Privacy Policy
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Last updated: 29.4.2021 

Beta Disclaimer

Please note that we currently offer our services only in a beta version. Therefore, the Services (see definition below) are still undergoing final testing before their official release. The platform, its software and all content found on it are provided on an “as is” and “as available” basis and we do not give any warranties, whether express or implied, as to the suitability or usability of the Services.

Should you encounter any bugs, glitches, lack of functionality or other problems with the Services, please let us know immediately so we can rectify these accordingly. Your help in this regard is greatly appreciated! You can write to us at this address welcome@anywell.com.

Introduction

anywell Hosting Solutions Ltd. D/B/A anywell  (“anywell”, “we”, or the “Company”) respects Your right to privacy, and is committed to protecting it. This privacy policy (“Policy”) describes our practices of processing data from (i) visitors to our websites, applications or landing pages that link to this Policy (“Visitor”, “Website” and “App”, respectively); (ii) our users that are registered to our Services and using our App and Services, as this term defined in this Policy (“User” or “Member”); and (iii) a business customer, a business partner that has a contractual relationship with us, or a prospective customer that is yet to be engaged in a contract with us (“Customer”). If not explicitly mentioned otherwise, the information in this Policy refers to all data subject types (“you” or “your’).

This Policy as an integral part of, and incorporated by reference into our Terms of Service (“TOS”) available at: https://www.anywell.com/terms-of-service.

If you are a resident of the state of California, please read our Privacy Statement for California Residents.

To ease Your navigation through this privacy policy, You may use the following headlines:

1. Preliminary Notes
2. Your Consent
3. Definitions Used in this Policy
4. Lawful Bases for Processing of Personal Data
5. Data We Collect and Process 
6. How We Collect Data
7. Cookies and Other Web Technologies
8. Sharing Personal Data 
9. Where we Store Personal Data
10. Data Retention
11. Your Rights Under this Policy
12. Choice and Control
13. Minors
14. Data Security
15. General
16. Contact Us

1. Preliminary Notes

1.1. Controller Details:

If You have questions, comments or complaints regarding this Policy or our data collecting practices, please contact us at:

(D/B/A) anywell Ltd. 

Dalia 29, Ramat Hasharon, Israel.

Or by email at: privacy@anywell.com. 

1.2. Changes to the Policy

We may modify this Policy at any time. Such changes will be effective immediately upon the display of the revised Policy. The last revision date will be reflected in the "Last Updated" heading. If we make material changes to this policy, we will make our best efforts to notify You, by email, or by means of a notice on our Website or App.

2. Your Consent

Please read this Policy carefully before using our Services, because in doing so and by continuing to use the Services (as the term defined in this Policy), or actively confirming the Policy (as the case may be) you agree to be bound by the terms and conditions set forth in this Policy, including to the collection and processing of your Personal Data (as defined below).

Please note: You are not obliged by law to provide us with any Personal Data (as this term defined in this Policy). You hereby acknowledge and agree that you are providing us with Personal Data at Your own free will, for the purposes described in this Policy, and, when available, via the form or screen in which you submit your Personal Data, and that we may retain such data in accordance with this Policy and any applicable laws and regulations. We do not collect any Personal Data from you or about you without your approval, which is obtained, inter alia, by your active acceptance of our TOS and this Policy.

3. Definitions Used in this Policy

To ease understanding of this Policy, we gathered here for your convenience, some of the terms used in this document, and their respective definitions:

• Book, Booking - means a confirmed booking of a Space by a Member via the Services, in exchange of Credit Points.
• Credit Points – means the credit points issued by anywell to a Customer or a Member, for purposes of a Booking.
• Guest(s) - means those persons who were invited by Members to meetings in Spaces.
• Member(s) - means a registered and approved member of the anywell App and respective Spaces.
• Services - when used in this Policy or TOS, shall mean to include the online and offline services provided by anywell, including the Websites, Apps, Member's account, the Booking platform, underlying technologies, and the services provided through such Websites, Apps and technologies, including intermediating Customers and Members for Booking of Spaces and Venues. 
• Space(s) - means a meeting or a working space, which is part of a Venue on anywell’s platform, and is available for booking by a Member in exchange for Credit Points. 
• Venue(s) - A location or a supplier of location who engages with anywell to offer Spaces on its Platform and offer them to Members in exchange for Credit Points.

4. Lawful Bases for Processing of Personal Data

If you are a resident of the european Union (EU) or the European Economic Area (EEA), this section applies to you, otherwise, you may skip it. 

We have included below information about which data we is collect and processed, how we process and use your data, but before, we would like to explain the lawful bases for processing your personal data (as defined under the EU/EEA General Data Protection Regulations “GDPR”):

4.1. Consent. 

• When Visitors access our Website or App, we collect certain online identifiers for purposes of Website and services functionalities, and at times, for purposes of advertising and marketing Our Services; certain online identifiers are processed subject to the Visitors consent to our cookies and other online technologies we use We will process necessary cookies regardless of a Visitor’s active consent, as part of our legitimate interest and our Website and App functionality necessities.  
• When a User signs up to our Services and chooses to open an account with us, we will process Personal Data associated with such an account and required for its management, protection and Services provisioning. In which case, we will do so based on the User’s consent, given at the point of account registration. We will also use the email address the User provided us with, to update, notify and inform them regarding theServices and actions taken as part of using the Services, such as Booking confirmation; based on either their consent, or on our legitimate interest, as the case may be and according to applicable laws.
• We may offer additional and optional features and enhanced Services to Members and Customers. When such enhanced Services involves the processing of Personal Data, we will do so based on the User’s consent.
• Where and when required by applicable laws.

4.2. Legitimate Interest. We may process certain Personal Data as part of our legitimate interest, while making sure we do not override your data protection interests or fundamental rights and freedoms, for instance, when we use the data in order to provide the core Services, or when used for anti fraud or protection purposes:

• Necessary cookies and other web technologies to make our Services function.
• To protect the Services, and the access to them, including authentication functions, anti fraud and anti spam.
• As the case may be, when certain data is required from time to time and allowed by applicable laws to be processed as part of our legitimate interest.

4.3. Contract. We will process our Customers’ and suppliers’ Personal Data to perform a contract with the entity they represent, or to prepare a contract for such engagement.

4.4. Other. In certain cases, we may have to process Personal Data to prepare for a legal claim, or as otherwise be required by applicable laws.

In any other case, we will also process Your personal data where you have provided us with consent to do so, or, where we have a legitimate interest, which is not overridden by your data protection interests or fundamental rights and freedoms.

5. Data We Collect and Process 

General: Depending on your interaction with us. i.e. whether You are a Visitor who just checks up our Website, a User that opened an account with us, or a Customer engaged with us in a business-to-business relationship, we may collect two types of data, as defined below: 

• Non-Personal Data: data that cannot personally identify or lead to identifying a natural person. For example, statistics or aggregated information, or any other type of data that can no longer be attributed to you. The Non-Personal Data, which is being collected may include your aggregated usage information and technical information transmitted to us.  
• Personal Data: data that identifies you as a natural person, or that may be used, either alone or in combination with other information, to personally identify you as a natural person. Such information may include, for example, a first and last name, an email address, phone number, a home or other physical address, and other contact information. In addition, in some jurisdictions (as the EU for example), and given the specific use we make of the information, an IP address, device ID and cookies could be considered as Personal Data as well.  The table below details the Personal Data processed by us.

Please note that You are not required by law to provide us with any data. You can always avoid providing us certain Personal Data; however, You acknowledge that it may prevent us from providing You some of the Services. 

In the event we combine Personal Data with Non-Personal Data, the combined information will be treated by us as Personal Data, for as long as it remains combined.

5.1. Data about  Visitors 

Type of Data

How do we use it? (Purpose)

Online Identifiers: We process IP addresses, cookies, pixel tags, user agents (namely, Your browser’s type, version, language and country). 

We may either directly or indirectly collect Visitors’ Online Identifiers. Such processing is subject to Your consent which is obtained explicitly (if you are a EU/EEA/UK resident) or implicitly through this Policy.  Necessary cookies will be used as part of our legitimate interest and for purposes of our Website’s and App’s functionality.

In certain cases,  third party cookies and tags will be used for analytics and statistics purposes, and for advertising and marketing of our Services.

Device Information: We may collect certain information about the device from which you access the Services, such as the type of device  (mobile/desktop), type, language and version of your device operating system.

We process device information for compatibility purposes and accessibility of our Services.

Analytics and Usage Information: certain technical data, which relates to your use of the Services, such as your clicks on buttons, view of pages and related events such as contacting, subscribing or any other action you take in our Website.

We use this technical data in order to operate and manage our Website or App and to extract analytics and statistics that help us understand how visitors use our Website. 

Contact details: In the event you contact us with any inquiry, either through an online form available on the Website, by sending us an email or by other means of communication we make available, you may be requested to provide us with your name and email address, or any other contact method you provide us with, and the subject matter of your inquiry.

We will use this data for our legitimate interest and solely for the purpose of responding to your inquiries and providing you with the support or information you have requested. We retain such information for as long as needed to provide you with the inquiry requested or as required under applicable law. 

Subscription: If You voluntarily subscribe to our email communications, that we may make available from time to time, you will be asked to provide us with your email address. You can unsubscribe at any time using the unsubscribe option in the body of the email sent to you or rather by contacting us at privacy@anywell.com.

We will use Your email address in order to send you information related to our services, and to keep you up to date  with news about new services we may offer from time to time.

Job seekers: In the event that you are interested in joining our team, and wish to submit your CV to us, you will be required to provide us with relevant application information, such as your name, email address, desired location, Linkedin profile link, and your CV file. You may optionally add further information about you if you wish to do so. For additional information.  

Your provision of Personal Data in connection with recruiting is voluntary, and only you determine the extent of information You provide us with. We will use the information you provide us with solely to communicate with your job application and  to manage our recruiting and hiring processes. If You will eventually be hired by us, the information may be used in connection with employment and corporate management and based on a contract with us.

5.2. Data about Users and/or Members

In addition to the Visitor information described above, the following may be collected and processed about our Users:

Type of Information

How Do We Use It?

Mobile Permissions: Depending on the type of User’s mobile device and its operating system, our App may request permission to access certain types of Personal Data such as User’s geolocation, camera and photo gallery. These permissions are subject to additional consent from our Users, which will be given separately.

We use these permissions for reasons which are elaborated prior to our request for User’s consent to the additional permission. The requested permissions are used to enhance our Users experience from the Services. For example, when we ask for permission to access a device photo gallery or to the device’s camera, it is meant to let Users upload a profile picture to the App.

Customer’s eligible employees information: When a Customer wishes to assign Credit Points to their eligible employees and make them Members, we will receive the following data about such employees for the Customer: first name, last name, work physical address, work email address, phone number, role with the company (aslo, a Customer), and home zip code. 

We use this information for the following purposes: 

• Issue Credit Points to a Customer, and to eligible employees within the Customer’s organization.
• Register the employee in our systems as an eligible employee and issue a URL link to the Members App, where they can register and access to their anywell account.
• Manage and sync the eligible employee’s details with the Member account and usage of the Services and Credit Points.
• Calculation and measurement of usage and Credit Points for billing purposes of Customers. 

Account information: eligible employees who use the aforementioned URL link, shall use it to register and open an account with us in order to use Credit Points. For the registration and account management, we will process the following information: 

• For Sign-up and registration: work email address and password you will create and be retained in a secure third-party authentication service.
• Upon authentication and confirmation of your account, you may edit or add information about you. Some information is required, such as: first name, last name and phone number. Other information will be optional and will be used to enhance and customize your usage of the account and Services, such as: creating a nick-name to protect your privacy, birth date, profile picture, and information about your preferences of Spaces and working environment, all as related to providing the Services. 

In addition to the purposes described under each data collection type, we will use this information for the purpose of performing our contract with Customer,  to contact eligible employees with account information, validation purposes, registration, authentication, account opening and management of Member activity, so as tracking general activity for purposes of measurement, calculation, reporting to Customers and billing for the Services. 

We may also use this information for any purpose related to providing the Services, including, verify your Member identity, designate an account, provide with customer support, send required information related to the Services and our business engagement (e.g., send you a welcome message, notify you regarding any updates to our Services) and other related notifications.  

App usage and activity: we process usage information such as action taken by the User, including, Booking and Credit Points usage, cancellation, Guests registration, visit completion and any information related to your use if the Services as may be required. 

We use this information to operate the Services, make sure they are available on an accurate and timely manner, to track usage of the Services, and sync Booking, so as to eliminate double Booking, to report to Customers about the usage they pay for, and to bill Customers, so as to ensure we improve the Services and make them fit to our Customers’ needs. 

Guests Information: When a Member finalizes a Booking which involves Guest/s via the Services, that Member is requested by us to forward Booking’s calendar invitation, which they receive from us upon Booking’s completion, to their expected Guest/s - for the Guest/s to confirm their arrival. In such a case, we may process information about a Guest that was submitted by a Member. This information may include: Guest’s full name and email address. 

We use this Personal Data about Guests in order to ensure their arrival to meetings; ensure Spaces’ capacity for the number of Guests submitted and to report a meeting completion, when that is the case.

5.3. Customers and suppliers

In addition to the Visitor information described above, the following may be collected and processed about our Customers or any of our supplier with which we are engage :

Type of Information

How Do We Use It?

Identifiers: anywell engages with representatives of Customers in order to create business collaboration. Such engagement may include the need for the Customer representative to provide the Company with details such as their full name; work email address; phone number; role at the relevant company and work address or any other information required for the then current business engagement, as indicated in the relevant communication with the Customer. 

We use such information to prepare for a contract with a Customer or, to perform such a contract, including for Service reporting and billing purposes.

6. How we Collect Data

Depending on the nature of your interaction with the Services, We may collect Data as in one or more of the following ways:

• Automatically. Certain online information may be automatically processed by the Services when you access them or install any part of them, including by accessing to your device local storage. This may include Cookies, tags or log files to process information locally on your device, gather some information automatically.
• Provided by you. When you contact us (either directly or by using third-party services), register to our Services or use them for certain purposes, for example, when performing a Booking, you actively submit your Personal Information to us. 
• Information provided by third-parties. 

• If you are a Member: Before you become a Member, we receive information about you from your employer as an eligible employee (to use Credit Points and the Services).
• We receive information about Users’ inquiers to our customer support service, Zendesk Inc (“Zendesk”).
• We receive information about Guests from the Member who invited them to a Space. 
• Information about a Member and a Guest visit in a Venue once completed, from the Venue, for recording, reporting, Credit Points calculating and billing purposes. 

• Publicly available data - If you are a Customer (or a prospective one), we might use information manifestly made publicly available by you to contact you.

7. Cookies and other web technologies

When you access or use the Website or App, We may use “cookies”, tags or pixels (or similar mobile technologies when using the App), which store certain information on your device (i.e., locally stored) and which will allow us to customize the Services and content as well as enhance Users experience of the Website and App. The use of cookies is a standard industry-wide practice. 

A "Cookie" is a small piece of information that a website or app assigns and stores on your device while you are viewing them. Cookies are very helpful and can be used for various different purposes such as allowing you to navigate between pages efficiently and making the interaction between you and the Services quicker and easier. 

We may permit third parties to use cookies or other technology to collect information about certain online actions across Our Services. 

8. Social Media Integrations

Our website includes social media features such as Linkedin links to our Services page and our founders profiles. When you browse Linkedin via our Website, Linkedin may collect your IP address or any other information related to the sources from which you browse the site. Your interactions with these features are governed by the privacy policy of the company providing it and not by this Policy. 

9. Sharing Data with Third Parties

We keep the Personal Data about our Users in strict confidence and only share it with third parties in very limited circumstances and for very specific purposes, as per the categories described below. We hereby emphasize and commit that we do not sell your Personal Data to any source and under no circumstances. 

Notwithstanding the foregoing, we might share our Data in the following cases:

• Customers: as part of our engagement with Customers, we will report them about the usage of the Services and Credit Points by their eligible employees (Members). 
• Venues: We share limited Personal Data about Members and Guests with Venues, when such a Member made a Booking to that Venue, in order for the Venues to be able to place reservations for Users in the Venue, allocate a Space  and certify Users' identity;
• Third Party Tools, Services and Integrations: anywell is partnering with a number of selected service providers, whose services and solutions complement, facilitate and enhance our own. These include media services who advertise the Services and send prospective Customers to us, data hosting, database and server co-location services (e.g., Amazon (AWS)), data analytics services (e.g. Google Analytics), forms and application management (such as Monday.com, Amazon Cognito) and session replay records for analytic purposes such as crashes, functionality and usability (e.g. MixPanel) and also customer support services (e.g. Zendesk), email services (e.g. Amazon SES)  and our business, legal and financial advisors (collectively, “Third Party Service Providers”). 

Such Third Party Service Providers may receive or otherwise have access to some of your Personal Data, depending on each of their particular roles and purposes in facilitating and enhancing the Services, and may only use your Personal Data for such purposes. Disclosures of Personal Data by us are subject to the respective third party’s undertaking of confidentiality obligations, and the prevention of any independent right to use this data, except as required to help us provide you with the Services.

• Law enforcement, legal proceedings: we may disclose or otherwise allow access to Personal Data pursuant to a legal requirement or request, such as a subpoena, search warrant or court order, or in compliance with applicable laws and regulations. Such disclosure or access may occur with or without notice to you, if we have a good faith belief that we are legally required 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;
• Protecting Rights and Safety: We may share your Personal Data with others, with or without notice to you, in cases of emergency or if we believe in good faith that this will help protect the rights, property or personal safety of the Company, any of our Users or any member of the general public;
• Change of control: In the event that anywell will be acquired by, or merged with, a third party entity, we reserve the right to transfer or assign the Personal Data collected by us, as part of such merger, acquisition, sale, or other change of control;
• Upon Your explicit consent: for the avoidance of doubt, We may share your Personal Data in additional manners, pursuant to your explicit consent;
• Additionally, we may transfer, share or otherwise use Non-Personal (including anonymized, statistical or aggregated) Data in our sole discretion and without the need for further approval.

10. Where we Store Your Personal Data

Your Personal Data will be maintained, processed and stored by us in secure cloud storage, provided by our Third Party Service Providers based in the United States. Make sure

While the data protection laws in jurisdictions where the information is physically stored may be different than the laws of your residence or location, please know that we, o and our service providers that store or process Personal Data on our behalf, are each committed to keeping it protected and secured, pursuant to this Policy, best industry standards, and globally acceptable standards to host, manage and secure Personal Data, regardless of any lesser legal requirements that may apply in a particular jurisdiction.

11. Data Retention

We retain Personal Data under certain retention principles that are designed to protect Users privacy, including minimal retention schedules only for as long as the Personal Data is needed to maintain an account, provide the Services and bill for them, or, as applicable law may otherwise require (billing information for example). 

If you withdraw your consent to us processing your Personal Data, or, if you choose to delete your account and terminate the engagement with us, we will delete your Personal Data associated with such account from our systems, except to the extent such data in whole or in part is required to comply with any applicable rule or regulation, or required for billing purposes, or to respond to a legal proceeding brought against us or our affiliates.

12. Your Rights Under the Policy

Depending on your country of residency, and on the type of a User you are (i.e. Visitor, Member or Customer) certain rights concerning your Personal Data may be available to you. Please contact us at privacy@anywell.com with your detailed request and sufficient information to allow us to verify you and your request, and we will process your verifiable request within the timeframe indicated in the applicable regulation. Please note, that when handling these requests, we may ask for additional information. 

If you are a Visitor of the Website, some of the following rights would not apply to you, and you may choose to exercise your rights by refusing certain types of cookies, deleting cookies or set your browser to refuse cookies to begin with.

1. Right of access: You may ask anywell to access any Personal Data held about you. If you maintain an account with us, you can access such data directly from you account, or, download such data from the account
2. Right to rectification: other than edits and corrections you can make directly from your account, you may also ask us to correct the information we hold about you; 
3. Right to erasure: You may ask us to delete your information or to stop using it. We can only do this when possible, and as allowed by applicable laws. Sometimes we need your information to complete a transaction based on an action you made, to comply with the law or simply to provide you or your employer (if you are a Member) with the Services. 
4. Right to the restriction of processing: You may ask us to temporarily cease the processing of your  Personal Data, or, for specific purpose or function. Please note that this too, might cause us to not be able to provide you with the Services or part thereof.
5. Objection to processing: you may request us to stop processing your Personal Data. Similar exceptions as mentioned above will apply to such a case as well. 
6. Right to data portability: You may contact us to request an export of your Personal Data in a reusable format, or to directly transfer such data to another vendor offering related services.
7. Right to withdraw consent: Where you have given us your consent to use your information for a specific purpose, you may, at any time, decide to withdraw your consent and we will then stop using your information for that purpose, under the exceptions listed above.
8. Right to lodge a complaint: If You live in a country where the EU GDPR applies (e.g. the EU, EEA or UK), you may lodge a complaint with the authority responsible for protecting Personal Data in your country of residence, if you believe that your rights have not been respected by us. In such a case, you are welcome to reach out to us first so we will be able to help you with such a matter, at: privacy@anywell.com. 

13. Choice and Control

Users who do not maintain an account with us, or are not engaged with us with a business-to-business contract, may seek to exercise their privacy rights as follows:

• Visitors: by setting their cookies and web technologies’ preferences via their browser settings, and, if actively submitted Personal Data to us, may reach out to us with requests about their Personal Data.
• Subscribers to our mailing list: by using the “unsubscribe” option available at the bottom of an email communication to opt-out from email communication.
• Job applicants: by reaching out to us by email with the relevant request, as detailed above. 

14. Minors

In order to use the Services, you must be over the age of 16. anywell does not knowingly collect Personal Data from or about children under that age, and does not wish to do so. We reserve the right to request proof of age from any of Users at any point - so that we can verify that people under the age of 16 are not using Our Services. 

In the event that it comes to our attention that a person under the age of 16 is using theServices, We may prohibit and block them in the system, or seek for the necessary approvals from their parent or employer. 

15. Data Security

We take great care in implementing and maintaining the security of our Services and of Personal Data maintained by us. We use highly trusted Third Party Services that employ strict security standards, both technically and physically, and maintain policies and audits to ensure the safety of data facilities. We also employ organizational and technical measures to ensure protection of Personal Data, reduce the risks stemming from loss of information and prevent unauthorized use of any such information. However, We do not and cannot guarantee that unauthorized access will never occur and reiterate that no measure can provide absolute information security.

16. General

This Policy, its interpretation, and any claims and disputes related hereto, shall be governed by the laws of the State of Israel, without respect to its criminal law principles. Any and all such claims and disputes shall be brought in, and you hereby consent to them being litigated in and decided exclusively by a court of competent jurisdiction located in Tel Aviv, Israel.

17. Contact Us

If you have any questions or comments concerning this Policy, we will be happy to hear from you. Please send us an email to: privacy@anywell.com, and we will try to get back to you as soon as possible.