Processor
Additional notices and contact details
You are not legally obligated to provide us with your Personal Data, and you may do so (or avoid doing so) at your own free will. However, please keep in mind that without it, we may not be able to provide you with the full range of our Services or deliver the best user experience when interacting with them. If you prefer not to share your Personal Data, or have it processed by us, please refrain from providing it, visiting or interacting with our Services. You may also submit a request to exercise your rights as explained inSection 9below.

1. What Personal Data we collect and why we collect it

We may collect or generate the following types of Personal Data about individuals through our Services:

Contact details, account information and other data concerning our Users, Customers and Prospects:Contact details (such as full name, email address, phone number, company name, job title, profile picture),our communications with individuals (correspondences, support tickets, sensory information including call and video recordings, and transcriptions and analyses thereof), contractual and billing details, as well as any expressed, presumed or identified needs, preferences, attributes and insights relevant to our potential or existing engagement.

Usage, login credentials, and device information concerning Users and Prospects:This includes certain connectivity, technical and aggregated usage data related to your interaction with our Services such asactivity logs, IP addresses, device data (such as type, operating system, device ID, browser version, location and language settings), your logincredentials, communication and performance logs, session recordings and analytics, issues and bugs, and thecookies and pixels installed or utilized on our Websiteand/or your device.

For the purposes of the California Consumer Privacy Act (“CCPA”),specifically in the last 12 months preceding the date this Privacy Policy was last updated, we have collected the personal information described above, which falls within these CCPA-defined categories: Identifiers; Customer Records Information; Professional or Employment-Related Information; Commercial Information; Internet or other Electronic Network Activity Information; Inferences; Audio, Electronic, Visual, Thermal, Olfactory, or Similar Information.

We do not use or disclose sensitive personal information as defined by the CCPA beyond what is necessary to provide our Services.

2. How we use your Personal Data

We use Personal Data as necessary for the performance of our Services and our contractual obligations (“Performance of Contract”); to comply with our legal obligations (“Legal Obligations”); to support our legitimate interests in maintaining and improving our Services, e.g. in understanding how our Services are used and how our campaigns are performing, and gaining insights which help us dedicate our resources and efforts more efficiently; in promoting our Services; providing customer services and technical support; and protecting and securing our Users, Prospects, Customers, ourselves and our Services (“Legitimate Interests”); or with your consent (“Consent”), when applicable, such as to inform you about offers and products in which you have expressed interest.

If you reside or are using our Services in a territory governed by privacy laws under which “consent” is the only or most appropriate legal basis for processing Personal Data as described in this Privacy Policy (either in general, based on the types of Personal Data you expect or elect to have processed by us, or due to the nature of such processing), your acceptance of ourTerms & Conditions(or the execution of another service agreement with Unleash) and this Privacy Policy will be deemed as your consent to the processing of your Personal Data for all purposes detailed in this Privacy Policy, unless applicable law requires a different form of consent. If you wish to revoke such consent, please contact us atprivacy@unleash.so.

Specifically, we use Personal Data for the following purposes and in reliance on the legal bases noted next to them:

Purpose	Lawful bases for processing
To facilitate, operate, enhance, and provide usage of our Services and all related features and functions	Performance of a Contract Legitimate Interests
To provide you with assistance and support, to test and monitor the Services, diagnose or fix technical issues	Performance of a Contract Legitimate Interests
To personalize our Services, including by recognizing an individual and remembering their information when they return to our Services, and to provide further localization and personalization capabilities	Performance of a Contract Legitimate Interests
To explore and pursue growth opportunities by facilitating a stronger local presence and tailored experiences	Performance of a Contract Legitimate Interests
To contact you with general or personalized service-related messages (such as password retrieval or billing issues), as well as promotional messages that may be of specific interest to you	Performance of a Contract Consent Legitimate Interests
To gain a better understanding on how individuals evaluate, use, and interact with our Services, to utilize such information to continuously improve our Services, offerings, and the overall performance, user-experience and value generated therefrom	Legitimate Interests
To create aggregated, statistical data, inferred non-personal data or anonymized or pseudonymized data (de-identified data), which we or others may use to provide and improve our respective Services, or for any other business purpose	Legitimate Interests
To enforce ourTerms & Conditions(“Terms”) and agreements, resolve disputes, and protect our business interests and the interests and rights of third parties	Legitimate Interests
To support and enhance our data security measures, including for the purposes of preventing and mitigating the risks of fraud, error or any illegal or prohibited activity	Legal Obligations Performance of a Contact Legitimate Interests
To comply with our contractual and legal obligations and requirements, and maintain our compliance with applicable laws, regulations and standards	Legal Obligations Performance of a Contact Legitimate Interests
To facilitate and optimize our marketing campaigns, ad management and sales operations, and to manage and deliver advertisements for our Services more effectively, including on other websites and applications. This may include contextual, behavioral and interests-based advertising based on your and other’s activities, preferences or other available data	Consent Legitimate Interests
To facilitate, sponsor and offer certain events, webinars and promotions	Legitimate Interests Consent
For any other lawful purpose, or other purpose that you consent to in connection with provisioning our Services	Legal Obligations Consent

3. How we protect and retain your Personal Data

a. Security: We have implemented appropriate technical, organizational and security measures designed to protect your Personal Data. However, please note that we cannot guarantee the complete security of the Personal Data processed by us. As the security of information depends in part on the security of the computer, 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.

b. Retention of your Personal Data:The information we collect will be retained as long as we deem it as reasonably necessary in order to maintain and expand our relationship and provide you with our Services and offerings, to comply with our legal and contractual requirements, or to have an accurate record of your dealings with us in the event of any complaints, challenges, disputes or legal issues, all in accordance with our data retention policy and applicable laws.

4. How wediscloseyour Personal Data

We may disclose Personal Data to third parties as described in this Policy and as further described below:

Service Providers: We engage selected third-party companies and individuals to perform both essential and complementary services that support our performance, Services, and offerings.Such service providers include providers of services such as hosting and server co-location, communications and content delivery networks (CDNs), billing and payment processing, data and cyber security, fraud detection and prevention, web and mobile analytics, e-mail, text messages and web/mobile notification distribution, monitoring and analytics, data optimization and marketing services, social and advertising networks, content providers, e-mail, voicemails, support and customer relations management systems, call and session recording services, and our legal, financial and compliance advisors(collectively, “Service Providers“);
Legal Compliance: If and to the extent necessary, we may disclose or allow access to regulators, courts or competent authorities, to your Personal Data, in order 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, to enforce our Terms, including investigations of potential violations thereof, to detect, prevent, or otherwise address fraud or security issues, or protect against harm to the rights, property or safety of Unleash, our Users, Customers, Prospects, Service Providers, yourself or the any member of the public;
Business customers: Our customers have access to any personal data we process on their behalf in our capacity as a “processor” or a “service provider”, as well as to personal data relating to their Users, as it relates to their use of our Services.
Change of Ownership: 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 will disclose your Personal Data to such third party (whether actual or potential) in connection with the foregoing events.
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 Personal Data in connection with the foregoing events;
Third Party Interactions: We enable you tointeractwith 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 Personal Data from you. Accordingly, we encourage you to read the terms and conditions and privacy policies of each Third Party Service.
Sharing your feedback or recommendations: If you submit a public review or feedback, note that we may (at our discretion) store and present your review on our sites and in our Services. If you wish to remove your public review, please contact us atprivacy@unleash.so.
Protecting rights and safety: We may share Personal Data with others if we believe in good faith that this will help protect the rights, property or personal safety of Unleash and our employees, any of our Prospects, Users or customers, or any members of the general public.
Additional disclosures: We may share or disclose Personal Data in additional manners, if you have provided us with your consent to disclose or transfer your Personal Data, or if we are legally obligated to do so, or if we have successfully rendered such data non-personal, non-identifiable and anonymous. We may transfer, share or otherwise use non-personal and non-identifiable data at our sole discretion and without the need for further approval.

In the past 12 months preceding the date this Privacy Policy was last updated, we may have disclosed to the third parties listed above the following CCPA-defined categories of personal information: Identifiers; Customer Records Information; Professional or Employment-Related Information; Internet or other Electronic Network Activity Information; Inferences; Audio, Electronic, Visual, Thermal, Olfactory, or Similar Information; and Location Information.

We may sell or share personal information, as such terms as defined under the CCPA. To learn more, please seeSection 7below.

5. Additional information regarding location and transfers of personal data

a.Data Location: Unleash and its Service Providers process Personal Data in Israel, the EU, the US and other locations, as necessary for the provision of our Services.

b.Data transfers: Unleash Labs Ltd. is headquartered in Israel, a jurisdiction recognized by the European Commission to provide adequate level of data protection to the Personal Data of EEA residents. The European Commission’s Adequacy Decision can be found here. Similarly, the UK Secretary of State and the Swiss Federal Data Protection Commissioner have awarded adequacy decisions to Israel. For cross-border data transfers not subject to adequacy decisions as described above, we use appropriate legal mechanisms to transfer such data, such as the standard contractual clauses adopted by the EU, and the UK (copies of these agreements can be shared with you upon request, please contact us at privacy@unleash.so).

6. Cookies and other tracking technologies

We and our Service Providersutilize “cookies”, anonymous identifiers and other tracking technologies in order to for us to provide ourServices, to analyze the performance of our Services and our marketing efforts, and present you with information that is customized to you. A “cookie” is a small text file that may be used, for example, to collect information about activity on the Website. Certain cookies and other technologies may serve to recall Personal Data, such as an IP address, previously indicated by a user. Most browsers allow you to control cookies, including whether or not to accept them and how to remove them. You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser.

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 such information to maintain and improveour Services.We do not combine the information collected through the use of Google Analytics with personal information: You may learn more about how Google collects and processes data specifically in connection with Google Analytics athttp://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 athttps://tools.google.com/dlpage/gaoptout/.

For more information about cookies and our practices, please see our Cookie Policy^‍‍

We reserve the right to remove or add new analytic tools.

7. Opt-out of sale and sharing/targeted advertising

Our disclosure of certain internet activity and device information with third parties through cookies or pixels may be considered a “sale” or “sharing” of personal information or processing for purposes of “targeted advertising” as such terms are defined under US State privacy laws. We do so in pursuit of the business and commercial purposes described inSection 2above.

In the last 12 months we have "sold" or "shared" or processed for targeted advertising, Internet or other electronic network activity information, Commercial Information, and Geolocation Information with our analytics and advertising partners and service providers.

You may opt out of all cookies that may result in a “sale” and/or “sharing” of your personal information or processing for purposes of targeted advertising in the following ways:

Click the “Cookie Settings” link available in the footerand select “Do Not Sell or Share my Personal Information”.
Set the Global Privacy Control (GPC) for each participating browser system that you use to opt out of the use of third-party Advertising/Targeting Cookies (instructions on how to download and use GPC are available).

8. Communications

We engage in services and promotional communications, throughemail, phone, SMS and notifications.

Services communications: We may contact you with important information regarding the Services. For example, we may send you notifications (through any of the means available to us) to inform you of changes or updates to our Services, billing issues, log-in attempts or password reset notices, etc. Please note that you will not be able to opt-out of receiving certain service communications which are integral to the provision of the Services.

Promotional communications: Subject to applicable regulations, we may also notify you about new features, additional offerings, events and special opportunities or any other information we think you will find valuable. We may provide such notices through any of the contact means available to us, through the Services, or through our marketing campaigns on any other sites or platforms. If you do not wish to receive such promotional communications, you may notify us at any time by sending an email to privacy@unleash.so or by following either of the following “unsubscribe”, “stop”, “opt-out” or “change email preferences” instructions contained in the promotional communications you receive.

9. Your Rights

Individuals have rights concerning their Personal Data. If you wish to exercise your privacy rights under any applicable law, including the EU or UK General Data Protection Regulation (“GDPR”), the Swiss Federal Act on Data Protection (“FADP”) or the California Consumer Privacy Act (“CCPA”), such as – to the extent applicable – the right to know/request access to (specific pieces of Personal Data collected; categories of Personal Data collected; categories of sources from whom the Personal Data was collected; purpose of collecting Personal Data; categories of third parties with whom we have disclosed Personal Data), to request rectification or erasure of your Personal Data held with Unleash, or to restrict or object to such Personal Data’s processing (including the right to direct us not to sell your Personal Data to third parties now or in the future), or to port such Personal Data, or the right to equal services and prices (e.g. freedom from discrimination) (each to the extent available to you under the laws which apply to you) – contact us atprivacy@unleash.so. If you are a GDPR-protected individual, you also have the right to lodge a complaint with the relevant supervisory authority in the EU or the UK, as applicable.

Please note that when you ask us to exercise any of your rights under this Policy or applicable law, we may need to ask you to provide us certain credentials to make sure that you are who you claim you are, to avoid the disclosure of your Personal Data to others and to ask you to provide further information to better understand the nature and scope of data that you request to access. Such additional data will be then retained by us for legal purposes (e.g., as proof of the identity of the person submitting the request).

We may redact from the data which we will make available to you, any Personal Data related to others.

10. Data Controller/Processor

Certain data protection laws and regulations, such as the EU and UK GDPR and the CCPA, typically distinguish between two main roles for parties processing personal data: the “data controller” (or under the CCPA, the “business”), who determines the purposes and means of processing; and the “data processor” (or under the CCPA, the “service provider”), who processes the data on behalf of the data controller (or business). Below we explain how these roles apply to our Services, to the extent that such laws and regulations apply.

Unleash is the data controller of Personal Data relating to Users and Prospects. In this capacity, we assume the responsibilities of a data controller under applicable data protection laws, as set forth in this Privacy Policy, and our Service Providers processing such data on our behalf will assume the role of data processors.

Unleash is the data processor of Personal Data relating to individuals contained in Customer Data. We process it on behalf of our Customers and strictly in accordance with our respective Customers’ documented instructions and as further stipulated in our Data Processing Addendum and other commercial agreements with them.

11. Additional notices and contact details

AI:We affirm that our organization does not use your Personal Data to develop, improve, or train generalized AI or machine learning (ML) models. This policy reflects our commitment to maintaining the highest standards of privacy and data protection.

Children: Our Services are not designed to attract children under the age of 16. We do not knowingly collect Personal Data from children and do not wish to do so. If we learn that a person under the age of 16 is using the Services, we will attempt to prohibit and block such use and will make our best efforts to promptly delete any Personal Data stored with us with regard to such a child. If you believe that we might have any such data, please contact us by e-mail atprivacy@unleash.so.

Database Controller: For the purposes of Israel’s Protection of Privacy Law, Unleash Labs Ltd. Serves as the “Database Controller” for the Personal Data covered by this Privacy Policy which it processes as a data controller, and may be contacted atprivacy@unleash.so.

Updates and amendments: We may update and amend this Privacy Policy from time to time by posting an amended version on our Services. The amended version will be effective as of the date it is published. We will provide prior notice if we believe any substantial changes are involved via any of the communication means available to us or via the Services. After such notice period, all amendments shall be deemed accepted by you.

Contact details: If you have any comments or questions regarding this Privacy Policy, or if you have any concerns regarding your Personal Data held with us, please contact us atprivacy@unleash.so.

Last updated: October , 2025.

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