CCPA Privacy Notice

 

[Last Updated: February 3, 2025] 

 

  1. INTRODUCTION AND SCOPE  

Virility Medical LTD. (including its affiliated companies and subsidiaries shall be collectively referred to herein as “Company”, “we”, “our” or “us”), is the owner of in2 patch – a wearable skin patch based on muscle stimulation, scientifically engineered to delay ejaculation ("Product").  

This CCPA Privacy Notice (“CCPA Notice”) is an integral part of Company’ Privacy Policy, subject to the provisions of the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 effective January 1, 2023 (collectively “CCPA”).  

This CCPA Notice applies to California residents who are users or visitors of our website available at https://thein2.com (“Visitor” and “website” respectively), and individuals who have made an online purchase of our Product (“Customers”) through our websites. Visitors and Customers shall be further referred to herein as “you”. The website and any services provided therein including the purchase of a Product shall be further referred to herein as “Services”. 

This CCPA Notice will provide you information regarding, among others, the categories of Personal Information we collect as the business, with whom we share it for a business purpose, your rights related to your Personal Information under the CCPA and the choices you can make.  

Any terms defined in the CCPA have the same meaning when used in this CCPA Notice.  Terms used herein, in the event not defined, shall have the same meaning as ascribed to them in our Privacy Policy. When we refer to “Personal Data” under our Privacy Policy, it shall also mean Personal Information as defined under the CCPA.  

If you wish to learn more about your California privacy rights, you may visit https://oag.ca.gov/privacy/consumer-privacy-resources. 

 

  1. CATEGORIES OF PERSONAL INFORMATION COLLECTED  

When you access our website and use our Services, we collect certain data regarding such interactions and use. This data includes “Personal Information” which is defined under the CCPA as any information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household or device as detailed in the table below. Personal Information may further include “Sensitive Personal Information”, as defined under the CCPA and as detailed in the table below.  

Personal Information does not include publicly available information that is lawfully made available from government records, that a consumer has otherwise made available to the public; de-identified or aggregated consumer information; information excluded from the CCPA’s scope, such as health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPPA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA) and the Driver’s Privacy Protection Act of 1994. 

Below we detail the categories of Personal Information that we collect (and have collected within the last 12 months) as a “business”. For additional details, please see Section (4) under our Privacy Policy “The Data We Collect and Purpose of Collection and Use”.  

Category 

Example 

Collected 

A. Identifiers. 

A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers. 

Yes.   

For example: 

If you create an Account with us or place an Order, we collect Contact Information and Account Registration and Login Data which includes your name, email address, or other similar identifiers.  

We further collect Online Identifiers such as Internet Protocol (IP) address, cookie identifiers and similar when you access our website and use our Services.  

B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). 

A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. 

Some personal information included in this category may overlap with other categories. 

Yes.  

For example: 

If you contact us, create an Account with us or place an Order, we collect Contact Information and Account Registration and Login Data which includes your name, address and phone number. 

  

C. Protected classification characteristics under California or federal law. 

Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). 

Not Collected.  

D. Commercial information. 

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.  

Yes.  

For example: 

We will maintain Orders Information which includes the records of Products you have purchased from us. 

E. Biometric information. 

Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. 

Not Collected. 

F. Internet or other similar network activity. 

Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement. 

Yes.  

For example: 

We collect Usage Data when you access the website or use the Services, which includes, for example, session durations time and date stamp, the content viewed on our website or Services, click stream, the URL or advertising campaign from which you have reached our website, etc.  

G. Geolocation data. 

Physical location, approximate location derived from IP address or movements.  

Yes.  

For example: 

We use Online Identifiers we have collected, such as IP address, are further used to generate certain information, for example, extract your approximate location (e.g., country). 

H. Sensory data. 

Audio, electronic, visual, thermal, olfactory, or similar information. 

Not Collected. 

 

I. Professional or employment-related information. 

Current or past job history or performance evaluations. 

 Not Collected. 

 

J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). 

Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. 

Not Collected. 

K. Inferences drawn from other personal information. 

Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. 

Not Collected. 

L. Sensitive personal information. 

Government-issued identifying numbers, financial account details, genetic data, precise geolocation, race or ethnicity, religious or philosophical beliefs, union membership, mail, email, text messages, biometric data, health data, and sexual orientation or sex life. 

Not Collected. 

 

 

 

  1. CATEGORIES OF SOURCES OF PERSONAL INFORMATION  

Depending on your interactions with our Service, the Personal Information is collected by us from the following categories of sources:  

  • Directly and indirectly from activity on our website and Services - for example, we may use cookies, and similar tracking technologies to gather some information when you access our website or otherwise interact with our Services, marketing communications, etc. 

  • Directly from you - we will collect Personal Information if and when you choose to provide us with information, such as when you contact us, create an Account, place an order, etc.  

 

  1. HOW WE USE OF PERSONAL INFORMATION 

We may use the Personal Information collected as identified above, for the following purposes:  

  • To fulfill or meet the reason you provided the Personal Information;  

  • Monitor and improve our Services;  

  • Provide supporting services for our Services;  

  • Market and promote our Services;  

  • Analyze your use of our Services;  

  • Respond to law enforcement; or  

  • Otherwise, as detailed in our Privacy Policy (please see Section (4) under our Privacy Policy “The Data We Collect and Purpose of Collection and Use”.).  

We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing a notice, as required under the CCPA.  

 

  1. DISCLOSURES OF PERSONAL INFORMATION FOR A BUSINESS PURPOSE 

We may disclose Personal Information to an affiliated company, contractor or service provider for a business purpose. When we disclose Personal Information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except performing the contract or as otherwise permitted under the CCPA (including restrict these third parties from selling or sharing your Personal Information).  

Please see below the categories of Personal Information we disclose (and have disclosed within the last 12 months) for a business purpose (as defined under the CCPA), the categories of Personal Information shared (corresponding with the table above) and the categories of recipients. (please see Section (7) under our Privacy Policy “Sharing Personal Data with Third Parties”). 

Business Purpose (as defined under CCPA) 

Category (corresponding with the table above) 

Category of Recipient  

Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.  

Category A 

Category F 

Category G 

Advertising partners; data analytics providers; social media networks.  

Helping to ensure security and integrity to the extent the use of your personal information is reasonably necessary and proportionate for these purposes. 

Category A 

Category B 

Category F 

Category G 

Affiliated companies, operational partner, security and fraud prevention providers, operating systems.  

Debugging to identify and repair errors that impair existing intended functionality. 

Category A 

Category F 

Category G 

Analytic providers, operational partner, security and fraud prevention providers, operating systems. 

Short-term, transient use, provided the personal information that is not disclosed to another third party and is not used to build a profile about a consumer or otherwise alter an individual consumer’s experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction. 

Category A 

Category F 

Category G 

Advertising partners data analytics providers; social media networks. 

Performing services on our behalf, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider 

Category A 

Category B 

Category D 

Category F 

Category G 

 

 

Payment processors, affiliated companies, operating systems, CRM, customer support, cloud computing and storage vendors, shipping and delivery service providers, etc.  

Undertaking internal research for technological development and demonstration. 

Category A 

Category B 

Category D 

Category F 

Category G 

Cloud and hosting providers, SaaS platforms for task management and development, customer support and optimization tools, analytic and statistical service providers.  

Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned or controlled by the business. 

Category A 

Category D 

Category F 

Category G 

Operating systems, cloud and hosting providers, SaaS platforms for task management and development, customer support and optimization tools, analytic and statistical service providers..  

Providing advertising and marketing services, except for cross-context behavioral advertising, to the consumer provided that, for the purpose of advertising and marketing, a service provider or contractor shall not combine the personal information of opted-out consumers that the service provider or contractor receives from, or on behalf of, the business with personal information that the service provider or contractor receives from, or on behalf of, another person or persons or collects from its own interaction with consumers. 

Category A 

Category F 

Category G 

Advertising partners, data analytics providers, social media networks, marketing service providers and technical platforms such as CRM and tracking tools.  

 

  1. SALE OR SHARE OF PERSONAL INFORMATION  

We do not “sell” any information as most people would commonly understand that term – meaning we do not, and will not, disclose your Personal Information in direct exchange for money or other payments.   

Under the CCPA the term “sharing” is defined as “communicating orally, in writing, or by electronic or other means, a consumer’s Personal Information” to “a third party for cross-context behavioral advertising, whether or not for money or other valuable consideration”. Due to such definition, our practice of sharing Personal Information (e.g., online identifiers, interactions with our website and location data) with our third-party marketing and analytic partners to advertise our Services, is considered as “sharing” or “selling” under the CCPA. The Personal Information is “shared” through our use of such third parties’ cookies, pixels or other tracking technology on our website, to enable marketing campaigns, including targeted ads, and to measure these marketing efforts, identify individuals that are interested in our Services, etc.  

The categories of Personal Information disclosed to such third parties under this practice considered “sell” or “share” includes Category A; Category D; and Category F.   

 

  1. CHILDREN  

Our Services are not intended for children under the age of 18. Accordingly, we do not, knowingly or intentionally, ‎collect Personal Information about individuals who are under that age. 

 

  1. DATA RETENTION 

Subject to applicable laws, we retain Personal Information for as long as needed to fulfill the purpose for which it was collected, as detailed under this CCPA Notice and our Privacy Policy, where we are permitted or required under applicable laws to retain Personal Information, or, until you exercise your applicable rights (for example, the right to request deletion of Persona Information).  

We may further extend the retention periods determined according to the criteria described above, as applicable to each category and purpose, in the following circumstances: 

  • Where we are required to retain Personal Information to comply with our legal, regulatory, tax, or accounting requirements and obligations;  

  • Where we deem it is needed in order to maintain accurate records of your engagement with us in the event of any complaints or disputes; or  

  • If we reasonably determine there is or might be a prospect of litigation relating to your Personal Information, including any legal proceeding between us, until such dispute will be resolved, and following, if we find it necessary, in accordance with statutory limitation periods. 

Please note that, other in cases where we are required under applicable laws to retain Personal Information, we are not obligated to retain your data for any specific period, and we may delete Personal Information at any time, at our sole, without providing a notice prior or upon deletion. 

 

  1. YOUR RIGHTS UNDER THE CCPA & HOW YOU MAY EXERCISE YOUR RIGHTS  

Under the CCPA, California residents may exercise certain rights related to their Personal Information collected and stored by a business.  

Below you will find explanation regarding your rights:  

  • The right to know – you have the right to know the categories of Personal Information we collected about you, including the sources from which it is collected, the business or commercial purpose for collecting, selling, or sharing your Personal Information, the categories of third parties with whom we share Personal Information, and the specific pieces of Personal Information we have collected about you. 

  • Deletion rights – you have the right to request us to delete Personal Information that we collected from you, subject to certain exceptions. 

  • Correct inaccurate Personal Information - you have the right to request us to correct inaccurate Personal Information that we maintain about you.  

  • Opt-out of “sharing” or “selling” Personal Information - you have the right to opt-out of the “sharing” of your Personal Information for cross-context behavioral advertising or “selling” Personal Information. As explained above, our practice of advertising our Services through placement of third parties marketing and analytic partners’ cookies and similar tracking technologies, is considered as “sharing” or “selling” Personal Information under the CCPA. You may easily opt-out by using the cookies preference management tool on our website to change your preferences and opt-out of cookies. 

  • Opt-Out of automated decision making –in certain circumstances, you have the right to opt-out of the use of automated decision making in relation to your Personal Information. Note that, we do not use your Personal Information for automated decision making.  

  • Data portability - you have the right to request to be provided with a copy of your Personal Information we retain, including specific pieces of Personal Information, and where applicable, to obtain a copy of the Personal Information you provided to us in a portable format. 

  • Non-discrimination – you have the right not to receive discriminatory treatment by a business for the exercise of your privacy rights conferred by the CCPA. This includes denying a consumer goods or services, charging different prices or rates for goods or services, providing a different level or quality of goods or services, etc. Note however that a business is entitled to charge different prices or rates, or provide a different level or quality of goods or services, if that difference is reasonably related to the value provided to the business by your Personal Information. 

To learn more about your California privacy rights, please visit https://oag.ca.gov/privacy/privacy-laws. 

How can you exercise the rights? 

We respect your rights related to your Personal Information and you may exercise these rights free of charge (except for limited circumstances under applicable law where we have the right to charge a fee). Please note that we may limit our response to your exercise of these privacy rights as permitted under applicable law, all as further detailed below and under our Privacy Policy. 

You may submit a request to exercise most of your rights, by filling out our Privacy Rights Request Form available HERE and send it to our privacy team at: support@thein2.com 

We will reply and fulfill your request within the timeframe set forth under applicable laws.  

Notwithstanding the above, you can easily exercise certain rights independently, and for example:  

  • You may change your cookies preference, opt-out including from “sale” or “share” related to our use of cookies, through the cookies’ preference management tool on our website. You can also opt out of interest-based advertising with some of the service providers we use, such as Google HERE, Google Analytics HERE, Google Ads HERE. 

  • You can opt-out from receiving our marketing emails by clicking the “unsubscribe” link.  

Authorized Agents  

“Authorized agents” on behalf of consumers may submit opt-out requests on a consumer’s behalf. We will accept requests from qualified third parties on behalf of other consumers, subject to the following verification procedures: 

  • When a consumer uses an authorized agent to submit a request to know or a request to delete, a business may require that the consumer do the following: (i) provide the authorized agent signed permission to do so or power of attorney; (ii) verify their own identity directly with the business; (iii) directly confirm with the business that they provided the authorized agent permission to submit the request. 

  • A business may deny a request from an authorized agent that does not submit proof that they have been authorized by the consumer to act on their behalf. 

Direct Marketing Requests: 

California Civil Code Section 1798.83 permits you, if you are a California resident, to request certain information regarding the disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please send us an email with your request and applicable details to: support@thein2.com 

Do Not Track Settings:  

Cal. Bus. and Prof. Code Section 22575 also requires us to notify you how we deal with the “Do Not Track” settings in your browser. As of the effective date listed above, there is no commonly accepted response for Do Not Track signals initiated by browsers. Therefore, we do not respond to the Do Not Track settings. Do Not Track is a privacy preference you can set in your web browser to indicate that you do not want certain information about your web page visits tracked and collected across websites. For more details, including how to turn on Do Not Track, visit www.donottrack.us.  

 

  1. NOTICE OF FINANCIAL INCENTIVE 

We do not offer financial incentives to consumers for providing their Personal Information. 

 

  1. CONTACT US  

Virility Medical LTD  

Address: 24 Hangar St. Hod Hasharon. Israel 

Email address: support@thein2.com 

 

You may further contact us through our designated Contact Us form available HERE.

 

(I) UPDATES:

This CCPA Notice was last updated on the date indicated under the header. As required under the CCPA, we will, if needed, update this CCPA Notice every 12 months. The last revision date will be reflected in the “Last Updated” at the top of this CCPA Notice.