Privacy Policy

Recently Updated: June XX, 2024

USARAD Holdings Inc. , a fully owned subsidiary of Nano-X Imaging Ltd. ("we", "us" or "our"), is a leading provider of teleradiology services including radiology and cardiology interpretation services as well as second opinion consultations (“Services”).

We respect your privacy and recognizes that your privacy is important. Therefore, we are providing this privacy policy ("Privacy Policy") to explain our practices regarding the collection, processing, usage, and transfer of certain data, including Personal Data (as defined below), from Individuals who visit our website available at: https://usarad. com/ (“website”), participating in events we host, subscribe to our newsletter, or otherwise (“Visitors”, “you” or “your”).

This Privacy Policy is an integral part of our website Terms and Conditions (“Terms and Conditions”) or any other agreement referencing this Privacy Policy.

This Privacy Policy applies to residents from all U. S. jurisdictions. However, if you are a resident of California, please refer to Section 12. Additional Specific Disclosures for California Residents for information about the categories of Personal Information we may collect and your rights under California privacy laws. If you are a resident of Colorado, Connecticut, Virginia, or Utah, please refer to Section 13. Additional Specific Disclosures for Certain United States Residents, which includes additional information about privacy rights for residents of such U. S. jurisdictions.

1. The Data Sets We Collect

We may collect two types of information from you, depending on your interaction with us:

The first type of information is non-identifiable and anonymous information (“Non-Personal Data”). We are not aware of the identity of the individual from who we have collected the Non-Personal Data. Non-Personal Data consists of technical information, and may contain, among other things, the type of operating system and type of browser, type of device, session duration, etc.

The second type of information is individually identifiable information, namely information that identifies an individual or may with reasonable effort identify an individual (“Personal Data” or “Personal Information” as defined under the applicable data protection law).

For the avoidance of doubt, any Non-Personal Data connected or linked to Personal Data shall be deemed as Personal Data as long as such connection or linkage exists.

Data collected directly from you:

• Contact Information - If you voluntarily contact us for support, request a services or other inquiries, or if you register to receive our newsletter, you will be required to provide us with your contact details such as name, phone number, email address and physical address. In addition, you can choose to provide us with additional information as part of your correspondence with us (“Contact Information”).

Data collected by using third party tools:

• Online Identifiers and Telemetry Data – When you interact with the website, we collect and generate online identifiers such as your Internet Protocol (“IP”) address, and additional identifiers allowing us to individually identify you, such as a Cookie ID which is assigned to your device ("Online Identifiers"). Further, additional information is automatically collected regarding your "website online behavior". Such information includes the pages you viewed, click stream data, access time stamp, etc. (collectively "Telemetry Data").

2. Why We Collect and Process Personal Information

We will use the data sets listed above for the following purposes:

• Respond your inquiries - We use your Contact Information to provide you with the support you requested or to respond to your inquiry.
• Website operation and functionality – Online Identifiers and certain Telemetry Data are used in particular to operate the website and enable its proper functionality, for security and fraud prevention purposes, debugging and to resolve technical problems. For example, in order confirm you are a real person.
• Marketing - We may use your Contact Information in order to send you marketing promotions, such as new features, additional offerings, special opportunities or any other information we think you will find valuable. You can opt-out at any time through the “unsubscribe” link within the email we sent you or by contacting us directly.  To the extent you choose to opt-out, your Contact Information will be retained in our suppression list to ensure we comply with such preference and choice.
• Analytics – Certain Online Identifiers and Telemetry Data are indirectly processed by third-parties marketing and analytic tools, for analytic and marketing purposes. We process this data to understand how our Visitors use the website and to measure effectiveness of some marketing campaigns we run in order to track conversions, build targeted audience, and market our Services to people who have taken some action on the website. You may opt-out from the operation of third party tracking tools which are not necessary for the proper and basic operation of the website or fraud prevention, by using the cookie preference settings as available in the footer of the website, or by managing opt-out through your browser or device.
• Legitimate interests – We process your information for our legitimate interests while applying appropriate safeguards that protect your privacy. Our legitimate interests include detecting, preventing, or otherwise addressing fraud, abuse, security, usability, functionality or technical issues with the website, protecting against harm to the rights, property or safety of other Visitors, or the public as required or permitted by law; enforcing legal claims, including investigation of potential violations of this Privacy Policy; comply or fulfil our obligations under applicable laws, regulations, guidelines, industry standards and contractual requirements, legal process, subpoena or governmental requests.

We will not process your information for purposes that are neither reasonably necessary to, nor compatible with, the purposes above for which such information is processed, unless we obtain your consent.

3. Cookies and Similar Tracking Technologies

We use “cookies” or similar tracking technologies on our website, which store certain information on your device (i. e. , locally stored) when you access the 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 are used by us for various purposes, including allowing you to navigate between pages efficiently, as well as for statistical purposes, analytic purposes and advertising. You can find more information about our use of cookies here: www. allaboutcookies. org.

If you wish to change the way such tracking tools collect your Personal Data through our website, please see our cookie list and policy available through our website footer, as well instructions on how to change your cookies settings and preferences at any time.

Also note that, most browsers will allow you to erase cookies from your device, 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 website, or to indicate when a cookie is being used by us, by adjusting the privacy and security settings of your web browser. Please refer to the support page of your browser to learn more about how you can adjust your privacy and security settings. 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.

4. Data Sharing – Categories of Recipients with Whom We Share Personal Data

We may disclose your information to the following parties for the following purposes: 

• Service providers - We may share certain information about you with third-party service providers that perform services on our behalf in connection with the website, such as cloud hosting providers, analytics and marketing service providers, our CRM provider, etc. Where your Personal Data is shared with such third parties, we ensure that the third party will deal with your information only on our behalf and on our instructions and solely for our benefit (and not for its own benefit).
• Affiliated companies - We may share certain information with our affiliated companies, which will provide us with certain services as well as for internal compliance. In addition, certain information may also be shared with potential affiliated companies in the event of a potential business re-organization while we undergo certain due diligence processes. In such event, those potential affiliated companies are bound by robust confidentiality obligations.
• Additional purposes, as permitted or required by applicable law. We may disclose certain information to third parties (authorities, legal representatives, regulators, government entities, and law enforcement) to the extent permitted or required by applicable laws. We may disclose your information when we believe it is appropriate to do so to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms and Conditions or this Privacy Policy, or as evidence in litigation in which we are involved.

5. Cross-Border Data Transfer

Transfers of your Information will be made in accordance with applicable laws. When Personal Data is transferred outside the country where it was originally collected, we will take the steps necessary (and to the extent required by applicable laws) to ensure that sufficient safeguards are provided to such data during its transfer and processing. Some of the measures implemented to safeguard your Personal Data include ensuring that the recipient is bound by specific contractual clauses approved by relevant data protection authorities to provide adequate protection for Personal Data. Where applicable, you can request a copy of the relevant contractual safeguards that we have put in place.

6. Data Retention

Unless you instruct us otherwise, we retain the information we collect for as long as needed to provide the applicable services and to comply with our legal obligations. We believe in data minimization and only keep the information we truly need and only for the period of time required.

7. Privacy Choices

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 applicable data protection laws that apply to you, you have the right to control and request certain limitations or rights to be executed.

In the table below you can review your choices depending on your interaction with us, how you can exercise them, and appeal a decision we take in this regard. Any specification per geo-location or territory are available below the table:

8. Security

We take great care in implementing and maintaining the security of your Personal Data. We employ industry standard procedures and policies to ensure the safety of individuals’ information and prevent unauthorized use of any such.

We have implemented technical, physical and administrative security measures to protect the Personal Data we process. Although we take reasonable steps to safeguard information, we cannot be responsible for the acts of those who gain unauthorized access or abuse our website, and we make no warranty, express, implied or otherwise, that we will always be able to prevent such access.

Please contact us at: info@usarad.com if you feel that your privacy was not dealt with properly, in a way that was in breach of our Privacy Policy, or if you become aware of a third party's attempt to gain unauthorized access to any of your Personal Data. We will make a reasonable effort to notify you and the appropriate authorities (if required by applicable law) in the event that we discover a security incident related to your Personal Data.

9. Minors

Our website is not intended for children under the age of 18. Therefore, we do not knowingly collect information from children under the age of 18. If we learn that we have collected information from a child under 18 years, we will delete that information as quickly as possible. If you believe that we might have any such information, please contact us at info@usarad.com.

10. Policy Amendments

We reserve the right to amend this Privacy Policy from time to time, at our sole discretion. The most recent version of this Privacy Policy will always be posted on the website and reflected in the “Recently Updated” heading. Any amendments to the Privacy Policy will become effective immediately, unless we notify otherwise. We recommend you review this Privacy Policy periodically to ensure that you understand our most updated privacy practices.

11. Contact Us

If you have any questions or comments concerning this Privacy Policy, you are welcome to send us an email at: info@usarad.com and we will make an effort to reply within a reasonable timeframe.

12.  Additional Specific Disclosures for California Residents

In this section, we provide information for California residents, as required under California privacy laws, including the California Consumer Privacy Act, as amended (“CCPA”), which requires that we provide California residents certain specific information about our information practices, including how we process their Personal Information. This section of the Privacy Policy does not apply to publicly available information or Personal Information that is otherwise exempt under the CCPA. To the extent you are a resident of California, and we collect “Personal Information” subject to CCPA, the following applies.

Categories of Personal Information Collected and Disclosed:

The table below identifies the categories of Personal Information we may collect about you (and may have collected in the prior 12 months), as defined by the CCPA, as well as the categories of third parties to whom we disclosed Personal Information for a business or commercial purpose.

Sales and Sharing of Personal Information:

The CCPA defines “sale” as disclosing or making available Personal Information to a third-party in exchange for monetary or other valuable consideration, and “sharing” includes disclosing or making available Personal Information to a third-party for purposes of cross-context behavioural advertising. We may “sell” identifiers as well as internet and electronic network activity information associates with you, as described above. We may also share your Personal Information with a third party to help serve personalized content or ads that may be more relevant to your interests, and to perform other advertising-related services such as enabling our partners to serve such personalized content.

We do not knowingly sell personal information about individuals who we know are under age sixteen (16).

Your CCPA Rights:

The CCPA provides California residents with specific rights regarding Personal Information. Subject to certain conditions and exceptions, California residents have the following rights with respect to their Personal Information:

• Right to Know. You have the right to request: (i) the categories or Personal Information we collected about you; (ii) the categories of sources from which the Personal Information is collected; (iii) our business or commercial purposes for collecting, selling, or Personal Information; (iv) the categories of third parties to whom we have disclosed Personal Information; and (v) a copy of the specific pieces of Personal Information we have collected about you.
• Right to Delete. You have the right to request we delete Personal Information we have collected from you.
• Right to Correct. You have the right to request that we correct inaccuracies in your Personal Information.
• Right to Opt-Out of Sales and Sharing. You have the right to opt-out of “sales” and “sharing” of your Personal Information, as those terms are defined under the CCPA.
• Right to Limit Use. You have the right to limit use and disclosure of your sensitive personal information.
• Right to Non-Discrimination. You have the right not to be subjected to discriminatory treatment for exercising any of the rights described in this section.

Exercising Your Privacy Rights:

California residents may exercise their CCPA privacy rights as set forth below:

• Right to Know, Delete, Correct, and Limit. California residents may submit CCPA requests to access/know, delete, and correct their Personal Information, and limit the use/disclosure of their Sensitive Personal Information by using the DSR available here.

When you submit a request, we will take steps to verify your identity and request by matching the information provided by you with the information we have in our records. In some cases, we may request additional information in order to verify your identity, or where necessary to process your request. If we are unable to verify your identity after a good faith attempt, we may deny the request and, if so, will explain the basis for the denial.

You may also designate someone as an authorized agent to submit requests and act on your behalf. Authorized agents will be required to provide proof of their authorization in their first communication with us, and we may also require that the relevant consumer directly verify their identity and the authority of the authorized agent.

• Right to Opt-Out of Sales and Sharing. To exercise your right to opt-out of the “sale” or “sharing” of your Personal Information, you may do by using the DSR available here. We will apply your opt out request based upon the Personal Information in our records that is linked or reasonably linkable to the information provided in your request. You may also click the “Do Not Sell or Share My Personal Information” link available through the cookies settings on the website. In addition, if we detect that your browser or device is transmitting an opt-out preference signal, such as the “global privacy control” or “GPC” signal, we will opt that browser or device out of cookies that result in a “sale” or “sharing” of your Personal Information.

13. Additional Specific Disclosures for Certain United States Residents

A. Colorado Residents:

Under the Colorado Privacy Act (“CPA”), Colorado residents acting in an individual or household context (and not in a commercial, employment context or as a job applicant) or someone on their behalf, are allowed to exercise certain rights regarding their Personal Data.

We will respond to your requests within 45 days after receipt of a verifiable Consumer Request (no more than twice in a twelve-month period). We reserve the right to extend the response time by an additional 45 days when reasonably necessary and provided consumer notification of the extension is made within the first 45 days. If we refuse to take action on a request, you may appeal our decision within a reasonable period time by contacting us at info@usarad.com and specifying you wish to appeal. Within 60 days of our receipt of your appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied, you may submit a complaint as follows: Colorado AG at https://coag. gov/file-complaint/

Any disclosures we provide will only cover the 12-months period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

B. Connecticut Residents:

Under the Connecticut Data Privacy Act (“CDPA”), Connecticut residents acting in an individual or household context (and not in a commercial or employment context or as a representative of business, non-profit or governmental entity) or someone on their behalf, are allowed to exercise certain rights regarding their Personal Data.

We shall respond to your request within 45 days of receipt. The response period may be extended once by 45 additional days when reasonably necessary, taking into account the complexity and number of requests and we inform you of such extension within the initial 45 days response period, together with the reason for the extension. If we decline to take action on your request, we shall so inform you without undue delay, within 45 days of receipt of your request. If we refuse to take action on a request, you may appeal our decision within a reasonable period time by contacting us at info@usarad.com and specifying you wish to appeal. Within 60 days of our receipt of your appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied, you may submit a complaint to the Connecticut Attorney General at link: https://www. dir. ct. gov/ag/complaint/ or (860) 808-5318.

We shall provide information in response to your request free of charge, up to twice annually, unless requests are manifestly unfounded, excessive or repetitive. If we are unable to authenticate your request using commercially reasonable efforts, we may request additional information reasonably necessary to authenticate you and your request. If we cannot authenticate you and your request, we will not be able to grant your request.

C. Virginia Residents

Under the Virginia Consumer Data Protection Act (“VCDPA”), Virginia residents acting in an individual or household context (and not in a commercial or employment context) or someone on their behalf, are allowed to exercise certain rights regarding their Personal Data.

We will respond to your request within 45 days after receipt of a verifiable Consumer Request (no more than twice in a twelve-month period). We reserve the right to extend the response time by an additional 45 days when reasonably necessary and provided consumer notification of the extension is made within the first 45 days. If we refuse to take action on a request, you may appeal our decision within a reasonable period time by contacting us at info@usarad.com and specifying you wish to appeal. Within 60 days of our receipt of your appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied, you may submit a complaint to the Virginia Attorney General at https://www. oag. state. va. us/consumercomplaintform.

Any disclosures we provide will only cover the 12-months period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

We shall provide information in response to your request free of charge, up to twice annually, unless requests are manifestly unfounded, excessive or repetitive. If we are unable to authenticate your request using commercially reasonable efforts, we may request additional information reasonably necessary to authenticate you and your request. If we cannot authenticate you and your request, we will not be able to grant your request.

D. Utah Residents

Under the Utah Consumer Privacy Act (“UCPA”), Utah residents acting in an individual or household context (and not in a commercial or employment context) are allowed to exercise certain rights regarding their Personal Data.

We will respond to your request within 45 days after receipt of your request (no more than twice in a twelve-month period). We reserve the right to extend the response time by an additional 45 days when reasonably necessary and provided consumer notification of the extension is made within the first 45 days. If we refuse to take action on a request, we will provide with the reasoning for our refusal.

Any disclosures we provide will only cover the 12-months period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

We shall provide information in response to your request free of charge, up to twice annually, unless requests are manifestly unfounded, excessive or repetitive. If we are unable to authenticate your request using commercially reasonable efforts, we may request additional information reasonably necessary to authenticate you and your request. If we cannot authenticate you and your request, we will not be able to grant your request.