Privacy Policy

Last updated March 2021

This “Privacy Policy” of the company of the NANOTRONICS IMAGING, INC. (herein referred to as “NANOTRONICS” “we” “us” or “our”) outlines how your personally identifiable information (your “Visitor Information”) may be collected, used, and shared in connection with your access to and/or visitation or use of our site: https://nanotronics.co/ (the “Site”), as well as what information we may collect through any third-party application or third-party sites, social networks, or social media sites (such as Facebook, Instagram, Twitter, Google, etc., collectively “Applications”). Moreover, this Privacy Policy applies to all Visitor Information collected through any related services, sales, marketing or events. This Privacy Policy also describes your choices and rights regarding the use, access, and correction or deletion of your Visitor Information. By visiting our Site, you consent to the use of your Visitor Information in accordance with this Privacy Policy. You may also be asked to provide clear and unequivocal affirmative consent to the collection, processing, and sharing of your Visitor Information via opt-in procedures. This Site is owned and operated by NANOTRONICS, and this Privacy Policy only applies to Visitor Information obtained by NANOTRONICS in connection with or related to your use of the Site. Please read this Privacy Policy carefully to understand our policies and practices regarding your personal information and how we will treat it. By accessing or using this Site you agree to this Privacy Policy. This Privacy Policy may change from time to time and your continued use of this Site means that you are consenting to be bound by the most recently updated version of this Privacy Policy.

General Information We Collect and How We Use It

We collect Visitor Information when you use our Site. Sometimes you may submit it to us yourself. Other times it may be collected automatically.

Information Collected When You Use Our Site

Your Visitor Information may be collected, used, and shared. As detailed below, the type of Visitor Information collected may vary based on how it was gathered, but may include, among other things, your name, email address, and other information that you voluntarily submit (e.g., when you request to receive our e-newsletter subscription), information automatically collected about your usage of our Site that does not include personally identifiable information (e.g., the content that you choose to view and how you interact), and information about you that third parties may share with us if such third parties have previously received your consent to do so.

Moreover, some information, such as your Internet Protocol (IP) address and/or browser and device characteristics, is collected automatically when you visit our Site. We automatically collect certain information when you visit, use or navigate the Site. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our and other technical information. This information is primarily needed to maintain the security and operation of our Site, and for our internal analytics and reporting purposes.

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Policy.

NANOTRONICS does not collect or process any data regarding race or ethnic origin; political opinions; religious or philosophical beliefs; trade union memberships; genetic or biometric data; health or mortality; sexual orientation.

Voluntary Submission

NANOTRONICS may collect Visitor Information that is voluntarily provided by you or with your permission. For example, we may ask you for information, such as your name and e-mail address, when you register to receive our enewsletter, when you participate in activities on the Site, or otherwise when you contact us. All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Third-Party Websites

The Site may contain links to websites not owned or controlled by NANOTRONICS. We do not have any control over these third-party websites and do not endorse them. We encourage you to be aware of third-party websites and their privacy policies, as we are not responsible for privacy policies or practices of third-party websites.

Web Beacons

NANOTRONICS may contain electronic images known as web beacons (invisible images often referred to as pixel tags or clear GIFs) on the Site in order to recognize users, assess traffic patterns, identify preferred content, and measure Site engagement. We may also include web beacons in our e-mail messages, including e-newsletters, in order to count how many e-mail messages have been opened, for example.

Log Files

NANOTRONICS’s servers log information about your IP address, your browser type, and the current URL you are requesting. This information is always provided by your browser and automatically logged. These log files are stored in a secure location and used in our internal analysis of traffic patterns.

Cookies and Similar Tools

Like many businesses, we also collect information through cookies and similar technologies. A cookie is a small data file that is written to a computer’s hard drive by a web browser. A cookie file can automatically collect information, such as a user identification code or IP address that a website will use to track the pages and number of times you have visited. The data read from these cookies may be linked to personally identifying (PII) and non-personally identifying (non-PII) information.

We and our partners may use cookies and similar technologies on the Site to personalize and optimize your browsing experience by: providing you tailored content, enabling social media features, safeguarding against spam and malware, analyzing trends, traffic, and user behavior, administering the website, gathering demographic information about our user base as a whole, tracking web and advertising analytics throughout the Site, remembering preferences and voluntarily-submitted information (e.g. name, email), performing location-related functionalities and analytics, participating in market research (e.g., website ratings), and educating NANOTRONICS about how the Site can continue to be improved.

Cookies fall into the subcategories below.

Essential Cookies. Certain cookies are used for specific purposes that are essential to your secure use and navigation of the Site. Without them, NANOTRONICS may not be able to provide core Site functions and features to you, and the Site would not operate as well as you or NANOTRONICS would like. These cookies collect and use information such as your server preferences, single-session data and corresponding identifier, web beacons and log files, and other credential-related information. Essential cookies also help inform NANOTRONICS whether you require, or have already been served, an affirmative consent request in connection with our data policies. Essential cookies also include analytics cookies, which provide us data that allows NANOTRONICS to better understand its users and improve the Site based on what we have learned from that data.

Preference Cookies. Other cookies are used to collect and process information about your preferences and similar choices in connection with the Site in order to optimize your browsing experience. Preference cookies include social media cookies, which collect information about your social media usage and other data you may have provided in connection with such usage (if you access the Site through a social media website or mobile application, you may have social media cookies). If you wish to modify or change your social media cookies, please visit the appropriate social media website and review the settings related to your applicable social media account(s).

Advertising Cookies. To help support the Site and further tailor your experience, NANOTRONICS and certain of their third party providers may also use cookies on the Site to personalize the content you may be shown. Some advertisements may use advertising cookies to provide targeted advertisements that may be more consistent with your interests than non-targeted advertisements. NANOTRONICS does not provide user information to third parties except in connection with the Site or as required by law.

Analytics

Services providing analytic tools (“Analytic Services”), including without limitation Google Analytics® are being used with the Site which transmits website traffic data to servers in the United States. Analytic Services do not collect personal information, identify individual users, or associate your IP address with any other data. We do not share any personally identifiable information with our Analytic Services in connection with their performing of any services on our Site. We use reports provided by Analytic Services to help us understand website traffic and webpage usage.

How Long We Keep Your Information

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). No purpose in this policy will require us keeping your personal information for longer than reasonably necessary.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

Use of Your Information

Your Visitor Information may be used for the purposes outlined below.

To Provide Communications to You

From time to time we may provide e-mails highlighting new features, promotions, or content on the Site to those users who have expressly provided us with their permission to send such communications.

Sharing of Information

You may be requested to voluntarily provide certain Visitor Information during your use of our Site. If you choose to do so, that Visitor Information may be shared with NANOTRONICS and its affiliates as well as business partners and vendors providing hosting and other web-based services for NANOTRONICS.

NANOTRONICS uses third parties to provide e-mail messaging, text messaging, account management and hosting services for the Site. When you sign up for services, we will share your Visitor Information as necessary for the third party to provide that service. These third parties are prohibited from using your Visitor Information for any other purpose. If you do not want your information to be shared, you can choose not to allow the transfer of your information by not using that particular service.

As Necessary to Provide Information or Services

We may occasionally hire other companies to provide limited services on our behalf, such as handling the processing and delivery of e-newsletter mailings, processing transactions, or performing statistical analysis of our services. We provide those companies the information they need to deliver the service. In some instances, these companies may collect information directly from you and you will be notified of the involvement of the external service provider. Such companies are subject to agreements that require them to maintain the confidentiality of your information and they are prohibited from using that information for any other purpose.

In the Event of Change in Ownership or Control

The ownership or control of NANOTRONICS may change at some point in the future. Should that occur, we want NANOTRONICS to be able to maintain a relationship with you. In the event of a change in ownership, merger, bankruptcy or control of NANOTRONICS, your information may be shared with the person or business that owns or controls this Site. You will be notified as described below in “Changes to Privacy Policy.”

As Required By Law

NANOTRONICS may disclose your personal information if required to do so by law, such as to comply with a subpoena or in the good faith belief that such action is necessary to conform to the edicts of the law, investigate fraud or comply with a judicial proceeding, court order, or legal process served on NANOTRONICS, or to protect and defend the rights or property of NANOTRONICS.

NANOTRONICS will not process your Visitor Information without a lawful basis to do so. In general, NANOTRONICS will process your Visitor Information on any of the following legal bases:

Consent: We may process your data if you have given us specific consent to use your personal information for a specific purpose.
Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.
Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract.
Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.

More specifically, we may need to process your data or share your personal information in the following situations:

Business Transfers: We may share or transfer your 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.

How We Protect Your Information

Your information may be stored on servers owned and operated by NANOTRONICS and its affiliates or by cloud/software service providers (“SaaS Services”) and located in the United States. Our SaaS Services are committed to using industry standard physical, electronic, and organizational safeguards to protect information against loss or theft as well as unauthorized access and disclosure to protect individuals’ privacy and to employing security techniques to protect such data from unauthorized access.

However, it must be noted that “perfect security” does not exist today. If you are concerned that your privacy may have been breached, please contact us.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Site, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on our Site.

Additional Privacy Considerations

See below for additional privacy considerations.

Third Party Policies

You should review the privacy policies of any third parties before you provide any personal information or complete any transaction with such parties. Please contact each third-party provider directly if you have any questions about their privacy policies or the information they require for you to complete any transaction.

Residents of California

NANOTRONICS collects certain, limited personal information from you in connection with your use of the Site. This information includes (i) your name and e-mail address, but only if you voluntarily provide this information in connection with a request to receive NANOTRONICS’s e-newsletter; (ii) information related to Web-Beacons; (iii) information related to Log Files; and, (iv) information related to Analytic Services. This information is used by NANOTRONICS for the purposes set forth in this Privacy Policy.

NANOTRONICS does not sell any personal information it collects about you to third parties. NANOTRONICS shares information related to Log Files, Web Beacons, and Analytic Services with third parties in connection with maintaining and improving the Site.

If you are a resident of California, under the California Consumer Privacy Act (“CCPA”), you have the right to:

Request NANOTRONICS disclose the categories and specific information that it has collected about you;
Request NANOTRONICS delete any personal information about you that it has collected;
Request NANOTRONICS not share your personal information at any time (the “right to opt-out”);
Request NANOTRONICS correct any inaccurate personal information it maintains about you; and
Request NANOTRONICS restrict its use and disclosure or your sensitive personal information.

If you would like to exercise your rights under the CCPA, you may contact NANOTRONICS as outlined below in accordance with the “Contacting Data Controller” section of this Privacy Policy. NANOTRONICS may not discriminate against you if you exercise any of your rights under the CCPA.

We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please contact our Privacy Officer as outlined below.

We endeavor to substantively respond to verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

The response we provide will explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Only you, or someone legally authorized to act on your behalf, may make a request related to your personal information. You may also make a request on behalf of your child. You may only submit a request to know twice within a 12-month period. Your request must:

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative of such person; and

Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. We will only use personal information provided in the request to verify the requestor’s identity or authority to make it.

California Shine The Light Law

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided in the “Contacting Data Controller” section below.

General Data Protection Regulation

NANOTRONICS does not actively target or market to any EU member state. However, NANOTRONICS does engage with some customer companies who have or maintain a presence in the EU or who have customers and data subjects in the EU, any of which may be covered under GDPR. In such instances, NANOTRONICS may process or control an EU citizen’s user information under a valid legal basis such as a contract to provide such services or with the consent of the EU citizen. This Privacy Policy and its enumerated provisions are intended to comply with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (the “General Data Protection Regulation” or “GDPR”) and provide appropriate protection and care with respect to the treatment of all of our users’ information in accordance with GDPR.

If you are a resident of the EU, you have specific rights including the right to know what user information NANOTRONICS collects or processes about you, a way to amend incorrect user information NANOTRONICS may have on its records, or make a request to delete user information. In some instances, NANOTRONICS may require explicit consent from you to process certain user information. In such instances, you will receive a direct request from NANOTRONICS for your permission to collect and/or process your user information and you will be required to provide affirmative consent. In any event, NANOTRONICS will clearly explain what user information is being collected and/or processed and how it will be used. NANOTRONICS only collects a minimum amount of user information necessary to perform its services. Explicit consent may always be retracted at any time by data subject covered under GDPR.

If you are a resident of the EU, and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: https://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.

If you are a resident in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html.

If you would like to make any requests under this regulation, you may contact us in accordance with the “Contacting Data Controller” section of this Privacy Policy.

Children’s Online Privacy Information

CHILDREN ONLINE PRIVACY PROTECTION ACT (“COPPA”) NOTIFICATION

Our Site is not designed for persons under the age of 18. We are not responsible for any access or use of the Site by children or minors under the age of 18. No one under age 18 may provide any personal information to or on our Site. We do not knowingly collect personal information from children under 18. If you are under 18, do not use or provide any information on our Site or through any of their features, register on our Site, make any purchases through our Site, use any of the interactive or public comment features of our Site, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us as outlined below in accordance with the “Contacting Data Controller” section of this Privacy Policy.

We do not knowingly solicit data from or market to children under 18 years of age. By using the Site, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of this Site. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us.

Changes to Privacy Policy

We may update this privacy notice from time to time. The updated version will be indicated by a revised “Updated” date and the updated version will be effective as soon as it is accessible. If we make any material changes to this Privacy Policy we will notify you by means of a notice on this Site prior to the change becoming effective. We reserve the right to amend this Privacy Policy at our discretion and at any time. We encourage you to periodically review this page for the latest information on our privacy practices and to review our most current Privacy Policy. Your continued use of our Site following the posting of changes constitutes your acceptance of such changes.

Contacting Data Controller

To request to review, update, delete, or otherwise control your personal information, or if you have any additional questions regarding this Privacy Policy or how to remove or modify your Visitor Information or related consents, please feel free to contact us by the e-mail or the mailing address below:

NANOTRONICS IMAGING, INC.
New Lab – Building 128
63 Flushing Ave, Unit 241
Brooklyn, NY 11205

Attention: PRIVACY OFFICER

By Email: privacy@nanotronics.co

[1287189]