Privacy Policy

This privacy policy (the “Privacy Policy”) describes how SPECTRALX and any of its affiliates (the “Company” or “us” or “we”) treat information that it collects or receives from you (the “Users” or “you”) through its website (https://spectral-x.com/, and any other website operated by Company, collectively the “Website(s)”). By using any of the Company’s Websites, you agree to be bound by this Privacy Policy. In case you are entering into this agreementon behalf of another legal entity, such other legal entity shall be considered the User, and you represent that you have the power and authority to agree to this Privacy Policy on behalf of such entity. This Privacy Policy is a part of theCompany’s Terms of Use, governing the use of the Website, which is available at [ https://spectral-x.com/]. This PrivacyPolicy further explains our practices and the choices you can make, about the way your information is collected and used in connection with the Website or other communication channels with the Company through the Website.

1. No Legal Obligation to Provide Information

For the avoidance of doubt, a User is not legally obligated to use the Website or to disclose any information whatsoever to the Company. However, if a User chooses to use the Website, the provision of certain information is a pre-requisite for such use of the Website.

2. Types of Information Collected

The company may collect both Personally Identifying Information and Non-Identifiable Information, as such termsare defined below (together “Information”). For this Privacy Policy, “Personally-Identifying Information” shall mean any information that may be used, either alone or in combination with other information, to personally identify an individual, including, but not limited to, a first and last name, a personal profile, an email address, a home or other physical address, telephone number or other contact and/or financial information. “Non-IdentifiableInformation” shall mean information collected regarding the use of the Website or other interactions with the Company which does not enable identification of an individual User.

3. How the Company Collects Information

Company may collect information during your interactions with Company via any of its Websites, such as, without limitation, by monitoring parameters of a User’s use of the Websites with the use of certain tools, when a User communicates with Company through the Website by email, when User applies for certain functions on or through the Website or otherwise, including by the following measures:

• Company collects cookies, analytic tools, and log files: The company collects Information when you access content, advertising, sites, interactive widgets, applications, and other features of the Websites, where data collection technologies (such as web beacons, development tools, cookies, and other technologies, etc.) are present. These data collection technologies allow us to understand your activity on and off our Websites and to collect and store Information when you interact with the You may refuse to accept browsercertain data collection technologies by activating the appropriate setting on your browser. However, if you selectthis setting, you may be unable to access certain parts of our Website.
• When you subscribe to our newsletter: If you choose to subscribe to the Company’s newsletter, the Company will collect your name and email address to send you the Company’s news, publications, communications, and You can opt out of such a subscription at any time, by clicking the“unsubscribe” link at any communication and completing the unsubscribe process.
• When you contact us (e.g. for more information about the Company): By submitting an online form that we make available or by sending an email to an email address that we display on the Websites, you are providing us with Information that will be collected and processed in connection with Company’s treatment of your application, maintaining our communication and business relations and providing you with certain In addition, the Company may address any such request or application by contacting you directly by phone and/or email.

4. How Information is Used

In addition to the Information and purposes described in each section above, the Company may use the Information collected by it for any of the following purposes:

• To develop, deliver, and improve the Website.
• To customize and personalize the Website and to enhance the User
• To provide you with information about the Company or any related services that might be of
• To communicate with you including responding to any queries, complaints, or questions submitted to us.
• To send important notices, such as communications about the
• To compile statistical information and insights related to performance or use of the Website, and use such statistical information and insights (including without limitation for research purposes or public use in aggregated non-identifying form).
• For marketing purposes, including without limitation, to send User’s information and to alert Users to new developments, promotions, specials, products or Website or other activities, announcements, promotions, and newsletters, and to personalize same; and to administer same.
• To monitor and analyze information regarding User browsing and viewing preferences and to diagnose problems with the Website;
• For fraud prevention, internal operations, legal compliance, and other public and security-related
• For general statistical information for the promotion and improvement of the Company’s products and services.

5. Retention and Removal of Information

Except as otherwise specified in this Privacy Policy, the Company does not alter the practices detailed herein based upon your selection of the “Do Not Track” setting or other “opt-out” setting or feature that may be offered by your browser; however, the Company reserves the right to do so in the future without notice to the user. A User may contact the Company through the address specified below to remove certain Information attained from suchUser, subject to applicable law (removal of Information however may impair or prevent User’s continued use of the Website and/or treatment of application for position). Unless requested by a User as aforementioned, the Companymay retain Information for an unlimited period for uses by this Privacy Policy (but is under no obligation however to retain Information for any given period whatsoever).

6. Sharing Information with Third Parties

Company may share User’s Information with Company’s third-party service providers to comply with applicable law, legal proceedings, regulation, or governmental request.

Transfer of User’s Information to Company’s shareholders, partners, investment committee members, and/or affiliates to store or process such information on our behalf by this Privacy Policy.

Disclose User’s Information or any information you submitted through the Website or other communication channels if such information is helpful or necessary to: (1) comply with any applicable law, regulation, legal proceedings, or governmental request; (2) enforce our Terms of Use; (3) detect, prevent, or otherwise address fraud or security issues; or (4) protect against harm to the rights, property or safety of Company, our users, yourself or the public.

Transfer User’s Information to a successor entity of Company by way of merger or acquisition of Company’s applicable assets (for any use permitted hereunder), provided such successor entity will be bound by the requirements of this Privacy Policy concerning its use of such Information.

Transfer User’s Information Company’s service providers or contractors who process Information on behalf of the Company to perform certain business-related functions. These companies may include marketing agencies, database service providers, backup and disaster recovery service providers, email service providers, and others.

The Information may be transferred as detailed above, to other countries, subject to applicable law.

The company may use information that does not enable identification of an individual User, such as aggregated information about the use of the Website, or disclose it to third-party service providers to improve the Website, including to advertisers and partners.

7. Links to and Interaction with Third-Party Sites/Products

The Site may enable you to interact with or may contain links to, other third-party websites, mobile software applications, and services that are not owned or controlled by the Company (each a “Third Party Site”). Thecompany is not responsible for the privacy practices or the content of such Third-Party Sites. Accordingly, we encourage you to read the terms and conditions and privacy policy of each Third-Party Site that you choose to useor interact with. User further acknowledges that use of any Third Party Sites is not governed by this Privacy Policy.

8. Protection of Information

The company is committed to protecting the security of its Users’ Information and takes commercially reasonable measures to assure information security. However, no method of internet transmission or electronic storage is 100% secure and the Company cannot guarantee the Information’s absolute security. By using the Website, the User expressly agrees that the Company will not be liable for any third-party action, misuse, abuse, or infringement of data and information security.

9. Representations

Information you provide us with does not and shall not violate, breach, or infringe any third-party right or applicable law. You have displayed all the required privacy policies, and have all the required permissions from, all the relevant individuals mentioned in, or related to, the Personally Identifying Information or such other information to permit the Company to use such information by this Privacy Policy.

10. Contact

We are committed to protecting your privacy. If you have any comments or questions regarding our Privacy Policy, or your Personally-Identifying Information that we may be storing and using, please contact us at: [sales@polarisolutions.co ].

11. Your State Privacy Rights

State consumer privacy laws may provide their residents with additional rights regarding the Company’s use ofyour personal information (such as the California Civil Code Sections 1798.83-1798.84)., which may entitle you to ask us for a notice identifying the categories of personal information which we share with our affiliates and/or third parties for marketing purposes and providing contact information for such affiliates and/or third parties. If you are a resident of any such State and would like a copy of this notice, please submit a written request to: [sales@polarisolutions.com ].

If you are a resident of the European Economic Area (EEA), you have certain data protection rights. The company aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personally Identifiable Information. If you wish to be informed what Personally Identifiable Information, we hold about you and if you want it to be removed from our systems, please submit a written request to: [sales@polarisolutions.com].

12. Amendments; Governing Law

Company may change the terms of this Privacy Policy by posting new terms, such terms shall be effective in respect of each User immediately once posted.

Any disputes or claims arising out of or in connection with this Privacy Policy will be governed by and construed by the laws of the State of Israel, excluding its conflict of law principles. The parties irrevocably agree that the competent courts of Tel Aviv Israel shall have exclusive jurisdiction to settle any disputes or claims arising out of or in connection with this Privacy Policy.

Last updated: [April 15, 2024].