PRIVACY POLICY

In order to ensure transparency and give you more control over your personal information, this privacy policy (“Privacy Policy”) governs how we, dave.io LTD (“dave.io”, “we”, “our” or “us”) use, collect and store personal information that we collect or receive from or about you (“you”) in connection with www.dave.io (the “Website”) and the services provided (the “Services”).

We greatly respect your privacy, which is why we make every effort to provide a platform that would live up to the highest user privacy standards. Please read this Privacy Policy carefully, so you can fully understand our practices in relation to personal information. With respect to Israeli privacy law, you are not legally required to provide us with personal information, and the provision of your personal information is voluntary and is provided based on your free will and consent. However, please note that if you choose not to provide certain information, we may not be able to provide you with the full range of the Website or Services or respond effectively to your requests.

Important note: Nothing in this Privacy Policy is intended to limit in any way your statutory rights, including your rights to a remedy or other means of enforcement.

Table of contents:

What personal information we collect, why we collect it, and how it is used How we protect and retain your personal information How we share your personal information Your privacy rights
International transfers of personal information Use by children Interaction with third party products Analytic tools/ Cookies Contact us

This Privacy Policy can be updated from time to time and, therefore, we ask you to check back periodically for the latest version of this Privacy Policy. If we implement material changes in the way we use your personal information, in a manner that is different from that stated at the time of collection, we will notify you by posting a notice on our Website or by other means and take any additional steps as required by applicable law.

WHAT PERSONAL INFORMATION WE COLLECT, WHY WE COLLECT IT, AND HOW IT IS USED

(i) We Process the Following Personal Information:

a. Personal information provided through the Services. We collect personal information that you voluntarily provide, including your full name, email address, password, as well as any other personal information that you decide to provide us. We also collect the contact and billing information of our customers.

b. Personal information provided through the Website. When you use the Website, we collect and process full name, email address, when you interact with the Website and/or the chat.

c. Personal information automatically collected. We automatically collect certain information through your use of dave.io's Services and Website, such as cookie, pixels, tracking technologies and similar identifiers (“Technologies”), your Internet protocol (IP) address, and other device identifiers that are automatically assigned to your device, browser type and language, geo-location information, hardware type, operating system, internet service provider and other personal information about actions taken through the use of the Services and Website .

d. Personal information from Other Sources. dave.io also may obtain personal information about you from other sources, including publicly - or commercially- available information, and through third-party data platforms, partners and service providers.

e. Personal information you provide to us in person. For example, when you visit one of our exhibition booths or attend one of our events and you provide us with your contact details.

f. Personal information we collect from online interactions. For example, if you attend a webinar, contact us via social media or otherwise interact with our business, including as a representative of a current / prospective customer, supplier or partner, we track and make a record of those interactions, which may contain your contact details, such as full name, email address, messages and any other personal information that you decide to provide us with.

(ii) We process personal information for the following purposes:

a. To provide you with the Services. We will use the personal information, including, without limitation, for the following purposes: (i) allow you to create an account; (ii) to provide you the Services and to process your requests; (iii) contact you with service-related communications; (iv) fulfill any instruction and/or request made by you in the context of the Services; (v) send you push notifications and/or emails and notifications regarding your account or certain features of the Services, including, updates pertaining to your subscription, and related to the services we provide you with; (vi) to personalize your experience with our Services; (vii) to allow you to create more users and administrate your users; and (viii) to generally administer and improve the Services.

b. To allow you to make use of our Website. We will use your personal information to allow you to make use of our Website, including, (i) if you request a demo, we will use your personal information to process and answer your request for a demo; (ii) to answer your questions and to allow you to communicate with us (e.g., by using the Website chat); (iii) to analyze your use of our Website and to improve our Website; and (iv) to customize your experience.

c. For Administrative Purposes. dave.io use your personal information (i) to respond to your questions, comments, and other requests for customer support, or information, including information about potential or future services; (ii) to provide you with the dave.io Services; (iii) for internal quality control purposes; (iv) to establish a business relationship; and (v) to generally administer the dave.io Services.

d. To Market our Website and Services. dave.io uses personal information to market the dave.io Services. Such use includes (i) notifying you about offers and services that may be of interest to you; (ii) to send you marketing communications and additional information about our Services and offerings; (iii) developing and marketing new products and Services, and to measure interest in dave.io's Services; (v) other purposes disclosed at the time you provide information; and (vi) as you otherwise consent.

e. Security purposes. Some of the personal information mentioned in this Privacy Policy will be used for detecting, taking steps to prevent and prosecuting fraud or other illegal activity; to identify and repair errors; to conduct audits; and for security purposes. Personal information may also be used to comply with applicable laws, with investigations performed by the relevant authorities, law enforcement purposes, and/or to exercise or defend legal claims.

f. De-identified and Aggregated Information Use. In certain cases, we may or will anonymize, aggregate and/or de-identify part or all of your personal information for the purposes of analyzing, enhancing, and improving dave.io Services (including through the use of artificial intelligence) and for research purposes.

g. Cookies and Similar Technologies. We use Technologies to automatically collect information through the Website and Services, which in certain cases could be considered personal information. We use Technologies that are essentially small data files placed on your device that allow us to record certain pieces of information whenever you visit or interact with the Website and Services. If you would like to opt out of the cookies and similar technologies we employ on the Website and Services, you may do so by blocking, deleting, or disabling them as your browser or device permits or by changing your setting and preferences in the mechanism available on the Website.

(iii) The lawful bases we rely on for processing personal information are (if and when applicable):

a. The data subject has given consent to the processing of his or her personal information;

b. Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract;

c. processing is necessary for compliance with a legal obligation to which the controller is subject; and/or

d. Processing is necessary for the purposes of legitimate interest.

HOW WE PROTECT AND RETAIN YOUR PERSONAL INFORMATION

2.1. Security. We implement and maintain industry-standard technical, organizational and security measures designed to protect your personal information. However, please note that we cannot guarantee that the personal information will not be compromised as a result of unauthorized penetration of our servers. As the security of information depends in part on the security of the computer, device or network you use to communicate with us and the security you use to protect your user IDs and passwords, please make sure to take appropriate measures to protect this information.

2.2. Retention of your personal information. Your personal information will be stored until we proactively delete it from our records, or until you send a valid deletion request. Please note that in some circumstances we store your personal information for longer periods of time, for example (i) where we are required to do so in accordance with legal, regulatory, tax or accounting requirements, or (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, and/or (iii) if we reasonably believe there is a prospect of litigation relating to your personal information or dealings.

HOW WE SHARE YOUR PERSONAL INFORMATION

We may share your personal information as follows:

3.1. The personal information dave.io gathers may shared with our partners and other third parties.

3.2. We also share personal information about you with our affiliated companies .

3.3. We use third party service providers to process your personal information for the purposes outlined above, including, without limitation:

3.3.1. With cloud service providers for hosting purposes; 3.3.2. With websites and web content creation platforms in order to help us manage our Website; 3.3.3. With email providers, marketing, CRM, other similar tool providers;
3.3.4. With artificial intelligence tools and features; and 3.3.5. With analytic companies, in order to help us understand and analyze information we collect in accordance with this policy. 3.4. To the extent necessary, with regulators, courts, banks or competent authorities, to comply with applicable laws, regulations and rules (including, without limitation, federal, state or local laws), and requests of law enforcement, regulatory and other governmental agencies or if required to do so by court order, as well as for internal compliance procedures and to protect the safety, security, and integrity of dave.io, our Services, customers, employees, property, and the public. We may use or disclose the personal information we collect in order to ensure that our users are complying with all applicable aspects of our policies.

3.5. We may disclose personal information with our lawyers, accountants, auditors and other professional advisors where necessary to obtain legal or other advice or otherwise protect and manage our business interests;

3.6. We may use or disclose the personal information to investigate, prevent, or take action regarding illegal activities, suspected fraud, cybersecurity threats, situations involving potential threats to the physical safety of any person, violations of this policy, or as otherwise required or allowed by law and regulations;

3.7. If, in the future, we sell or transfer, or we consider selling or transferring, some or all of our business, shares or assets to a third party, we will disclose your personal information to such third party (whether actual or potential) in connection with the foregoing events (including, without limitation, our current or potential investors). In the event that we are acquired by, or merged with, a third party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer, disclose or assign your personal information in connection with the foregoing events.

3.8. Where you have otherwise provided your consent to us for sharing or transferring your personal information.

YOUR PRIVACY RIGHTS

4.1. The following rights (which may be subject to certain exemptions or derogations) shall apply to certain individuals (some of which only apply to individuals protected by specific laws):

i. You have the right to withdraw consent to the processing, where consent is the basis of processing.
ii. You have the right to request access to your personal information held by us, along with details on how it is processed, subject to certain conditions. You have the right to demand rectification of inaccurate personal information about you. We will promptly correct any information found to be incorrect. iii. You have the right to object to unlawful data processing under certain conditions. iv. You have the right to the erasure of past personal information about you (your “right to be forgotten”) under certain conditions. v. You have the right to demand that we restrict the processing of your personal information, under certain conditions, if you believe we have exceeded the legitimate basis for processing, the processing is no longer necessary, or if you believe your personal information is inaccurate. vi. You have the right to data portability of personal information concerning you that you provided us in a structured, commonly used, and machine-readable format, subject to certain conditions. vii. The personal information we collect is not used for automated decision-making and profiling, except for automated processes in the context of marketing. As stated above, you can opt out of direct marketing by contacting dave.io directly or by following the instructions through the unsubscribe options in our email messages. 4.2. You can exercise your rights by contacting us at privacy@dave.io. You may use an authorized agent to submit a request on your behalf if you provide the authorized agent written permission signed by you (where this is permitted by applicable law). To protect your privacy, we may take steps to verify your identity before fulfilling your request. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly in accordance with applicable law or inform you if we require further information in order to fulfil your request. When processing your request, we may ask you for additional information to confirm or verify your identity and for security purposes, before processing and/or honoring your request. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive. In the event that your request would adversely affect the rights and freedoms of others (for example, would impact the duty of confidentiality we owe to others) or if we are legally entitled to deal with your request in a different way than initially requested, we will address your request to the maximum extent possible, all in accordance with applicable law.

4.3. Deleting your account: Should you ever decide to delete your account, you may do so by emailing privacy@dave.io. If you terminate your account, any association between your account and personal information we store will no longer be accessible through your account. However, given the nature of sharing on certain services, any public activity on your account prior to deletion will remain stored on our servers and will remain accessible to the public.

4.4. Marketing emails – opt-out: You may choose not to receive marketing email of this type by unsubscribing in the link found at the bottom of the email.

INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION.

In order to run our business and provide our Website and Services to you, we transfer personal information to certain countries around the world, including to our affiliates and service providers, many of whom are located outside of your jurisdiction. Therefore, your personal information may be processed in countries with privacy laws that are different from privacy laws in your country. Whenever personal information is transferred internationally, we ensure it is protected by using Standard Contractual Clauses or other lawful mechanisms:

i. making sure the destination country has been deemed by the European Commission to provide an adequate level of protection for personal information; and/or ii. by executing data onward transfer instruments such as data processing and protection agreements.

According to the Israeli law, by providing your consent to this Privacy Policy, you acknowledge and agree that Personal Information relating to you may be transferred to and stored outside the borders of Israel, in accordance with applicable law and for the purposes described herein.

USE BY CHILDREN

We do not offer our products or Services for use by children and, therefore, we do not knowingly collect personal information from, and/or about children under the age of 18. If you are under the age of 18, do not provide any information to us without the involvement of a parent or a guardian. In the event that we become aware that you provided personal information in violation of applicable privacy laws, we reserve the right to delete it. If you believe that we might have any such information, please contact us at privacy@dave.io.

INTERACTION WITH THIRD PARTY PRODUCTS

We enable you to interact with third party websites, mobile software applications and products or services that are not owned, or controlled, by us (each, a “Third Party Service”). We are not responsible for the privacy practices or the content of such Third Party Services. Please be aware that Third Party Services can collect personal information from you. Accordingly, we encourage you to read the terms and conditions and privacy policies of each Third Party Service.

ANALYTIC TOOLS/COOKIES

Google Analytics. The Website uses a tool called “Google Analytics” to collect information about use of the Website. Google Analytics collects information such as how often users visit this Website, what pages they visit when they do so, and what other websites they used prior to coming to this Website. We use the information we get from Google Analytics to maintain and improve the Website and our products. We do not combine the information collected through the use of Google Analytics with information we collect. Google’s ability to use and share information collected by Google Analytics about your visits to this Website is restricted by the Google Analytics Terms of Service, available at https://marketingplatform.google.com/about/analytics/terms/us/, and the Google Privacy Policy, available at http://www.google.com/policies/privacy/. You may learn more about how Google collects and processes data specifically in connection with Google Analytics at http://www.google.com/policies/privacy/partners/. You may prevent your data from being used by Google Analytics by downloading and installing the Google Analytics Opt-out Browser Add-on, available at https://tools.google.com/dlpage/gaoptout/.

Mixpanel. We collect personal information such as your email address and your user activity through the use of Mixpanel. Mixpanel’s ability to use and share personal information is governed by the Mixpanel Terms of Use, available at https://mixpanel.com/terms/, and the Mixpanel Privacy Policy, available at https://mixpanel.com/privacy/. You can opt-out of Mixpanel’s services by clicking on the following link: https://mixpanel.com/optout/.

LinkedIn Analytics. We use LinkedIn Analytics (and/or the LinkedIn Insight Tag) to help us understand how visitors use the Website, measure and improve our marketing campaigns, and understand interactions with our ads and content. LinkedIn may collect or receive information about your device and your use of the Website (for example, pages visited, interactions, IP address, and device identifiers) and may process such information in accordance with its privacy policy. For more information about LinkedIn’s data practices, please review LinkedIn’s Privacy Policy (https://www.linkedin.com/legal/privacy-policy ).

We use log files. We use such personal information to analyze trends, administer the Website, track user movement around the Website, and gather demographic information.

We reserve the right to remove or add new analytic tools, cookies, pixels and other tracking technologies.

CONTACT US

For any questions, concerns, or to exercise your privacy rights, please contact us at: privacy@dave.io.

Data controller: dave.io LTD.