Privacy Policy

Last Revised: August 26th , 2019

MetaFlow Ltd. (“Meta Flow”, “Company” “we”or “us”) are committed to protect the privacy of the users of ourwebsite located at (the “Website”) and of theusers of the Lumen device (the “Lumen Device”) and of the services weprovide in connection with use of the Lumen Device through the Lumen mobileapplication (respectively“User(s)” or “you”; the “Lumen Services” and the “LumenApp”), in compliance with applicable privacy andpersonal data laws and regulations. The Website, the Lumen Device, the LumenServices and the Lumen App shall be together referred to hereunder as the “Services”This Privacy Policy (the “Privacy Policy”) is intended todescribe our practices regarding the information we may collect from you whenyou use the Services, the manners in which we may use such information, and theoptions and rights available to you.This Privacy Policy supplements, and should be read in conjunctionwith our Terms of Use (the “TOU”), which providesadditional information on the Services. Capitalized terms which are not definedherein, shall have the meaning ascribed to them in our TOU.



2. Types of information we may collect from our Users
We may collect three types of data and information from our Users:

i. Personal Information, which is informationthat identifies an individual or may with reasonable effort identify anindividual, either alone or in combination with other information, all unlessanonymized. Such as name, email, address, location and date of birth. Sometechnical parameters may also be considered as Personal Information, such as IPaddress and UDID (Unique Device Identifier), and;

ii. Health, Wellnessand Nutrition Related Information (“Health Information”), which is Personal Information that correspondsto a measurement of your physical/mental objective an/or subjective state andnutrition data, such as height, weight, sleep habits, food, caffeine and waterintake, heart rate, breath data, real-time assessment of carbohydrateavailability and metabolic fuel use as measured via use of the Lumen Device andthrough the Lumen App, as well as body activity data, such as types ofexercise, number of steps, speed and distance and any Personal Information wederive from such information; and

‍iii. Non-personalInformation, which is non-identifying and without reference to the identity ofany User, such as technical data that is necessary for the performance ofthe Service, for example app analytics, taps and inputs, Wi-Fi networkinformation, operating system, mobile device type, Lumen Device technicalinformation, browser and keyboard language, the 'click-stream' and activitieson the Service, and the period of time the Service were used and related timestamps.

For the avoidance of doubt, any Non-personal Information connectedor linked to any Personal Information shall be deemed as Personal Informationas long as such connection or linkage exists. In this context it is importantto note that Health Information is included within the category of PersonalInformation for the purposes of this Agreement.
3. How do we collect information?
We collect personal information from youand any devices (including mobile devices) you use when you: use or access ourServices, register for an account with us, provide us information on a web formor other text field, update or add information to your account, or throughcorrespondence you and we conduct with each other.

More specifically we collect and use thefollowing categories and types of information:

3.1.   Personalinformation you provide us when you use our ServicesGenerally, this category refers to anyinformation, data or content you actively and voluntarily create or providethrough our Services such as:·      Contact information such as your name, email and physicaladdresses, or telephone number that you provide through the Services when youfill our online form or register for an account with us or when you update youraccounts details.·      Information you provide during a transaction you perform throughthe Services, or other transaction-based content that you generate related tosuch transaction.·      Other content that you generate, or your actions in your use ofyour account (such as adding items to your shopping cart, adding items to yoursaved items list etc.·      Health Information and any other information you provide us in thescope of your use of the Lumen Services, the Lumen App and the Lumen Device,such as breath samples, daily diet, exercise routine, emotional and mentalstate, perceived sense of viability, as well as ongoing feedbacks that youprovide us regarding your satisfaction from the diet plans, the difficulty tofollow-up with the plans, etc. ·       The contents of your interactionwith our customer support or sales departments, which may includetext/video/audio recording and transcripts of such communications includinginformation you enter in our “Contact Us” online form or any similar input.·      Financial information (such as credit card or bank accountnumbers) that you provide us in the scope of transactions you make through theServices, which is processed by our third party services providers as furtherdetailed below and to which we have no access. ·      Shipping, delivery, postage, billing and other information used totransact and deliver through the Services, as well as, where applicable,information required to clear customs (such as Tax ID or other identificationnumbers).3.2.   Personalinformation we collect automatically when you use our ServicesIn other words, we are aware of your usage ofthe Services and Website and may gather, collect and record the informationrelating to such usage, including by using our third party service providers asdetailed in Section ‎‎5 (sharinginformation with third parties) below, and by using “cookies” and othertracking technologies, as further detailed in Section ‎13 (Third PartyServices/Software, Cookies and Other Tracking Technology) below.·      We collect information about your interactionwith and use of our Services, including in certain cases about your impressionsof and reactions to our advertisements, and information related to ourcommunications with you. This is information we receive from devices (includingmobile devices) and software you use when you access our Services. Thisinformation could include the following: mobile device geo-location, mobiledevices motion, Device ID or unique identifier, device type, ID foradvertising, unique device token, operating system, information regarding yourclicks and “clicks stream”, views and engagement with our advertisement andServices, information concerning your traffic to and from the Website, yourreferral URL to and from our Website, ad data, your IP address, your web loginformation, and location information as can be derived from your IP address.For more information about our use of thesetechnologies, and how to control them, see our Cookies Policy·      We collect and process Personal Informationwhich is derived from other Personal Information we collect or obtain from you.This means that we process Personal Information in order to provide you withthe output of our Lumen Services such as recommendations, suggested analysisand other insights we may offer through use of the Lumen Services.  Please takeinto consideration that certain portions of such abovementioned information mayalso be collected from your device or software, when the Lumen App is runningin the background, i.e. when it has been launched but not used.   Please keep inmind - that mostmobile devices and auxiliary software, allow you to control or disable the useof certain collectable information including location services, by anyapplication, in the device's settings menu.3.3.   Personalinformation collected from third parties ·      Whenusing the Lumen Services you may choose to connect your Account with certainother third party accounts you hold with such third party applications andplatforms (such as Apple Health Kit, Android Fit, etc.), and thereby to provideus with access to information available on such accounts. ·      SocialMedia - We allow you to share information with social platforms, or use socialplatforms to create your account or to connect your account with the respectivesocial platforms. Those social platforms may give us automatic access tocertain personal information retained by them about you (e.g., content viewedby you, content liked by you, your public profile other profiles you areassociated with, and information about the advertisements you have been shown orhave clicked on, etc.). You control the personal information you allow us tohave access to through the privacy settings on the applicable social platformsand the permissions you give us when you grant us access to the personalinformation retained by the respective social platforms about you.·      We mayalso collect personal information concerning you, from third parties who haveassured us that they have obtained your consent for such provision ofinformation or that you have freely and publicly provided. For example, we maycollect and use demographic and other information that is publicly available inan applicable jurisdiction, additional contact information, credit/checkinformation, and information from credit bureaus, as allowed by applicablenational laws.Byassociating your Account with your social platform account or other third partyaccounts and authorizing us to have access to information maintained by suchthird party accounts, you agree that we can collect, use and retain suchinformation in accordance with this Privacy Policy.We will not collect any Personal and Health Information from youor related to you without your explicit approval, which is obtained, inter-alia,through your active acceptance of the TOU and this Privacy Policy.  PLEASE NOTE - If you give uspersonal information about someone else, you must do so only with that person’sexpress authorization. You should inform them how we collect, use, disclose,and retain their personal information according to this Privacy Policy beforeyou provide us with their personal information.
4. The Purposes and Legal Basis of the Collection, Processing and use of Information
4.1.   Legal Basis for useWe collect, process and use your Personal Information, which isadequate, relevant and limited to what is necessary in relation to the purposesdescribed in this Privacy Policy, based at least on one of the following legalgrounds:  ·       In Performing an agreement with you: We collect and process your Personal Information in order to provideyou with the Service, following your acceptance of this Privacy Policy andpursuant to the Terms of Use; to maintain and improve our Services; to developnew services and features for our Users; and to personalize the Services inorder for you to get a better user experience. ·       Withyour consent: We ask for your consent and approvalto collect and process your Personal Information including specifically anyHealth Information for the purposes set forth in this Privacy Policy and youhave the right to withdraw your consent at any time. ·       Legitimateinterest: We process your Personal Informationfor our legitimate interests while applying appropriate safeguards that protectyour privacy. This means that we process your information for things likedetecting, preventing, or otherwise addressing fraud, abuse, security,usability, functionality or technical issues with our Services, protectingagainst harm to the rights, property or safety of our properties, or  our users, or the public as required orpermitted by law; enforcing legal claims, including investigation of potentialviolations of this Privacy Policy; defending legal claim made by you or on yourbehalf against us, in order to comply and/or fulfil our obligation underapplicable laws, regulation, guidelines, industry standards and contractualrequirements, legal process, subpoena or governmental request, as well as ourTOU. 4.2.   Purpose of use We may use the Personal Information that we collect about you forthe following purposes: ·       To provide, operate and improve the Services.·       Toverify the identity of our Users·       To personalize the Services and content provided to you, to customizeand improve your use experience of the Services, and to enable you to retrieveyour information.·       To be able to contact Users for the purpose of providing them withtechnical assistance, support, handle requests and complaints and collectfeedback;·       To send you updates, notices, notifications, and additionalcommunications regarding the Services·       To study and analyze the information on an aggregated, statistical basisto discover patterns and anomalies, to study complications and treatmentmethods and improvements, and other health related research and development; ·       To enable us to further develop, customize and improve the Service basedon Users’ common preferences, uses, third party services, features andfunctionalities, statistical and research purposes, attributes and anonymized data etc.;·       Toprevent, detect, mitigate, and investigate fraud, security breaches or otherpotentially prohibited or illegal activities;·       Todisplay or send to you marketing and advertising material and general andpersonalized content and advertisement via the Services, the Website, email,postal mail, telephone, mobile devices and/or when you visit other sites.·       Toperform functions or services as otherwise described to you at the time ofcollection;·       Tocomply with any applicable rule or regulation, to protect our legal interestsand/or respond to or defend against (actual or potential) legal proceedingsagainst us or our affiliates.
5. Sharing Information with Third Parties
MetaFlow willnot share or otherwise allow access to any Personal or Health Information itcollects to any third party, except in the following cases: (a) Lawenforcement, legal proceedings, and as authorized by law: We may disclosePersonal Information to satisfy anyapplicable law, regulation, legal process, subpoena or governmental request; (b) ProtectingRights and Safety: We may share Personal Information to enforce thisPrivacy Policy and/or the TOU, including investigation of potential violations thereof;to detect, prevent, or otherwise address fraud, security or technical issues;to respond to claims that any content available on the Service or the Siteviolates the rights of third-parties; or otherwise if we believe in good faiththat this will help protect the rights, property or personal safety ofMetaflow, any of our Users, or any member of the general public. (c) OurAffiliated Companies: We may share Personal Information internally with ourfamily of companies for the purposes described in this Privacy Policy. Inaddition, when MetaFlow or any of our affiliated companies is undergoing anychange in control, including by means of merger, acquisition or purchase of allor substantially all of its assets, we may share Personal Information with theparties involved in such event. If we believe that such change in control mightmaterially affect your Personal Information then stored with us, we will notifyyou of this event and the choices you may have via e-mail and/or prominentnotice on our website or Services;(d) ThirdParty Services: We are partnering with a number ofselected service providers, whose services and solutions complement, facilitateand enhance our own.  Such ThirdParty Service Providers may have access to, or process on our behalf Personaland Health Information which we collect, hold, use, analyze, process and/or manage. These ServicesProviders include hosting, database and server co-location services (e.g.Aamzon Web Services), data analytics services (e.g. Google Analytics), sessionreplay records for app analytic purposes such as crashes, functionality andusability (e.g. MixPanel), and our business, legal and financial advisors (collectively, "ThirdParty Service Providers"). We remain responsible for any PersonalInformation processing done by Third Party Service Provider on our behalf notin accordance with the terms hereof, except for events outside of itsreasonable control and except for such Third Party Service Providers with whomyou have a direct contractual relationship.
6. Storage, Transfer and Retention of your Information
Informationregarding the Users will be maintained, processed and stored by us and ourauthorized affiliates and service providers in the United States, EU and inIsrael, and as necessary, in secured cloud storage, provided by our third partyservice provider.Whilethe data protection laws in the above jurisdictions may be different than thelaws of your residence or location, please know that we, our affiliates and ourservice providers that store or process your Personal Information on the ourbehalf are each committed to keep it protected and secured, pursuant to thisPrivacy Policy and industry standards, regardless of any lesser legalrequirements that may apply in their jurisdiction. Specifically, each of ourservices providers who stores or processes your Personal Information either,(i) assured us that it provides adequate safeguards to protect your rights toprivacy, (ii) holds and processes such information on our behalf in ajurisdiction which has been determined to ensure an adequate level protectionby the EU Commission, or (ii) if in the US, is certified under the EU-USPrivacy shield framework.Byproviding your information, you expressly consent to the place of storage andtransfer described above, including transfers outside of the jurisdiction inwhich the information was provided.Weretain the Personal Information we collect only for as long as legitimatelyneeded and to the extent required for the achievement of the purposes listed under Section 4 including without limitation, as reasonably necessary to comply with ourlegal obligations and/or protect ourlegitimate interests. We then either delete from our systems or anonymize itwithout further notice to you. If youare under a limited Subscription plan, your access rights to the Lumen Servicesshall expire upon expiration of your Subscription and your Account shall bedeactivated, unless you renew your Subscription by completing payment toMetaflow, of the then applicable Subscription Fees. Unless you notify us ofyour request to delete your Account as specified in Section ‎7 below, we may maintain your inactive Accountincluding all data and reports therein, in order to allow you to reactivate theAccount if you choose to renew your Subscription at a later stage.
7. Your Rights: Deletion, Withdrawal of Consent, modification or obtaining a copy of Personal Information
If the law applicable to you grantsyou such rights, you may ask to access, correct, or delete your personalinformation that is stored in our systems or that we otherwise control. You mayalso ask for our confirmation as to whether or not we process your personalinformation or ask to withdraw any consent you have previously provided to MetaFlow in connection with our use and processing of your Personal Information.Exercising such rights of deletion and/or withdrawing such consent may resultin our inability to provide you with our Services and in such event, we maynotify you of termination of our engagement with you or otherwise ceaseproviding you with our Services.Subject to the limitations in law, youmay request that we update, correct, or delete inaccurate or outdatedinformation. You may also request that we suspend the use of any personalInformation the accuracy of which you contest while we verify the status ofthat data.Subject the limitations in law, youmay also be entitled to obtain the Personal Information you directly providedus in a structured, commonly used, and machine-readable format and may have theright to transmit such data to another party.If you wish to exercise any of theserights or withdraw your consent, please contact us at: Whenhandling these requests, we may ask for additional information to confirm youridentity and your request. Please note, upon request to delete your PersonalInformation, we may retain such data in whole or in part to comply with anyapplicable rule or regulation and/or response or defend against legalproceedings versus us or our affiliates, or as we are otherwise permitted undersuch law applicable to you. To find out whether these rights applyto you and on any other privacy related matter, you can contact your local dataprotection authority if you have concerns regarding your rights under locallaw.
8. Minors
To open an Account on our Services, you mustbe over the age of eighteen (18). Without relieving you of your responsibilityto comply with the TOU and the terms hereof we reserve the right (withoutobligation) to request proof of age at any stage so that we can verify thatminors under the age of eighteen (18) are not using our Services.In the event that it comes to our knowledgethat a person under the age of eighteen (18) is using our Services, not inaccordance with the abovementioned terms, we will prohibit and block such Userfrom accessing our Services and will make all efforts to promptly delete anyPersonal Information (as such term is defined in herein with regard to suchUser).
9. Local Storage and Third Party Software/Service, Cookies and other Tracking Technology
When you access or use the Service, we may use industry-widetechnologies which temporarily store certain information on the Lumen Deviceand/or your smartphone, your computer or other mobile device (“Local Storage”)and which will allow us to enable automatic activation of certain features, andmake your Service experience much more convenient and effortless. The LocalStorage used by the Service is created per session and is removed as yoursession ends, provided that you have completed your attempt to upload HealthInformation to the Meta Flow Platform and until such completion the informationshall remain on Local Storage. We also use certain monitoring andtracking technologies, including ones offered by third party service providersin order to collect and process Personal Information we specified above. Thesetechnologies are used in order to maintain, provide and improve our Services onan ongoing basis, in order to provide a better experience to our Users and toprovide our customers and potential customers with more relevant advertisementsof our Services. For example, these technologies enable us to: (i) keep trackof and apply our customer's and potential customers’ Lumen Services and Websitepreferences and authenticated sessions, (ii) better secure our Services bydetecting abnormal behaviors, (iii) identify technical issues and improve theoverall performance of our Services, (iv) monitor and analyze our ads’ performance(v) create and monitor analytics relating to use of our Services, and (v)deliver to you targeted advertisements that are more tailored to you based onyour browsing activities and inferred interests.·       Cookies: A cookie is a small datafile that is downloaded and stored on your computer or mobile device when youvisit our Website. Learn more about cookies here: ·       Pixel Tags: Pixel tags (alsocommonly known as web beacons) are transparent images, iFrames, or JavaScriptplaced on our Website or our advertisements and emails, that our third partyservice providers use to understand how the Website, such advertisements andemails are interacted with.To learn more about our use ofCookies and other tracking technology that we use please see our CookiePolicy. Some of these tracking technologiesare provided to us by our Third Party Services Providers who collect andprocess personal information on our behalf. These Third Party ServicesProviders may have direct contractual relationship with you (such as Google andFacebook). Additionally the services provided to us by such Third PartyServices Providers may entail collection and processing of personal informationby such Third Party Services Providers, in a scope which is broader than thescope of personal information we are eventually provided with by such ThirdParty Services Providers. This means that sometimes these Third Party ServicesProviders have more access to your personal information than we do. Forexample, our payment gateway service provider has access to your financialinformation under strict terms, while we do not receive such access at all inorder to better protect your rights. To the extent you have direct contractualrelationship with any of our Third Party Services Providers, any rights you mayhave with respect to your information, collected by such Third Party ServicesProviders, shall be governed by such contractual relationship.  Otherwise the terms of this Privacy Policyshall fully apply.                             In this context you should notethat we may use Google Analytics, Facebook, Twitter and LinkedIn’sfunctionality of re-marketing through their tracking cookies and pixel-basedretargeting services. This means that if you provided your consent to Google,Facebook, Twitter or LinkedIn (the “Social Ad Platforms”) to be providedwith personalized commercial offers, you may be served with ads (includingadvertisements of third parties) based on your access to the Services orWebsite, outside of the Services and Website and across the internet. In suchevent the Social Ad Platforms, will place cookies on your web browser and usesuch cookies to serve you ads based on past visits to our Services andWebsite.   Please visit the Social Ad Platforms Privacy policy to find outhow they use such information:·       Google Adwords: ·       Facebook:·       Twitter: ·       LinkedIn: If you wish to opt-out of such re-targeting and trackingfunctionality of the Social Ad Platforms, you may do so at the following links:·       Google Adwords: ·       Facebook: ·       Twitter: ·       LinkedIn:  PLEASE NOTE – such tracking and targeting by Social Ad Platforms,is provided pursuant to your engagement with such Social Ad Platforms and theactual nature and scope of Personal Information collection and processingperformed by such Social Ad Platforms is not transparent to us. If you wouldlike to learn more or make further inquiries with respect to such nature orscope please refer to each of such Social Ad Platforms directly.In addition, if you wish that we donot use your personal information we obtain through use of cookies and pixeltags for the purpose of serving you personalized relevant ads, please send usan e-mail to and we will respond within areasonable timeframe and in accordance with applicable laws.Learn more about your choices andhow to opt-out of tracking technologies:In order to delete or block any tracking technologies, pleaserefer to the “Help” area on your internet browser for further instructions, orlearn more by visiting our CookiePolicy. You may also opt out of third party tracking technologies byfollowing the relevant instructions provided by each such third party in itsprivacy policy or by visiting, or Please note however that deletingany of our tracking technologies or disabling future tracking technologies mayprevent you from accessing certain areas or features of our Services, or may otherwiseadversely affect your user experience. Please also note that we do not respondto the ‘Do Not Track’ setting on your browser as the protocol and form for suchsetting has not yet been generally accepted.
10. Direct Marketing
By registering to our Services and/orproviding us with your e-mail address or any other contact information(including without limitation through any form on our Website), you expresslyagree to receive promotional content, messages or calls from Meta Flow or ourpartners (acting on our behalf). Accordingly, we or our affiliatedrepresentatives, shall be permitted to call you or send you promotional contentor messages by e-mail, SMS, direct text messages, marketing calls and similarforms of communication.If you wish not to receive such promotionalmessages or calls, you may withdraw your consent by sending a written notice toMeta Flow by email to the following address: [insertemail address]or by pressingthe “Unsubscribe” link contained in the promotional communications you receive.Please note that we may also contact you withimportant information regarding your use of our Services and/or Website. Forexample, we may notify you (through any of the means available to us) ofchanges or updates to our Services, payment issues, service maintenance, etc.You will not be able to opt-out of receiving such service messages.
11. How We Protect Personal Information
We maintain administrative, technical andphysical safeguards designed to protect Personal and Health Information weobtain through Meta Flow's Services, against accidental, unlawful orunauthorized destruction, loss, alternation, access, disclosure or use. OurServices, or parts thereof, are hosted on AMAZON AWS, which provides advancedsecurity features. Meta Flow employs industry standard security procedures,including secured transmission protocols, SSL and advanced authentication.  However, we do not and cannot guarantee thatunauthorized access will never occur.We urge you to use the strongest password combination available onyour mobile device and employ reasonable physical security means to protectunauthorized access.
12. Changes to the Privacy Policy
Meta Flow reserves the right to change thisPrivacy Policy at any time, so please re-visit this page frequently. We willprovide notice of substantial changes of this Privacy Policy on the Serviceand/or we will send you an e-mail regarding such changes to the e-mail addressthat is registered with your Account. Such substantial changes will take effectseven (7) days after such notice was provided on any of the above-mentionedmethods. Otherwise, all other changes to this Privacy Policy are effective asof the stated “Last Revised” date, and your continued use of the Serviceor the Site after the Last Revised date will constitute acceptance of, andagreement to be bound by, those changes.
13. Notice of Electronic Disclosure
Subjectto and in accordance with the terms hereof, PHI may be stored, processed,conveyed, and in some instances, disclosed in an electronic format. Meta Flowwill provide you with a written notice and request a separate authorization inthe event of electronic disclosure as authorized or required by state orfederal law.
14. General Information
Dependingon your primary place of residency, this Privacy Policy, its interpretation,and any claims and disputes related hereto, shall be governed by the followinggoverning laws specified below, and any and all such claims and disputes shallbe brought in, and you hereby consent to them being litigated in and decidedexclusively by a court of competent jurisdiction located in the followinglocations: a) Ifyour primary residence is in the USA, the governing law and the exclusivejurisdiction shall be the laws of the state of New York and the city of NewYork (respectively); b) ifyour primary residence is in Europe, the governing law and the exclusivejurisdiction shall be the laws of England and Wales and the city of London(respectively);c) Ifyour primary residence is in Israel or in any other territory not mentioned ina) or b) above, the governing law and the exclusive jurisdiction shall be thelaws of the State of Israel and the city of Tel Aviv.  ThisPrivacy Policy was written in English and may be translated into otherlanguages for your convenience. If a translated (non-English) version of thisPrivacy Policy conflicts in any way with the English version, the provisions ofthe English version shall prevail.
15. Have Any Questions?
If you have any questions (or comments) concerning this Privacy Policy, you are welcome to send us an email at: [insert email address] and we will make an effort to reply within a reasonable timeframe.By contacting Meta Flow you warrant and agree that you are free to do so, and that you do not provide Meta Flow with information, which violate any third-party intellectual rights (the “Information”). Without degrading from the aforesaid, all rights, including intellectual property, arising from your communication with us will be owned by Meta Flow and will be considered as Meta Flow’s confidential material.  It is clarified that any use of the Information, will be done in Meta Flow’s sole discretion, and Meta Flow is not obligated to use all or part of this Information.