Privacy Policy

This privacy policy (the “Privacy Policy”) applies to ReWalk Robotics Ltd. (DBA Lifeward™), a limited company with registered offices at 3 Hatnufa st. Yokneam, Israel, incorporated and registered under the law of Israel, together with all its subsidiaries (together “Lifeward”, “Us”, “We”, or the “Company”). Lifeward engages in the development and marketing of products intended for use in the rehabilitation of individuals with lower limb disability due to stroke, through websites, systems, physical products, mobile applications or any other services (the “Services“).

This Privacy Policy describes the manner in which Lifeward handles and manages any information related to its clients and/or users of its Services (each, a “User” or “Users”). Such information may be subject to various legal requirements and obligations, including, but not limited to, the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (“GDPR”) and any other applicable laws or regulations governing the processing of personal data in the framework of the Services.

Contacting Lifeward / EU Representative

LIFEWARD acts as data controller and has appointed a Privacy Protection coordinator

The data protection coordinator and/or the EU Representative appointed by LIFEWARD shall be contacted by using the following information:

Privacy protection coordinator: Ishay Tal

Address: 3 Hatnufa st. 6th fl. Yokneam, 2069203 Israel

Telephone: +972 4 959 0123

Email: ishay.tal@rewalk.com

EU Representative: MedNet EC-REP GmbH

Address: Borkstrasse 10, 48163 Münster, Germany

Tel: +49 251 3226664

Email: contact@mednet-ecrep.com

Collection of Personal Identification Information

As part of its Services Lifeward may collect, maintain, store or process Personal Data or personal identification information from Users in a variety of ways, including, but not limited to, when Users visit Lifeward websites, register on such websites, fill out a form, sign a contract, purchase a product and in connection with other activities, use applications and benefit from Services proposed by Lifeward. Such personal identification information may include, as appropriate and relevant, name, date of birth, email address, mailing address, phone number, etc. in addition, and in some cases, the data may also include some medical information regarding the User health status. For example, you may provide us with your medical data voluntarily and upon your choice, in order to check the suitability of any of our products for your case. In addition, Lifeward may collect some usage data and marketing and communication data regarding its Users and websites visitors. Some of this data and information may be collected through automatic means like cookies and similar technologies (please refer to the description below, under “Cookies Usage”).

Collection of Non-personal Identification Information

Lifeward may collect non-personal identification information about Users whenever they use a Lifeward website or application or other online service. Non-personal identification information may include technical information about Users means of connection, such as the operating system and the Internet service provider utilized, geographical information such as country of origin, behavioural information such as time spent on site, as well as further non-personal analytical data to improve customer experience, products and services.

Lifeward may also collect, use, and share aggregated data such as statistical or demographic data for any purpose, even if such data was derived from Users’ Personal Data, to the extent such data cannot be linked to any identified individual. Such anonymized or aggregated data, may be used by Lifeward as part of its Services and ongoing operations, including for research or statistical purposes, without further notice.

The performance of the Services may depend on the collection and processing of personal identification information and non-personal identification information. As a User, you do not have to provide Lifeward with your personal identification information, but in some cases, if you do not, it may mean that you won’t be able to use some of the Services. For example, Lifeward cannot provide you with any customer’s service and cannot treat any inquiry unless you will provide Lifeward with the relevant information for contacting you and responding to your inquiry. Similarly, Lifeward cannot provide you with any of its rehabilitation and/or exoskeleton products, unless you provide Lifeward with some medical information.

Cookies and similar technologies

Lifeward may use cookies (including pixels, web beacons or any other similar technology) to improve the User’s experience in regard of the Services and website usage. Cookies are basically small files which are being implemented in User’s computer in order to gather a certain set of information used to customize the navigation and use of the Services, thus enabling certain unique functionalities.

Lifeward may use various types of Cookies, including basic cookies designated for the proper and easy use of a website or system:

Essential Cookies – which are necessary for the site to work properly (usually appears under “ReWalk” cookie tag). Sometimes those cookies are just “Session Cookies” which are stored only temporarily during a browsing session and are deleted from your device when you close the browser.
Functional Cookies – designated to save your settings, such as language or other view preferences (also, under ReWalk Cookie tag).
Analytics Cookies – Lifeward may also use analytics cookies, which provide Lifeward with aggregated information which enables us to improve the way websites and systems works, usually through the use of Google analytics – a web analytics service. It is operated by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. The information generated by the cookie about your use of this website is usually transmitted to a Google server in the USA and stored there. Lifeward, as a website and systems operator have a legitimate interest in analysing user behaviour to optimize both its website and its advertising.
Targeting Cookies – these cookies are used to collect information from any User to help Lifeward with serving the User with targeted advertisements relevant to them (e.g. Google’s AdWords Cookies).

In addition, Lifeward may use social media cookies and plugins for improving Users experience and allowing the connectivity between its website and Services with the User’s social media accounts:

Facebook plugins and pixels (Like & Share buttons)

Plugins for the social network Facebook, Facebook Inc., 1 Hacker Way, Menlo Park, California 94025, USA. The Facebook plugins can be recognized by the Facebook logo or the Like button on our site. For an overview of Facebook plugins, see https://developers.facebook.com/docs/plugins/.

When you visit our site, a direct connection between your browser and the Facebook server is established via the plugin. This enables Facebook to receive information that you have visited our site from your IP address. If you click on the Facebook “Like button” while you are logged into your Facebook account, you can link the content of our site to your Facebook profile. This allows Facebook to associate visits to our site with your user account. Please note that, as the operator of this site, we have no knowledge of the content of the data transmitted to Facebook or of how Facebook uses these data. For more information, please see Facebook’s privacy policy at https://www.facebook.com/policy.php.

If you do not want Facebook to associate your visit to our site with your Facebook account, please log out of your Facebook account.

Twitter plugin

Functions of the Twitter service have been integrated into Lifeward’s website and app. These features are offered by Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA. When you use Twitter and the “Retweet” function, the websites you visit are connected to your Twitter account and made known to other users. In doing so, data will also be transferred to Twitter. We would like to point out that, as the provider of these pages, we have no knowledge of the content of the data transmitted or how it will be used by Twitter. For more information on Twitter’s privacy policy, please go to https://twitter.com/privacy.

Your privacy preferences with Twitter can be modified in your account settings at https://twitter.com/account/settings.

LinkedIn plugin

Lifeward website uses functions from the LinkedIn network. The service is provided by LinkedIn Corporation, 2029 Stierlin Court, Mountain View, CA 94043, USA.

Each time one of our pages containing LinkedIn features is accessed, your browser establishes a direct connection to the LinkedIn servers. LinkedIn is informed that you have visited our web pages from your IP address. If you use the LinkedIn “Recommend” button and are logged into your LinkedIn account, it is possible for LinkedIn to associate your visit to our website to your user account. We would like to point out that, as the provider of these pages, we have no knowledge of the content of the data transmitted or how it will be used by LinkedIn.

More information can be found in the LinkedIn privacy policy a thttps://www.linkedin.com/legal/privacy-policy.

Please note that the data collected by use of Cookies may be linked to and combined with any other data, including personal identified information. Also note, that the data collected from our website through cookies by third parties (e,g., Facebook) may be linked by those third parties to other data they collect on other websites and the data they hold on you from their independent applications and services (e.g., your Facebook account). We are not responsible nor aware of the use of any such third party in that external data, and in any concern regarding this data you should connect such third party.

Managing cookies and opting out: aside from the essential and functional Cookies described above, you can always configure your browser to reject all cookies or notify you when a cookie is set, or use the “cookies bar” installed in the website to limit the use of cookies, but sometimes in that case, certain services, features, and functionality in our website may not be available to you.

How Lifeward Uses Collected Information

Principally, personal and non-personal identification information is used to provide the Users with the Services and to insure a full efficiency of the Services they have registered for or they requested in any other manner.

In this framework, Lifeward may collect and use Users’ personal and non-personal identification information for the following purposes:

To check your suitability to our products: As part of your interaction with us as a potential customer and user of our products, we may collect some data regarding your health status, in order to evaluate the suitability of our products to your case. We may collect such data through direct conversations and meetings, online questionnaires or any other manner.
To improve Services: Information Users provided will help Lifeward to respond to certain Users’ requests.
To personalize User experience: Lifeward may use non-personal identification information to understand how Users as a group use Lifeward Services.
To improve Lifeward’s websites and other internet presence as well as other communication tools or tools for specific Services: Lifeward may use feedback that Users provide to improve its products and services.
To send periodic emails and other text messages and/or notifications: Lifeward may use the email address or mobile phone number provided by Users to respond to inquiries, questions, and/or other requests. If Users decide to opt-in to Lifeward notification list, they will receive periodic information that may include company news, updates, related product or service information, private sales, information from Lifeward service providers on joint projects etc. (the “Periodic Information Service”). For the case that, at any time, Users would like to unsubscribe from the Periodic Information Service, Lifeward includes detailed unsubscribe instructions at the bottom of each such email or other text message.

Legal Basis under the GDPR

As with respect to any personal identification information which is subject to the GDPR (personal identification information of Users residents of the EU), Lifeward will only process and use such information in accordance with the limitations set by the GDPR, i.e. when Lifeward have a Lawful Basis for such usage. Such Lawful Basis can be any of the following:

Processing actions which Lifeward need to take as part of a contract with a User – e.g. any action required for the fulfilment of an order or completion of any purchase, contacting a User per “Contact” form filled by them or subscribing a User to any Periodic Information Services or any action which is part of our negotiations with you for the purpose of purchasing any of our products, such as filling an initial questionnaire, etc.
Processing actions which are necessary to meet Lifeward’ responsibilities towards regulators, tax officials, law enforcement authorities, or otherwise required for meeting its legal responsibilities.
Where the use of your information is part of Lifeward’s legitimate interest as a commercial organization. For example, to operate and improve its services and to keep people informed about its products and services. In these cases, Lifeward will use any personal identification information at all times in a way which is proportionate and respects Users’ privacy rights, making sure that Lifeward legitimate interest is not overridden by Users’ interests or fundamental rights and freedoms.

In general, and as detailed above, Lifeward do not rely on consent as a legal basis for processing personal identification information. Yet, in any case in which a User has provided consent to the processing of personal identification information, the User will always have the option to withdraw the consent by contacting Lifeward through the contact details provided above.

Protection of Personal Identification Information

Lifeward adopts appropriate data collection, storage and processing practices and security measures to protect against unauthorized access, alteration, disclosure or destruction of Users’ personal identification information within the limits of Lifeward’ role with respect to the relevant Services (as certain specific services may be rendered by third parties).

We take reasonable measures to ensure that any personal identification information data is being collected on an as needed basis in connection with the purposes set out in this Privacy Policy, and under strict minimalization requirements.

It is User’s sole responsibility to ensure the security and protection of any data transferred to Lifeward by the User, and Lifeward shall not be responsible for any such transfer made through an unsecured method (e.g. Email).

Sharing Personal Identification Information

Lifeward does not sell, trade, or otherwise transfer to third parties Users’ personal identification information. However each User accepts that his/her personal identification information can be transmitted to website hosting and editing partners and other sub-contractors who assist Lifeward in providing the Services, conducting its business, or servicing the User, so long as those sub-contractors undertake to process the information only according to Lifeward’s instructions and to comply with the applicable law regarding the protection of personal identification information. In addition, any such transfer will be made subject to contractual terms ensuring the security and protection of any personal identification information, in accordance with any legal requirements.

Lifeward may also release User’s personal identification information when it believes that such release is necessary to comply with the law, enforce its websites’ general terms of use, or protect its or others’ rights, property, or safety.

However, Users non-personal identification information may be provided to third parties for marketing, advertising, or other uses.

Data Retention

Lifeward takes all reasonable measures to ensure that User’ personal data are processed for the minimum period necessary for the purposes set out in this Privacy Policy. The Personal Data will be retained by Lifeward according to the following criteria:

as long as LIFEWARD maintain an ongoing relationship with the User (e.g., where the User is a recipient of LIFEWARD’s services, or is lawfully included in LIFEWARD ’s mailing list and has not unsubscribed);
as long as the User’ personal data are necessary in connection with the purposes set out in this Privacy Policy, for which LIFEWARD has a valid legal basis
with the User’ prior consent, until the expiry of any additional retention period.

Lifeward undertakes to delete or to anonymise the User’ personal data upon expiry of the retention period as described above.

Data Processing Location

Any transfer of data which originates in the European Union (“EU”) to a country outside of the European Economic Area (EEA), shall be made in compliance with the provisions of chapter 5 of the GDPR. Such transfer can be made to countries which are recognized as providing an adequate level of legal protection or where Lifeward can be satisfied that alternative arrangements are in place to protect your privacy rights, e.g. signing a Standard Contractual Clauses which were published and authorized by the relevant EU authorities.

It is important to note that Lifeward are headquartered in Israel, a country which is considered by the European Data Protection Board to be offering adequate level of data protection regulation.

Data subject rights

Under EU law, EU residents and individuals, have certain rights to apply to us to provide information or make amendments to how we process data relating them. Similar rights may be granted to Users under other jurisdictions. Those rights include:

right to access any personal identification data – any User can ask Lifeward to confirm whether or not Lifeward holds their personal identification data, and if so, the User can ask for a copy of their data.
right to correct personal identification data – any User can ask Lifeward to correct any of their personal identification data, which is incorrect, after verifying the accuracy of the data first.
right to erase personal identification data (the right “to be forgotten”) – any User can ask us to erase your personal identification data if you think Lifeward no longer need to use it for the purpose it has been collected for, or in any case in which the process of the data was based on consent, or if you believe Lifeward has used it unlawfully. Any such request for erasure will be subject to Lifeward obligations under the law (e.g. obligation to keep some records for tax or customs purposes), or any other lawful justification allowing Lifeward to keep the information.
right to restrict Lifeward use the personal identification data – any User can ask us to restrict the use of their personal identification data in certain circumstances.
right to object any use of personal identification data – any User can object to any use of their personal identification data which have been justified under a “Lawful Basis” of legitimate interest (see above) if the User believes their fundamental rights and freedoms to data protection outweigh Lifeward’s legitimate interest in using the information.
require Lifeward to refrain from using personal identification information for direct marketing purposes.
portability right – any User can ask Lifeward to transfer their personal identification information to another organization and/or provide them with a copy of their personal identification data.

For exercising any such User’s right, please contact us by sending an email to ishay.tal@rewalk.com. Those rights may only be exercised within the limits of any contractual or legal obligation. Each User has also a right to lodge a complaint with the supervisory authority from his country of residence, or from the country he is located when his personal data are collected. however, Lifeward will appreciate the chance to deal with any concern or inquiry before approaching the authorities, so please feel free to contact us in the first instance.

Links to other sites

Lifeward Website may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about the User or visitor. Lifeward do not control these third-party websites and is not responsible for their privacy statements.

Acceptance of these terms

By using the Services, Users confirm their acceptance of this Privacy Policy. If a User does not agree with this Privacy Policy, Lifeward recommends to such User that he shall not use the Services. The continued use of the Services following the posting of changes to this Privacy Policy will be deemed as an acceptance of those changes.

Changes to this Privacy Policy

Lifeward has the discretion to update this Privacy Policy at any time. Lifeward will therefore revise the “last update date” at the bottom of this page. Lifeward encourages Users to frequently check this page for any changes. Users acknowledge and agree that it is their responsibility to review this Privacy Policy periodically and become aware of modifications.

Last updated January 2024