Privacy Policy

Last Updated: August 23, 2023

This Privacy Policy (“Policy”) explains how AlphaScan Ltd. (the “Company” or “AlphaScan AI”) may gather, collect, record, hold, distribute, share, disclose, or otherwise use your personal information and the rights and choices you have in relation to your personal information.

This Policy applies to all personal information collected during any written, electronic, and oral communications or collected online or offline, including our website at https://alphascan.xyz/, and all corresponding webpages, software applications or mobile applications (collectively, the “Site”), when you interact with our mobile applications, accounts on messaging and social media platforms and websites, including but not limited to, Telegram, Twitter, Discord, and YouTube (the “Social Media Accounts”), and when you interact with our advertising and applications on third-party websites and services, if the advertising and applications include links to this Policy (collectively, the “Services”).

Please read this Policy before accessing or using our Services. By using our Services, you agree to the collection and use of your personal information in accordance with this Policy and our Terms of Service (https://alphascan.gitbook.io/docs/alphascan/the-fineprint/terms-of-service). If you do not agree to all of the terms of this Policy or the Terms of Service, then you should not use or access our Services.

We may change this Policy from time to time, to reflect how we are processing your personal information, and if we make changes, we will notify you by revising the effective date or last modified date at the top of this Policy. We encourage you to look for updates and changes to this Policy by checking this date when you access our Site. If we make changes that materially affect your privacy rights, we will provide advanced notice so that you can review the changes before you continue to use the Services. Your continued access or use of our Services after receiving notice of the changes, constitutes your acknowledgement that you accept the updated Policy.

Please note that our Site may contain links to third-party websites, such as delivery services and social media pages. These links are intended for your convenience only. These third-party websites and services are not related to the Company and may have separate privacy policies and data collection practices. We have no responsibility for these websites or their privacy practices and encourage you to read the privacy policies of all websites that you visit.

1. INFORMATION WE COLLECT

AlphaScan AI collects certain personal information about you and your use of our Services. Personal information is generally any information that identifies you or makes you identifiable. Personal information does not include anonymized or aggregated information. The types of personal information that we may collect falls into two primary categories: (1) information you voluntarily provide to us; (2) information we collect from you automatically; and (3) information we receive from third parties.

Information You Voluntarily Provide. To use our Services you will need to provide us with certain personal information that can be used to contact or identify you such as your name, screen name, IP address, email address, mailing address, phone or mobile number.

Information We Automatically Collect. To the extent permitted under applicable law, we may collect certain types of personal information automatically, such as whenever you interact with the Site or use the Services. This information helps us address customer support issues and improve the performance of our Site and Services. We may collect the following types of information from you automatically:

· Website Log Data. When you browse our Site, we automatically collect information such as your Internet Protocol (“IP”) address, browser type and version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

· Device Information. When you access the Service on your device, we may collect certain information automatically, including but not limited to, the type of device you use, its unique ID, operating system, and other diagnostic data. We may also collect information that your browser sends whenever you visit our Site or use our Services.

· Cookies and Other Web-based Tracking Technologies. We may use different technologies such as cookies, web beacons, or other types of small temporary files or web-based tracking technologies to gather certain information. Like many other websites, cookies and these other web-based tracking technologies may be used by us during your visit to the Site to improve your individual experience as a user of our Site and our Services.

Information We May Receive from Third Parties. We may receive information about you from other sources to help us correct or supplement our records, improve the quality or personalization of our Services to you, and prevent or detect fraud. We may also collect personal information about you that we receive from our partners, group members or other third parties. For example, if you visit one of our social media account pages, the respective provider may provide us with statistical information regarding your use of our account(s).

2. HOW WE USE YOUR PERSONAL INFORMATION

In general, we use personal information to create, develop, operate, deliver, and improve our Site and Services. The Company may use personal information for the following purposes:

· To Provide the Services. We process your personal information to provides the Services to you, including the monitoring of our Services. We process your personal information also to manage your registration as a user of the Services.

· To Contact You. We may process your personal information to contact you by email, telephone call, SMS, or other equivalent forms of electronic communication, such as a mobile application’s push notifications regarding updates or informative communications related to the functionalities, products or contracted Services, including any security updates, when necessary or reasonable for their implementation.

· To Maintain Legal Compliance. We may process your personal information to comply with our legal obligations, resolve any disputes we may have with you or another member, and to enforce our agreements with third parties.

· Security and Fraud Detention. We may use the information we collect to prevent and detect potential fraudulent transactions, breach of policies or terms, and threats of harm.

· For Research and Development of Our Services. We may use the information we collect to understand how our members use the Site and improve our Services.

· To Provide Marketing Communications. We may use the information we collect through the Site to develop and send advertising, direct marketing, and communications about the Services.

· To Respond to Your Requests. We may process your personal information when you contact us, such as with questions, concerns, and feedback.

· For Other Purposes. We may use Your information for other purposes, such as data analysis, identifying usage trends, and evaluating and improving our Services.

· With Your Consent. We may process your personal information for any other purpose which is reasonably necessary to provide the Services, with your permission or upon your direction.

Notwithstanding the above, we may use information that does not identify you (including information that has been aggregated or de-identified) for any purpose except as prohibited by law or contractual obligation.

3. SHARING AND DISCLOSURE OF INFORMATION

We share information we collect as needed to fulfill the purposes described in this Policy and as permitted by applicable law. We may share your personal information in the following situations:

· With Service Providers. We may share your personal information with service providers to monitor the use of our Service, for payment processing, cloud or other data storage, and to contact you.

· Analytics Partners. We may use analytics services provided by a third-party service provider or by using one of their tools, such as but not limited to Google Analytics, to collect and process certain analytics data. These services may also collect data about your use of other websites, apps, and online resources.

· Advertising Partners. We may work with third-party advertising companies to provide you with advertisements or other information that we believe might interest you. These partners may set or access their own cookies, pixel tags, or similar technologies on our Services or they may otherwise collect or have access to data about you which they may collect over time and across different online services.

· Social Media Features. We may offer social media features that let you share actions that you take on our social media pages. Your use of such features enables the sharing of personal information with the public, depending on the settings you establish with the entity that provides the social sharing feature.

· With Other Users. When you share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside. If you interact with other users or register through a third-party social media service, your contacts on the third-party social media service may see your name, profile, pictures, and description of your activity.

· With Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honor this Policy.

· With Business Partners. We may share your information with our business partners to offer you certain products, services or promotions.

· During Corporate Transactions. We may share or transfer your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of our business to another company. By engaging with us or using our Services, you understand and agree to our assignment or transfer of rights to your personal information. We will provide you with notice before your personal information is transferred and becomes subject to a different Policy.

· As Required by Law. We may disclose your information if we believe that the disclosure is required by law, if we believe that the disclosure is necessary to enforce our agreements or policies, in response to valid requests by public authorities (e.g., a court or a government agency), or if we believe that the disclosure will help us protect the rights, property, or safety of AlphaScan AI or its users.

· Outside Professional Advisors. We may share or disclose your personal information with any of the Company’s outside professionals to facilitate the professional advice from those outside professionals.

· With Notice to You and Your Consent. We may disclose your personal information for any other purpose with your consent.

This Privacy Policy does not apply to other advertisers, websites, and third-parties. Please consult any other advertisers’, websites’, or third-parties’ privacy policy for more information.

4. COOKIES AND SIMILAR TRACKING TECHNOLOGIES

We, and third parties acting on our behalf, may employ various tracking technologies, such as cookies and similar technologies (collectively “Tracking Technologies”) to collect additional personal information as you interact with our Services. This additional information helps us to personalize your experience with our Services and helps us better manage on content our Site by informing us what content is effective.

A cookie is a small file placed on your device. You can instruct your browser to refuse/reject all cookies or to indicate when a cookie is being sent. However, if you do not accept Cookies, you may not be able to use some parts of our Services. Unless you have adjusted your browser setting so that it will refuse cookies, our Services may use cookies.

Certain features of our Site may use local stored objects (or Flash Cookies) to collect and store information about your preferences or your activity on our Site. Flash Cookies are not managed by the same browser settings as those used for Browser Cookies. For more information on how you can delete Flash Cookies, please read “Where can I change the settings for disabling, or deleting local shared objects?” available at https://helpx.adobe.com/flash-player/kb/disable-local-shared-objects-flash.html#main_Where_can_I_change_the_settings_for_disabling_or_deleting_local_shared_objects. Certain sections of our Site and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).

Cookies can be “Persistent” or “Session” Cookies. Persistent Cookies remain on your personal computer or mobile device when you go offline, while Session Cookies are deleted as soon as you close your web browser.

We may use both Session and Persistent Cookies for the purposes set out below:

· Necessary / Essential Cookies. These cookies are essential to provide you with Services available through the Site and to enable you to use some of its features. They help to authenticate users. Without these cookies, the Services that you have asked for cannot be provided, and we only use these cookies to provide you with those services.

· Performance/Analytics Cookies. These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our Services. All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies we will not know when you have visited our Site, and will not be able to monitor its performance.

· Functionality Cookies. These cookies allow us to remember choices you make when you use the Site, such as remembering your login details or language preference. The purpose of these cookies is to provide you with a more personal experience and to avoid your having to re-enter your preferences every time you use the Site.

· Tracking and Performance Cookies. These cookies are used to track information about traffic to the Site. The information gathered via these cookies may directly or indirectly identify you as an individual visitor. This is because the information collected is typically linked to a pseudonymous identifier associated with the device you use to access the Site. We may also use these cookies to test new pages, features, or new functionality of the Site to see how our users react to them.

You can also use the browser with which you are viewing this website to enable, disable, or delete cookies. To do this, follow the instructions provided by your browser or review the instructions provided by the browsers listed here: Google Chrome, Mozilla Firefox, Safari Desktop, Safari Mobile, and Android browser. Please note, if you set your browser to disable cookies, you may not be able to access secure areas of the Site and our Services. Also, if you disable cookies other parts, the Site may not work properly.

There are also additional tools available to manage third party cookies. Please visit the following to the extent you would like to learn more, including how to opt out of website interest-based advertising: optout.aboutads.info/, youradchoices.ca/en/tools, optout.networkadvertising.org/?c=1, youronlinechoices.eu/.

Mobile Advertising. You can opt out of having your mobile advertising identifiers used for certain types of advertising by accessing the appropriate settings in your mobile device and following the instructions. If you opt-out, we will remove all data about you and will not collect any further data. The random ID previously assigned to you will be removed. Thus, if at a later stage, you decide to opt-in, we will be unable to continue and track you using the prior ID and you will for all practical purposes be a new user. For iOS devices, to limit interest-based ad tracking, go to Settings>Privacy>Advertising>Turn on “Limit ad Tracking.” For Android devices, go to Settings>Google services>Ads>Turn on “Opt out of Ads Personalization.” For iOS and Android, you can also reset the advertising identifier that is currently assigned to you.

To opt out of data collection for interest-based advertising across mobile applications by participating companies, download the DAA’s AppChoices mobile application opt-out offering here: youradchoices.com/appchoices.

Flash Cookies. If you do not want Flash Cookies stored on your computer, you can adjust the settings of your Flash player to block Flash Cookies storage using the tools contained in the website storage settings panel: macromedia.com/support/documentation/en/flashplayer/‌help/‌settings_manager07.html. You can also control Flash Cookies by going to the global storage settings panel and following the instructions. Setting the Flash Player to restrict or limit acceptance of Flash Cookies may reduce or impede the functionality of some Flash applications, including, potentially, Flash applications used in connection with our Services or online content.

Do Not Track. Some Internet browsers – like Firefox and Safari – include the ability to transmit “Do Not Track” or “DNT” signals. Since uniform standards for “DNT” signals have not been adopted, our Site does not currently process or respond to “DNT” signals.

5. CHILDREN’S PERSONAL INFORMATION

Our Services are not directed towards children under 16 (or other age as required by local law), and we do not knowingly collect personal information from children. If we become aware that a child has provided us with personal information in violation of applicable law, we will delete any personal information that we have collected, unless we have a legal obligation to keep it.

6. RETENTION OF YOUR INFORMATION

The Company will retain your personal information only for as long as is necessary for the purposes set out in this Policy. We will retain and use your personal information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or improve the functionality of the Site, or we are legally obligated to retain this data for a longer period of time.

7. DATA SECURITY

We maintain our Service and all associated data with technical, administrative, and physical safeguards to protect against loss, unauthorized access, destruction, misuse, modification, and/or improper disclosure.

Notwithstanding, no method of transmission over the Internet, or method of electronic storage can be guaranteed to be secure. We do not and cannot guarantee the security of our databases or the databases of third parties with whom we may share information, nor do we or can we guarantee that the information you supply will not be intercepted while being transmitted over the Internet. You should, accordingly, take special care in deciding what information you send to us via electronic communication. We are not responsible for circumvention of any privacy settings or security measures contained on the Site. If you have any questions about the security of your personal information, you may contact us at [e-mail].

8. UPDATING YOUR INFORMATION

You may, depending on your location, have the right to access, correct, or update your personal information that has been previously provided to us through the Site. We are committed to ensuring that your personal information is kept accurate and up to date. However, it is up to you to update it with any changes. In order to correct, update, or modify your personal information as it appears, contact us at [e-mail].

9. YOUR RIGHTS AND CHOICES REGARDING NON-TRANSACTION AND/OR NON-SECURITY COMMUNICATIONS

To provide the Services to you we may send you communications related to your transactions, security, or the administration of the Site. From time to time we may also send you other messages or updates about the Company, our Site, and promotions or other activities. If you do not wish to receive non-transaction/non-security related communications from us, you may opt-out by clicking the “unsubscribe” link in the communication you received from us, or send an email message to [e-mail] stating that you no longer want to receive these communications. Users from the EEA, the UK, Switzerland, Singapore, South Africa, Saudi Arabia, the United Arab Emirates, or Canada will, if required by applicable law, receive such communications only after having consented hereto. Please note that opt-out and “unsubscribe” requests may not take effect immediately and may take a reasonable amount of time to receive, process, and apply, during which time your information shall remain subject to the Policy. Additionally, you should be aware that any information provided to third-parties prior to your election to opt-out or unsubscribe will not be retrieved or rescinded, unless required by applicable law.

10. INTERNATIONAL TRANSFER OF PERSONAL INFORMATION

Your information, including personal information, is processed at the Company’s operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to and maintained on computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction. We will take all steps reasonably necessary to ensure that your personal information is treated securely and in accordance with the Policy and that no transfer of personal information will take place to an organization or country unless there are appropriate safeguards in place as required under the applicable data protection laws and ensuring the security of your personal information maintained. If you do not want your information transferred to or processed or maintained outside of the country or jurisdiction where you are located, you should not use the Site or Services.

11. NOTICE TO CALIFORNIA RESIDENTS

This section applies only to California residents and is intended to inform such California residents, at or before the time of collection of personal information, about our data collection practices, your privacy rights under California law, including, beginning on January 1, 2023, the California Privacy Rights Act (“CPRA”). As used in this section only, the term “personal information” is defined as it is used in the CPRA.

Categories of Personal Information Collected. We collect personal information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device. We generally collect the following categories of personal information:

· Identifiers such as name, address, unique personal identifier, email, phone number, your device’s IP address, software, and identification numbers associated with your devices.

· Commercial information such as records of services purchased, obtained, or considered by you.

· Internet or other electronic information regarding your browsing history, search history, the webpage visited before you came to our Site, length of visit, and number of page views, clicks, stream data, locale preferences, your mobile carrier, date and time stamps associated with transactions, and system configuration information.

· Inferences about your preferences, characteristics, behavior, and attitudes.

We generally do not collect biometric, or education-related information.

We collect your personal information for the business purposes described in Section 2 above. A “business purpose” means the use of personal information for the business’s operational purposes, or other notified purposes, provided the use of personal information is reasonably necessary and proportionate to achieve the operational purpose for which the personal information was collected or another operational purpose that is compatible with the context in which the personal information was collected.

The categories of third parties with whom we may share your information are listed in Section 3 above.

Your Rights. If you are a California resident, you may be entitled to the following rights subject to certain exceptions.

Access to Specific Information and Data Portability Rights. You have the right to request a copy of the personal information that we collected about you during the 12 months preceding your request. Once we receive your request and verify your identity, we will disclose the following to you;

· The categories of personal information that we have collected about you;

· The categories of sources for the personal information that we have collected about you;

· Our business or commercial purpose for the collection of your personal information;

· The categories of third parties with whom we share your personal information; and

· The specific pieces of personal information that we collected about you.

The Right to Delete personal information collected by the Company (with some exceptions).

The Right to Opt-Out of the sale or sharing of your personal information.

The Right to Correct inaccurate personal information that the Company has about you.

The Right to Limit the use and disclosure of sensitive personal information collected about you.

12. NOTICE TO USERS LOCATED IN THE EUROPEAN ECONOMIC AREA, SWITZERLAND, AND THE UNITED KINGDOM

This Section provides additional information to individuals located in the EEA, the United Kingdom, or Switzerland at the time their personal information is collected by the Company.

Legal Basis for Our Processing. The legal basis of our processing within the scope of application of the GDPR, the UK-GDPR or the Swiss Data Protection Act is as follows:

· Contract (Art. 6 (1) b GDPR). Where we provide our Services and answer your support and customer service requests the legal basis for processing your information is for the performance of our contract with you.

· Legitimate Interests (Art. 6 (1) f GDPR). We have a legitimate interest in processing your personal information: (1) to provide a secure website user experience; (2) for internal operations; (3) to protect our financial interests or to otherwise protect ourselves against fraud or unauthorized transactions; (4) to promote our Services and/or facilitate any contests, sweepstakes, or promotions and process and deliver entries and rewards; and (5) to protect our rights and interests, such as when we share information with any of the Company’s professional advisors such as attorneys or accountants in order to facilitate professional advice.

· Consent (Art. 6 (1) a GDPR). Unless consent is not required by applicable law, the legal basis for processing when we send you promotional communication(s) about our Services, or news and information we think will be of interest to you, only after you have consented to such communication, is your consent. You can withdraw your consent at any time with future effect.

· Compliance with Legal Obligations (Art. 6 (1) c GDPR). We process your personal information for compliance purposes as may be required by applicable laws or regulations or as requested by any judicial process or governmental agency (including without limitation for Company’s tax reporting) or as may be requested, e.g., under any subpoena or court order.

Your Data Protection Rights. If you reside in the European Economic Area (EEA), Switzerland, or the United Kingdom, you may have the right to exercise the following privacy rights available to you under applicable law. However, we may limit these requests under the applicable law when: (1) denial of access is required or authorized by law; (2) granting access would have a negative impact on another’s privacy; (3) necessary for the protection of our rights and properties; and (4) the request is frivolous or burdensome. To assert your privacy rights, please contact us at [e-mail]. We may seek to verify your identity when we receive your privacy rights request to ensure the security of your personal information.

· Right to Access. You may have the right to obtain a copy of your personal information that we hold about you, as well as other supplementary information, such as the purpose of processing, the categories of personal information that we process, and the entities to whom we disclose your personal information.

· Right to Rectification. You may have the right to request that we correct any of your personal information in our files.

· Right to Ensure. Under certain circumstances, you may have the right to request the erasure of your personal information that we hold about you. Note, however, that the right is not absolute, and we may refuse your right to erasure if there are compelling legitimate grounds for keeping your information.

· Right to Restriction. You have the right to request that we restrict our processing of your personal information in certain circumstances. For example, this right is available if you contest the accuracy of the personal information that we hold about you or if you objected to our processing of your personal information.

· Right to Object. You have the right to object to our processing of your personal information at any time and as permitted by applicable law if we process your personal information on the legal basis of consent or legitimate interests as detailed above. However, we may continue to process your personal information if it is necessary for the defense of legal claims, or for any other exceptions permitted by applicable law.

· Right to Portability. Under certain circumstances, you may have the right to receive personal information that we hold about you in a structured, commonly used, and machine-readable format so that you can provide that personal information to another controller.

If you believe that we have infringed your rights, we encourage you to first submit a request to us directly at [e-mail] so that we can try to resolve the issue or dispute informally and efficiently. Without prejudice to any other administrative or judicial remedy, you may have the right to lodge a complaint with a supervisory authority in a specific region and according to applicable law. you can find details of EEA Supervisory Authorities at: https://edpb.europa.eu/about-edpb/board/members_en.

International Transfers. We may share your personal information with recipients (including our group members, service providers, and/or business partners, as described in this Policy), located in the United States and/or otherwise in countries outside the EEA, the United Kingdom, and Switzerland which do not provide for an adequate level of data protection under EEA, United Kingdom, or Switzerland law. For such transfers, we will ensure that the recipients are subject to appropriate safeguards as permitted under the applicable data protection laws, e.g., by entering into appropriate data transfer agreements on the basis of applicable standard contractual clauses issued by the EU Commission, or by reliance upon Article 49 GDPR derogations or corresponding derogations under the Swiss Data Protection Act, as applicable.

13. HOW TO CONTACT US

If you have any questions regarding this Policy, please contact AlphaScan at [e-mail].