Privacy Policy

This Privacy Policy ("Privacy Policy"), is an integral part of our Terms of Use ("Terms"), and governs the processing and transfer of personal data collected or processed by Valority Technologies Ltd. ("Valority", "Company", "we", "us" or "our") in connection with our Site and our Services.

Any capitalized terms not defined herein shall have the meaning ascribed to them in the Terms.

This Privacy Policy explains what data we may collect from you, how such data may be used or shared with others, how we safeguard it and how you may exercise your rights related to your Personal Data (as defined below), among others, and where applicable, as required according to the EU General Data Protection Regulation ("GDPR") and the California Consumer Privacy Act ("CCPA").

In the event you are a California resident and the CCPA applies to you – please also review our CCPA Privacy Notice.

APPLICABILITY

This Privacy Policy explains Company's data collection practices that are applicable toward: (i) any visitor of our Site ("Visitor"); (ii) any entity which uses the Services and their users (i.e., their employees) ("Customer");

Customers and Visitors will be jointly referred to as "you" or "your".

Website vs. Services Distinction.

This Privacy Policy applies to personal data processed by Valority in connection with the public website and marketing, demo, and informational services.

Personal data processed on behalf of Customers in connection with the use of the Valority software platform is governed by the applicable customer agreement and Data Processing Addendum ("DPA"), under which Valority acts as a data processor.

1. INFORMATION PROCESSED BY THE COMPANY

We may collect two types of data and information from you, depending on your interaction with us. The first type of information is non-identifiable and anonymous information ("Non-Personal Data"). We are not aware of the identity of the individual from which we have collected the Non-Personal Data. Non-Personal Data which is being gathered consists of technical information, and may contain, among other things, the type of operating system and type of browser, type of device, your action in the Site or Services (such as session duration and page impressions), or approximate geo-location.

The second type of information is individually identifiable information, namely information that identifies an individual or may with reasonable effort identify an individual ("Personal Data").

For avoidance of doubt, any Non-Personal Data connected or linked to any Personal Data shall be deemed as Personal Data as long as such connection or linkage exists.

We are considered as the Data Controller of the Personal Data we collect from our Visitors and Customers. It is clarified that is certain cases (i.e. support and maintenance of the Services) with respect to Personal Data collected from Visitors and prospective Customers, Valority acts as a data controller.

With respect to Personal Data processed on behalf of Customers in connection with the Services, Valority acts as a data processor, and processes such data solely in accordance with the Customer's instructions and the applicable Data Processing Addendum.

We do not knowingly collect or process any Special Categories of Personal Data, however our Customer's might upload or provide us with access to such. Special Categories of Personal Data constituting or revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data, data concerning a person's health or data concerning a person's sex life or sexual orientation ("Special Categories of Personal Data" or "Sensitive Data"). Moreover, in connection with Customers' use of the Services, we do not monitor the data uploaded to our Services, therefore it is the Customer's responsibility to ensure that if Sensitive Data is transmitted or uploaded to the Services it is done in compliance with applicable Data Protection Law.

2. AI AND MODEL USAGE

Valority does not use Customer Personal Data or Customer Content processed through the Services to train, fine-tune, or improve general-purpose artificial intelligence or machine learning models, except where explicitly agreed in writing or required to provide the Services (e.g., model evaluation, security, or compliance).

3. HOW WE COLLECT INFORMATION

Depending on the nature of your interaction with the Site and Services, we may collect information as follows:

3.1. Automatically – we may use cookies (as elaborated below) or similar tracking technologies to gather some information automatically when you interact with our Site.

3.2. Provided by you voluntarily – we will collect information if and when you choose to provide us with the information.

Valority limits the collection of Personal Data to what is relevant and necessary for the purposes described in this Privacy Policy and does not process Personal Data in a manner incompatible with those purposes.

4. SHARING PERSONAL DATA

We may share Personal Data only under the following limited circumstances:

• • With trusted partners and third parties who assist us in operating the Services and conducting our business.
• • With our affiliates and connected companies, such as subsidiaries, sister-companies and parent companies.
• • With third parties if necessary, 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, to take precautions against legal liability, or in the event of a corporate sale, merger, reorganization, dissolution or similar event.
• • Other third parties with your consent to do so.

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

Service Providers

Valority uses vetted third-party service providers (such as cloud hosting providers, analytics providers, CRM and marketing platforms) to support its operations. These providers process Personal Data only under Valority's instructions and are subject to contractual confidentiality and data protection obligations.

5. COOKIES & TRACKING TECHNOLOGIES

We use "cookies" (or similar tracking technologies) when you access the Site or interact with the Services we offer. This use is a standard industry-wide practice. A "cookie" is a small piece of information that a website assigns and stores on your computer while you are viewing a website. Cookies can be used for various purposes, including allowing you to navigate between pages efficiently, as well as for statistical purposes.

There are several types of cookies, the three main and common ones are:

• Essential, Functionality, Operation & Security Cookies – essential for enabling user movement around the Site, for the Site to function properly, and for security purposes. Please note that these cookies either cannot be disabled, or if disabled, certain features of the Services may not work.
• Analytic, Measurement & Performance Cookies – used to collect information about how users use the Site (clickstream, navigation, time and date of access, etc.) in order to improve our Services and the way we offer them, as well as assessing performance of the content available in the Site.
• Preference, Targeting & Advertising Cookies – used to advertise across the internet and to display relevant ads tailored to users based on the parts of the Site they have (e.g., the cookie will indicate you have visited a certain webpage and will show you ads relating to that webpage).

Cookies Opt-Out

Please note that, most browsers will allow you to erase cookies from your computer's hard drive, block acceptance of cookies, or receive a warning before a cookie is stored. By following the instructions of your device preferences, and by adjusting the privacy and security settings of your web browser, you may remove cookies, however, if you block or erase cookies some features of the Services may not operate properly and your online experience may be limited.

Where required by applicable law, Valority implements a cookie consent mechanism that allows users to accept, reject, or manage non-essential cookies.

6. USER RIGHTS

Privacy laws in different jurisdictions provide different rights regarding your Personal Data, such as the right to access your Personal Data; the right to delete Personal Data; the right to opt-out from Personal Data processing, and so on.

Principally, if you are a resident of the European Economic Area ("EEA") or California state, the provisions of the GDPR and the CCPA, respectively, provide you with the following rights:

• The right to be informed: in order to ensure fair and transparent processing of Personal Data, you have the right to be provided with information regarding how we collect collection and our privacy practices, as detailed herein.
• The right to access data: you have the right to request a confirmation from us that we process your Personal Data, and under certain circumstances, be provided with a copy of the Personal Data we process.
• The right to request deletion of your Personal Data: you have the right to require us to delete certain Personal Data, if certain conditions are satisfied. Please note, this right is not absolute. We may reject your request under certain circumstances, including where we have to retain the data in order to comply with legal obligations or defend against legal claims, etc.
• The right to object: you have the right to object the processing of Personal Data, in the event the basis for our processing activity is based on our legitimate interests, however, we will be permitted to continue the processing if our legitimate interests override your rights, or when processing is necessary to establish, exercise or defend a legal claim or right, etc.
• The right to restrict processing: you may ask us to restrict the processing your Personal Data, when: the accuracy of the data is contested; processing is unlawful and you request restriction instead of erasure; the Personal Data is no longer needed for the original purpose it was collected, however the retention of data is still required to establish, exercise or defend legal rights; or is there are overriding grounds in the context of an erasure request.
• Rectification (in the event you are an EEA resident): you have the right to require updating or amending Personal Data which is not correct.
• Portability: you have the right to have your Personal Data "port" to a third-party, subject that: the Personal Data was provided by you; the Personal Data is processed automatically; and the Personal Data was processed on the legal bases of contract or consent;
• The Right to Non-Discrimination (in the event you are a California resident): you have the right not to be discriminated against for having exercised your rights under the applicable laws.

You may exercise your data subject rights by contacting us directly at: privacy@valority.ai. We may request reasonable verification of identity before fulfilling your request.

7. CALIFORNIA RESIDENTS

California residents have the right to limit the use of sensitive personal information and the right to opt out of certain data sharing activities, as applicable under the California Privacy Rights Act (CPRA).

8. DATA RETENTION

We retain Personal Data we collect as long as it remains necessary for the purposes set forth above, all in accordance with applicable laws, or until an individual expresses a preference to opt-out. We may at our sole discretion, delete or amend information from our systems, without notice to you, once we deem it is no longer necessary for such purposes.

9. SECURITY

Valority implements appropriate technical, organizational, and administrative measures designed to protect Personal Data against unauthorized access, loss, misuse, alteration, or destruction.

Data is hosted using reputable cloud service providers located in multiple jurisdictions. While Valority takes reasonable steps to protect Personal Data, no security system is impenetrable, and we cannot guarantee absolute security.

10. TRANSFER OF DATA

We use third party's cloud services as detailed above to store our data which are located in the EU and US. Further certain processing activities are conducted in Israel. In the event of data transfer out of your jurisdiction, we will take appropriate measures to ensure that your Personal Data an adequate level of data protection when it is being transferred as required under applicable law.

Where Personal Data is transferred outside the EEA, UK, or Switzerland, Valority relies on approved transfer mechanisms such as Standard Contractual Clauses or other lawful safeguards.

11. CHILDREN

Our Site and Services are intended for the general audience, which is not directed to persons under 16 years old. If a parent or guardian becomes aware that his/her child has provided us with Personal Data without their consent, he/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.

12. CHANGES AND UPDATES

The terms of this Privacy Policy will govern the use of the Site, the Services and any information collected therein. Company reserves the right to change this Privacy Policy at any time, so please re-visit this page frequently. In the event of any substantial change of this policy, we will make reasonable efforts to post a clear notice on the Site. Such substantial changes will take effect seven (7) days after such notice was provided on the Company Services or sent by email. Otherwise, all other changes to this Privacy Policy are effective as of the stated "Last Revised" date and your continued use of the Services after the Last Updated date will constitute acceptance of, and agreement to be bound by, those changes.

13. DATA PROTECTION OFFICER

If you have any requests regarding the data collected under this Privacy Policy, including without limitation, requests to remove, delete, amend, modify or transfer the data, please contact our Data Protection Officer at: privacy@valority.ai. Please include your name, address, email address and applicable DSR form, in any correspondence so that we can respond to your inquiry or request.