Privacy Policy.

We collect personal data about you, which refers to any information that could potentially identify you through reasonable means (such as email address or name). This section outlines how and when we collect and process personal data about you.

1.1 Account information: If you decide to register an account with our Services, we may collect your full name, phone number, email address, your company's name and job title.

1.2 Payment information: If you make a purchase through our Services, we will collect the billing and payment information required to process your charges. This may include your postal address, email address, or payment information.

1.3 Usage information: When you use our Services, we collect information about your interaction with our Services. Such information includes purchase history and data pertaining to your activities on our Services, as well as information generated when you interact with the Platform (for instance, how and when you use the Platform).

1.4 Identifiers and technical information: When you use our Services, we collect technical information such as IP address, device identifiers (e.g., IDFV for iOS devices and Android ID for Android devices), information about your device and connection, including user agent, connection type, timestamp, system language, device model, screen resolution and settings, battery level, available storage space, time zone, and operating system.

1.5 Communication information: When you contact us via email or through the support channels on the Platform, we collect the personal data you provide, which include your name, email address, company, and any other information you choose to provide.

We do not knowingly collect, process or disclose any sensitive personal data.

To the extent that you provide us with information regarding other individuals (for example, family members) or on their behalf, you are required to obtain their consent to this Policy. You represent and warrant that you have obtained and will maintain at all times during which such personal information is held by Sponsa, all necessary consents from such third parties for the disclosure of their details and personal information to Sponsa and/or its representatives. You shall bear sole responsibility in this regard.

When you access or use our Services, we use cookies, pixels, beacons, local storage and similar technologies ("Tracking Technologies"). These Tracking Technologies allow us to automatically collect information about you, your device, and your online behavior, in order to enhance your navigation in our Services, improve our Services' performance, perform analytics, customize your experience and offer you, for example, tailored content that better correspond with your interests.

2.1 What types of Tracking Technologies do we use? When you access or use our Services, we use the following categories of Tracking Technologies:

• (a) Strictly necessary Tracking Technologies: these Tracking Technologies are automatically placed on your computer or device when you access or take certain actions on our Services. These Tracking Technologies are essential to enable you to navigate around and use the features of our Services.
• (b) Functionality Tracking Technologies: these Tracking Technologies allow our Services to remember choices you make (such as your language) and provide enhanced and personalized features. For example, these Tracking Technologies are used for authentication (to remember when you are logged-in) and support other features of our Services.
• (c) Performance Tracking Technologies: these Tracking Technologies collect information about your online activity (for example the duration of your use of our Services), including referral source and IP-based geolocation. These Tracking Technologies are used for analytics, research and to perform statistics (based on aggregated information).

2.2 How and by whom are Tracking Technologies stored on your device? We store Tracking Technologies on your device when you visit or access our Services – these are called "First Party Tracking Technologies". In addition, Tracking Technologies are stored by other third parties (for example, our analytics service providers, business partners and advertisers), who run content on our Services – these are called Third-party Tracking Technologies. Both types of Tracking Technologies may be stored either for the duration of your visit on our Services or for repeat visits.

There are various ways in which you can manage and control your Tracking Technologies settings. You can change your preferences using our cookie settings tool (however, please note that this tool may only be available in certain jurisdictions). Other methods of managing your Tracking Technology preferences through your browser settings include changing your browser settings to send a "Do-Not-Track" signal. In such case, your browser will send us a special signal to stop tracking your activity. However, please note that certain features of the Services may not work properly or effectively if you delete or disable cookies.

Below is a list of useful links that can provide you with more information on how to manage your cookies: Google Chrome; Mozilla Firefox; Safari (Desktop); Safari (Mobile); Android Browser; and Microsoft Edge.

You can learn more and turn off certain third-party targeting and advertising cookies by visiting the following third-party webpages: The Interactive Advertising Bureau (US); The Interactive Advertising Bureau (EU); European Interactive Digital Advertising Alliance (EU); Digital Advertising Alliance; Network Advertising Initiative.

We may share your personal data with:

4.1 Affiliated companies: We may share personal data internally within our affiliated companies and subsidiaries, for the purposes described in this Policy.

4.2 Payment processors: We share your payment information with third party payment processors, for the purpose of facilitating your payments when using our Services. These third parties may have access to your personal data so that they may perform these tasks on our behalf. We currently use Stripe to process payments. When you make payment through Stripe, their privacy policy, located at https://stripe.com/privacy, will apply to the information that you provide to them and we will not have access to such information.

4.3 Service providers: Service providers working on our behalf and who need access to certain personal data in order to provide their services to us. These companies include, but are not limited to, cloud storage providers, analytics services, fraud prevention, etc.

4.4 Law enforcement agencies: We may disclose some data about you to government or law enforcement officials or private parties. The disclosure will be made in our sole discretion, as we believe it necessary or appropriate to respond to claims and legal procedures (including but not limited to subpoenas), to protect our or a third-party's property and rights, to protect the safety of the public or any person, or to prevent or stop any activity we consider to be, or to pose a risk of being, illegal, unethical, inappropriate or legally actionable. We also may be required to disclose an individual's personal data in response to a lawful request by public authorities, including meeting national security or law enforcement requirements.

4.5 Auditors and advisers: We share your data with our external auditors, advisors and professional service providers (e.g., lawyers, accountants, insurers etc.) to ensure our compliance with regulatory requirements and industry standards, auditing, managing disputes etc.

4.6 Mergers and acquisitions: We may transfer or otherwise share your data in case of entering into a business transaction such as a merger, acquisition, reorganization, bankruptcy, or sale of some or all of our assets.

6.1. Depending on the jurisdiction in which you reside, you may have certain rights under relevant applicable laws regarding the collection and processing of your personal data. To the extent these rights apply and concern you, you can contact us via the contact details available below and ask to exercise the following rights:

6.1.1 Rights of access to your personal data: You have the right to receive confirmation as to whether or not personal data concerning you is being processed, and access your stored personal data, together with supplementary information.

6.1.2 Right of data portability: You have the right to request us to move, copy and transfer your personal data easily from one IT environment to another, in a safe and secure way, without affecting its usability.

6.1.3 Right of rectification: You have the right to request rectification of your personal data in our control in the event that you believe the personal data held by us is inaccurate, incomplete or outdated.

6.1.4 Right of deletion/erasure: You have the right to request that we erase or delete personal data held about you at any time.

6.1.5 Right to restriction or objection to processing: You have the right to request that we restrict or cease to conduct certain personal data processes at any time.

6.1.6 Right to withdraw your consent: To the extent we process personal data on the basis of your consent, you may have the right to withdraw your given consent at any time.

6.1.7 Right not to be subject to automated decision making: You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects or similarly significantly effects on you.

6.1.8 Right to opt-out of the sale or share of personal data: In the event that we sell or share your personal data for behavioral advertising purposes, you may have the right to submit a request to opt-out of the sale or share of your personal data. After you opt-out, we may continue disclosing some personal data to our partners to help us perform business-related functions such as, but not limited to, providing the Services, ensuring that the Services are working correctly and securely, providing aggregate statistics and analytics and preventing fraud.

6.1.9 Right to limit use and disclosure of your sensitive Personal Data: You have the right to request to limit the collection of your sensitive personal data, to only such data that is necessary to perform our Services.

6.1.10 Right to non-discrimination: You have the right to be free from any discrimination for exercising your rights, such as offering you different pricing or products, or providing you with a different level or quality of services, based solely upon your request.

6.1.11 Right to lodge a complaint: All requests, complaints or queries may be addressed to Sponsa to the following email address: info@sponsa.ai. We will consider any requests, complaints or queries and provide you with a reply in a timely manner. We take our obligations seriously and we ask that any concerns be brought to our attention first, so that we can try to resolve them. If you are unsatisfied with our response, you can lodge a complaint with the applicable data protection supervisory authority or appeal our denial of your request by contacting us as set out in the "Contact Us" section below.

Please note that these rights are not absolute and may be subject to our own legitimate interests and regulatory requirements. You are welcome to contact us for any questions or requests through our contact details below.

We will only use personal data provided in a verifiable consumer request to verify the requestor's identity or authority to make the request. Making a verifiable consumer request does not require you to create an account with us.

Authorized agent. Depending on your jurisdiction, you may designate an authorized agent to make a request on your behalf. We will require authorized agents to confirm their identity and authorization to act on your behalf, in accordance with applicable laws.

We operate globally, thus any information that we collect, disclose or share, including your personal data, can be stored and processed in various jurisdictions around the world, including (but not limited to) the European Economic Area, United Kingdom, Israel and United States, for the purposes detailed in this Policy. These countries' data protection rules may differ from those in your country and provide lower protection on your privacy than your country. We will take appropriate measures to ensure our transfers of Personal Data comply with applicable data protection laws.

To the extent that the GDPR or UK GDPR are applicable, we will only transfer or share your personal data to data recipients:

• (a) located in the EEA or in the UK;
• (b) located in non-EEA countries or UK which have been approved as providing adequate level of data protection; or
• (c) who have entered into legal agreements ensuring an adequate level of data protection.

We reserve the right to change this Policy at any time. The most current version will always be posted through our Services (as reflected in the "Last Updated" below). You are advised to check for updates regularly. By continuing to access or use our Services after any revisions become effective, you agree to be bound by the updated Policy.

If you do not agree to the modified Policy, your sole remedy will be to terminate your account and immediately cease accessing and using the Services.