Datenschutzrichtlinie

OrCam Technologies Terms and Conditions Recently updated on November 2018 Welcome to OrCam MyEye, provided by OrCam Technologies (“OrCam” or “we”). OrCam harnesses the power of artificial vision by incorporating pioneering technology into a wearable platform which improves the lives of individuals who are visually impaired. These Terms and Conditions (“T&C”) represent the rules and guidelines that govern your access to and use of the mobile application OrCam MyEye (“App”), OrCam’s devices, and/or other services (collectively, “Services”) and form a legally binding contract between you and OrCam including its affiliates and subsidiaries**.** Please read these T&C carefully and visit this page regularly for updates and changes. Should you have any questions in connection with these T&C, please contact us at: support@orcam.com. By downloading the App, and/or using OrCam’s Services, you agree to be bound by these T&C, the user guide accompanying your device (“User Guide”), OrCam’s Privacy Policy and OrCam’s Cookie Policy, all as may be amended from time to time. If you do not agree to be bound by these T&C, you should cease all use of the Services, and uninstall the App from your device. As long as you do not cease using any of the Services, you will be conclusively deemed to have accepted these T&C. Our Services Who can use the Services. Our Services are intended for (i) Users over the age of 16, children under such age are not permitted to register to or use our Services, without the supervision and consent of a parent or guardian; (ii) having no legal, medical or other restriction which could preclude or restrict the User from using the Services or entering into; (iii) using the Services for their personal, non-commercial use. Prior to using the App and the Services, you must: Read the applicable User Guide in full, including the important safety Instructions, Receive in-person or online training by an authorized OrCam Trainer or participate in an OrCam training program. Important Safety Note. While we do our best to ensure that our Services provide a reliable experience to our Users, we cannot guarantee that no errors in identification or other malfunctions occur. Our Services are not intended and should not be relied upon in circumstances where such potential malfunctions may cause severe harm, be life-threatening or health-threatening, or otherwise put you or others in harm’s way. Specifically, the Services are not intended to enable driving vehicles, operating machinery, identifying medications, detergents, establishing the existence of allergens, or in connection with other hazardous materials or equipment.  Nothing in these T&C, the User Guide or OrCam training program replaces the need to exercise user discretion, caution and common sense in connection with use of our Services and any safety concerns.   Creating an Account You may need to create an account in order to activate and use the App and Services. You agree to provide us with accurate, updated and complete information as required in order to create an account and complete the registration and activation process. You further agree to keep that information up to date. You may be entitled to request the erasure or the restriction of your Personal Data, and we will comply with such requests, to the extent required under applicable law. For additional information on how we use personal data, see our Privacy Policy. You are entirely responsible for maintaining the confidentiality of your login credentials, namely your username and password. You agree and undertake not to use the login credentials of another user at any time, or to disclose your login credentials to any other user or other third party. You are responsible for all activities that occur through your account. You agree to notify us immediately if you suspect any unauthorized use of your login credentials or your account. Changes to our Services We continuously improve our Services and develop new features, products and services as well as enhancements and fixes to existing Services. Therefore, we might at any time and at our sole discretion with or without notice, make changes to the Services whether by adding or removing features, products and functionalities, or by providing updates including fixes, or by suspending or imposing limitations with regards to the Services or by imposing other changes to the Services (“Changes”). We will implement Changes, inter alia, by providing software updates including automatic updates. You agree to automatic updates and further agree that the Services may be negatively impacted if you do not allow the installation or implementation of such Changes. You also agree that these T&C as amended from time to time, will apply to any and all Changes. In addition, we have no obligation to provide any Changes or to continue to provide or enable any particular features or functionality of any of our Services. Some of our Services may be released in their testing stage, and made available as a “Private Beta” versions. This means that we may not have yet completed development of all available Services and that not all features are completely functional or available. OrCam reserves the right at any time and from time to time, without being obligated to provide prior notice, to modify, suspend, or discontinue, temporarily or permanently, the Services or any part thereof, or user’s access thereto, all at its sole discretion. You will have no claim, complaint or demand against OrCam or against any related parties or affiliates of OrCam, for applying such changes or for failures incidental to such changes. Restrictions You may not, whether directly or indirectly (unless laws prohibit these restrictions or you have our written permission to do so), and you undertake that you will not, and will not allow others, to: Modify the Services, or decompile, disassemble, or otherwise attempt, directly or indirectly, to disrupt the Services, servers or networks connected to the Services, deny service to, hack, crack, reverse engineer, or otherwise interfere with the Services and their underlying software, or other technology, code, algorithm or other proprietary information of OrCam in any manner, or disobey any requirements, procedures, policies, or regulations of networks connected to the Services and/or interfere with the automatic process of downloading and/or installing the mandatory updates or upgrades to the Services, with or without notification; Attempt to circumvent or overcome any technological protection measures intended to restrict access to any portion of the Services, technology or any software thereto; Create a database by systematically downloading and storing all or any content from the Services; Use the Services for any illegal, immoral or unauthorized purpose, to encourage criminal behavior or conduct that would constitute a criminal offense under any law, or in a manner that could give rise to civil liability or other lawsuit, including but not limited to, using the Services in order to download content in violation of copyright, for distribution or development of any malware, take any action relating to piracy on the web, etc.; Use the Services in any way which is prohibited in these T&C; Use any automated means or interface to access the Services or extract other users’ information; Use or develop any third-party applications that interface or interact with the Services or other users’ information; Use OrCam logos or marks for any purpose without first obtaining OrCam’s written consent; Violate any third party or other user’s right to privacy or other rights, or harvest or collect personal information about users of the Service (including another user’s account, username, or password, solicit login credentials); Defame, abuse, harass, threaten, or otherwise violate the legal rights of others including the intellectual property rights (i.e. copyrights, patents); Transmit or otherwise make available in connection with the Services any computer code, file, or program including any virus, worm, Trojan Horse, spyware, or any other, that may or is intended to damage or hijack the operation of any hardware, software, or telecommunications equipment, or any other actually or potentially harmful, disruptive, or invasive code or component; Interfere with or disrupt the operation of the Services, or the servers or networks that host the Services or make the Services available, or disobey any requirements, procedures, policies, or regulations of such servers or networks; Probe, scan, or test the vulnerability of our Services; Sell, license, or exploit for any commercial purposes any use of or access to the Services; Frame or mirror any part of the Services; We reserve the right to refuse to provide the Services, and may terminate or suspend your account or access to the Services at any time, in case your use violates these T&C or applicable law. You may terminate these T&C at any time and for any reason by ceasing any use of the Services and uninstalling the App from your device. Privacy OrCam respects its users‘ right to privacy and we are committed to protecting and safeguarding our clients‘ and users‘ personal information. It is important for us to enable you to understand our privacy policy and your rights in connection with the personal data we may hold about you. You should also be aware that we use cookies and similar technologies to collect and save information when you visit our website. To learn more – please see our Privacy and Cookie Policy. Ownership The Services, the App, their underlying technology, and any and all Content and information provided on and through the Services, including, without limitation, any of OrCam’s logos, trademarks, graphics, designs, information, texts, databases, images, data, underlying software, code, algorithm, technology, hardware, firmware, patents, and other material displayed, available or associated with the Services, are the property of OrCam, the copyrighted and/or trademarked work of OrCam and/or proprietary information, patents and knowledge protected under trade secrets, patents, or otherwise, and owned exclusively by OrCam and its affiliates and/or licensors. OrCam retains any and all rights, including any and all intellectual property rights, in the Services, the App, and all the above (collectively, “OrCam’s Intellectual Property”). You have no right to modify, edit, copy, reproduce, publish, make available to the public, sell, rent, distribute, broadcast, transmit, create derivative works of, reverse engineer, alter, convey to a third party, enhance or in any way exploit any part of the Services or OrCam’s Intellectual Property. Nothing in these T&C shall be construed to derogate in any way from OrCam’s rights in its Intellectual Property, or transfer any such rights to the user. Without derogating from the above, it is clarified that “OrCam”, the OrCam logo, and other trade and/or service marks are the property of OrCam. Subject to full compliance with all provisions of these T&C, and full payment of consideration due to OrCam in connection with the Services, OrCam grants you a personal, non-assignable, non-exclusive, revocable at will, and non-sublicensable, limited right to use the App and Services, solely for your personal, non-commercial needs. Content and Back Up Our Services provide Users with the option to create certain personalized labels for their use, such as identification of people and products by names chosen by the User (“User Content”). User content may be encrypted and stored in our cloud services, to provide our Users with back up of their content. We do not access, review or monitor User Content. We do not use User Content or process it in any way other than providing the User with encrypted backing of the data. You are solely responsible and liable for any User Content. OrCam does not control and is not aware of the content of any User Content, and shall not be responsible or liable in connection with such content. We always love to hear from our Users. If you choose to provide us with feedback or suggestions, you acknowledge and agree that we may use such feedback for any purpose, and waive any consideration or compensation of any kind. Third Parties Our Services are designed to enable our Users to interact with the world, and with people, services, products and activities in it. We do not control and are not responsible or liable for any such interactions with services and products provided by third parties (“Third Party Services”), and do not endorse or recommend any specific Third Party Service. You should exercise care and discretion when using, interacting with or participating in Third Party Services. The reliance upon Third Party Services is made entirely at User’s sole risk. Communications with Us By using the Services, you expressly agree we may communicate with you regarding the Services or respond to your communications to us through the App, by email, or other electronic means directed to your device and that certain information about your usage of the App may be communicated to us automatically from your device. LIMITATION OF LIABILITY AND WARRANTY OrCam does not make any representations or warranties regarding the Services, App, their functions or any output they produce. The OrCam end-user limited product warranty (the “Limited Warranty”) covers the owner of an OrCam product against defects in material or workmanship at the time of its original purchase, for a subsequent period of one (1) year, and for any additional applicable legal warranty period. Original proof of purchase/delivery is required from the owner in order to obtain this coverage. OrCam will repair or replace, at its discretion, any product that is determined by OrCam to be covered under this Limited Warranty. OrCam will not be responsible for conditions arising as a result of intentional damage or misuse of the product. The owner is responsible for the costs of shipping the product to the location specified by OrCam. This Limited Warranty is the sole and exclusive warranty applicable to OrCam Services. No third party has the authority to make any representation, warranty, or agreement on behalf of OrCam with respect to OrCam products. No warranty of any kind or nature is made by OrCam beyond those expressly stated herein. In no event shall OrCam be liable for any special, collateral, indirect, punitive, incidental, consequential, or exemplary damages in connection with or arising out of the use of the Services and/or the App. Unless as otherwise expressly stated herein, you acknowledge and agree that the Services and App and any of their content, are provided “as is”, “as available”, and “with all faults”, are used only at your own risk, to the fullest extent permissible by law. Without derogating from any provisions limiting liability under these T&C, the Limited Warranty, if applicable to User, will not apply, and the owner will reimburse OrCam for any costs and expenses incurred in the event that: (i) the Services have been used other than in accordance with the User Guide and these T&C or other written operating instructions provided by OrCam; (ii) the Services have been subject to tampering, misuse, negligence, or accident; (iii) parts identification labels have been removed or the device has been otherwise altered; (iv) an OrCam product has been opened, modified, repaired, serviced, maintained, or altered by someone other than an authorized OrCam representative; (v) the Services have been combined with software, hardware, or other equipment not supplied by OrCam or not approved in writing by an authorized OrCam representative in advance; (vi) any OrCam product has been intentionally damaged, or exposed to water, heat, or high voltage; (vii) the Services have been used by a person who has not completed training by an authorized OrCam Trainer™ or OrCam in-person or online training program. Any parts replaced pursuant to the warranty will be under warranty for the remaining time of the original warranty period or for ninety (90) days from the date of repair, whichever is longer. If you believe that your product needs warranty support, please contact us at: support@orcam.com. You will be responsible for any shipping costs associated with support services. However, if it is determined that the warranty request is valid, OrCam will pay the total cost of shipping the repaired or replaced product. ORCAM DISCLAIMS ANY AND ALL WARRANTIES, WHETHER EXPRESSED OR IMPLIED, INCLUDING WITHOUT LIMITATION, THE IMPLIED WARRANTIES AS TO FITNESS FOR A PARTICULAR PURPOSE, MERCHANTABILITY, TITLE, NON-INFRINGEMENT, RESULTS, ACCURACY, COMPLETENESS, ACCESSIBILITY, COMPATIBILITY, SUITABILITY, RELIABILITY, AVAILABILITY, TIMELINESS, QUALITY, AND LACK OF VIRUSES. ORCAM DOES NOT WARRANT THAT THE PRODUCT WILL BE ERROR FREE OR “BUG” FREE, WILL OPERATE WITHOUT INTERRUPTION, THAT ANY IMAGES OR SOUNDS PRODUCED BY THE PRODUCT WILL BE ACCURATE OR THAT THE OPERATION OF THE PRODUCT WILL BE SECURE AND HEREBY DISCLAIMS ANY AND ALL LIABILITY ON ACCOUNT THEREOF. THIS SECTION SHALL BE ENFORCEABLE TO THE FULLEST EXTENT ALLOWED BY APPLICABLE LAW. The Services and/or App do not support all types of devices and it is your responsibility to check the feasibility of using your device with the Services. Portions of the Services may be contingent upon availability and continuity of wireless internet connection of the device. The User shall bear all charges made by a cellular communication provider associated with use of internet communication for the Services, including in the event of exceeding the User’s cellular package. Refund policy. You can return your undamaged device for a refund within the period required by local law or 30 days following receipt, whichever is longer. Returns may be subject to a re-stocking fee. Training fees are nonrefundable. Please contact your local representative or OrCam Support to initiate a return process. ORCAM’S ENTIRE LIABILITY AND YOUR EXCLUSIVE REMEDY WITH RESPECT TO ANY DISPUTE WITH US (INCLUDING WITHOUT LIMITATION YOUR USE OF THE SERVICES) IS TO DISCONTINUE YOUR USE OF THE SERVICES. ORCAM AND ITS AFFILIATES, OR THEIR RESPECTIVE SHAREHOLDERS, DIRECTORS, OFFICERS, EMPLOYEES, SERVANTS OR AGENTS SHALL NOT BE LIABLE FOR ANY DIRECT, INDIRECT, SPECIAL, INCIDENTAL, CONSEQUENTIAL OR EXEMPLARY DAMAGE (EVEN IF SUCH DAMAGE COULD HAVE BEEN REASONABLY FORESEEN) ARISING FROM YOUR USE OF THE SERVICES. THESE EXCLUSIONS FOR DIRECT, INDIRECT, SPECIAL, INCIDENTAL, CONSEQUENTIAL OR EXEMPLARY DAMAGES INCLUDE, WITHOUT LIMITATION, DAMAGES FOR LOST PROFITS, LOST DATA, LOSS OF GOODWILL, WORK STOPPAGE, COMPUTER FAILURE OR MALFUNCTION, OR ANY OTHER COMMERCIAL DAMAGES OR LOSSES, EVEN IF WE HAD BEEN ADVISED OF THE POSSIBILITY THEREOF AND REGARDLESS OF THE LEGAL OR EQUITABLE THEORY UPON WHICH THE CLAIM IS BASED. BECAUSE SOME STATES OR JURISDICTIONS DO NOT ALLOW THE EXCLUSION OR THE LIMITATION OF LIABILITY FOR CONSEQUENTIAL OR INCIDENTAL DAMAGES, IN SUCH STATES OR JURISDICTIONS, OUR LIABILITY SHALL IS LIMITED TO THE EXTENT PERMITTED BY LAW. USER ACKNOWLEDGES AND AGREES THAT WITHOUT THE FOREGOING EXCLUSIONS AND LIMITATIONS OF LIABILITY, WE WOULD NOT BE ABLE TO OFFER THE SERVICES. For the avoidance of doubt, OrCam shall not be liable towards you or any third party for any damage, loss, injury or harm caused by any action taken by you as a result of content presented through the App and Services. OrCam assumes no responsibility or liability if any Services were used other than in accordance with the instructions in the User Guide and/or training program. Services should not be relied upon in circumstances that are potentially life- or health threatening (including to identify medication/read prescriptions) or that could lead to financial loss. The Services should especially never be relied upon to drive vehicles or operate heavy machinery of any kind. OrCam shall not be responsible in the event that Services are used in such situations, or otherwise in violation of the user guide or these T&C. You acknowledge and understand that the App and/or Services require internet connection which may have different associated charges (such as mobile data expenses) and necessitate consumption of the mobile device battery. You shall have no claim or demand towards OrCam with regards to the aforesaid.

BREACH AND INDEMNITY Without derogating from any applicable law, you agree to indemnify and hold harmless OrCam and its employees, officers, directors and agents, as well as all third parties from and against all claims, damages, expenses, losses and liabilities that arise as a result of your violation of these T&C. Miscellaneous We may modify these T&C from time to time in our discretion. If fundamental changes are introduced, a notice will be posted in the updated version of the Services. Your continued use of the Services after the T&C have been modified signifies your assent to the updated T&C. If you dissent to the updated T&C or to any term within them, you must discontinue all further use of the Services. These T&C and the Services will be governed solely by the laws of the State of Israel, without giving effect to any conflicts of law principles. Any dispute, claim or controversy arising out of, connected with or relating to these T&C and the Services, will be under the exclusive jurisdiction of the competent court in Jerusalem, Israel. You may not assign or transfer your rights in and to the Services, or allow any other person to use your device or access your account on the App, without the prior written consent of OrCam. OrCam may assign its rights in and to the Service to a third party at its sole and absolute discretion, provided that the third party undertakes our obligations to you under these T&C. These T&C, together with the policies that are an integral part of these T&C, namely the Privacy Policy and Cookie Statement, shall all constitute the entire and complete agreement between you and us concerning the OrCam Services. These T&C and your use of the Services, do not, and shall not be construed as creating any relationship, partnership, joint venture, employer-employee, agency, or franchisor-franchisee relationship in any way and of any kind between the parties hereto. You are welcome to contact us in any matter relating to these T&C or the Services, by sending us an email to: support@orcam.com.

OrCam Technologies OrCam MYEYE Privacy Statement Recently updated on November 2018

OrCam thinks highly of your privacy and we are committed to protecting and safeguarding our clients‘ and users‘ personal information. This statement describes how OrCam Technologies, including its affiliates and subsidiaries (collectively, “OrCam” or “Us” or “We”), processes personal data regarding our clients and users in connection with services provided by us, our website, and the MyEye mobile application (respectively, the “App” and the “Services”), the types of personal data we collect and process, to what purposes we use and process your personal data, how your personal data is protected, and with whom your personal data may be shared. It is important for us to enable you to understand our privacy policy and your rights in connection with the personal data we hold about you. You should also be aware that we use cookies and similar technologies to collect and save information when you visit our website, available at: www.orcam.com, to ensure that we give you the best possible experience. To learn more about the use of such technologies, please see our Cookie Policy below. If you feel that a concern you have in connection with your privacy has not been met by the following Privacy Statement, please contact us at: privacy@orcam.com and let us know. If you choose to download the App, use, interact with, register or provide data to us in connection with the Services, you explicitly agree to the use of such data in accordance with this Privacy Statement. You may not use the Services or submit any data to us if you do not agree to any of the terms hereunder. This Privacy Statement shall not be construed in any manner to derogate from our Terms of Use or any other agreement made by and between OrCam and you.

THE HIGHLIGHTS:

• You are not required by law to provide us with any Personal Data. Sharing Personal Data with us is entirely voluntary.
• Our Services are intended for Users over the age of 16 or equivalent minimum age for providing consent to processing of Personal Data in the relevant jurisdiction. Children under such age are not permitted to register to or use our Services. If you are under such age you should cease to use the Services immediately.
• You may be entitled to request to review, amend, erase or restrict the processing of your Personal Data, pursuant to data protection laws applicable to you. Please note that in case you request to erase or restrict the processing of your Personal Data, your use of the Services may be restricted or disabled.
• We do not sell, trade, or rent Users‘ Personal Data to third parties. We only share Personal Data with third parties in connection with the provision of the Services to our Users, or other limited circumstances specified herein.

The following topics are included in our Privacy Statement. You may click on any topic and be directed to the relevant information:

What is Personal Data, and what data is collected about me by OrCam? What will OrCam do with my Personal Data? Legal basis of processing Personal Data Sharing personal data with others How does OrCam protect my Personal Data? How long will OrCam retain my Personal Data? What can I do to control my Personal Data? Will OrCam transfer my Personal Data internationally? Persons under 16 Applicable Laws How can I contact OrCam? Cookie Statement

1. What is Personal Data, and what data is collected about me by OrCam?

„Personal Data„, means any information which identifies or can be used to identify a natural person, including, but not limited to, first and last name, phone number, email address, IP address, billing information, etc. OrCam collects the following types of Personal Data:

• Data you give us about yourself

When you contact us or purchase our product through our website, you will be requested to provide us with certain information, contact details (name, email address, ID, mailing address, and phone number), your location, payment details, date of birth, relevant medical condition, your interest in our products, and other information. When you register for an account on the App, we collect and process the information you provide during registration, such as you contact details. If you contact our customer service for assistance in connection with any questions you may have or handling registration or warranty issues, as well as contact us for other purposes such as providing feedback, we will retain information provided to us by you in this context. Such information may include, in addition to your contact details and the nature of your customer service issue, data concerning your device model and serial number, your location, statistics regarding your operation with the device, and the way you operate your device. We also collect automatically certain information in connection with the use of the App and the device, such as hardware, software or internet network information, operating system, versions, settings (i.e. language), statistics regarding your use of the App and the device as well, and location information, data regarding the date and time of your interaction with the App and the device, and additional information about the way you interact with the App and the device, such as features used, pages visited, content viewed, down time, reset, etc. This information is used by us for diagnostic purposes, to analyze how the App and the device are used and to ensure the operation of the App, the device and our Services.

• Data you give us about someone else

In the event you interact with us on behalf of a person close to you, you may wish to provide us with Personal Data regarding that person. While we value your assistance and care for others, please note that it is your responsibility to make sure that any person whose Personal Data you provide is aware of the principles of this statement and agrees that you will provide Personal Data to us on this basis. Please note that we may not be able to provide all services to the person on whose behalf you contacted us without receiving his/her direct consent. Therefore we may request your assistance in communicating with that person.

• Data collected automatically

When you visit our website or install our App, certain information will be collected automatically, using cookies, web beacons, and similar technologies. To learn more about the use of such technologies, please see our Cookie Policy below. Personal Data collected automatically may include IP address, hardware, software or internet browser information, operating system, versions, settings (i.e. language), statistics regarding your use of our services and location. We also collect data regarding the date and time of your visit in our website, apps and social media pages, information about the way you interact with our website or app, such as pages you visited, content viewed by you, etc.

• Data we receive from others

In the event you purchased our products indirectly through a partner or distributer of OrCam, we may receive Personal Data about you in connection with such purchase and the use of our product. For example, when a distributer transfers data concerning a client in the context of customer support issues.

1. What will OrCam do with my Personal Data?

• Non-Personal Data.

Non-Personal Data is used mainly for click stream analysis in order to constantly improve and maintain our Services, including among others, in order to measure and understand the level of engagement to our services, for general business analytics and in order to provide a more personalized experience and tailored content, for ensuring the technical functioning of our network, to help prevent fraudulent use of our Services and for developing new services.

• Personal Data.

Personal Data is used only for the following limited purposes:

• Provision of our Services and products to users, to communicate with users regarding customer service issues, or to provide updates with respect to material changes to this Privacy Statement or our Terms of Use.
• Responding to questions or comments and to help resolve any problems.
• For the purposes of our legitimate interests, to the extent permitted under applicable law.
• To protect the security or integrity of our databases and the Services, and to take precautions against legal liability.
• To improve our products and Services, and to develop new features, products and services.
• To improve your experience on our website and mobile app, and customize our Services to your interests.
• To protect and enforce our legal rights and the rights of our users and third parties.
• Back up of User Content
• The App enables Users to create certain personalized labels for their use, such as identification of people and products by names chosen by the User (“User Content”). User content may be encrypted and stored in our cloud services, to provide our Users with back up of their content.
• We do not access, review or monitor User Content. We do not use User Content or process it in any way other than providing the User with encrypted backing of his/her data.
• You are solely responsible and liable for any User Content. OrCam does not control and is not aware of the content of any User Content, and shall not be responsible or liable in connection with such content.

1. Legal basis of processing Personal Data

• Certain processing activities conducted by us are based on the necessity of such activities for the performance of the agreement and obligations between us and our users. For example, we need your contact details and billing information in order to enable the purchase of our product. We also need certain medical information about you in order to ensure that the product you purchase will be suitable to your needs.
• Other processing activities are based on the grounds that they are necessary for the purposes of our legitimate interests or the legitimate interests of third parties, except where such interests are overridden by the interests or fundamental rights and freedoms of users.
• There may be certain processing activities based on your consent to this Privacy Statement. In connection with such activities, you may rescind your consent, by sending us an email to: privacy@orcam.com.

Please note that in the event you rescind your consent to the processing of Personal Data, we may not be able to provide you with some or all of the Services and products. If you choose to register to purchase OrCam’s products on the Website, you will be requested to provide us with certain Personal Data, such as contact information and information regarding the characteristics of your condition. For example, we may ask if a User suffers from any hearing loss, in addition to low vision. This information is requested in order to establish whether our products will be suitable for the User. When a User continues with the purchase process and submits this information, the determination of compatibility of our products will be made automatically. In certain jurisdictions such processing of Personal Data is defined as profiling, or automatic decision making. If relevant to you under applicable law, you may be entitled to object to such processing, and may do so by sending us a notice to: privacy@orcam.com.

1. Sharing Personal Data with others

• Non-Personal Data

Non-Personal Data, aggregate and statistical or otherwise anonymized data may be shared without limitation with third parties at our discretion, such as Google Analytics. This information does not contain any Personal Data and is used to develop content and services for our Users.

• Personal Data

We share Personal Data only under the following limited circumstances:

• With our distributors and service providers, in order to provide high quality service to you, we will ask in some cases (depending on regions and some other cases like native language) a representative of OrCam (a distributor, consultant or other business partner) to be in touch with you regarding your inquiries and needs. In such cases we will share with this representative certain Personal Data – usually your name and contact details but also other relevant information.
• With payment providers and financial institutions, who assist us in connection with validating payments and credit cards, in order to process your payments and complete your order.
• With third parties who assist us in operating the Services, conducting our business, expanding our business or servicing you, and for personalizing your experience of the Services and products.
• Otherwise, only with your prior consent.
• To comply with a legal requirement, for the administration of justice, to protect your vital interests or the vital interests of others, to protect the security or integrity of our databases or the Services and products, to take precautions against legal liability, or in the event of a corporate sale, merger, reorganization, dissolution or similar event, to enforce applicable Terms of Service, to address fraud, security, or technical issues, to protect against harm to the rights, property or safety of OrCam, our customers, or the public as required or permitted by law.

1. How does OrCam protect my Personal Data?

All information collected by us, will be maintained in confidence and protected by using appropriate data protection mechanisms. We are taking appropriate actions to protect against accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to Personal Data transmitted, stored or otherwise processed by us. We use customary software systems and procedures, whether by ourselves or by our business partners, including security and technical procedures to protect your Personal Data.

1. How long will OrCam retain my Personal Data?

We reserve the right to retain any Personal Data for as long as reasonably necessary in order to: (i) fulfill the purposes described herein; (ii) in the defense or assertion of legal claims and liability; (iii) for the analyses and improvement of the Services and products; and (iv) to comply with applicable law. Non-Personal Data and statistical or anonymized data may be retained by us without limitation.

1. What can I do to control my Personal Data?

There are multiple ways in which you can be in control of your Personal Data collected by us subject to applicable law.

• **Reviewing and amending your Personal Data. **You are entitled to review your Personal Data. You may exercise this right by sending us a request in connection with your Personal Data to: privacy@orcam.com. In the event any Personal Data is incorrect or outdated, you may update and correct such data by providing us with appropriate notification. You can ask us to receive a copy of the Personal Data we hold about you.
• Right of erasure and restriction. You may also be entitled request the erasure or the restriction of your Personal Data, and we will comply with such requests, to the extent required under applicable law.
• **Personal Data Portability of Personal Data. **To the extent applicable to you and to the Services and products, you may request the portability of your Personal Data, and we will comply with such requests, to the extent required under applicable law.
• Changes to previous consents. In cases where we process your Personal Data on the basis of your consent, you may withdraw that consent at any time. In cases where we use your Personal Data for legitimate business interest, you can object at any time to processing.
• If you can’t find such actions within our website, application, social media or otherwise then you can contact us at the below contact details.
• You are also entitled to file a complaint with the appropriate supervisory authority in connection with concerns you may have with regards to your privacy and Personal Data.

1. Will OrCam transfer my Personal Data internationally?

Our databases are currently located in the USA. Some of our processing activities are made in Israel. Please note that the European Commission has determined that the State of Israel ensures an adequate level of privacy and data protection, therefore, in accordance with the GDPR, the transfer of Personal Data to Israel is lawful and does not require any specific authorization. Any further transfer of Personal Data outside the EEA to a third country (other than Israel) shall be made in accordance with applicable law, including by providing adequate protections, or otherwise implementing appropriate safeguards to ensure the protection of our users‘ privacy.

1. Persons under 16

Our site, app Services and products are intended for a general audience, and are not directed to persons under 16 years old. If a parent or guardian becomes aware that his or her child has provided us with Personal Data without their consent, he or she should contact us immediately. We do not knowingly collect or solicit Personal Data from people under 16 years old. If we become aware that a person under 16 years old has provided us with Personal Data, we will delete such data from our databases.

1. Applicable Laws

The provisions included in this Notice relating to matters regulated under the GDPR will apply only to the processing of Personal Data which is subject to the GDPR in accordance with the applicability provisions contained therein. If the GDPR does not apply to the processing of your Personal Data, some of the provisions above may not apply to you. We may change this statement from time to time, as will be described in this statement. However, we will not derogate from any rights you have under this statement or applicable law without your prior consent.

1. How can I contact OrCam?

If you have any questions about this Privacy Statement or our data collection practices, please contact us at the following email address:

privacy@orcam.com OrCam Technologies Ltd.