ODYSIGHT.AI PRIVACY POLICY

Odysight.ai® Inc. (“Company”, “we”, “our” or “us”) is pioneering the predictive maintenance and condition-based monitoring markets with its visualization and AI platform (the “Platform”). We also operate the website www.odysight.ai, its subdomains and related features (“Website”, and together with the Platform, the “Services”). We are dedicated to protecting your privacy rights and making our practices regarding your personal data more transparent and fair. This Privacy Policy (“Policy”) was designed to help you better understand the information we collect, store, use and share, and it applies whenever you visit our Website, interact with our Platform, or otherwise access or use any of our Services.

We strongly urge you to read this Policy and make sure that you fully understand and agree to it. If you do not agree to this Policy, please discontinue and avoid using our Services. You have the right to cease using our Services, pursuant to this Policy at any time.

You are not legally required to provide us with any Personal Data, but without it we will not be able to provide you with the full range or with the best experience of using our Services.

This Policy is integrated into and forms part of the Odysight® Terms of Use which are currently available here.

TYPES OF DATA COLLECTED AND PURPOSES:

Depending on your interaction with us, we may collect two types of data from you:

“Non-Personal Data” meaning aggregated, non-personal non-identifiable information, which may be made available or gathered via your access to and use of the Services. We are not aware of the identity of the user from which the Non-Personal Data is collected. Such Non-Personal Data may include aggregated usage information and technical information transmitted by your device, such as browser version, operating system type and version, mobile network information, device settings, and software data.

“Personal Data” (as defined under the GDPR) or “Personal Information” (as defined under the CCPA) meaning individually identifiable information, namely information that identifies an individual or may, with reasonable effort, be used to identify an individual.

For the avoidance of doubt, any Non-Personal Data connected or linked to any Personal Data shall be deemed as Personal Data as long as such connection or linkage exists.
Subject to the stated below, we do not knowingly collect or process any Personal Data constituting or revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data, data concerning a person’s health, government identifiers, precise geolocation or data concerning a person’s sex life or sexual orientation (“Special Categories of Personal Data”).
The table below details the types of Personal Data we collect, the methods and purpose of such collection, and our lawful basis for processing such Personal Data (where the GDPR applies):

Please note that the actual processing operation per each purpose of use and lawful basis detailed in the table above may differ. Such processing operation usually includes a set of operations made by automated means, such as collection, storage, use, disclosure by transmission, erasure or destruction. The transfer of Personal Data to third party countries as further detailed in the Data Transfer Section is based on the same lawful basis as stipulated in the table above.

We may collect different categories of Personal Data and Non-Personal Data from you, depending on the nature of your interaction with the Services, as detailed above.

HOW WE COLLECT YOUR INFORMATION:
• Automatically, when you interact with out Services, including through the use of cookies (as detailed below) and similar tracking technologies.
• When you voluntarily choose to provide us with information, such as when you contact us, all as detailed in this Policy.

COOKIES AND SIMILAR TECHNOLOGIES:
We currently do not, but may use “cookies” (or similar tracking technologies) in the future when you will access our Website. The use of cookies is a standard industry-wide practice. A “cookie” is a small piece of information that a website assigns and stores on your computer while you are viewing a website. Cookies can be used for various purposes, including allowing you to navigate between pages efficiently, as well as for statistical purposes, analytic purposes and marketing. You can find more information about our use of cookies here: www.allaboutcookies.org.

The cookies we use on our website are:

Most browsers will allow you to erase cookies from your computer’s hard drive, block acceptance of cookies, or receive a warning before a cookie is stored. You may set your browser to block all cookies, including cookies associated with our Services, or to indicate when a cookie is being used by us, by adjusting the privacy and security settings of your web browser. Below is a list of useful links that can provide you with more information on how to manage your cookies:

• Google Chrome;
• Mozilla Firefox;
• Safari (Desktop);
• Safari (Mobile);
• Android Browser; and
• Microsoft Edge

You can learn more and turn off certain third party targeting and advertising cookies by visiting the following third party webpages:

• The Interactive Advertising Bureau (US);
• The Interactive Advertising Bureau (EU); and
• European Interactive Digital Advertising Alliance (EU)

Additionally, you may opt out of certain advertisers’ cookies and browser-enabled, interest-based advertising. You can withdraw your consent to personalized advertising experience on your device at any time by using your device settings as follows:
• On iOS, depending on the applicable iOS version, you may withdraw consent across all apps by either enabling the “Limit Ad Tracking” setting or disabling the “Allow Apps to Request to Track” permission in your iOS device settings. Depending on the applicable iOS version, instead of withdrawing consent on a device-wide basis, you may also have the option of withdrawing consent on a per-app basis by disabling tracking permissions for specific apps that appear under the “Allow Apps to Request to Track” setting in your iOS device settings (precise directions may differ depending on the applicable iOS version).
• On Android devices, you may withdraw your consent in the Google Ads settings within your Android settings by enabling the “Opt out of Ads Personalization” setting (precise directions and the name of the setting may differ depending on the applicable Android versions and device manufacturer).

Please note that once you choose to opt out or disable cookies, some features of the Website may not operate properly and your online experience may be limited. In addition, even if you do opt-out, you may still receive some content and advertising, however, it will not be targeted content or advertising.
For additional information, please see the User Rights section below.

DATA SHARING – CATEGORIES OF RECIPIENTS WE SHARE PERSONAL DATA WITH:
We share your Personal Data with third parties, including our service providers that help us maintain our Services. More information about the categories of such third-party recipients is described below:

We reserve the right to use, disclose or transfer (for business purposes or otherwise) aggregated and processed Non-Personal Data to third parties, including, inter alia, affiliates, for various purposes including commercial use. This information may be collected, processed and analyzed by us and transferred in a combined, collectively and aggregated manner (i.e., your information is immediately aggregated with other users) to third parties.
When we share information with services providers, we ensure they only have access to such information that is strictly necessary for us to provide the Services. These parties are required to secure the Data they receive and to use the Data for pre-agreed purposes only while ensuring compliance with all applicable data protection regulations (such service providers may use other Non-Personal Data for their own benefit).

USER RIGHTS:
We acknowledge that different people have different privacy concerns and preferences. Our goal is to be clear about what information we collect so that you can make meaningful choices about how it is used. We allow you to exercise certain choices, rights, and controls in connection with your information. Depending on your relationship with us, your jurisdiction and the data protection laws that apply to you, you have the right to control and request certain limitations or rights to be executed.

the following table describes all the rights you are entitled to. Please note that some rights are only available for residents of specific jurisdictions:

• Right of access: The right to know which Personal Data we collected, including the categories of Personal Data, the sources from which the Personal Data is collected, the business or commercial purpose for collecting, selling, or sharing Personal Data, the categories of third parties to whom we disclose Personal Data, and the specific pieces of Personal Data that we collected about you.
• Right to deletion: The right to delete Personal Data that we collected from you, subject to certain exceptions.
• Right to correction: The right to correct inaccurate Personal Data that we maintain about you.
• Right to opt-out of cross-contextual targeted advertising: You have the right to opt-out of the sharing of your Personal Data for “cross-contextual behavioral advertising”, often referred to as “interest-based advertising” or “targeted advertising”.
• Right to opt-out of the sale of Personal Data: The right to opt-out of the sale of your Personal Data, as these terms are defined under the applicable privacy laws.
• Right to limit the use or disclosure of Sensitive Personal Information (SPI): You have the right to request to limit the collection of your Sentivie Personal Information (as this terms is defined under the applicable privacy law), to that use which is necessary to maintain our Services.
• Right to Opt-out from profiling in furtherance of decisions that produce legal or similarly significant effects concerning you: You have the right to request to opt-out from processing involving profiling, in furtherance of decisions that produce legal or similarly significant effects concerning you. “Profiling” means any form of automated processing performed on Personal Data to evaluate, analyze or predict personal aspects related to your economic situation, health, personal preferences, interests, reliability, behavior, location or movements.
• Right to opt-out of the use of automated decision making: Under certain circumstances, you have the right to opt-out of the use of automated decision making in relation to your Personal Data.
• Right to non-discrimination: The right not to receive discriminatory treatment by the business for the exercise of privacy rights, including an employee’s, applicants, or independent contractor’s right not to be retaliated against for the exercise of their rights, denying a consumer goods or services, charging different prices or rates for goods or services, providing you a different level or quality of goods or services, etc. We may, however, 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 us by your Personal Data.
• Right to data portability: You may request to receive a copy of your Personal Data, including specific pieces of Personal Data, including, where applicable, to obtain a copy of the Personal Data you provided to us in a portable format.
• Right to restrict or object to processing: You have the right to object/withdraw consent to the processing of your Personal Data unless certain exceptions apply.

your rights may be exercised by contacting us via the contact details available below.

DATA RETENTION:
we retain the data we collect for as long as it remains necessary for the purposes set forth above, all under the applicable laws, or until you express your preference to opt-out, where applicable.

The retention periods are determined according to the following criteria:

• where we have a valid a business reason to process your Personal Data, such as the provision of our service.
• where we are required to do so in accordance with legal, regulatory, tax, or accounting requirements;
• for us to have an accurate record of your dealings with us in the event of any complaints or challenges;
• if we reasonably believe there is a prospect of litigation relating to your Personal Data.

Please note that except as required by applicable law, we will not be obligated to retain your data for any particular period, and we may delete it for any reason and at any time, without providing you with prior notice if our intention to do so. However, retention periods will be determined by taking into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time and in a way that prevents the Data from being restored or reconstructed.

SECURITY MEASURES:
We work hard to protect the Personal Data we process from unauthorized access, alteration, disclosure, or destruction. We have implemented physical, technical, and administrative security measures that comply with applicable laws and industry standards, such as minimizing the amount of data that we store on our servers, restricting access to Personal Data by Company employees, contractors, agents, etc. Note that we cannot be held responsible for unauthorized or unintended access beyond our control, and we make no warranty that we will always be able to prevent such access.

Please contact us via the methods available below if you feel that your privacy was not managed properly, or if you become aware of an attempt by a third party to gain unauthorized access to your Personal Data. We will make a reasonable effort to notify you and the relevant authorities (if required by applicable law) in the event that we discover a security incident related to your Personal Data.

INTERNATIONAL DATA TRANSFER:
We operate globally, and any information that we collect, disclose or share, including (but not limited to) your Personal Data, can be stored and processed in the European Economic Area, United Kingdom and United States, for the purposes detailed in this Policy. To the extent that the GDPR or UK GDPR are applicable, we will only transfer or share your Personal Data to data recipients:
• located in the EEA or in the UK;
• located in non-EEA countries or UK which have been approved as providing adequate level of data protection by the European Committee; or
• who have entered into a legal agreement ensuring an adequate level of data protection, including the Standard Contractual Clauses as approved by the European Committee.

ELIGIBILITY AND CHILDREN PRIVACY:
The Website is not intended for use by individuals under the age of majority, as defined by the applicable law in such individual’s jurisdiction of residence (“Minor”). We do not knowingly process Minor’s information and will discard any data we receive from a user that we find or reasonably suspect to be a Minor immediately upon discovery. Please contact us via the details available below if you have reason to believe that a Minor has shared any data with us.

US RELATED INFORMATION:
This part of the Policy addresses the specific disclosure requirements under the California Consumer Privacy Act of 2018 (Cal. Civ. §§ 1798.100–1798.199), as amended by the California Privacy Rights Act of 2022, the California Consumer Privacy Act Regulations by the Attorney General (collectively: “CCPA”), the Virginia Consumers Data Protection Act of 2021 (“VCDPA”), the Colorado Privacy Act of 2023 (“CPA”), Connecticut Data Privacy Act of 2023 (“CTDPA”) and the Utah Consumer Privacy Act of 2022 (“UCPA”) (Collectively: “US Privacy Laws”).

Personal Information does not include: Publicly available information that is lawfully made available in government records; information that a consumer has made available to the public; De-identified or aggregated consumer information, and information excluded from US Privacy Laws such as Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPPA); clinical trial data, and any Personal Information covered by certain sector-specific privacy laws, such as the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) and the Driver’s Privacy Protection Act of 1994.

Collection, disclosure and sharing of Personal Information
In the preceding twelve (12) months, we have collected the following Personal Information:

Category A- Identifiers: a real name, unique personal identifier, online identifier, Internet Protocol address, email address.

Category B- Internet or other similar network activity: information on a consumer’s interaction with a website
Category C- Geolocation data approximate location derived from IP address or movements.
We collected such Personal Information from the following categories of sources:
• Directly and indirectly from activity on our Services: For example, directly from you when you inquire about our Website, or indirectly, we collect your usage data automatically from measurement tools.
• Directly from you: For example from forms you complete, contact us, and etc.
• Indirectly from you: we track your activities across the internet, for example, when you view or interact with certain content, web page or ad.
• From third-parties: For example, from vendors who assist us in performing services for consumers, advertising networks, internet service providers, data analytics providers, social networks, and data brokers.

We may use the Personal Information collected for the following purposes:
• To fulfill or meet the reason you provided the Personal Information (support, respond to a query, etc.)
• To improve our Services
• To maintain our Website
• For marketing our Website
• For analyzing your use of the Website
• To respond to law enforcement
• To enforce our policies, to defend from claims or exercise our legal rights
• Any other reason detailed in this Policy.

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 you notice.

We do not “Sell” or “Share” personal information, as these terms are defined under US Privacy Laws

In the preceding twelve (12) months we disclosed your Personal Information. 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 the performance of the contract. We also prevent the recipient from selling or sharing your Personal Information.

For more information about the disclosure of your Personal Information, please see the following table:

Authorized Agents

“Authorized agents” may submit opt out requests on a consumer’s behalf.

Special requirements under the CCPA: Under the CCPA, If you have elected to use an authorized agent, or if you are an authorized agent who would like to submit requests on behalf of a consumer, the following procedures will be required prior to acceptance of any requests by an authorized agent on behalf of a California consumer. Usually, we will accept requests from qualified third parties on behalf of other consumers, regardless of either the consumer or the authorized agent’s state of residence, provided that the third party successfully completes the following qualification 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:
  • Provide the authorized agent signed permission to do so or power of attorney.
  • Verify their own identity directly with the business.
  • Directly confirm with the business that they provided the authorized agent permission to submit the request.
• We 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.

Notice Of Financial Incentive

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

ADDITIONAL DISCLOSURES FOR CALIFORNIA RESIDENTS:

Direct Marketing Requests: California Civil Code Section 1798.83 permits you, if you are a California resident, to request certain information regarding disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please use the Data Subject Request Form.

“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 so 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.

POLICY AMENDMENTS:

The updated date of this Policy will be reflected in the “Last Updated” heading, indicated at the header of the Policy. As required by the CCPA we will review this Policy every twelve (12) months and amend it as necessary. Where required by applicable law, we will obtain your consent. We recommend you review this Policy periodically to ensure that you understand our most updated privacy practices

CONTROLLING VERSION:

This Policy has been drafted in the English language, which is the original and controlling version of this Policy. All translations of this Policy into other languages shall be solely for convenience and shall not control the meaning or application of this Policy. In the event of any discrepancy between the meanings of any translated versions of the Policy and the English language version, the meaning of the English language version shall prevail.

CONTACT INFORMATION:

If you have any question, inquiry or concern related to this Policy or the processing of your Personal Data, you may contact our privacy team as follows:

By Email: [email protected]

Address:

• 7A Building, Omer Industrial Park, POB 3030, Omer 8496500
• 12 Abba Hillel Silver Road, Sasson Hugi Tower, Ramat-Gan, 5250606

Tel: 972-73-3704695