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Privacy Policy

Personal Information We Collect

We process information about you while providing the Aleph Products. Below, we outline the kinds of information we collect.

Information You Give to Us

We collect information about you when you provide it to us directly.

Information We Collect Automatically

We automatically collect information about you when you access or use the Aleph Products.

Information We Collect from Other Sources

We may also obtain information about you from other sources.

How We Use Personal Information

We use information about you for the following purposes.

How We Share Personal Information

We may share your personal information as follows.

Security

The security of your personal information is incredibly important to us. We have implemented and we continually maintain a variety of technical and organizational measures to protect your personal information from unauthorized access and against unlawful processing, accidental loss, destruction, and damage.

Retention

We only keep your personal information for as long as necessary to fulfill the purposes we collected it for, after which it will be deleted or archived unless we are required to keep it to comply with our legal obligations or for another legitimate and lawful purpose. To determine the appropriate retention period for personal information, we consider several factors, including:

In some cases, we may anonymize your personal information so that you are no longer identifiable, in which case we may use the resulting information without further notice to you.

Children

The Aleph Products are not directed to individuals under the age of 16, and we do not knowingly collect or sell the personal information of children under 16.

Your Choices

You have choices about how Aleph collects and uses your personal information.

Supplemental Notice for the EEA, UK, and Switzerland

This section provides additional details about the personal information we process subject to the General Data Protection Regulation (GDPR) and UK GDPR.

Controller of Your Information

Unless otherwise stated in a supplemental notice, Aleph, Inc. is the data controller of your personal information.

Your Rights

Subject to applicable law, you have the following rights with respect to your personal information.

To exercise your rights, please complete our Data Subject Rights intake form or contact us as outlined in the "Contact Us" section below. Please note that we may ask you to provide us with additional information to confirm your identity.

Legal Bases for Processing Personal Information

We process your personal information on one or more of the following legal bases:

International Data Transfers

Your personal information may be collected in, transferred to, accessed from, or stored in a country other than the one you are in, including the United States, which may have data protection rules that are different from those of your country. Your personal information is only transferred out of your country in accordance with applicable data protection law, including, for example, to third countries that adequately safeguard personal data, or under the European Commission-approved Standard Contractual Clauses. Your rights with respect to your personal information are outlined above in the "Your Rights" section above.

We comply with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce (together, the "DPF"), and we have certified to the U.S. Department of Commerce that we adhere to the EU-U.S. Data Privacy Framework Principles with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework Principles with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF (together, the "DPF Principles"). A full list of all participating organizations is available on the U.S. Department of Commerce's dedicated DPF website.

If you have any questions, concerns, or complaints about our compliance with the DPF, we encourage you to contact us as outlined in the "Contact Us" section below, where you can also find information regarding our EU representative that can respond to your questions or complaints. If you have an unresolved complaint regarding our handling of personal data received in reliance on the DPA, you may contact TRUSTe, our U.S.-based third-party dispute resolution provider, free of charge. Finally, if you have a complaint that we have violated the DPF Principles that has not been resolved by other means, you may have the ability to invoke binding arbitration as outlined more fully on the DPF website. Please note that we are subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC).

In some cases, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

If we transfer your personal data onward to a third party, we will continue to remain liable under the DPF Principles if the information is processed in a manner inconsistent with the DPF Principles.

Complaints

You may lodge a complaint with a data protection authority for your country or region where you have your habitual residence, where you work, or where an alleged infringement of applicable data protection law occurs.

Supplemental Notice for the United States

This section provides additional details about the personal information we collect about individuals and the rights afforded to them under various applicable U.S. state data-protection and privacy laws, including the California Consumer Privacy Act, as amended (CCPA), the Colorado Privacy Act (CPA), the Connecticut Data Privacy Act (CTDPA), and the Virginia Consumer Data Protection Act (VCDPA).

Your Rights

Subject to applicable law, you have the following rights with respect to your personal information.

If you or your authorized agent wishes to exercise any of these rights, please complete our Data Subject Rights intake form or contact us as outlined in the "Contact Us" section below. Please note that we may ask you or your agent to provide us with additional information to confirm your identity.

If you submit a request to exercise one of the above rights and you disagree with our decision regarding your request, you may have the right to appeal our decision under applicable law. To do so, please reply to our response.

Categories of Personal Information Collected

The personal information that we've collected in the past 12 months fall into the following categories specifically established under the CCPA:

For more information about the categories of personal information we collect, please see the "Personal Information We Collect" section above.

Categories of Personal Information Disclosed for a Business Purpose

The personal information that we've disclosed for a business purpose (including to our service providers) in the past 12 months fall into the following categories specifically established under the CCPA:

For more information about the categories of personal information we disclose to other parties, including to our services providers, please see the "How We Share Personal Information" section above.

No Sale or Sharing of Personal Information

We do not sell or share (for the purpose of cross-context behavioral advertising) your personal information, as those terms are defined under the CCPA.

Changes to this Privacy Policy

We may occasionally update this Privacy Policy. The date at the top of this Privacy Policy indicates when it was last revised. Any changes will become effective when we post the revised Privacy Policy on this page.

Contact Us

We have appointed Alef Pitronot Technologim LTD as Aleph's EU representative under Article 27 of the GDPR. You may contact our EU representative at privacy@aleph.tech.