You have the right to ask that Panax shall update and correct anyoutdated or inaccurate Personal Information that we keep about you. Should youfind that the Personal Information related to you is not accurate, complete, orupdated, then please provide us the necessary information to correct it.
7.3. If you wish to exercise any of the rights described above, please notifyus by email to privacy@thepanax.com, and wewill use commercially reasonable efforts to accommodate your request. Panaxshall not charge you for requesting to exercise any of theaforementioned rights.
8. SPECIFIC PROVISIONS FOR EU-RESIDENTS
8.1. This Section 8 applies to you, if you are from the European Union. Panax adopted thefollowing provisions, to comply with the EU 2016/679 Directive General DataProtection Regulation (“GDPR”), pursuant to which Panax will beconsidered as a "Data Controller" with respect to our use of PersonalInformation of residents of the European Union.
8.2. Legal Basis. We baseour processing of any personal data as “Data Controllers” based on thefollowing lawful grounds:
8.2.1. Panax relies, primarily, onyour consent to the terms of this Policy and the terms set forth under our Terms of Service, as a legal basis for processingany Personal Information related to you or communicating any other promotionalmaterial.
8.2.2. Panax may collect and useyour Personal Information when it is necessary for one of the legitimate usesset out in Section 3 above, which we believe are not overridden by your fundamental rights.
8.2.3. We may process yourPersonal Information to comply with a legal obligation and to protect ourusers' vital interests.
8.2.4. If, at any time, you wishto exercise your rights in accordance with the provisions provided by law(including as provided under Section 7 of this Policy) you may send us an email to via privacy@thepanax.com, andrequest:
8.2.4.1. to access your Personal Information together with information about how,and on what basis, such information is being processed. Should you desire toreceive such information in a different format than the one that was providedto you, you can contact us via privacy@thepanax.com and we shall use commercially reasonableefforts to accommodate your request, if applicable.
8.2.4.2. to rectify any of the Personal Information being held when suchinformation is inaccurate.
8.2.4.3. to delete or restrict access to your Personal Information in limitedcircumstances as described under the GDPR. Please note that if we need todelete any Personal Information related to you, as per your request, it cantake time until we completely delete residual copies of such data from ourservers and backup systems.
8.2.4.4. to withdraw your consent to the processing of your Personal Information.However, please note that exercising this right will not affect the lawfulnessof any previous processing activities based on consent that was lawfullyobtained before its withdrawal.
8.2.4.5. to obtainand reuse your Personal Information for your own purposes across differentservices, as part of your right to data portability.
8.3. Please note that you havethe right to complain to a Data Protection Authority about our collection anduse of your Personal Information. For more information, please contact yourlocal data protection authority in the European Economic Area (EEA).
8.4. If you have any concernswith respect to our methods of processing any Personal Information related toyou, or if wish to withdraw your consent, for any reason, kindly let us know bysending an email to privacy@thepanax.com.
8.5. If you reside in a countryfrom the European Economic Area, then, by agreeing to the terms of this PrivacyPolicy, you agree to Panax sharing your Information outside of the EuropeanEconomic Area. These transfers are subject to special rules under data protectionlaws. If this happens, we will ensure that the transfer will be compliant withdata protection law and all personal data will be secure. Our standard practiceis to use ‘standard data protection clauses’ which have been approved by theEuropean Commission for such transfers. Those clauses can be accessed here.
8.6. Panax shall not charge you for requesting to exercise any of theaforementioned rights.
9. SPECIFICPROVISION FOR CALIFORNIA RESIDENTS
This Section9 applies to you only ifyou reside in the State of California, United States. Panax adopted thefollowing provisions to comply with the California Consumer Privacy Act (“CCPA”)and any terms defined in the CCPA have the same meaning when used in thisSection 9.
9.1. Thefollowing categories reflect the type ofpersonal information which Panax has collected within the last twelve (12)months:
9.1.1. Identifiersand Personal information as listed in the California Customer Records statute(Cal. Civ. Code § 1798.80(e)), for example, first names, surnames, telephonenumbers, address, online Identifier, Internet Protocol address, business orprivate email addresses, account usernames, as well as Personal Information assuch term is defined in this Privacy Policy.
9.1.2. Electronicnetwork activity information, including, but not limited to, browsing history andany additional information related to your interaction with our Service.
9.2. Panax has obtained such information asset forth in Section 9.1above and Personal Information as provided under Section 1.1above (for the purpose of this Section 9,the “Personal Data”).
9.3. Panax may use the Personal Data itcollects or receives for its legitimate interests (as set out in Section 3above), which Panax believes are not overridden by your fundamental rights.Panax may also disclose such Personal Data to third parties for its legitimatepurposes as described in Section 3above.
9.4. In the preceding twelve (12) months,Panax has disclosed the following Personal Data for our businesspurposes:
9.4.1. Identifiers(including your name, email address, profession).
9.4.2. PersonalData's categories as listed in the California Customer Records statute.
9.4.3. Inferences.
9.5. In the preceding twelve (12) months,Panax has not sold any of your Personal Data.
9.6. Your rights as a California Resident. You are entitled to request the following specific rightsunder the CCPA, solely with respect to Personal Data related to you:
9.6.1. Requestto know (a) what categories and specific components of Personal Data we collectabout you and from which sources; (b) categories of Personal Data that wedisclosed for the purpose described in Section 3 above, and thecategories of third parties with whom we have shared any particular category ofyour Personal Data. If we disclose any of your Personal Data to a third-party,we will provide you, after authenticating your identity, with a list that will identifythe specific category of your Personal Data which was disclosed.
9.6.2. Requestthat we delete any Personal Data we collect about you. After authenticatingyour identity, we will delete (and direct our service providers to delete) anyPersonal Data related to you from our records, unless an exception applies.Please note that if we need to delete any Personal Data related to you following your request, it can take time until we completelydelete residual copies of Personal Data from our servers and backup systems.
9.6.3. Instructus not to sell any Personal Data related to youthat was collected by us.
9.6.4. Youhave the right not to bediscriminated against by Panax, for exercising your rights under the CCPA.
9.7. If you have anyconcerns about how we process Personal Data related to you, or if you wish towithdraw your consent, for any reason, kindly let us know by sending an emailto privacy@thepanax.com. Please note that exercising this right will not affect thelawfulness of any previous processing activities based on consent that waslawfully obtained before its withdrawal. Also, please note that Panax shall notcharge you for requesting to exercise any of the rights set forth in thisSection 9.
10. SPECIFIC PROVISIONS FOR USERS FROM ISRAEL, UNDER THE ISRAELI PROTECTIONOF PRIVACY ACT, 5741-1981.
10.1. If you are an Israeliresident, you should note that we collect, use, disclose, and otherwise processInformation as described above with your consent where required by applicablelaw.
10.2. Users are underno legal obligation to provide Panax with any Personal Information, however, ifyou choose not to provide us the data categories we request, some (or all) of thefeatures and functionality of the Service may not be available to you.
10.3. Further, ifUser provides Panax with details of any other individual, he/she must give acopy of this Policy to, and obtain consent from, that individual beforedisclosing their Personal Information to us.
10.4. Please notethat according to the Israeli Privacy Protection Law, 1981 (the “PPA”),every individual is entitled to review information about themselves, eitherpersonally, or through a duly authorized legal representative, or through aguardian. If you submit such a request to access and/or review your PersonalInformation we keep about him/her (which may be a digital copy), Panax will notcharge you with a fee for such request.
10.5. If, afterexamining your Personal Information, you find it to be incorrect, incomplete,unclear, or outdated, you may request that we correct or delete saidinformation.
10.6. If we declineyour request in accordance with the PPA, we shall notify you, in the manner andprocedure prescribed by the PPA and the applicable regulations.
10.7. Please notethat Panax may request you to provide certain credentials to verify youridentity as a condition for reviewing your application.
11. LINKS TO OTHER WEBSITES; THIRD PARTY SERVICES
11.1. This Privacy Policy appliesonly to the Service offered by Panax. Nonetheless, please note that the Servicemay contain links to other websites or applications not operated or controlledby Panax. We are not responsible for the content, accuracy or opinionsexpressed in such websites or applications, and such websites or applicationsare not investigated, monitored or checked for accuracy or completeness byPanax. Please note that when you use a link to go from Panax’s Service toanother website or application, your access to and use of such websites orapplications are governed by the websites or applications’ own rules andpolicies.
11.2. Panax may make availablethrough the Service, third-party content, applications, products and servicessolely as a convenience (the "Third Party Services"). Youacknowledge and agree that Panax is not, and shall not be, responsible for anyThird Party Services, including their accuracy, completeness, timeliness,validity, copyright compliance, legality, decency, quality or any other aspectthereof. Panax does not assume and shall not have any liability orresponsibility to you or any other person or entity for any Third PartyServices accessed and/or consumed by you or any third parties, and if you orany third party choses to access and use them, you do so at your own risk andsubject to the rules and policies of such Third Party Services.
12. COMPLIANCE
If you believe that we havenot adhered to our Policy as outlined herein, please notify us by email to privacy@thepanax.com. Panaxwill examine any query and make commercially reasonable efforts to resolve anyexisting or potential dispute. Note that when you send us a request to exerciseyour rights, we will need to reasonably authenticate your identity andlocation, and therefore we may ask you to provide us credentials to make surethat you are who you claim to be and will further ask you questions tounderstand the nature and scope of your request.
13. CHANGES TO THIS POLICY
We reserve the right tochange this Policy from time to time, so please review it frequently. If wemake material changes to this Policy, and you are a registered user of theService, we will notify you by email when we make any changes.
14. GOVERNING LAW
This Policy shall beconstrued in accordance with and governed for all purposes by the substantivelaws of the State of Israel withoutregard to conflicts of law provisions. You agree that any claim or dispute youmay have against us and/or our affiliates, directors, officers, employees, andrepresentatives will be resolved exclusively by the competent courts located inTel Aviv – Jaffa, Israel, and waiveany jurisdictional, venue or inconvenient forum objections to such courts.
15. CONTACT US
If you have any questionsabout this Policy, please contact us via privacy@thepanax.com or via post to 8 Shaul Hamelech St., Tel Aviv – Jaffa, Israel.
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