Privacy Policy

Sternum Ltd. (“Sternum“, “we“, “our” or “us“) provides a security and visibility solution which, using robust technology and seamless integration, enables manufacturers of various products to offer managed and monitored IoT devices with built-in real-time security (the “Service”).

This Privacy Policy describes how we collect, store, use and disclose personal data of our business customers (“Customers” or “you”), as well as personal data submitted to us by Customers via their IoT devices using the Service, with regards to the end-users of such devices (“Consumers”).

This Policy also describes our roles as “Data Controller” (of Customers’ data); and “Data Processor” (of Consumers’ data, on our Customers’ behalf), and our general data practices in relation to the Service.

Specifically, this Privacy Policy describes our practices regarding:

1.      Data Collection

2.      Data Uses

3.      Data Location and Retention

4.      Data Sharing

5.      Cookies and Tracking Technologies

6.      Communications

7.      Data Security

8.      Data Subject Rights

9.      Data Controller/Processor

10.     Additional Notices

Please read this Privacy Policy carefully and make sure that you fully understand and agree to it. If you do not agree to this Privacy Policy, please discontinue and avoid using our Service.

You are not legally required to provide us with any data (which, to the extent it relates to an identified or identifiable individual, will be deemed as “Personal Data”). That said, please note that we do require certain Personal Data concerning you, and without it we will not be able to provide you with the full range of the Service. On the other hand, Customers are prohibited from submitting any data regarding their Consumers, except to the limited extent described in Section 1 below, without our prior written permission.

1.      Data Collection

Customer Data:

You may provide us with Personal Data such as your name, workplace and position, contact details (such as e-mail, phone and address), as well as any other data you choose to provide in order to procure our Service or contact us. To the extent that such data concerns a non-human entity, we will not regard it as “Personal Data” and this Privacy Policy shall not apply to it.

Moreover, we collect or generate certain technical data concerning your use of the Service. We collect or generate such data either independently or with the help of third-party services (as detailed in Section 4 below), including through the use of “cookies” and other tracking technologies (as further detailed in Section 5 below). This mainly consists of connectivity, technical and aggregated usage data, such as IP addresses, non-identifying data regarding a device, operating system, browser type, locale and language settings, the cookies and pixels installed on such device, session logging, heatmaps and scrolls, screen resolution, ISP, referring or exit pages, and date/time stamps, and the activity (clicks, browsing, zooms and other interactions) on our website and/or the Service.

Consumer Data:

The use of our Service typically requires the submission of limited Personal Data pertaining to the Consumers of our Customer’s IoT device, namely the IP address through which such device is connected (which may relate to the Consumer in certain circumstances), and additional technical data concerning the device (which in itself does not relate to the Consumer, however it will be relatable to the connection’s IP address).

Other than as stated above, Customers are prohibited from submitting any data relating to an identifiable individual(s) to our Service without our prior written permission. In particular, Customers must refrain, and are contractually prohibited from providing Sternum with any Personal Data of children under the age of 16; any health, financial, or insurance data; or other data which is subject to specific regulatory or statutory protection regimes (including "special categories" of data under the EU GDPR).

We do not monitor or legally review any of the data submitted to the Service and are not able to classify it as personal/sensitive or not, nor do we utilize it for our own purposes.

If you still choose to submit any excess Personal Data regarding your Consumers, you must receive their explicit consent for such disclosure and use, and you remain solely responsible and fully liable for its protection.

2.      Data Uses

We use Personal Data as necessary for the performance of our Service; to comply with applicable law; and to support our legitimate interests in maintaining and improving our Service and our offerings, understanding how our Service is used, optimizing our marketing, advertising and sales activities, customer service and support operations, and protecting and securing Customers, Consumers, ourselves and our Service.

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

Specifically, we use Personal Data for the following purposes:

a.       To facilitate, operate, and provide our Service;

b.      To further develop, customize and improve the Service and general user experience, based on common or personal preferences, experiences and difficulties;

c.       To provide you with assistance and support;

d.      To support and enhance our data security measures, including for the purposes of preventing and mitigating the risks of fraud, error or any illegal or prohibited activity;

e.       To create aggregated statistical data, inferred non-personal data or anonymized or pseudonymized data (rendered non-personal), which we or our business partners may use to provide and improve our respective services; and

f.        To comply with any applicable laws and regulations.

3.      Data Location and Retention

Data Location:  

Personal Data may be maintained, processed and stored by us and our authorized affiliates and Service Providers (defined below) in the United States of America (U.S.), the State of Israel and other jurisdictions, including the European Union, as necessary for the proper delivery of our Service, or as may be required by law.

Sternum has offices in Israel, which offers an adequate level of protection for the Personal Data of EU Member State residents.

Sternum may be required to transfer Personal Data to countries other than the country in which the data originated. Any such transfers shall be done in compliance with all applicable laws. While privacy laws may vary between jurisdictions, Sternum, its affiliates and Service Providers (as defined below) are each committed to protect Personal Data in accordance with this Privacy Policy and customary industry standards, regardless of any lesser legal requirements that may apply in their jurisdiction.

Data Retention:

We retain Customer Personal Data for as long as reasonably necessary in order to maintain and expand our relationship with them and to provide them with our Service.

We retain Consumer Personal Data in accordance with the instructions of the Customer on whose behalf we process such data.

We will also retain Customer Personal Data and Consumer Personal Data for as long as is required in order to comply with our legal and contractual obligations, or to protect ourselves from any potential disputes (i.e. as required by laws applicable to log-keeping, records and bookkeeping, and to have proof and evidence concerning our relationship, should any legal issues arise following your discontinuance of use), in accordance with our data retention policy.

Please note that except as required by applicable law or under our commercial agreements with you, we will not be obligated to retain Personal Data for any particular period, and we are free to securely delete 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 email at privacy@sternumiot.com.

4.      Data Sharing

Legal Compliance:

We may disclose or allow government and law enforcement officials access to Personal Data, in response to a subpoena, search 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 we are legally compelled to do so, or that it is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing.

Service Providers:

We may engage selected third party companies and individuals to perform services complementary to our own, namely - hosting, data analytics, consulting, development, support, marketing and advertising, data and cyber security, user engagement, e-mail distribution and monitoring, text messaging and session recording; as well as our business, legal and financial advisors (collectively, “Service Providers“). These Service Providers may have access to Personal Data, depending on each of their specific roles and purposes in facilitating and enhancing our Service, and may only use it for such purposes.

Sharing Personal Data with our Customers:

We may share the Personal Data of our Customer’s Consumers (if any), with such Customer. Sternum is not responsible for, and does not control any further disclosure, use or monitoring by or on behalf of the Customer, that itself acts as the “Data Controller” of such data (as further described in Section 10 below).

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 Sternum, any of our Customers, their Consumers, or any members of the general public.

Sternum Subsidiaries and Affiliated Companies:

We may share Personal Data internally within our group, for the purposes described in this Privacy Policy. In addition, should Sternum or any of its subsidiaries or affiliates undergo any change in control or ownership, including by means of merger, acquisition, fund raising or purchase of its shares or assets, Personal Data may be shared with the parties involved in such an event. If we believe that such change in control might materially affect any Personal Data then stored with us, we will notify our Customers of this event and the choices they may have.

For the avoidance of doubt, Sternum may share Personal Data in additional manners, such as pursuant to your explicit approval, if we are legally obligated to do so, or if we have successfully rendered such data non-personal and anonymous. We may transfer, share or otherwise use non-personal data at our sole discretion and without the need for further approval.

5.      Cookies and Tracking Technologies

Our websites and some of our Service Providers integrated there utilize “cookies”, anonymous identifiers and other tracking technologies which help us provide, secure and improve our websites, personalize your experience and monitor the performance of our activities and campaigns.

A cookie is a small text file that is placed, for example, to collect data about activity on our websites. Some cookies and other similar technologies serve to recall Personal Data, such as an IP address, that was previously indicated by the person using our websites.

While we do not change our practices in response to a “Do Not Track” signal in the HTTP header from a browser and recommend the use of cookies for an optimal user experience of our Service, most browsers allow you to control cookies, including whether to accept them or to remove them. You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser.

6.      Communications

Service Communications:

We may contact Customers with important information regarding our Service. For example, we may notify you (through any of the means available to us) of changes or updates to our Service, billing issues, service changes, etc. We may also send you notifications, messages and other updates.

Promotional Communications:

We may also contact Customers with promotional messages (such as newsletters, special offers and sales, new product announcements, etc.) or any other information we think is valuable. We may provide such notices through any of the contact means available to us (e.g. phone or e-mail), through the Service or through our marketing campaigns.

If you do not wish to receive such promotional communications, you may notify us at any time by sending an email to privacy@sternumiot.com, changing your communications preferences in your email account, or by following the instructions contained in the promotional communications you receive.

7.      Data Security

In order to protect Personal Data held with us and our Service Providers, we use industry-standard physical, procedural and electronic security measures. However, please be aware that regardless of any security measures used, we cannot and do not guarantee the absolute protection and security of any Personal Data stored with us or with any third parties as described in Section 4 above.

8.      Data Subject Rights

Customers Rights:

If you wish to exercise your 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 request access to, and rectification or erasure of your Personal Data held with Sternum, or to restrict or object to such Personal Data’s processing, or to port such Personal Data, or the right to equal services and prices (each to the extent available to you under the laws which apply to you) – please contact us by e-mail at support@sternum.com.

Consumers Rights:

Customers must provide adequate notice (for example through a privacy policy) to their Consumers whose data they intend to submit to the Service – including sufficient reference to the processing of such Consumer Personal Data for such purposes, and any other information necessary to comply with all applicable laws.

If a Consumer would like to make any requests or queries regarding Personal Data which they believe we process on our Customer’s behalf, we encourage them to contact such Customer directly. Should such requests or queries be made to Sternum instead, we may forward them to the Customer we believe to be relevant.

9.      Data Controller/Processor

Certain data protection laws and regulations, such as the GDPR or the CCPA, typically distinguish between two main roles for parties processing Personal Data: the “Data Controller” (or 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 (or business). Below we explain how these roles apply to our Service, to the extent that such laws and regulations apply.

Sternum is the “Data Controller” of its Customers’ Personal Data, and with respect to which, assumes the responsibilities of Data Controller (solely to the extent applicable under law), as set forth in this Privacy Policy.

Only to the extent that a Customer has submitted any Consumer Personal Data to the Service, such data shall be processed by Sternum on behalf of our Customer, and may be shared with such Customer in accordance with this Privacy Policy and in accordance with their reasonable instructions and our agreements with them. Such Customer shall be deemed the “Data Controller” of its Consumers’ Personal Data and Sternum will process such data on this Customer’s behalf, as its “Data Processor”. The Customer will be responsible for meeting any legal requirements applicable to Data Controllers (such as establishing a legal basis for processing and responding to Data Subject Rights requests concerning the data they control).

10.  Additional Notices

Updates and Amendments:

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

Children:

Our Service is not designed to attract children under the age of 16. We do not knowingly collect or process Personal Data from children and do not wish to do so. If we learn that a person under the age of 16 is using the Service, we will prohibit and attempt to block such use and will make reasonable efforts to promptly delete any Personal Data stored with us with regard to such child. If you believe that we might have any such data, please contact us by email at privacy@sternumiot.com.

External Links:

While our websites may contain links to third parties’ websites, services or applications, we are not responsible for their privacy practices, and encourage you to pay attention when you leave our websites for the website, service or application of such third parties and to read the privacy policies of each and every website, service or application that you interact with. This Privacy Policy applies only to our websites and Service.

Questions, Concerns or Complaints:

If you have any comments or questions about this Policy or if you have any concerns regarding Personal Data, please send an email to privacy@sternumiot.com. If you are a GDPR-protected individual, you also have the right to lodge a complaint with an EU supervisory authority.

Effective Date: March 10, 2020