INTERAI PRIVACY POLICY ("PRIVACY POLICY")

Last date updated: Nov 7th 2020

IMPORTANT:BY USING INTERAI LTD.'S ("COMPANY" OR "WE") SOFTWARESOLUTION AND SERVICES GENERALLY KNOWN AS WORKAPP AND MANAGEMENT CONSOLE  (COLLECTIVELY, THE "SERVICES")YOU ("YOU") CONSENT TO THE TERMS AND CONDITIONS OF THISPRIVACY POLICY AND CONSENT THAT ALL PII (DEFINED BELOW) THAT YOU SUBMIT OR THATIS PROCESSED OR COLLECTED THROUGH OR IN CONNECTION WITH YOUR USE OF THE SERVICESWILL BE PROCESSED BY THE COMPANY AND ITS AFFILIATES IN THE MANNER AND FOR THEPURPOSES DESCRIBED IN THE FOLLOWING PRIVACY POLICY.

Companyis a controller of the PII it processes in relation to its customers, vendors,service providers or partners. When Company processes PII on behalf of its customers,Company is a data processor under the GDPR, to the extent applicable. In thatcase, Company’s customer will be a data controller under the GDPR, and will beresponsible to obtain the data subject’s consent or establish any otherapplicable lawful basis for processing and to ensure that data subjects canexercise their rights set forth in Section 8 below.

YOU ARENOT LEGALLY REQUIRED TO PROVIDE US WITH PII, HOWEVER, USE OF THE SERVICES REQUIRESTHAT YOU PROVIDE PII. IF YOU CHOOSE TO WITHHOLD ANY PII REQUIRED IN RESPECTTHEREOF, IT WILL NOT BE POSSIBLE FOR YOU TO USE THE SERVICES. IF YOU DO NOTAGREE TO THE TERMS AND CONDITIONS SET FORTH HEREIN PLEASE DO NOT USE THE SERVICES.

PII” means any information relating toan identified or identifiable natural person; an identifiable natural person isone who can be identified, directly or indirectly, in particular by referenceto an identifier such as a name, an identification number, location data, anonline identifier or to one or more factors specific to the physical,physiological, genetic, mental, economic, cultural or social identity of thatnatural person.

We recognize that privacy is important. This PrivacyPolicy applies to all of the services, information, tools, features andfunctionality available on the Services offered by the Company or itssubsidiaries or affiliated companies and covers how PII that the Companycollects and receives, including in respect of any use of the Services, istreated. If you have any questions about this Privacy Policy, please feel freeto contact us at: privacy@interai.co  

1. Information We Collectand How We Use It

Summary: We collect personaldata about our customers and their representatives and visitors of ourServices. We also collect personal data included in publicly available sources.We use PII to provide andimprove our Services, and to meet our contractual, ethical and legalobligations.

In order to provide and operate our Servicesand provide services in connection therewith, we collect and process PII,including the following types of information:

1.1. Your Contact Information. When you subscribe to use the Services we askyou to provide PII, including: Full name, email address and phone number.

1.2. Third Parties. We sometimes supplement thePII with information that is received from third parties.

1.3. Usage Information. When you use the Services,we automatically receive and record information from your browser, includingwithout limitation information and statistics about your online/offline status,your  IP address, geolocation data(including country and city), browser identifiers, internet service provider,connection speed, search history, type of browser, your regional and languagesettings and software and hardware attributes. Our systems automaticallyrecord and store technical information regarding the method and nature of youruse of the Services. An IP address is a numeric code that identifies yourbrowser on a network, or in this case, the Internet. Your IP address is alsoused to gather broad demographic information. The Companyuses all of thePII identified in this Section in order to understand the usage trends andpreferences of our users, including recent visits to our Services and how youmove around different sections of our Services for analytics purposes and inorder to make our Services more intuitive.

1.4. Screenshots. When you provide Companywith access to screenshots, Company will process any PII contained therein.

1.5. User Communications. When you send emails or other communications tothe Company, we retain those communications in order to process your inquiries,respond to your requests and improve our Services. We will send you newslettersand promotional communications, you may opt-out of the list at any time by clickingthe “unsubscribe button” in the promotional communication.

1.6. Aggregate and AnalyticalData. In order to improve ourservices and develop and improve our Services, we often conduct research on theuse of our Services. This research is compiled and analyzed on an aggregatebasis, and we share this aggregate data with Company’s affiliates, agents andbusiness partners and also disclose aggregated information in order to describeour services to current and prospective business partners or investors. Thisaggregate information does not identify you or your customers personally.

2. Cookies

Summary: We use cookies,pixels and similar technologies on our Services. You can disable cookies butthen your online experience on our Services will be limited.

 In order to collect the data described hereinwe use temporary cookies that remain on your browser for a limited period oftime. We also use persistent cookies that remain on your browser until theCompany's Services are removed, in order to manage and maintain the Servicesand record your use of the Services. Cookies by themselves cannot be used todiscover the identity of the user. A cookie is a small piece of informationwhich is sent to and stored on your browser. Cookies do not damage yourbrowser. Most browsers allow you to block cookies butyou may not be able to use some features on the Services if youblock them. You may set most browsers to notify you if you receive a cookie (this enables you to decide if you want toaccept it or not). We also use web beacons via the Services tocollect information. Web beacons or "gifs", are electronic imagesthat are used in our Services or in our emails. We use Web beacons to delivercookies, count visits and to tell if an email has been opened and acted upon. Weuse third party cookies such as Google Analytics under the following Terms of Use.

3. Links

Links to other services,sites and applications are provided by the Company as a convenience to ourusers. The Company is not responsible for the privacy practices or the contentof other sites and applications and you visit them at your own risk. This PrivacyPolicy applies solely to PII collected by us.

4. Minors

If any of your data subjects are minors underthe age of 18, you must obtain parental consent prior to using our Services. TheCompany will not knowingly contact or engage with children under the age of 18without said parental consent. If you have reason to believe that a childhas provided us with their PII, please contact us at the address given aboveand we will endeavor to delete that PII from our databases.

5. Information Sharing

Summary: Wetransfer your PII to third parties who assist us in providing the Services. Wehave a contract with those third parties to govern their processing on ourbehalf. Wemay also transfer PII to comply with any obligations by which we arebound or to an investor or in connection with a merger or acquisition orsimilar transaction.

As part of providing the Services ouraffiliates, agents, representatives and service providers will have access toyour PII. We require these parties to process such information in compliancewith this Privacy Policy and subject to security and other appropriateconfidentiality safeguards.  The Company willalso share PII in the following circumstances: (a) as required for providingthe Services; (b) for maintenance and improvement of the Services; (c) if webecome involved in a reorganization, merger, consolidation, acquisition, or anyform of sale of some or all of our assets, with any type of entity, whetherpublic, private, foreign or local; and/or (d) to satisfy applicable law orprevention of fraud or harm or to enforce applicable agreements and/or theirterms, including investigation of potential violations thereof.

6. Data Security

acceptable means to protect your PII, we cannot guarantee its absolute security. We retain your PII only for as long as reasonably necessary for the purposes for which it was collected or to comply with any applicable legal or ethical reporting or document retention requirements.

7. Data Retention

Summary: We retain PII onlyfor as long as necessary to meet our legal and ethical obligations, which fordifferent types of PII will be different periods.

7.1. Company will retain PIIin accordance with its record retention policy. PII associated with our customers,will be retained for the duration of our engagement, and a period of sevenyears thereafter. Company performs periodic reviews of our databases, and haveestablished specific time limits for data retention, based on the criticalityof the PII and the purposes of the data processing.We will also retain PIIto meet any audit, compliance and business best-practices.

7.2. PII with respect to which Company is the processorwill be deleted only on instruction of the controller, except where such datamust be retained by us, in our judgment, as above.

The Company processes PII only for the purposes for which it was collected or used and in accordance with this Privacy Policy or any applicable service agreements. We review our data collection, usage, storage and processing practices to ensure that we only collect, use, store and process the PII needed to provide or improve our Services. We take reasonable steps to ensure that the PII we process is accurate, complete, and current, but we depend on our users to update or correct their PII whenever necessary. Nothing in this Privacy Policy is interpreted as an obligation to store information, and we may, at our own discretion, delete or avoid from recording and storing any and all information.

8. Data Integrity.

The Company processesPII only for the purposes for which it was collected and in accordance withthis Privacy Policy or any applicable service agreements. We review our datacollection, storage and processing practices to ensure that we only collect,store and process the PII needed to provide or improve our Services. We takereasonable steps to ensure that the PII we process is accurate, complete, andcurrent, but we depend on our users to update or correct their PII whenever necessary.Nothing in this Privacy Policy is interpreted as an obligation to storeinformation, and we may, at our own discretion, delete or avoid from recordingand storing any and all information.

9. Rights of Data Subjects.

9.1. Right of Access and Rectification. Data subjects have the right to know what PIIwe collect about them and to ensure that such data is accurate and relevant forthe purposes for which we collected it. We allow data subjects the option toaccess and obtain a copy of their PII and to rectify such PII if it is notaccurate, complete or updated. However we may first ask data subjects toprovide us certain credentials to permit us to identify their PII.

9.2. Right to Delete PII orRestrict Processing. Data subjects have theright to delete their PII or restrict its processing. We may postpone or deny suchrequests if the PII is in current use for the purposes for which it wascollected or for other legitimate purposes such as compliance with legalobligations.

9.3. Right to WithdrawConsent. Data subjects have the right to withdraw theirconsent to the processing of their PII. Exercising this right will not affectthe lawfulness of processing the PII based on consent obtained before itswithdrawal.

9.4. Right of Data Portability. Where technicallyfeasible, data subjects have the right to ask to transfer their PII inaccordance with their right to data portability, if required pursuant toapplicable law.
Data subjects may exercise the above rights bysending a request to privacy@interai.co.

9.5. Right to Lodge Complaint. Data subjects also havethe right to lodge a complaint with a data protection supervisory authorityregarding the processing of their PII.

10. Enforcement

The Company regularlyreviews its compliance with this Privacy Policy. Please feel free to direct anyquestions or concerns regarding this Privacy Policy or our treatment of PII bycontacting us as provided above. When we receive formal written complaints itis the Company's policy to contact the complaining user regarding his or herconcerns. We will cooperate with the appropriate regulatory authorities, includinglocal data protection authorities, to resolve any complaints regarding thetransfer of PII that cannot be resolved between the Company and an individual.

11. Changes to This PrivacyPolicy

The Companymayupdate this Privacy Policy. We will notify you about significant changes in theway we treat PII by sending a notice to the email address provided by you or byplacing a prominent notice on the Services. We encourage you to periodicallyreview this Privacy Policy for the latest information about our privacypractices. Our customers and business partners will be notified of such changesand are responsible to inform their data subjects.

12. Legal Justification and ConsentTo Processing

12.1. By providing any PII to us pursuant to this PrivacyPolicy, all users, including, without limitation, users in the United States,Israel and member states of the European Union, fully understand andunambiguously consent to this Privacy Policy and to the collection andprocessing of such PII abroad. The server on which the Services are hostedand/or through which the Services are processed may be outside the country fromwhich you access the Services and may be outside your country of residence.Some of the uses and disclosures mentioned in this Privacy Policy involve thetransfer of your PII to various countries around the world that may havedifferent levels of privacy protection than your country and will betransferred outside of the European Economic Area. If there is a transfer ofyour PII outside the EEA we will, in the absence of an EC Adequacy decisionrelevant to the destination country or to the transfer, seek to rely onappropriate safeguards such as entering into appropriate EC approved standardcontractual clauses (see http://ec.europa.eu/justice/data-protection/international-transfers/transfer/index_en.htm). By submitting your PII through the Services,you consent, acknowledge, and agree that we will collect, use, transfer, anddisclose your PII as described in this Privacy Policy.

12.2. When Company processes PII on behalf of itscustomers, Company is a data processor. In that case, Company’s customer will bea data controller, and will be responsible to obtain the data subject’s consentor establish any other applicable lawful basis for processing and we rely onour contractual relationship with the controller (i.e. our customer).

13. Questions.

If you have anyquestions about this Privacy Policy or concerns about the way we process yourPII, please contact us atprivacy@interai.co. If you wish to delete all information regardingyour use of the Services, please contact us at: privacy@interai.co.

Last Date Updated: February 25, 2021