Last Updated: December 22, 2025

1. Introduction
This privacy policy (the “Privacy Policy”) explains how Pulsar Medtech Ltd. (“Pulsar”, “we”, “our”, or “us”) collects, uses, discloses, and protects your information when you access and use the FHP Care mobile application (the “App”) and when you connect the App to a compatible Pulsar FHP Device (the “Device”) via Bluetooth.
This Privacy Policy explains what information we collect when you use the App, and the steps we take to safeguard your personal information.
By using the App, you acknowledge and agree to the data practices described in this Privacy Policy. With respect to Israeli privacy law, the provision of your personal information is voluntarily, and its provision is subject to your consent and free will. Important note: Nothing in this Privacy Policy is intended to limit in any way your statutory rights, including your rights to a remedy or other means of enforcement.
This Privacy Policy can be updated from time to time and, therefore, we ask you to check back periodically for the latest version of this Privacy Policy. If we implement material changes in the way we use your personal information, in a manner that is different from that stated at the time of collection, we will notify you by posting a notice on our App or by other means and take any additional steps as required by applicable law.

2. Categories Of Personal Information We Collect
When you are a user of the Device and the App, we collect the following personal information: User name, email address, User ID, gender (optional), information related to the user’s health problem (e.g., information about the location of a bone fracture) or other relevant details necessary for the operation of the Device, metadata and logs generated by the Device, such as operational files or diagnostic logs. We also collect the App activity (e.g., information about how users interact with the App, such as the number of visits to specific sections or features accessed). In addition, we collect Device operation data (e.g., battery voltage, operation time, errors), and device sensory data (e.g. temperature & humidity inside the device, inertial movement of the device etc.), FHP Device name, ID, MAC address (if required by OS), pairing and connection status and Device Firmware’s versions.

3. How We Use Your Information
We use the collected personal information for the following purposes:
• To provide you with the Device and the App
• To allow you to enter and make use of the Device and App
• To display treatment measurements within the App
• To analyze trends and generate reports for your healthcare provider
• To sync data with cloud backup (if enabled)
• To improve Device connectivity and App functionality (with aggregated data)
• To provide customer support
• To ensure App security and prevent misuse
• Some of the above personal information will be used to detect, prevent, and prosecute fraud or illegal activity, identify and fix errors, conduct audits, and ensure security. It may also be used to comply with applicable laws, support investigations by authorities, for law enforcement, or to exercise or defend legal claims. In some cases, we may anonymize or de-identify your personal information for internal uses such as improving our services and research. “Anonymous Information” means data that does not identify individual users, such as aggregated usage information.

4. Sharing Your Information
We may share your personal information as follows: 

4.1 Service Providers
With our vendors and service providers who support:
• Cloud storage
• Analytics
• Customer support
• Bluetooth device integration
These providers are contractually required to protect your information.

4.2 Our entities of the group and partners.
• The personal information we gather may be shared with our partners and other third parties.
• We also share personal information about you with our affiliated companies.
• We may disclose personal information with our lawyers, accountants, auditors and other professional advisors where necessary to obtain legal or other advice or otherwise protect and manage our business interests.

4.3 Legal Requirements
We may disclose information if required to:
• Comply with applicable laws and regulations.
• Respond to legal requests (court orders, subpoenas).
• Protect the safety, rights, or property of our users or the public.
• To the extent necessary, with regulators, courts, banks or competent authorities, to comply with applicable laws, regulations and rules (including, without limitation, federal, state or local laws), and requests of law enforcement, regulatory and other governmental agencies or if required to do so by court order, as well as for internal compliance procedures and to protect the safety, security, and integrity of Pulsar, our Devices and App, customers, patients, employees, property, and the public. We may use or disclose the personal information we collect in order to ensure that our users are complying with all applicable aspects of our policies.
• We may use or disclose personal information to investigate, prevent, or take action regarding illegal activities, suspected fraud, cybersecurity threats, situations involving potential threats to the physical safety of any person, violations of this policy, or as otherwise required or allowed by law and regulations.

4.3 In case of a merger or acquisition
If, in the future, we sell or transfer, or we consider selling or transferring, some or all of our business, shares or assets to a third party, we will disclose your personal information to such third party (whether actual or potential) in connection with the foregoing events (including, without limitation, our current or potential investors). In the event that we are acquired by, or merged with, a third party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer, disclose or assign your personal information in connection with the foregoing events.

4.4 Healthcare Providers (Optional in case of clinical trials)
Only if you explicitly enable sharing:
• Doctors, clinics, or caregivers
• Institutional health platforms

5. Permissions the App Uses
The App may request the following permissions:
• Bluetooth & Bluetooth LE: to detect and connect to the Device
• Location Permission (Android requirement): needed for Bluetooth scanning for certain Android devices (before generation Android 13)
• Notifications: to alert you about measurement results, errors, important information (e.g. battery level) or reminders
• Storage: to save logs, reports, or device data
We only request permissions necessary for app functionality.

6. Data Retention
Your personal information will be stored until we proactively delete it from our records, or until you send a valid deletion request. Please note that in some circumstances we store your personal information for longer periods of time, for example (i) where we are required to do so in accordance with legal, regulatory, tax or accounting requirements, or (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, and/or (iii) if we reasonably believe there is a prospect of litigation relating to your personal information or dealings.

7. Data Security
We implement and maintain industry-standard technical, organizational and security measures designed to protect your personal information. However, please note that we cannot guarantee that the personal information will not be compromised as a result of unauthorized penetration of our servers. As the security of information depends in part on the security of the computer, device or network you use to communicate with us and the security you use to protect your user IDs and passwords, please make sure to take appropriate measures to protect this information. 

8. Children’s Privacy
The App is not intended for children under 18. without parental or guardian consent and supervision. We do not knowingly collect personal information from children. If you are a parent or guardian and believe your child has provided us with personal information, please contact us, and we will take steps to delete such information.

9. International Data Transfer
Your information may be transferred to and processed in countries other than your country of residence, including Israel and other jurisdictions where our service providers operate. These countries may have different data protection laws than your country. We ensure appropriate safeguards are in place to protect your information in accordance with this Privacy Policy and applicable laws, including standard contractual clauses where required.

10. Your Rights
The following rights (which may be subject to certain exemptions or derogations) shall apply to certain individuals (some of which only apply to individuals protected by specific laws):
• Access your data – You have the right to request access to your personal information held by us, along with details on how it is processed, subject to certain conditions. You have the right to demand rectification of inaccurate personal information about you. We will promptly correct any information found to be incorrect.
• Request deletion – you can request the deletion of your personal information (subject to legal retention requirements)
• Data portability – You can request to receive your data in a structured, machine-readable format
• Withdraw consent – you can withdraw consent where processing is based on consent
• Object to certain uses – you can object to the processing of your personal information in certain cases.
• Restriction – Request limitation of processing in certain circumstances
• Deleting your account – Should you ever decide to delete your account, you may do so by emailing info@pulsarmt.com. If you terminate your account, any association between your account and Personal Data we store will no longer be accessible through your account. However, given the nature of sharing on certain services, any public activity on your account prior to deletion will remain stored on our servers and will remain accessible to the public.
You can exercise your rights by contacting us at info@pulsarmt.com. You may use an authorized agent to submit a request on your behalf if you provide the authorized agent written permission signed by you. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly in accordance with applicable law or inform you if we require further information in order to fulfil your request. When processing your request, we may ask you for additional information to confirm or verify your identity and for security purposes, before processing and/or honoring your request. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive. In the event that your request would adversely affect the rights and freedoms of others (for example, would impact the duty of confidentiality we owe to others) or if we are legally entitled to deal with your request in a different way than initial requested, we will address your request to the maximum extent possible, all in accordance. 

11. Changes to This Policy
We may update this Privacy Notice from time to time. When we make changes, we will update the date at the top of this Notice. We encourage you to review this Notice periodically.

12. Contact Us
If you have questions about this Privacy Policy, please contact:
Pulsar Medtech Ltd.
Metsada St. 9, BSR3
Bnei Brak, Israel
Telephone: +972-350-12170
Email: info@pulsarmt.com