Privacy Policy

Our Commitment to You

ThetaRay Ltd. and its affiliated companies (together: “ThetaRay”) are dedicated to providing you with the highest level of transparency and control over the use of your data. In order for us to provide you with our Services we are required to collect and process certain personal information about you and your activity.

This Privacy Policy (“Privacy Policy” or “Policy”) was designed to help you understand the information we collect, store, use and share, and it applies whenever you visit our Websites, or otherwise access or use of our Services (as both terms are defined below).

We strongly urge you to read this Privacy 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 Privacy Policy at any time.

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

This Privacy Policy is integrated into and forms part of the ThetaRay Terms of Service, which are currently available at https://thetaray.com/terms-and-conditions/.

Contents

1. Grounds for Data Collection
2. What Type of Data We Collect?
3. How Do We Receive Data About You?
4. How Do We Use the Data We Collect?
5. With Whom Do We Share Your Personal Data?
6. Tracking Technologies
7. How We Protect Your Information
8. Retention
9. EU User Rights
10. Transfer of Data Outside the EEA
11. How to Contact Us?
12. Our Policy Toward Children
13. Links to Other Websites or Services
14. Updates to This Policy

Grounds for Data Collection

Processing of your “Personal Data” (meaning any information which may potentially allow your identification with reasonable means) is necessary for the performance of our contractual obligations towards you, for providing our services (the “Services“) and the operation of our website at: thetaray.com, and any domain or subdomain associated with it (the “Website”), to protect our legitimate interests and for compliance with legal and regulatory obligations.

When you visit our Website, you consent to the collection, storage, use, disclosure and other uses of your Personal Data as described in this Privacy Policy.

What Type of Data We Collect?

Personal Data

When you visit or interact with us through our Website, we may collect certain Personal Data to provide and improve the provision of our Services, to contact or identify you, to enable you to access certain parts of the Website or as otherwise indicated in this Policy. We collect the following Personal Data about you:

• Contact Information – when you create an account on our Website, or subscribe to our communications (such as newsletter or Services updates), we will ask you to provide us with certain contact details such as your name, email address and phone number. If you contact us, for example by using the “contact us” form on our Website, we may also receive your name, email address, and any other Personal Data you may choose to provide us with.
• When using our Website – our server may automatically collect certain online such as your IP-address and your general location, and device identifiers (which may be considered pseudonymous Personal Data in certain jurisdictions).

Non-Personal Data

We also collect data about the use of our Website and the characteristics and activities of users, in order to operate it and improve it. We may collect the following non-Personal Data:

• Technical information – this includes data such as the browser you are using and its display settings, your operating system, device type, session start/stop time, referral URL, time zone, network connection type, and cookie information.
• Information from third parties – we may also receive certain pseudonymous (which cannot identify you) identifiers from our business partners, such as IDFA, GAID or other online identifiers. Some business partners such as analytics providers, advertisers or other third parties share with us this information so we could administer, analyze and improve our Website and Services. This information is also used to enhance data points about a particular unique browser or device.

If we combine Personal Data with non-Personal Data, the combined data will be treated as Personal Data. Further Personal Data will only be stored and processed if you voluntarily provide it to us, e.g. through a contact form.

How Do We Receive Data About You?

We receive your Personal Data from various sources:

• Registration Information – when you create an account on our Website, or subscribe to our communications (such as newsletter or Website updates), we will ask you to provide us with certain contact details, which are needed for us to provide with our Services.
• When you communicate with us – For example when you send us an email, we collect the Personal Information you provided us with.
• Third party information – We may receive your data from third parties who help us with the provision and maintenance of our Service, such as traffic analytics vendors, fraud prevention agencies and others.
• Technical information – When operating our Website, we use various technological tracking tools to collect information regarding your use of the Websites. Along with our partners, we may use tracking technologies such as cookies, JavaScript, beacons and Local Storage, which are used to store content information and preferences. You can read more about our use of tracking technologies below.

How Do We Use the Data We Collect?

• Provision of Website – for the provision and improvement of our Website, including for support and to respond to your queries.
• Website announcements – we will use your Personal Data to communicate with you and to keep you informed of our latest updates to our Website and Services, and to offer you Service offers and updates.
• Marketing purposes – We may use your Personal Data in the following ways: we may send you promotional material concerning our Services, or our partners’ services, which we believe might interest you; we may also display certain adverts on our Website or our partners’ websites, which we believe will be relevant for you. We make our best efforts to make sure you see only relevant ads and receive relevant communications from us, including but not limited to, by building an automated profile based on your Personal Data.

Opt-out – You may choose not to receive our promotional or marketing emails (all or any part thereof) by clicking on the “unsubscribe” link in the emails that you receive from us. You can also update your email preferences by clicking the “manage your email preferences” link in the emails you received from us.

Please note that even if you unsubscribe, we may continue to send you service-related updates and notifications, or reply to your queries and feedback you provide us.

If you do not want us to share your Personal Data for marketing purposes, you may opt-out in accordance with this “Opt-out” section. Please note that even if you opt-out, we may still use and share your Personal Data with third parties for non-marketing purposes (for example to fulfill your requests and orders, communicate with you and respond to your inquiries, etc.). In such cases, the companies with whom we share your Personal Data are authorized to use your Personal Data only as necessary to provide these non-marketing Websites.

You may also object to the use of your Personal Data for advertising purposes by disabling your cookies, as described in the “Tracking Technologies” section herein.

• Analytics, surveys and research – from time to time, we may conduct surveys, test features, or analyze the data we have, to develop, evaluate and improve our Service and Website and think of new and exciting features for our clients and users.
• Protecting our interests – we may use your Personal Data when we believe it’s necessary in order to take precautions against liabilities, investigate and defend ourselves against any third party claims or allegations, investigate and protect ourselves from fraud, protect the security or integrity of our Website or Service and protect the rights and property of ThetaRay, its users or partners.
• Enforcing of policies – we may use your Personal Data in order to enforce our policies.
• Compliance with legal and regulatory requirements – we may use your Personal Data to investigate violations, and as required by law, regulation or other governmental authority, or to comply with a subpoena or similar legal process.

With Whom Do We Share Your Personal Data?

• Internal concerned parties – we share your information with companies in our group, as well as our employees, in order to provide you with our Services and Websites.
• Business partners – we may share your information with business partners, such as storage, CRM and analytics providers, who help us provide you with our Services and Websites. These third parties may have access to your Personal Data so that they may perform these tasks on our behalf, but they are obligated to comply with this Privacy Policy and may not use your Personal Data for any other purpose.
• Compliance with laws and law enforcement entities – we cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We will disclose any data about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal processes (including but not limited to subpoenas), to protect our or a third party’s property and rights, to protect the safety of the public or any person, or to prevent or stop any activity we may consider to be, or to pose a risk of being illegal, unethical, inappropriate or legally actionable. We also may be required to disclose an individual’s Personal Data in response to a lawful request by public authorities, including meeting national security or law enforcement requirements.
• Merger and acquisitions – we may share your data if we enter into a business transaction such as a merger, acquisition, reorganization, bankruptcy, or sale of some or all of our assets. Any party that acquires our assets as part of such a transaction may continue to use your data in accordance with the terms of this Privacy Policy.

Tracking Technologies

When you visit or access our Website we use (and authorize third parties to use) web beacons, pixels, cookies, local storage, and other tracking technologies. These allow us to automatically collect information about you, your device and your online behavior, in order to enhance your navigation in our Website, improve our Website’s performance, perform analytics and customize your experience. In addition, we may merge information we have with information collected through these tracking technologies with information we may obtain from other sources and, as a result, such information may become Personal Data.

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, the cookie can help make our Website more user-friendly, for example by remembering your language preferences and settings. Cookies are widely used in order to make websites work in an efficient way. You can find more information about cookies at www.allaboutcookies.org.

Similar Technologies – Local storage, such as HTML 5, allows a website or mobile app to store and retrieve data on a user’s device. Pixels are small blocks of code embedded on a web page, mobile app, or advertisements, and are a used for passing information from your device to a third party. Web beacons are electronic files that allow a website to count users who visited a page or to access cookies.

Below are the third party Tracking Technologies used on our Website:

Category	Tracking Technology Partner	Type	Purpose
Site Analytics	Google Analytics	Third Party Tracking Technology – Performance Tracking	Google Analytics collects information such as how often Users access the Website, what pages they visit when they do so, etc. We use the information we get from Google Analytics only to improve our Websites. Google Analytics collects the IP address assigned to you on the date you visit, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Google’s ability to use and share information collected by Google Analytics about your visits to our Websites is restricted by the Google Analytics Terms of Use and Google’s Privacy Policy.
Marketing	Hubspot	Third Party Tracking Technology – Performance Tracking	HubSpot and its partners use cookies or similar technologies to analyze trends, administer the Website, track users’ movements around the Website, and to gather demographic information about our user base as a whole. To learn more please visit Hubspot’s Privacy Policy.

How to manage your cookie settings – 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 Websites 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:

• Google Chrome
• Internet Explorer
• Mozilla Firefox
• Safari (Desktop)
• Safari (Mobile)
• Android Browser
• Opera
• Opera Mobile

For other browsers, please consult the documentation that your browser manufacturer provides.

• Turning off third party cookies – You can turn off certain third party targeting/advertising cookies by visiting the following link: Network Advertising Initiative

How We Protect Your Information

We have implemented administrative, technical, and physical safeguards to help prevent unauthorized access, use, or disclosure of your Personal Data. Your data is stored on secure servers and isn’t publicly available. We limit access of your information only to those employees or partners on a “need to know” basis, in order to enable the carrying out of the agreement between us.

While we seek to protect your information to ensure that it is kept confidential, we cannot absolutely guarantee its security. You should be aware that there is always some risk involved in transmitting information over the internet. While we strive to protect your Personal Data, we cannot ensure or warrant the security and privacy of your Personal Data or other content you transmit using the Website, and you do so at your own risk.

Retention

We will retain your Personal Data for as long as necessary to provide our Services, to operate our Website, and as necessary to comply with our legal obligations, resolve disputes, and enforce our policies. Retention periods will be determined 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. Under applicable regulations, we will keep records containing client Personal Data, account information, communications and anything else as required by applicable laws and regulations.

EU User Rights

This section addresses the specific rights applying to residents of the EU or residents of other jurisdictions that grant the below rights.

You may request to:

1. Receive confirmation as to whether or not Personal Data concerning you is being processed, and access your stored Personal Data, together with supplementary information.
2. Receive a copy of Personal Data you directly volunteer to us in a structured, commonly used and machine-readable format.
3. Request rectification of your Personal Data that is in our control.
4. Request erasure of your Personal Data.
5. Object to the processing of Personal Data by us.
6. Request to restrict processing of your Personal Data by us.
7. Lodge a complaint with a supervisory authority.

Please note that these rights are not absolute, and may be subject to our own legitimate interests and regulatory requirements. Users, including those outside the EU, are welcome to contact us for any questions or requests through our contact details below.

We will make an effort to reply within a reasonable timeframe. Please feel free to reach out to us at any time via the following email address: info@thetaray.com. If you are unsatisfied with our response, you can lodge a complaint with the applicable data protection supervisory authority.

Transfer of Data Outside the EEA

If you reside in the European Union (“EU“), please note that your Personal Data may be transferred outside the EEA. In such case, we will transfer your data only to such countries as approved by the European Commission as providing adequate level of data protection, or enter into legal agreements ensuring an adequate level of data protection.

Our Policy Toward Children

We understand the importance of protecting children’s privacy, especially in an online environment. The Website is not designed for or directed at children under the age of 16 years old (“Minors”). We do not knowingly collect Personal Data from Minors. If a parent or guardian becomes aware that his or her Minor child has provided us with Personal Data, he or she should contact us using the details provided above.

Links to Other Websites or Services

As part of the Website, we may provide links or access to third-party websites. However, we are not responsible for the privacy practices employed by those websites, or the information or content therein. This Privacy Policy applies solely to information collected by us. Therefore, this Privacy Policy does not apply to your use of a third-party website or service accessed from our Website.

Updates to This Policy

This Privacy Policy is subject to changes from time to time, in our sole discretion. The most current version will always be posted on our website (as reflected in the “Last Updated” heading). You are advised to check for updates regularly. By continuing to access or use our Website after any revisions become effective, you agree to be bound by the updated Privacy Policy.

How to Contact Us?

If you wish to exercise any of the aforementioned rights, or receive more information, please contact us using the details provided below:

ThetaRay Ltd.

Email: info@thetaray.com.

International Headquarters

8 Hanagar Street, Hod HaSharon 4501309, Israel

UK Offices

68 Lombard Street, EC3V 9LJ, London, England

USA Headquarters

31 West 34th Street – Suite #17019, New York, NY 10001, United States