Privacy Policy

QT Imaging Holdings, Inc.
Privacy Notice

This Privacy Notice (“Notice”) describes how QT Imaging Holdings, Inc., its global affiliates, and subsidiaries (collectively, “QT Imaging,” “we,” “our,” or “us”) collect, use, disclose, and otherwise process the personal information described in this Notice and the rights and choices individuals have regarding such personal information.

For information about your privacy choices, please review Section 7 Your Privacy Choices.

Your use of our Services (defined below), and any dispute over privacy, is subject to this Notice and our Terms of Use, available at https://www.qtimaging.com/terms-of-use/.

Table of Contents

1. Scope
2. Personal Information Collected
3. Purposes for Collecting and Processing
4. Disclosures of Personal Information
5. Aggregate and De-identified Information
6. Cookies and Tracking
7. Your Privacy Choices
8. Retention
9. Children’s Information
10. Security
11. Third-Party Links
12. Changes to this Privacy Notice
13. Contact Us

1. Scope

Except as otherwise described below, this Notice applies to the personal information QT Imaging collects and processes related to your use of our website, www.qtimaging.com, where this Notice is posted, and other websites that may display or include a link to this Notice (“Site” or “Sites”), other online and offline services, and other products or services we make available to you, (collectively, “Services”).

Not in Scope. This Notice does not apply to the personal information that we collect and process about QT Imaging employees, contractors, personnel, job applicants, or candidates.

This Notice also does not apply to the personal information that we process in our capacity as a service provider to our customers (“Business Customers”). In general, we process information/patient information that we receive in our capacity as a service provider for the purposes for which our Business Customers provided the information and subject to our contract with the particular Business Customer. Please note that we may use information, including personal information, that we have collected and/or processed on behalf of our Business Customers in our capacity as a service provider where we believe it is required or permitted by law or necessary to protect the security of our Services, our rights and interests, and/or the rights and interests of other persons.

In the course of providing Services, we may process personal information that, in accordance with applicable state privacy laws and state consumer health laws, falls under specific exemptions, including protected health information that is subject to Health Insurance Portability and Accountability Act of 1996, as amended, and its implementing regulations (HIPAA). Consequently, certain privacy obligations that may apply to personal information do not pertain to the data processed by us on behalf of our Business Customers.  We note that at this time, we are not a Covered Entity or a Business Associate of a Covered Entity as such words are defined under HIPAA.

2. Personal Information Collected

As further described below, we collect personal information directly from individuals, from third parties, and automatically through your use of our Services.

Personal Information Collected Directly from You. The personal information we may collect from you depends on how you use our Services or otherwise interact or engage with us, but generally includes:

• Contact information. When you contact us, including via email, phone, or webform, we collect certain personal information from you, such as your name, address, phone number, email address, postal address, institution, and any personal information that you otherwise submit to us.
• Survey responses. When our customers, or the patients of our customers, fill out our surveys, we may collect survey responses, including information regarding preferences and opinions about our products and Services. Participation in our surveys is voluntary.
• Transaction Information. If you purchase products from us, we collect payment information, such as wire transfer details, purchase history, and information for purposes of credential authentication.
• Communications and interactions. When you email, call, or otherwise communicate with us, we collect and maintain a record of your contact details, a history of our interactions with you, and information about your use of our products. We also maintain records of communications and information that you may post on our social media channels, and information you provide to us related to any customer support request.
• If you register for or attend an event that we host or sponsor, we may collect personal information related to your registration for and participation in such event. 

Personal Information Collected from Third Parties. We may collect personal information about you from third-party sources, such as public databases, joint marketing/promotional partners, social networking platforms, or other third parties.

• Lead and prospect information. We may receive lead and prospect information, such as names, email addresses and contact information from third parties about individuals who may be interested in engaging with us.
• Social network information. If you post information about us or engage with us on third-party platforms, such as through your social media account, we may collect personal information about you from that third-party platform or account (e.g., your name and/or handle). These third-party platforms and services control the information that they collect and share about you. For information about how they may use and disclose your information, including any information you make public, please consult their respective privacy policies.
• Distributors. Our distributors may provide us with information regarding the use of our products in order for us to provide support and improve our products.

Personal Information Collected Automatically. We and our providers automatically collect and derive personal information related to your use of our Services and your interactions with us. Such information may include:

• Device and browsing information. We use cookies, log files, pixel tags, and other tracking technologies to automatically collect information when users access or use our Services. We may collect device IP address, general location information, domain name, pageviews, browser type, device type, referring and exiting URLs, clickstream data, and similar device and usage information. For more information, please see Section 6 Cookies and Tracking.
• Activities and usage. We also collect activity information related to your use of the Services, such as information about links clicked, searches, features used, items viewed, and time spent within the Services.
• Location Information. We may collect or derive general location information about you such as through your IP address.

3. Purposes for Collecting and Processing

Generally, we collect, use, and otherwise process the personal information that we collect for the following purposes:

• Services and support. To provide our products and to operate our Services, communicate with you about your use of our products and Services, respond to your inquiries, gather feedback, fulfill your requests, communicate with you, run our day-to-day operations, and for similar support purposes.
• Relationship management. To manage our business relationship with you, for example, to process your transactions, manage and maintain your account with us, respond to your questions and comments, and for other similar purposes.
• Analytics and improvement. To better understand how users access and use our Services, products, and offerings, and for other research and analytical purposes, such as to evaluate and improve our Services and business operations, to develop Services, features and new products and offerings, and for internal quality control and training purposes. 
• Customization and personalization. To tailor the content that we may send you, including to offer personalized help and instructions, and to otherwise personalize your experience.
• Marketing, advertising, and public relations. For marketing, advertising, and public relations purposes. For example, to send you information about our products and Services and the products and services of our affiliates, such as newsletters, and other marketing content, as well as any other information that you sign up to receive and to provide you with information about, or samples of, our product range for marketing purposes. We also may use certain personal information that we collect to manage and improve our advertising campaigns (both online and offline) so that we can better reach individuals with relevant content based on your interests and geographic region.
• Planning and managing events. For event planning and management, including registration, attendance, connecting you with other event attendees, and contacting you about relevant events and Services.
• Research, surveys, and product development. To administer surveys, such as for market research, customer satisfaction purposes or improving our products and Services, to conduct statistical and data analytics, and for other similar purposes.
• Security and protection of rights. To protect our Services and our business operations; to prevent and detect fraud, unauthorized activities and access, and other misuse; where we believe necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety or legal rights of any person or third party, or violations of our Terms of Use (https://www.qtimaging.com/terms-of-use/) or other agreements we have with you or this Notice; or to defend our rights, including through legal or other dispute resolution processes. 
• Legal proceedings and obligations. To comply with the law and our legal obligations, to respond to legal process and related legal proceedings, and government or law enforcement requests. 
• General business and operational support. To consider and implement mergers, acquisitions, reorganizations, bankruptcies, and other transactions such as financings, and related to the administration of our general business, accounting, auditing, compliance, recordkeeping, and legal functions. 

4. Disclosures of Personal Information

Generally, we disclose the personal information that we collect to provide our Services, respond to and fulfil your transactions or requests, as otherwise directed or consented to by you, and as follows:

• Global affiliates and subsidiaries. We may disclose the personal information we collect to our global affiliates and subsidiaries who will use and disclose this personal information in accordance with the principles of this Notice.
• Vendors and service providers. We may disclose the personal information that we collect to our service providers and others who perform functions on our behalf or provide us services. These may include, for example, service providers that host or operate our Site, payment processors, information technology service providers, customer service vendors, consultants, auditors, and legal counsel. These companies and individuals may only use the data as permitted by our contracts with them.
• We may disclose personal information to industry professionals, such as doctors and statisticians for purposes of regulatory approval, product improvement, and product development.
• Advertising and analytics platforms, providers, and networks. We may disclose or make available personal information to the platform providers and vendors that we use to provide or make available certain features or portions of the Services, or as necessary to respond to your requests. We may also make certain information (such as browsing information) available to advertising platforms, providers and networks in support of our marketing, advertising, and campaign management.
• Distributors. We may disclose personal information to our distributors for purposes of providing support and to improve our Services.
• General operations. If we or our affiliates are or may be acquired by, merged with, or invested in by another company, or if any of our assets are or may be transferred to another company, whether as part of a bankruptcy or insolvency proceeding or otherwise, we may transfer the information we have collected about you to the other company. We may also share certain personal information as necessary prior to the completion of such a transaction or corporate transactions such as financings or restructurings, to lenders, auditors and other advisors, including attorneys and consultants, as part of due diligence or as necessary to plan for a transaction.
• Others as permitted or required by applicable law. We may disclose personal information to other parties to the extent permitted or required by applicable law. This may include regulators, government entities, and law enforcement. 
• Security and protection of rights. We may disclose your personal information when we believe it is appropriate to do so to investigate, prevent, or take action regarding actual or suspected illegal activities, fraud, situations involving potential threats to the safety of any person, violations of our Terms of Use (https://www.qtimaging.com/terms-of-use/) or this Notice, or as evidence in litigation in which we are involved.
• With permission. We may disclose personal information in ways not described above. If we do so, we will notify you, and if necessary, obtain your consent.

5. Aggregate and De-Identified Information

We may use and disclose aggregate and other de-identifiable data related to our business and the Services for quality control, analytics, research, development, and other purposes. Where we use, disclose, or otherwise process de-identified data (data that is no longer reasonably linked or linkable to an identified or identifiable natural person, household, or personal or household device) we will maintain and use the information in deidentified form and not to attempt to reidentify the information, except (1) in order to determine whether our deidentification processes are reasonable and adequate pursuant to applicable privacy laws; or (2) where required by law.

6. Cookies and Tracking

We and our providers use cookies, pixel tags, and other similar tracking technologies to automatically collect information about browsing activity, device type, and similar information within our Site and Services. This information, which may be considered personal information in some jurisdictions, is used, for example, to analyze and understand how you access, use, and interact with our Site and Services; to identify and resolve bugs and errors in our Site and Services; to assess, secure, protect, optimize, and improve the performance of our Site and Services; to personalize content on our Site; and for marketing, advertising, measurement and analytics purposes. We may also de-identify and/or aggregate such information to analyze trends, administer our Site and Services, and gather broad demographic information for aggregate uses, and for any other lawful purposes.

Cookies. Cookies are alphanumeric identifiers used for tracking purposes. Some cookies allow us to make it easier for you to navigate our Site and Services, while others are used to enable a faster log-in process, to support the security and performance of the Site and Services, or to allow us to track activity and usage data within and across our Site and Services.

Pixel Tags and Similar Technologies. Pixel tags (sometime called web beacons or clear GIFs) are tiny graphics with a unique identifier, similar in function to cookies. We may use these tracking technologies to understand users’ activities, to help manage content and compile usage statistics, and in emails to let us know when they have been opened or forwarded so we can track response rates and gauge the effectiveness of our communications.

Local Storage Objects. Local storage is a web storage mechanism that allows us to store data on a browser that persists even after the browser window is closed. Local storage may be used by our web servers to cache certain information in order to enable faster loading of pages and content when you return to our Sites. You can clear data stored in local storage through your browser. Please consult your browser “Help” menu for more information.

Analytics. We use analytics tools, such as Google Analytics, to evaluate usage and traffic on our Site and Services. These analytics providers use cookies, pixels, and other tracking technologies to collect usage data to provide us with reports and metrics that help us analyze, improve, and enhance performance and user experience. You can learn more about Google Analytics at www.google.com/policies/privacy/partners/, and you can prevent certain uses of Google Analytics relating to your use of the Site by downloading the tool at https://tools.google.com/dlpage/gaoptout. You must opt out on each browser and on each device.

Cross-Device Tracking. We and ad networks we work with may use the information we collect about you within our Site and Services, and on other third-party websites and services, to help us and these third parties identify other devices that you use (e.g., a mobile phone, tablet, other computer, etc.) to interact or engage with us or our Site and Services.

Advertising Networks. We work with ad networks, channel partners, mobile ad networks, analytics and measurement services, and others (“ad networks”) to personalize content, as well as to manage our advertising on third-party websites, mobile apps, and online services. We may share certain information with ad networks, and we may each use cookies, pixels tags, and other tools to collect usage and browsing information within our Services, as well as on third-party websites, apps, and services. This information may include IP address, location information, cookie and advertising IDs, and other identifiers, as well as browsing information.

Do-Not-Track. Currently, our Services do not recognize web browser “Do-Not-Track” requests. You may, however, disable certain tracking as discussed below (e.g., by disabling cookies).

7. Your Privacy Choices

You have certain choices regarding our processing of your personal information, and we make available several ways for you to manage your preferences and privacy choices, as described below:

Marketing Communications. We may send periodic promotional and operational emails or other similar communications to you. You may change your preferences or unsubscribe by following the instructions provided to you in the communication. If you opt out of receiving promotional emails from us, we may still send you communications that you have requested to receive from us.

Correction. You may contact us to correct or update any personal information you have provided us if you believe that we maintain inaccurate information about you. We will endeavor to fulfil your request; however, we may not be able to do so in all circumstances.

Deletion. If you decide that you do not want your personal information used for the purposes described in this Notice, you may contact us at our mailing address below to request removal of your personal information from our database. We will endeavor to fulfil your request; however, we may not be able to do so in all circumstances.

Cookie Settings. You can set your browser to block certain cookies or notify you when a cookie is set; you can also delete cookies. The “Help” portion of the toolbar on most browsers will tell you how to prevent your device from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to delete cookies. Visitors to our Site who disable cookies will be able to browse the Site, but some features may not function. If you visit our Site from a different device or from a different browser on the same device, you will need to apply your cookie settings for that browser and/or device as well.

Industry Ad Choice Programs. You can control how participating ad networks use the information that they collect about your visits to our Site and Services and those of third parties, in order to display more relevant targeted advertising to you. You can obtain more information and opt out of receiving targeted ads from participating ad networks at aboutads.info/choices (Digital Advertising Alliance) and optout.networkadvertising.org (Network Advertising Initiative).

8. Retention

We retain your personal information for as long as reasonably necessary to fulfill the purposes for which it was collected or as otherwise necessary to comply with our legal obligations, resolve disputes, maintain appropriate business records, and enforce our agreements.

9. Children’s Information

Our Services are not designed for children. If we discover that a child has provided us with personal information, we will delete such information from our systems. If you are a parent or guardian and believe we have collected your child’s information in violation of applicable law, please contact us as set forth in Section 14 Contact Us.

10. Security

We have implemented safeguards that are intended to protect the personal information we collect from loss, misuse, unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our efforts, no data security measures can guarantee security.

11. Third-Party Links

Our Site and Services may contain links to third-party websites. Any access to and use of such linked websites is not governed by this Notice, but instead is governed by the privacy notices of those third-party websites. We are not responsible for the information practices of such third-party websites.

12. California Shine the Light Rights.California’s “Shine the Light” law (Cal. Civ. Code § 1798.83) permits California residents who provide us certain personal information to request and obtain from us, free of charge, information about the personal information (if any) we have shared with third parties for their own direct marketing purposes. To make a California Shine the Light request, please email us at Stas.Budagov@qtimaging.com. Requests may be made once per year.

13. Changes to this Privacy Notice

We may make changes to this Notice from time to time, so please be sure to check back periodically. We will post updates to the Notice on the Site. If we make any material changes to this Notice, we will endeavor to provide you prior notice, such as by emailing or posting prominent notice on our Site.

14. Contact Us

QT Imaging welcomes your questions and comments about your privacy or this Notice. Please contact us at https://www.qtimaging.com/contact/.