OURCROWD PRIVACY STATEMENT

Your privacy is important to us. This privacy statement (the “Privacy Statement”) describes how OurCrowd Management Limited and its affiliates (collectively, “us,” “we” or “OurCrowd“) collect, use and disclose Personal Data that you submit via the OurCrowd investment portal and other OurCrowd web properties that link to this Privacy Statement (collectively, the “Site”).

This Privacy Statement is incorporated within the OurCrowd Terms of Use on the Site (the “Terms”), and capitalized terms used and not otherwise defined in this Privacy Statement shall have the corresponding meanings set forth in the Terms.

To better protect your privacy, we provide this notice explaining our online information practices, including the choices you can make about the way in which Personal Data you submit via the Site is collected and used by OurCrowd. If you do not agree to the processing of your Personal Data as described in this Privacy Statement, you should cease all use of the Site and refrain from submitting any Personal Data.

If you elect to subscribe for one or more services offered by OurCrowd, your agreement(s) with OurCrowd for the provisioning and procurement of such services will include applicable provisions pertaining to your submission and OurCrowd’s rights and obligations in respect of any Personal Data you submit to OurCrowd.

It is important that you understand there is no requirement by law for you to provide OurCrowd with your personal details – the information you share with us is entirely voluntary, and you may avoid providing such information either by not filling in specific forms or by disabling cookies. In addition, information which OurCrowd has irreversibly anonymized or aggregated will not include any Personal Data.

“Personal Data” or “Personal Information” means any information that can be used, alone or together with other data, to uniquely identify any living human being and any information deemed as Personally Identifiable Information by privacy laws. Please note that this is a master privacy policy and some of its provisions only apply to individuals in certain jurisdictions. For example, the legal basis in the table below is only relevant to GDPR-protected individuals.

1.  WHAT INFORMATION WE COLLECT, WHY WE COLLECT IT, AND HOW IT IS USED

Information we collect from you when you browse or visit our Site

a) What data is collected: Cookies, analytic tools and log files

b) For What Purposes is the Data Collected

• To improve, modify and update OurCrowd services and content offered on the Site.
• To monitor and ensure the orderly and proper operation and development of the Site and associated services.
• To analyze and derive statistical information with the goal of improving and customizing your experience and the content that is presented to you on the Site.

c) Legal basis (GDPR only)

• Consent
• Legitimate interest (e.g. essential cookies)

When you contact us (e.g. submit a request) – for the purposes of processing

a) What data is collected:

• Full name
• Contact information (e.g., email and phone number)
• Job title
• Company name
• Country

b) For What Purposes is the Data Collected

• To process and answer questions
• To customize your experience

c) Legal basis (GDPR only)

• 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
• Legitimate interest (e.g. respond to a query sent by you)

When you contact us (e.g. submit a request) – for the purposes of consent

a) What data is collected:

• Full name
• Contact information (e.g., email and phone number)

b) For What Purposes is the Data Collected

• To contact you occasionally regarding OurCrowd’s services. (Note: Even if you authorize OurCrowd to contact you, you may revoke/withdraw such authorization any time. In addition, you may opt–out of OurCrowd’s mailing lists by following the unsubscribe instructions in each of the emails you receive or by contacting us as described in this Privacy Statement).

c) Legal basis (GDPR only)

• Consent

When you create an account and when you log in

a) What data is collected:

• Email address
• First Name
• Last Name
• Country of Residence
• Phone number

b) For What Purposes is the Data Collected

• To be able to create an account
• To be able to log in
• To be able to enjoy features available to registered users only

c) Legal basis (GDPR only)

• 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
• Legitimate interest (e.g. respond to a query sent by you)

When you subscribe to our distribution list(s)/newsletter(s)

a) What data is collected:

• Full name
• Contact information (e.g., email and phone number)
• Job title
• Company name
• Country

b) For What Purposes is the Data Collected

• To send you newsletters for which you have subscribed (together with an unsubscribe option in each communication that is sent you).

c) Legal basis (GDPR only)

• Consent
• Legitimate interest (e.g. send you more information about OurCrowd)

When we process your job application      

a) What data is collected:

• Full name
• Email address
• Phone number
• Resume/CV
• Any other Personal Data you decide to provide us with

b) For What Purposes is the Data Collected

• To process your job application
• To assess you as a candidate
• To communicate with you for job application-related matters

c) Legal basis (GDPR only)

• 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
• Legitimate interest (e.g. process your job application)

When you register to our webinars – for the purposes of processing

a) What data is collected:

• Full name
• Contact information (e.g., email and phone number)
• Job title
• Company name
• Country

b) For What Purposes is the Data Collected

• To process your registration and participation in webinars, conferences and/or other OurCrowd events in which you have registered.

c) Legal basis (GDPR only)

• To allow you to register to a webinar
• To send you webinar-related communications

When you register to our webinars – for the purposes of consent

a) What data is collected:

• Full name
• Email address

b) For What Purposes is the Data Collected

• To send you more information about us and marketing communications

c) Legal basis (GDPR only)

• Consent

When you make use of, or interact with, our Site platform

a) What data is collected:

• Full name
• Address
• Email
• Password
• Company name

b) For What Purposes is the Data Collected

• To establish an account for return customers and to provide customer service activities

c) Legal basis (GDPR only)

• Consent
• 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

When you engage in investment opportunities on the OurCrowd platform

a) What data is collected:

• Financial and personal information (e.g., forms of identification, tax documentation, banking details, etc.)

b) For What Purposes is the Data Collected

• For use in connection with OurCrowd’s KYC and investor evaluation processes.

c) Legal basis (GDPR only)

• 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

We may use non-personally identifying information in the aggregate that we collect to provide statistical information about users of the Site (i.e., on an anonymous basis), to improve the quality, design and content of our Site, to analyze the use of our Site and to cooperate with law enforcement. The information collected is used to improve our website usability and is stored and used for aggregated and statistical reporting.
We review our retention periods for Personal Data on a regular basis. We will hold your Personal Data on our systems for as long as is necessary to fulfil the purposes outlined in this Privacy Statement, or as long as is set out in any relevant contract you hold with us, unless a longer retention period is required or permitted by law.
By providing any Personal Data to OurCrowd you warrant and represent that the information you provide is complete, accurate and correct. Your failure to do so will likely result in OurCrowd being unable to contact you about your inquiries. It is your responsibility to update us if any of the information you provided is no longer correct or accurate, and to inform OurCrowd of the required updates. In addition, if you provide us with Personal Data on behalf of another person or entity, you represent to us that you were authorized by that person or entity to allow us to collect give us consent to use the submitted information.

2. SHARING OF INFORMATION WITH THIRD PARTIES
We do not, and currently do not intend to, sell any of your Personal Data to any third party. If we elect to do so, we’ll first obtain your consent. Moreover, OurCrowd will not transfer your personal details or any information collected pertaining to your activities on the Site (provided, that, such details and information identify you personally) to any third party, except in the following cases or as otherwise outlines in this Privacy Statement.
We may disclose your Personal Data under the following circumstances:

• OurCrowd share Personal Data with its affiliates, for the purpose of assisting in the processing activities detailed herein or if such affiliate is the best suited to handle your inquiry.
• OurCrowd may share Personal Data with its consultants, vendors and service providers for the purpose of helping OurCrowd execute certain tasks outsourced to them, or providing capabilities which OurCrowd requires. The service providers to which OurCrowd provides Personal Data collected through the Site include without limitation: (1) email service providers for email campaigns management and to send you emails on our behalf, with the express provision that their use of such information must comply with our instructions; (2) recruiting service providers, in relation to activities on the Site related to submission and processing of CV and job applications through the Site; (3) registration management of users to events through the website; (4) billing, processing payments, marketing automation, OurCrowd advertisements on social media, CRM platform, analytics tools providers, web page building tools, cloud services, support and maintenance operation tools. Our service providers do not have any right to use your Personal Data collected from the Site beyond what is necessary for the purpose of facilitating their services for us, and are subject to data protection agreements to the extent required under applicable law. Our vendors with whom we may share Personal Data include entities such as AWS, Hubspot, SalesForce and more. If you want to receive a full and updated list of our vendors, please send a request to privacy@ourcrowd.com.
• As permitted or required by, or in response to lawful requests (e.g., subpoenas, court orders and other legal processes) by applicable local law enforcement agencies or regulatory agencies, or agencies with responsibility to oversee and enforce national security;
• In any case of dispute, or legal proceeding of any kind between you and OurCrowd, or between you and other users or third parties;
• When we believe it is appropriate to investigate, prevent, or take action regarding illegal or suspected illegal activities; and in connection with our Terms and other agreements, including where we believe you may have breached the Terms or other agreements with OurCrowd;
• Where you have provided your consent to us sharing or transferring your Personal Data (e.g., where you provide us with marketing consents or opt in to optional additional services or functionality); and/or
• Other than as set out above, you will be notified when Personal Data about you will be shared with third parties, and you will have an opportunity to choose not to have us share such information.

3. DATA TRANSFERS AND GLOBAL PROCESSING
The Site may be operated in countries other than your own location, and your Personal Data may be accessed and/or processed from and/or transferred to countries other than your own location. We may do this where data is accessed/processed for any of the basis identified above.
By consenting to the collection and use of your Personal Data, you agree to your Personal Data being transferred and stored in this manner and for the specified purposes.
The safeguards we deploy for performing such transfers across boundaries:

• Adequacy. Any transfers to OurCrowd affiliates may be made on the basis of an adequacy decision made by the European Commission;
• Model Clauses. With some of our processors, we use standard contractual clauses approved by the European Commission that are binding standards of processing of Personal Data committed to contractually by third parties processing information for us and on our behalf;

4. LINKS
The Site contains links to other sites. OurCrowd is not responsible for and has no liability for privacy policies and/or practices on other sites. We advise you to read the privacy policy stated on other sites you link to through the Site. Our Privacy Statement only governs information that we collect on the Site.

5. SECURITY
We take appropriate precautions to protect your Personal Data by using physical as well as technological security devices. Additionally, we have implemented physical, electronic and procedural safeguards that are designed to protect the security of your information in compliance with applicable laws and regulations. Although we have invested in leading-edge security software, systems and procedures to offer you a safe and secure investing platform and to protect your personal, financial and investment data, no security system is impenetrable. Thus, we are continually monitoring the effectiveness of our security system while constantly refining and upgrading our security technology and procedures to ensure maximum protection.

6. RETENTION OF YOUR PERSONAL DATA
Your Personal Data will be stored until we delete the record and we proactively delete it or you send a valid deletion request, please note that in some circumstances we may store your Personal Data 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, or (iii) if we reasonably believe there is a prospect of litigation relating to your Personal Data or dealings.

7. SOCIAL MEDIA FEATURES
The Site includes social media plugins, including links to Facebook, LinkedIn and Twitter. These features may collect your IP address, which page you are visiting on our Site, and may set a cookie to enable the plugin to function properly. Social media features are governed by the privacy policy of the company providing it.

8. CHILDREN’S PRIVACY
You must be at least Eighteen (18) years old in order to register for or use the Site. Notwithstanding the foregoing, if you reside in a state, country or other jurisdiction that requires a higher minimum age for your use of the Site or participation in its activities, you must comply with the applicable law. OurCrowd does not knowingly collect Personal Data from minors who are under the age of 18 through the Site. If a parent or guardian becomes aware that his or her child has provided us with personally identifiable information via the Site without his/her consent, then he or she should contact OurCrowd at the information described below. If we become aware that a child under the age of 18 has provided us with personally identifiable information, we will delete such information from our files.

9. DATA SUBJECT RIGHTS
9.1. 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 the GDPR):
You have a right to access Personal Data held about you. Your right of access may normally be exercised free of charge, however we reserve the right to charge an appropriate administrative fee where permitted by applicable law;

• You have the right to request that we rectify any Personal Data we hold that is inaccurate or misleading;
• You have the right to request the erasure/deletion of your Personal Data (e.g. from our records). Please note that there may be circumstances in which we are required to retain your Personal Data, for example for the establishment, exercise or defense of legal claims;
• You have the right to object, to or to request restriction, of the processing;
• You have the right to data portability. This means that you may have the right to receive your Personal Data in a structured, commonly used and machine-readable format, and that you have the right to transmit that data to another controller;
• You have the right to object to profiling;
• You have the right to withdraw your consent at any time. Please note that there may be circumstances in which we are entitled to continue processing your data, in particular if the processing is required to meet our legal and regulatory obligations. Also, please note that the withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal;
• You also have a right to request certain details of the basis on which your Personal Data is transferred outside the European Economic Area, but data transfer agreements and/or other details may need to be partially redacted for reasons of commercial confidentiality ;
• You have a right to lodge a complaint with your local data protection supervisory authority (i.e., your place of habitual residence, place or work or place of alleged infringement) at any time or before the relevant institutions in your place of residence. We ask that you please attempt to resolve any issues with us before you contact your local supervisory authority and/or relevant institution.

9.2. The following rights (which may be subject to certain exemptions or derogations) shall apply to individuals protected by the Consumer Privacy Act of 2018 (“CCPA”):

• You have the right to know what Personal Information is being collected about you, This include the right to request that we disclose what Personal Information of yours we collect, use, disclose, and sell;
• You have the right to request the erasure/deletion of your Personal Information (e.g. from our records and the records of our service providers).
  Please note that there may be circumstances in which we are required to retain your Personal Information, for example for the establishment, exercise or defense of legal claims;
• You have the right to know whether your Personal Information is sold or disclosed and to whom;
• You have the right to restriction of, or object to, processing of your Personal Information, including the right to opt in or opt out of sale of your Personal Information to third parties, if applicable, where such requests are permitted by law;
• You have the right not to receive discriminatory treatment for the exercise of the privacy rights conferred by the CCPA;
• You have a right to lodge a complaint with your local data protection supervisory authority (i.e., your place of habitual residence, place or work or place of alleged infringement) at any time or before the relevant institutions in your place of residence (e.g. the Attorney General in your State). We ask that you please attempt to resolve any issues with us before you contact your local supervisory authority and/or relevant institution. You have certain choices about your Personal Information. Where you have consented to the processing of your Personal Information, you may withdraw that consent at any time and prevent further processing by contacting us as described in this Privacy Policy. Even if you opt out, we may still collect and use non-Personal Information regarding your activities on our services and for other legal purposes as described above. While we cannot guarantee privacy perfection, we will address any requests to the best of our ability as soon as possible. We will process such requests in accordance with applicable laws.

9.3. You may exercise the rights set forth in this Privacy Statement to the extent these rights apply to you by contacting OurCrowd via the contact information listed herein. We will undertake to respond to your request within the applicable time frame prescribed by applicable law, and in any event we will make efforts to respond within 30 days of receipt of your request. Although OurCrowd will make reasonable efforts to accommodate your requests, in some circumstances we may deem your request unfounded or not eligible under applicable law. If that should happen, OurCrowd expressly reserves the right to refuse your request. Before OurCrowd is able to accommodate any request, provide you with any information or correct any inaccuracies – we may verify your identity by requesting certain information or identification.
9.4. You can also request that we close your OurCrowd account, or request that we no longer use your information to provide you Services, by emailing Customer Service at privacy@ourcrowd.com. After we close your account, we may retain some information if we believe it may be necessary to prevent fraud, assist with investigations, resolve disputes, analyze or troubleshoot programs, if required by law, enforce our Terms of Use and take actions otherwise permitted by law. Notwithstanding the foregoing, if you are an active investor on the OurCrowd platform, it would not be possible to close your OurCrowd account while any investment(s) is/are actively managed by OurCrowd.

10. SPECIFIC PROVISIONS APPLICABLE UNDER CALIFORNIA/DELAWARE PRIVACY LAWS
10.1. CCPA Disclosure
This section is only applicable to California residents for purposes of compliance with the CCPA. Defined terms used in this section, including but not limited to “Business Purpose”, “Consumers,” and “Sale” (or “Sell”) are used as such terms are defined by and interpreted pursuant to the CCPA.
The categories of Personal Information we have collected about Consumers, for of which we have disclosed for a business purpose, in the preceding 12 months are (please refer to the table at the top of this Privacy Notice for more detail):

• Identifiers, such as name and Social Security number;
• Personal information, as defined in the California safeguards law, such as contact information and financial information;
• Characteristics of protected classifications under California or federal law, such as sex and marital status;
• Commercial information, such as transaction and account information;
• Internet or network activity information, such as browsing history and interactions with the Site;
• Geolocation data, such as device location;
• Audio, electronic, visual, and similar information, such as video, photography and call and video recordings;
• Professional or employment-related information, such as work history and prior employer.
• Education information, such as school and date of graduation;
• Inferences drawn from any of the Personal Information listed above to create a profile about, for example, an individual’s preferences and characteristics; and
• The sources we have collected this Personal Information from are: directly from California residents or their representatives.

In the past 12 months, however, we have not “sold” Personal Information relating to California residents within the meaning of the CCPA. For purposes of this Privacy Notice, “sold” means the disclosure of Personal Information for monetary or other valuable consideration.
If you are a California resident, you may request that we disclose to you the following information covering the 12 months preceding your request:
(a) the categories of Personal Information that we collected about you and the categories of sources from which we collected such Information;
(b) the business or commercial purpose for collecting Personal Information about you;
(c) the categories of Personal Information about you that we disclosed to third parties for a business purpose and the categories of third parties to whom we disclosed such Personal Information (if applicable); and
(d) the specific pieces of Personal Information we collected about you.
If you are a California resident, you may also request that we delete Personal Information that we collected from you.
10.2. California / Delaware “Do Not Track Disclosures”
California and Delaware law require us to indicate whether we honor “Do Not Track” settings in your browser concerning targeted advertising. OurCrowd adheres to the standards set out in this Privacy Statement and does not monitor or respond to Do Not Track browser requests.
10.3. Choice/Opt-out
You will be required to ‘opt-in’ to having your Personal Data used for any purpose not directly related to the Site upon registration to the Site. If you no longer wish to receive additional information or promotional materials from OurCrowd, you may opt-out of receiving these communications by using the opt-out mechanism described in the relevant email.

11. LOG FILES
We use log files. We use such information to analyze trends, administer the Website, track users’ movement around the Website, and gather demographic information.

12. ANALYTIC TOOLS

• 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. 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/.
• Inspectlet. We have engaged Inspectlet to analyse the activities of visitors to this website, and Inspectlet’s authorized use of cookies and other tracking technologies enable it to have access to Personal Information of visitors to this website. Such access to and use of Personal Information by Inspectlet is governed by Inspectlet’s Privacy Policy.
• Mixpanel. We may collect certain information such as 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/.
• Advertising Partners. Through our services, we may allow third party advertising partners to set technologies and other tracking tools to collect information regarding your activities and your device (e.g., your IP address, mobile/website identifiers, page(s) visited, location, time of day). We also may combine and share such information and other information (such as demographic information and past purchase history) with third party advertising partners. These advertising partners will potentially use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit third party websites within their networks. This practice is commonly referred to as “interest-based advertising” or “online behavioral advertising. We may allow access to other data collected by the services to share information that may be useful, relevant, valuable or otherwise of interest to you. If you prefer not to share your Personal Information with third party advertising partners, you may let us know.
  We reserve the right to remove or add new analytic tools.

13. NOTIFICATION OF CHANGES
This Privacy Statement may change from time to time and we will post the amended terms on the OurCrowd Site and/or notify you by email of major changes.
Amended terms will take effect immediately for new users, and 30 days after they are posted for existing users. You should review the Privacy Statement periodically to remain informed of any changes. You agree to accept posting of a revised Privacy Policy as actual notice to you.
Your continued use of the Site after any changes to this Privacy Statement have been posted (or, if applicable, notified) signifies your acceptance of those changes. If you do not agree to the revised Privacy Statement, please refrain from using our products or services and contact us by sending an email to privacy@ourcrowd.com.

14. QUESTIONS AND FEEDBACK
If you have questions or feedback regarding this Privacy Statement, you may direct them to privacy@ourcrowd.com, and we will make every effort to answer your questions promptly.
Last Updated: May 2022