APPLIED SPECTRAL IMAGING PRIVACY POLICY

1. INTRODUCTION

This privacy policy (“Privacy Policy“) outlines how we, Applied Spectral Imaging Ltd. (“ASI”, “we”, “our” or “us”), collect, use, store, share, and protect Personal Information (as defined below) about individuals who use and visit our website (http://www.spectral-imaging.com/) (together with its subdomains, content, and services, the “Website“), as well as when you make use of ASI’s products and services (the “Services“).

We are committed to protecting your privacy and the privacy of all users of our Website and Services. This Privacy Policy describes our practices regarding the collection, use, and disclosure of your Personal Information, as well as the rights and choices available to you. “Personal Information” means any information relating to an identified or identifiable natural person, as defined under applicable law, including but not limited to a name, email address, identification number, location data, online identifier, or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that person.

If you do not agree to this Privacy Policy, please do not use our Website and/or Services.

2. WHAT PERSONAL INFORMATION WE COLLECT, WHY WE COLLECT IT, AND HOW IT IS USED

We collect and process Personal Information about you in the following ways, as permitted or required by applicable law:

2.1 When you make use of the Services:

A. Cookies, Log Files, and Tracking Technologies.

• Categories of Personal Information. When you visit or access our Services, we automatically collect certain information about your device and your online activity. This includes information such as your IP address, device and browser type, operating system, referring URLs, pages viewed, dates and times of your visits, and other technical data. We also use cookies, web beacons, pixel tags, scripts, and similar tracking technologies to collect information about your device and online behavior.
• Purposes. To enhance your navigation on our Services, improve performance, customize your experience, perform analytics, administer the Services.
• Legal basis (only for GDPR purposes). Legitimate interests (for example, to operate and secure the Services, improve performance, and analyze usage), and, where required by law, your consent.
• Consequences of not providing the Personal Information. If you do not allow the collection of this information (for example, by disabling cookies), some features of the Services may not function properly or as intended.

B. Account Registration Services. 

• Categories of Personal Information. In order to use certain features of the Services, you will be required to create and register an account (“Service Account“). When you register, we collect Personal Information such as your name, email address, password, and any other information you provide to us. Mandatory fields will be indicated. You are responsible for providing accurate and complete information and for maintaining the confidentiality of your account credentials.
• Purposes. To create and manage your account, provide you with access to the Services, communicate with you regarding your account or the Services, ensure the security of your account, and comply with legal obligations.
• Legal basis (only for GDPR purposes). Legitimate interest (e.g., allow you to register to the Services)
• Consequences of not providing the Personal Information: If you do not provide the required Personal Information, you will not be able to create or maintain a Service Account, and you may be unable to access certain features or services that require such registration.

2.2 When you make use of the Website

A. Cookies, Log Files, and Tracking Technologies.

• Categories of Personal Information. When you visit or access our Website, we automatically collect certain information about your device and your online activity. This includes information such as your IP address, device and browser type, operating system, referring URLs, pages viewed, dates and times of your visits, and other technical data. We also use cookies, web beacons, pixel tags, scripts, and similar tracking technologies to collect information about your device and online behavior.
• Purposes. To enhance your navigation on our Website, improve performance, customize your experience, perform analytics, administer the Website, deliver content, improve our website, enhance user browsing experience, serve personalized ads or content, and analyse our traffic.
• Legal basis (only for GDPR purposes). Legitimate interests (for example, to operate and secure the Website, improve performance, and analyze usage), and, where required by law, your consent.
• Consequences of not providing the Personal Information. If you do not allow the collection of this information (for example, by disabling cookies), some features of the Website may not function properly or as intended.

B. Account Registration Distributors Portal. 

• Categories of Personal Information. We collect Personal Information such as your name, email address, username, and password, as well as any other information you provide to us. Mandatory fields will be indicated. You are responsible for providing accurate and complete information and for maintaining the confidentiality of your account credentials.
• Purposes. To create and manage your distributor account, provide you with access to the distributor’s portal, communicate with you regarding your account, for security purposes, and to comply with legal obligations.
• Legal basis (only for GDPR purposes). Performance of a contract. Legitimate interest (e.g., to allow you to register for the portal as our distributor)
• Consequences of not providing the Personal Information. If you do not provide the required Personal Information, you will not be able to create or maintain a distributor account, and you may be unable to access certain features or services that require such registration.

C. Ordering HiSKY Probe Kit.

• Categories of Personal Information. If you choose to order a HiSKY Probe Kit, you will be asked to provide certain Personal Information, such as your full name, company name, email address, phone number, shipping address, details of the order, message and any other information you choose to share as part of your order.
• Purposes. To process and fulfill your order, communicate with you regarding your order, arrange for delivery, provide customer support, and comply with legal and regulatory requirements.
• Legal basis (only for GDPR purposes). Performance of a contract. Legitimate interest (e.g., to allow you to make an order)
• Consequences of not providing the Personal Information. If you do not provide the required personal information, we will not be able to process or fulfill your order for the HiSKY Probe Kit, and you will not receive the product or related communications.

D. Ordering Whole Chromosome Paints.

• Categories of Personal Information. If you choose to order Whole Chromosome Paints, you will be asked to provide certain Personal Information, such as your full name, company name, email address, phone number, shipping address, details of the order, message and any other information you choose to share as part of your order.
• Purposes. To process and fulfill your order, communicate with you regarding your order, arrange for delivery, provide customer support, and comply with legal and regulatory requirements.
• Legal basis (only for GDPR purposes). Performance of a contract. Legitimate interest (e.g., to allow you to make an order)
• Consequences of not providing the Personal Information. If you do not provide the required personal information, we will not be able to process or fulfill your order for Whole Chromosome Paints, and you will not receive the product or related communications.

E. Sign Up to Receive Tips, News and More.

• Categories of Personal Information. Email address.
• Purposes. To send you updates, tips, news, and other relevant information, and to manage your subscription preferences.
• Legal basis (only for GDPR purposes). Consent, legitimate interest (e.g., B2B communications)
• Consequences of not providing the Personal Information. If you do not provide your email address, you will not be able to subscribe to or receive updates, tips, news, or other communications.
  You may choose not to receive future promotional, advertising, or activity related emails from us by selecting an unsubscribe link at the bottom of emails/notification that you receive from us, or by otherwise contacting us. Please note that even if you opt out of receiving the foregoing emails/notifications, we may still send you a response to any “Contact Us” request as well as administrative emails that are necessary to facilitate your use of the Website.

F. When you contact us and complete an online available form (E.g., contact us, request live demo)

• Categories of Personal Information. If you contact us via the Website, email, or other means, we collect the information you provide, such as your name, email address, and the content of your inquiry. You may also choose to provide additional information.
• Purposes. To answer your inquiries, to contact you, to send you more information about our Services, and to provide you with a live demo.
• Legal basis (only for GDPR purposes). Legitimate interest (e.g., to answer your inquiry)
• Consequences of not providing the Personal Information. If you do not provide the information, we cannot respond to your questions and queries.
• Marketing communications. We will collect your full name and email address to send you marketing communications. If you do not provide us with the Personal Information, we cannot send marketing communications.

G. When we process your job application

• Categories of Personal Information. We collect Personal Information you choose to provide, including your full name, email address, phone number, and any other details you submit. This may include information entered into free-text fields, as well as any data contained in your CV or other files uploaded with your application.
• Purposes:To evaluate your suitability for a position and to manage the screening, recruitment, and hiring processes; to communicate with you, respond to your inquiries and requests, and provide updates regarding your application; and for documentation, compliance, and legal defense purposes.
• Legal basis (only for GDPR purposes). Not relevant in the EU.
• Consequences of not providing the Personal Information. If you do not provide information relevant to the submission of your job application, this may affect our ability to assess your candidacy.

2.3 Other use cases:

A. Information from Other Sources.

• Categories of Personal Information. We may receive Personal Information about you from other sources, such as business partners, service providers, or publicly available sources. This may include your name, contact details, and other information relevant to your relationship with us.
• Purposes. To supplement and verify the information we collect directly from you, to communicate with you.
• Legal basis (only for GDPR purposes). Legitimate interests (for example, to ensure the accuracy of our records and provide our services).
• Consequences of not providing the Personal Information. If we do not receive this information, we may not be able to supplement or verify your information.

B. In-Person and Event Information (e.g., webinars).

• Categories of Personal Information. If you interact with us at events, exhibitions, or in person, we may collect your contact details and other Personal Information you provide us with (e.g., business card).
• Purposes. To communicate with you, provide you with information about our products and Services, follow up on your inquiries, and manage our relationship with you.
• Legal basis (only for GDPR purposes). Legitimate interest (for example, to respond to your inquiries and manage our business relationships).
• Consequences of not providing the Personal Information. If you do not provide this information, we may not be able to respond to your inquiries or provide you with information about our products and Services.

C. Social Media and Online Interactions.

• Categories of Personal Information. If you interact with us via social media or other online platforms, we may collect information such as your name, contact details, and the content of your communications.
• Purposes. To communicate with you, respond to your inquiries, and manage our social media presence.
• Legal basis (only for GDPR purposes). Legitimate interests (for example, to respond to your inquiries and manage our online presence).
• Consequences of not providing the Personal Information. If you do not provide this information, we may not be able to respond to your communications or interact with you via social media or online platforms.

D. When we use the Personal Information of our service providers, partners and suppliers

• Categories of Personal Information. Full name, email address, company name, phone number, payment information, and any other Personal Information you choose to provide to us.
• Purposes. To contact our service providers/partners, to execute and perform the agreement, and to collaborate on our partnership.
• Legal basis (only for GDPR purposes). Legitimate interests (for example, to contact our vendors and service providers), performance of a contract.
• Consequences of not providing the Personal Information. We cannot contact our service providers/partners, cannot execute and perform the agreement, and cannot collaborate on our partnership.

Finally, please note that some of the abovementioned Personal Information will be used for detecting, taking steps to prevent, and prosecution of fraud or other illegal activity, to identify and repair errors, to conduct audits, and for security purposes. Personal Information may also be used to comply with applicable laws, with investigations performed by the relevant authorities, law enforcement purposes, and/or to exercise or defend legal claims and proceedings. In certain cases, we may or will anonymize or de-identify your Personal Information. “Aggregated Information” means information which does not enable identification of an individual user, such as aggregated information about the use of our Website and/or Services. We may use Aggregated Information and/or disclose it to third parties without restrictions (for example, in order to improve our services and enhance your experience with them).

You are under no legal obligation to provide your Personal Information, and in certain circumstances, where required under applicable law, the provision of such information is subject to your choice and consent (as a legal basis).

3. THE TRACKING TECHNOLOGIES.

We use tracking technologies (“Tracking Technologies”) to automatically collect information about your device and online behavior, in order to deliver content, improve our website, enhance user browsing experience, serve personalized ads or content, and analyse our traffic. The Tracking Technologies may also be used to collect statistics about the usage of our Services, deliver tailored content, and administer our Website and Services.

What are cookies? Cookies are small text files (composed only of letters and numbers) that a web server places on your computer or mobile device when you visit a webpage. When used, cookies can help make our Website and/or Services more user-friendly, for example by remembering your language preferences and settings. You can find more information about cookies at www.allaboutcookies.org.

Cookies are widely used in order to make websites work in an efficient way. The use of cookies allows you to navigate between pages efficiently. Cookies remember your preferences, and make the interaction between you and the Website and/or Services smoother and more efficient. Cookies are also used to help ensure that the advertisements you see online are relevant to you and your interests.

Storing Tracking Technologies. We store Tracking Technologies when you visit or access our Website and/or Services (for example when you are visiting our websites) – these are called “First Party Tracking Technologies”. In addition, Tracking Technologies are stored by other third parties (for example our analytics service providers) who run content on our Website – these are called “Third Party Tracking Technologies”.

Both types of Tracking Technologies may be stored either for the duration of your visit on our Website and/or Services or for repeat visits.

What types of Tracking Technologies do we use?

There are four main types of Tracking Technologies:

A. Strictly necessary Tracking Technologies 

These Tracking Technologies are essential to enable you to login, navigate around and use the features of our Website, or to provide a service requested by you (such as your username). We do not need to obtain your consent in order to use these Tracking Technologies. These Tracking Technologies can be used for security and integrity reasons – for example to detect violation of our policies and for support or security features.

B. Functionality Tracking Technologies 

These Tracking Technologies allow our Services to remember choices you make (such as your language) and provide enhanced and personalized features. For example, these Tracking Technologies are used for authentication (to remember when you are logged-in) and support other features of our Services.

C. Analytics Cookies 

Analytical cookies are used to understand how visitors interact with the website. These cookies help provide information on metrics such as the number of visitors, bounce rate, traffic source, etc.

D. Performance Tracking Technologies 

These Tracking Technologies collect information about your online activity (for example the duration of your visit on our Services), including behavioral data and content engagement metrics. These Tracking Technologies are used for analytics, research and to perform statistics (based on aggregated information).

E. Marketing or Advertising Tracking Technologies  

These Tracking Technologies are used to deliver tailored offers and advertisements to you, based on your derived interests, as well as to perform email marketing campaigns. They can also be used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaign. They are usually placed by our advertisers (for example advertising networks) and provide them insights about the people who see and interact with their ads, visit their websites or use their app.

How to manage your cookie settings

Please note that we do not recognize or respond to automated browser signals regarding Tracking Technologies, including “Do Not Track” requests. However, there are various ways in which you can manage and control your cookie settings. Please remember that, by deleting or blocking cookies, some of the features of the Services and/or Website may not work properly or as effectively.

• Turning off cookies via your web browser. Most web browsers will provide you with some general information about cookies, enable you to see what cookies are stored on your device, allow you to delete them all or on an individual basis, and enable you to block or allow cookies for all websites or individually selected websites. You can also normally turn off third party cookies separately. Please note that the settings offered by a browser or device often only apply to that particular browser or device.
• Information about cookies is usually found in the “Help” section of the web browser. Below are some links to some commonly used web browsers:

Chrome

Chrome for mobile

Internet Explorer and Microsoft Edge

Mozilla Firefox

Safari

• Turning off third party cookies. You can turn off certain third party targeting/advertising cookies by visiting the following link: Network Advertising Initiative.
• Cookie consent mechanism on the Website. You can select and modify your preferences via the online widget available at all times on our Website. Non-essential cookies and similar tracking technologies will only be set with your explicit consent, which is recorded and can be withdrawn at any time. See the “cookie” widget at the bottom corner on the Website.

4. CUSTOMER INFORMATION

A. For the avoidance of doubt, in the context of the Services, ASI processes certain information, including Personal Information, on behalf of its customers (“Customer Information”) as a data processor. ASI’s customers are the data controllers of such Customer Information and are solely responsible for the security, integrity, and authorized use of Customer Information within the Services. Customers are also responsible for obtaining all necessary consents, permissions, and for providing any required data subject rights and fair processing notices in connection with the collection and use of Customer Information.

B. ASI maintains a contractual relationship with its customers, and, as part of the Services, customers may upload, input, or otherwise provide Customer Information to the Services at their sole discretion.

C. Customer Information is not governed by this Privacy Policy and this section is provided for transparency only. If you have any questions or requests regarding Customer Information, please contact the relevant customer directly.

5. HOW WE SHARE YOUR PERSONAL INFORMATION?

We may share your Personal Information with the following parties as necessary to achieve the purposes described in this Privacy Policy:

A. With our business partners with whom we jointly offer products or services as well as vendors and service providers, including providers of business operation. We may also share Personal Data with our affiliated companies;

B. To service providers who assist us in our operations, including, without limitation: Tracking Technologies, providers of business operation systems, electronic mailing systems providers, hosting, identity verification/authentication providers, bug tracking and monitoring tools, account management, security tools, customer support platforms, cloud storage, communication tools, infrastructure providers, CRM vendors, ERP, systems to manage customer relationships and order fulfillment, vendors or service providers as necessary to process your order and arrange delivery, email service providers, marketing platforms;

C. In the event that ASI is acquired by, merged with, or transferred to a third party, or in connection with any other corporate transaction (such as a sale of assets, reorganization, or bankruptcy), we may transfer or assign your Personal Information as part of such transaction, subject to the requirements of applicable data protection laws. In such cases, we will take steps to ensure that your Personal Information continues to be protected in accordance with this Privacy Policy and applicable law.

D. When we are required to disclose Personal Information to respond to regulators, subpoenas, court orders or competent authorities, requests of law enforcement, regulatory and other governmental agencies or legal process, in the event of bankruptcy or a comparable event, or to establish or exercise our legal rights or defend against legal claims, we reserve the right to transfer, disclose or assign your Personal Information in connection with the foregoing events, including, in connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or to another company;

E. Where we have a good-faith belief sharing is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, cybersecurity and other situations involving potential threats to the physical safety of any person, violations of our service agreement, or as otherwise required to comply with our legal obligations;

F. We may disclose 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; and/or

G. As you may otherwise consent from time to time.

6. INTERNATIONAL INFORMATION TRANSFERS. In certain cases, your Personal Information is transferred to, and processed in, countries outside of your country of residence, including countries that may not provide the same level of data protection as your home jurisdiction. Where we transfer Personal Information outside the European Economic Area (the “EEA”) or Israel, we will ensure that appropriate safeguards are in place, such as reliance on adequacy decisions, Standard Contractual Clauses approved by the European Commission, or other lawful transfer mechanisms according to applicable law, to ensure an adequate level of protection for your Personal Information. You hereby agree to the international transfer of information as described in this section.

7. DATA SUBJECT 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):

• Request access to your Personal Information;
• Request rectification of inaccurate or incomplete Personal Information;
• Request erasure of your Personal Information (“right to be forgotten”), subject to legal or contractual restrictions;
• To request rectification or erasure of your Personal Information if you find that your personal information is incorrect, incomplete, unclear, or not up to date;
• Object to or request restriction of processing of your Personal Information;
• Request data portability, where applicable;
• Withdraw your consent at any time, where processing is based on consent; and/or
• Lodge a complaint with a supervisory authority (your local privacy protection authority).

To exercise these rights, please contact us at privacy@spectral-imaging.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 with applicable law.

However, please note that above rights are not absolute, and may be subject to our own legitimate interests and regulatory requirements. You also have a right to lodge a complaint with a supervisory authority.

You may choose not to receive marketing email from us you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails, and we will process your request within a reasonable time after receipt.

8. RETENTION

Your Personal Data will be stored until we delete the record and we proactively delete it or you send a valid deletion request, please note that in some circumstances we will retain your Personal Information for as long as necessary to fulfill the purposes for which it was collected, including to comply with our legal, regulatory, tax or accounting obligations and requirements, to resolve disputes or if we reasonably believe there is a prospect of litigation relating to your Personal Information or dealings, and to enforce our agreements (including our Terms). Retention periods are determined based on the type of Personal Information, the purpose for which it was collected, and applicable legal requirements. We will delete or anonymize Personal Information when it is no longer required for these purposes.

9. DATA SECURITY

We have implemented industry standard administrative, technical, and physical safeguards designed to protect your Personal Information against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access. These measures are regularly reviewed and updated to ensure an appropriate level of security in relation to the risks involved in processing your personal information.

While we seek to protect your Personal Information and maintain its confidentiality, no method of transmission over the Internet or method of electronic storage is completely secure. Therefore, although we take reasonable steps to protect your Personal Information, we cannot guarantee its absolute security.

10. CHILDREN DATA

The Website and Services are not intended for or directed at children under the age of 18. We do not knowingly collect Personal Information from children under 18 without appropriate parental or guardian consent as required by applicable law. If we become aware that we have collected Personal Information from a child under 18 without such consent, we will take steps to delete that information as soon as possible. If you believe we might have any Personal Information from or about a child under 18, please contact us at privacy@spectral-imaging.com.

11. INTERACTION WITH THIRD PARTY PRODUCTS

We enable you to interact with third party websites, mobile software applications and products or services that are not owned or controlled by us (each a “Third Party Service”). We are not responsible for the privacy practices or the content of such Third Party Services. Please be aware that Third Party Services can collect Personal Information from you. Accordingly, we encourage you to read the terms and conditions and privacy policies of each Third Party Service.

12. UPDATES OR AMENDMENTS TO THE PRIVACY POLICY

We may revise this Privacy Policy from time to time, in our sole discretion, and the most current version will always be posted on our Website (as reflected in the “Last modified” heading) or by other means. We encourage you to review this Privacy Policy regularly for any changes. If we make material changes to this Privacy Policy, we will notify you by posting a notice on our Website, by email, or by other means as required by applicable law.

Your continued use of the Website or Services following notification of such amendments constitutes your acknowledgement and acceptance of the amended Privacy Policy. If you do not agree to the amended terms, you should discontinue your use of the Website and/or Services.

13. CONTACT INFORMATION

If you have any questions, concerns, or complaints regarding our compliance with this notice and data protection laws, or if you wish to exercise your rights, we encourage you to first contact us at privacy@spectral-imaging.com or at Carlsbad, CA 92009.

Last updated: September,  2025