DATAFLINT APP
PRIVACY POLICY

1. What personal information we collect, why we collect it, and how it is used

We process the following personal information: When you use the App, we will collect your email address, data usage and any other information you choose to provide us with.

We process personal information for the following purposes: We will use the information: (i) to allow you to create an account; (ii) to provide you the App and to process your requests; (iii) to communicate with you about your use of the App and for support purposes; (iv) to fulfill any instruction or request made by you in the context of the App; (v) to send you push notifications, and emails regarding your account or certain features of the App, including, updates pertaining to your subscription; (vi) to personalize your experience with our App; (vii) to allow you to create more users and control access rights of such users; and (viii) generally to administer and improve the App.

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

• The data subject has given consent to the processing of his or her personal information.
• 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.
• processing is necessary for compliance with a legal obligation to which the controller is subject; and/or
• Processing is necessary for the purposes of legitimate interest.

2. How we protect and retain your personal information

Security. Taking into account the state of the art, the costs of implementation, the scope, the context, the purposes of the processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons We implement and maintain technical and organizational security measures designed to protect your information. However, please note that we cannot guarantee that the information will not be compromised as a result of unauthorized penetration to our servers. As the security of information depends in part on the security of the 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.

Retention of your information. Subject to the next sentence, we will delete the information you provide us within the earlier of (a) thirty (30) days following the date you terminate your account with us, and (b) five (5) business days following your written notice to us to delete your information. Please note that in some circumstances we may retain your 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 claims or disputes, and/or (iii) if we reasonably believe there is a prospect of litigation relating to your information or dealings.

3. How we share your personal information

We share your information as follows:

1. The information DataFlint gathers is shared with our partners and other third parties.
2. We also share information with our affiliated companies about you.
3. We use third party service providers to process your information for the purposes outlined above, including, without limitation:
   1. With cloud service providers for hosting purposes;
   2. With app content creation platforms in order to help us manage our App;
   3. With email providers, marketing, CRM, other similar tool providers; and
   4. With analytic companies, in order to help us understand and analyze information we collect in accordance with this policy.
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 DataFlint, our App, customers, employees, property, and the public.
5. 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 may disclose your 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 information in connection with the foregoing events.
6. Where you have otherwise provided your consent to us for sharing or transferring your information.

4. Additional information regarding transfers of personal information

1. We store the personal information with the following hosting and storage providers and locations: AWS – North Virginia (USA); AuthO. Inc- USA.
2. In order to run our business and make the App available 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 we make such transfers, we will use commercially reasonable efforts to implement an appropriate level of protection to your personal information by implementing at least one of the following safeguards:

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

5. Your privacy rights

The following rights (which may be subject to certain exemptions or limitations in accordance with applicable law) shall apply to certain individuals (some of which only apply to individuals protected by specific laws):

• You have the right to withdraw consent to the processing, where consent is the basis of processing.
• You have the right to access the personal information that we hold and request further details about how we process it, under 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.
• You have the right to object to unlawful data processing under certain conditions.
• You have the right to the erasure of past data about you (your “right to be forgotten”) under certain conditions.
• 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.
• 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.
• The personal information we collect is not used for automated decision-making, except for automated processes in the context of marketing. As stated above, you can opt out of direct marketing by DataFlint by contacting DataFlint directly or by following the instructions through the unsubscribe options in our email messages.

You can exercise your rights by contacting us at privacy@dataflint.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. 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 initial requested, we will address your request to the maximum extent possible, all in accordance with applicable law.

Deleting your account: Should you ever decide to delete your account, you may do so via the App or by emailing privacy@dataflint.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.

Marketing emails - opt-out: You may choose not to receive marketing email of this type by sending a single email with the subject "BLOCK" to privacy@dataflint.io. Please note that the email must come from the email account you wish to block OR if you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails, and we will process your request within a reasonable time after receipt.

6. Use by minors

We do not offer our products or services for use by minors and, therefore, we do not knowingly collect information from, and/or about persons 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 provide 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@dataflint.io.

7. 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 information from you. Accordingly, we encourage you to read the terms and conditions and privacy policies of each Third Party Service.

8. Analytic tools / Cookies

• Google Analytics. The App uses a tool called “Google Analytics” to collect information about use of the App. 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, the App and our other 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 https://www.google.com/policies/privacy/. You may learn more about how Google collects and processes data specifically in connection with Google Analytics at https://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 information such as your email address and your user activity through the use of Mixpanel. Mixpanel’s ability to use and share 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/.
• When you visit or log in to our website, cookies and similar technologies may be used by our online data partners or vendors to associate these activities with other personal information they or others have about you, including by association with your email. We (or service providers on our behalf) may then send communications and marketing to these email. You may opt out of receiving this advertising by visiting: https://app.retention.com/optout.
• We reserve the right to remove or add new analytic tools, cookies, pixels and other tracking technologies.

9. Contact us

If you have any questions, concerns or complaints regarding our compliance with this notice and the data protection laws, or if you wish to exercise your rights, we encourage you to first contact us at privacy@dataflint.io