This US Privacy notice (“US Privacy Notice”) applies to Binah.ai Ltd. website visitors (“consumers” or “you“) who are California, Virginia, Nevada and Colorado residents, in accordance with the following data protection laws to the extent applicable – the California Consumer Privacy Act of 2018 as amended and revised by the California Privacy Rights Act of 2020 (“CPRA” and collectively “CCPA“), the Virginia Consumer Data Protection Act (“VCDPA”), the Connecticut Act Concerning Personal Data Privacy and Online Monitoring (“CTDPA”), or the Colorado Consumer Protection Act (“CPA”)  (collectively “Data Protection Law(s)“). Further, this Notice contains below a designated notice to Nevada residents.

This US Privacy Notice applies to Consumers’ Personal Information, which we collect directly or indirectly while using our website.

This US Privacy Notice is an integral part of our Privacy Policy. Any capitalized terms not defined herein shall have the meaning ascribed to it under the Data Protection Laws or the Privacy Policy.

Part I: A Comprehensive Description of the Information Practices:

1. Categories of Personal Information We Collect

We collect Personal Information which is defined under the Data Protection Laws as any information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household or device, all as detailed in the table below.

Personal Information definition under Data Protection Laws further includes Sensitive Personal Information (“SPI”) or Sensitive Data, as detailed in the table below. However, certain types of such data are excluded from the Data Protection Laws, such as (in accordance with the specific state laws): health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPPA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; biometric data covered by the Biometric Information Privacy Act (BIPA); Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA), California Financial Information Privacy Act (FIPA) or the Driver’s Privacy Protection Act of 1994. Therefore, Patient’s data collected during the use of our websites and the System is excluded from the scope of this Notice.

The Company may have collected the following categories of personal information from its website visitors within the last twelve (12) months:

2. Categories of Sources of Personal Information

Depending on the nature of your interaction with The Company, The Company collects the Personal Information as follows:

From website’s visitors:

• Provided by the visitor voluntarily in order to contact The Company.
• Automatically through The Company third party website providers – for example, in order to collect visitors’ IP address.

From Job Applicants:

• Provided voluntarily and directly when the candidate files an application to a position.
• Automatically through The Company third party website providers – for example, in order to collect visitors’ IP address, or following the application from relevant recruitment agencies.

3. Use of Personal Information

We may use, or disclose the Personal Information we collect for one or more of the following business purposes:

• To fulfill or meet the reason you provided the Personal Information. For example, if you contact us with an inquiry and share your name and contact information, we will use that Personal Information to respond to your inquiry, review your CV considered for a job position, etc.;
• For security and fraud detection purposes, monitoring and to maintain the safety, security, and integrity of our website and Platform;
• To improve our business operation, which includes but not limited to, analyze which types of content should be provided as part of the website; marketing; analyzing your use of the website;
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations;
• As described to you when collecting your Personal Information or as otherwise set forth in the Privacy Policy.

We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

4. Disclosures of Personal Information for A Business Purpose

We may disclose your Personal Information to a contractor or service provider for a business purpose. When we disclose Personal Information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except performing the contract. We further restrict the contractor and service provider from selling or sharing your Personal Information. In the preceding twelve (12) months, the Company has disclosed the following categories of Personal Information for a business purpose:

5. Sale or Share of Personal Information

We do not “sell” information as most people would commonly understand that term, we do not, and will not, disclose your Personal Information in direct exchange for money or some other form of payment.  We may “share” Personal Information for “interest-based advertising” or “cross-context behavioral advertising”. The CCPA and other applicable Data Protection Laws defines “sharing” as “communicating orally, in writing, or by electronic or other means, a consumer’s Personal Information” to “a third party for cross-context behavioral advertising, whether or not for money or other valuable consideration”. In other words, we may share your Personal Information with a third party to help serve personalized content or ads that may be more relevant to your interests, and to perform other advertising-related services such as enabling our partners to serve such personalized content.

In the preceding twelve (12) months, we “sell” or “share” the following categories of Personal Information for a business purpose:

6. Children Under the Age of 18

We do not knowingly collect information from children under the age of 18.

7. Data Retention

In general, we retain the Personal Information we collect for as long as it remains necessary for the purposes set forth above, all under the applicable regulation, or until you express your preference to optout, where applicable.

The retention periods are determined according to the following criteria:

• For as long as it remains necessary in order to achieve the purpose for which the Personal Information was initially processed. For example, if you contacted us, we will retain your contact information at least until we will address your inquiry.
• To comply with our regulatory obligations. For example, transactional data will be usually retained for seven years as of termination of engagement (or even more under certain circumstances) for compliance with our bookkeeping obligations purposes.
• To resolve a claim we might have or a dispute with you, including any legal proceeding between us, until such dispute will be resolved, and following, if we find it necessary, in accordance with applicable statutory limitation periods.

Please note that except as required by applicable law, we will not be obligated to retain your data for any particular period, and we may delete it for any reason and at any time, without providing you with prior notice if our intention to do so.

PART II: YOUR RIGHTS UNDER THE DATA PROTECTION LAWS

(A) THE RIGHTS AND EXECRISING THEM

The Table below applies to California, Connecticut, Virginia, Colorado Residence (Nevada related rights are separately detailed below):

You can exercise your rights by reviewing this US Privacy Notice and the Privacy Policy, in case you would like to receive the specific pieces please fill in this Data Subject Request (DSR) form to and sending it to us by mail: info@binah.ai. We reserve the right to reject such request under certain circumstances, and will inform you of the basis for the denial, which may include, but is not limited to, ensure the security and integrity, provide the services, a legal obligation, etc.

Note: In some cases, unless legally required otherwise, you may not exercise those rights more than twice within 12 years.

Nevada Residents Rights: Nevada law allows Nevada residents to opt out of the sale of certain types of personal information. Subject to several exceptions, Nevada law defines “sale” to mean the exchange of certain types of personal information for monetary consideration to another person. We currently do not sell personal information as defined in the Nevada law. However, if you are a Nevada resident, you still may submit a verified request to opt out of sales and we will record your instructions and incorporate them in the future if our policy changes. You may send opt-out requests to info@binah.ai.

(B) Authorized Agents

“Authorized Agents” may submit opt out requests on a consumer’s behalf. If you have elected to use an authorized agent, or if you were an authorized agent who would like to submit requests on behalf of a consumer, the following procedures will be required prior to acceptance of any requests by an authorized agent on behalf of a California consumer. Usually, we will accept requests from qualified third parties on behalf of other consumers, regardless of either the consumer or the authorized agent’s state of residence, provided that the third party successfully completes the following qualification procedures:

• When a consumer uses an authorized agent to submit a request to know or a request to delete, a business may require that the consumer do the following:
• Provide the authorized agent signed permission to do so or power of attorney.
• Verify their own identity directly with the business.
• Directly confirm with the business that they provided the authorized agent permission to submit the request.
• A business may deny a request from an authorized agent that does not submit proof that they have been authorized by the consumer to act on their behalf.

(C) Response Time and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require additional time (up to an additional forty-five (45) days), we will inform you of the reason and extension period in writing by mail or electronically, at your option. If we determine that the request warrants a fee, we will tell you why we made such decision and provide you with a cost estimate before completing your request.

For Connecticut Colorado and Virginia Residence: We may require specific information from you to help us confirm your identity and process your VCDPA request. If we denied a request, you may appeal our decision, and within 60 days of our receipt of your appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions.

If the appeal is denied, you may submit a complaint to your state of residency’s Attorney General:

• Virginia at https://www.oag.state.va.us/consumercomplaintform.
• Colorado at https://coag.gov/file-complaint/.
• Connecticut at https://portal.ct.gov/AG/Common/Complaint-Form-Landing-page.

(D) Notice Of Financial Incentive

We do not offer financial incentives to consumers for providing Personal Information.

DO NOT TRACK SETTINGS AND SHINE THE LIGHT LAW FOR CALIFORNIA RESIDENTS

Cal. Bus. And Prof. Code Section 22575 also requires us to notify you how we deal with the “Do Not Track” settings in your browser. As of the effective date listed above, there is no commonly accepted response for Do Not Track signals initiated by browsers. Therefore, we do not respond to the Do Not Track settings. Do Not Track is a privacy preference you can set in your web browser to indicate that you do not want certain information about your web page visits tracked and collected across websites. For more details, including how to turn on Do Not Track, visit: www.donottrack.us.

Further, California’s “Shine the Light” law (Civil Code Section § 1798.83), permits employees that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send us the Data Subject Request Form available HERE.

CONTACT US:

By email: info@binah.ai

Our address is: 2 Zeev Jabotinsky St., Ramat Gan, 5250501 Israel.

UPDATES:

We will update this US Privacy Notice at least every 12 months. The last revision date will be reflected in the “Last Updated” heading at the top of this US Privacy Notice.

Last update: July-25-2023