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Welcome to https://bilton.tech/ website (“Website”). This Privacy Policy (“Privacy Policy”) is a legally binding agreement between you, the person or entity that will be accessing or using Our Website and/or services (referenced below as “You” or “Your”), and Bilton Technologies Inc. (referenced below as “Company”, “We”, “Us” or “Our”, as applicable), with respect to the use of the Website.

Company respects Your privacy and is committed to protect the Personal Information that You share with Us on Our Website and/or other services within Our Website. This policy describes the scope of Personal Information collection on Our Website and the usage of it.

By using Company’s Website, You acknowledge that You have reviewed both Our Terms and Conditions https://bilton.tech/terms-conditions/ and this Privacy Policy and agree to be bound by them. Please be aware that this Privacy Policy does not apply to the practices of any third parties to whom The Company may disclose Personal Information (as defined below) pursuant to the terms of this Privacy Policy.

While using the Website or using any of the services offered through it, including contacting Us, You may be requested to provide information, including Personal Information (as defined hereafter). You are not legally required to provide Personal Information, however in the event you refuse to provide your Personal Information, you may be unable to access and use the services on Our Website.

By using the Website You hereby acknowledge, agree and explicitly consent of your own free will and although not necessarily required to do so under applicable law, that your Personal Information, will be stored, processed, used, held and managed by Us and/or on Our behalf, inter alia, by means designated for digital processing or in other forms of database(s) in accordance with applicable law, for the purposes and in the manner described herein in this Privacy Policy.

This Privacy Policy may be occasionally updated. If We make any substantial changes in the manner We use Your Personal Information, then We will provide a proper notice.

1. FROM WHERE DO WE COLLECTION PERSONAL INFORMATION

We collect Personal Information that you voluntarily provide to Us and/or to which We gain access to in the course of your use of Our Website, including via automatically means.

• Personal Information you disclose to Us voluntarily:

We collect Personal Information that you voluntarily provide to Us when you express an interest in obtaining information about Us or Our services, when you participate in activities on the Website or when you otherwise contact Us.

The Personal Information that We collect depends on the context of your interactions with Us and Our Website, the choices you make and the services and features you use.

• Information automatically collected:

We automatically collect certain information when you visit, use or navigate Our Website and services. For more on certain types of such collection of information, please also see Our “COOKIES” section below.

• Information that We obtain from third party sources:

From time to time, We may receive Personal Information about you from third party sources, but only where We have checked that these third parties either have your consent or are otherwise legally permitted or required to disclose your Personal Information to Us. These third party sources include, for example, individuals with your contact information, or social media websites.

2. WHAT DATA AND PERSONAL INFORMATION WE COLLECT

Personal Information – Personal Information in this Privacy Policy refers to any information that We may collect from You and that You share with Us on the Website in respect of yourself and/or others, that may be used to identify an individual, either alone or in combination with other information, including, for example, Your contact information such as Your full name, email address, telephone, physical address, as well as any other non-public information about You that is associated with or linked to any of the foregoing data. The Personal Information types are collected in accordance with Your use of Our Website and may include:

Contact and identifiable information – Such as Your full name and/or nickname, a company or other entity to which You are affiliated, Your position, e-mail address and phone number.

Application/request information, questions, inquiries, comments, responses and/or derived correspondences with the Company.

Any information provided by You when You interact with Us.

Other Information – We may use other analytics tools to collect information about the use of the Website and types of technical data in the context of the use of the Website, including information about Your computer or mobile device or any other device and system, software, language preference etc.

We may collect, use, store, disclose, protect or otherwise process any Personal Information by lawful means, in a reasonable manner, and in accordance with this Privacy Policy. Any Personal Information, whether of You or of any third party, provided by You to Us on the Website, constitutes (i) Your consent to Our use, disclosure and processing of the Personal Information in accordance with this Privacy Policy and applicable laws, and (ii) a representation on Your side of its accuracy and truthfulness and a warranty that You have all necessary rights to share such Personal Information with Us and that We are entitled to rely on such representation. For the avoidance of doubt, We are not responsible for any Personal Information that is shared by You.

The Personal Information You shared with Us on the Website and/or collected by Us will be stored in Our database, for the purposes listed in section 3 below and in accordance with applicable law. You acknowledge that You are not required to provide Us with any Personal Information under applicable law. By sharing any Personal Information with Us on the Website, You understand and confirm that You do so at Your own risk, under Your own free will the appropriate necessary consents, and You release Us from any liability in this regard.

3. HOW DO WE USE YOUR PERSONAL INFORMATION – PURPOSE OF DATA COLLECTING AND PROCESSING

Generally, We use the information gathered to provide, improve, and develop Our Website and/or other services including to communicate with You, to offer You better services, and to protect Us and Our users. When You interact with or make use of Our Website and/or other services We use a variety of technologies to process the information that We collect about You for various reasons.

The purposes of Our collection and processing of information in the context of Our website are:

To operate Our Website and/or other services to Our users;

To address users’ applications, inquiries, questions, requests, comments, responses etc.

To study the users’ interaction with Our Website and/or to study the behavior of users in the context of their use of Our Website, for the purpose of assessing the Website performance and/or effectiveness.

To operate, evaluate, develop, manage, improve and enrich the information and the services

offered through the Website and create new services and content that meet the requirements and

expectations of users as well as modify or cancel existing services;

To prevent illegal and/or unauthorized use of Our Website and to comply with and enforce applicable legal requirements, relevant industry standards and policies, including this Privacy Policy and Our Terms and Conditions;

To increase and maintain the safety and security of Our Website and/or other services;

To fulfil contractual obligations with third parties;

For any other purpose required or permitted by applicable law or specified in this Privacy Policy;

4. LEGAL BASIS FOR PROCESSING

In addition to Your consent to the collection and processing of information as set forth herein, Our collection and processing of information, including Personal Information, is based on the following:

To the extent that We use the information, including Personal Information, to provide customer service and/or customer support and/or to interact with Our Website users, including addressing users’ applications, inquiries, questions, requests, comments and responses, the basis for Our collection of data is Our legitimate interest to conduct an effective interaction with Our users which are customers and/or potential customers.

To the extent that We use the information to analyze users’ interaction with Our Website, the basis for Our collection of data is Our legitimate interest to study the use of Our Website and the behavior of users in the context of their use of Our Website.

To the extent that We use the Personal Information for advertising or promotional activities, We will request Your specific, freely-given, unbundled, informed and separate consent to such uses.

5. INFORMATION SHARING AND DISCLOSURE

We are committed to protecting Your privacy and will not sell, trade, or otherwise share or disclose Your Personal Information, unless otherwise permitted under the following terms and/or circumstances:

When We have Your consent to share such information;

When We need to share Your information to provide the product and/or service You have requested as part of Our contractual relationship (our services providers that help Us run and manage Our business, such as technology service providers, analytics providers, utility providers);

When We need to send the information to service providers and partners who work on Our behalf to provide a product and/or service You have requested as part of Our contractual relationship (they are prohibited from using that information for any other purpose);

For the purpose of analysis and statistics, provided that such disclosure is done anonymously and is non-personal identifiable;

For Our subsidiaries and affiliates, for the purposes the information was provided by You or as reasonably necessary for Our internal administrative and business purposes;

In the event of sale or transfer, in whole or in part, of the Company or any of its affiliate’s shares or assets, in cases of mergers or in case of negotiations with respect to the foregoing;

In the event that the Company deems that the disclosure of the information is necessary in order to prevent serious damage to the bodies or property of the users or of any other party;

If required to do so by applicable law, or in the good-faith belief, that (i) disclosing such information is necessary to comply with any applicable law or respond to any court order, search warrant or equivalent, or where in reasonable belief an action is needed in order to protect the personal safety of any individual; and (ii) such disclosure is appropriate or necessary in order to enforce the Terms and Conditions, take precautions against liabilities, investigate and defend4 against any third party claims or allegations, assist government enforcement agencies, protect the security or integrity of Our Website and servers and protect Our rights and property.

All Personal Information as described above may be stored on servers and/or transferred (for the above purposes) to recipients which may be located outside of Israel, and in some cases may have a lower level of protection than that within the applicable law. You acknowledge and agree to such transfer of personal information, and the Company undertakes that it will take the necessary measures to ensure a sufficient level of protection.

Other than as described above, any other transfer of Your Personal Information to third parties will be subject to Your consent.

6. COOKIES

We have not sold consumer information for any monetary value. However, Our use of cookies, advertising and tracking technologies may be a “sale” under certain U.S. state consumer privacy laws. This use of tracking technologies may also constitute “sharing” under certain U.S. state consumer privacy laws.

We may also collect Personal and Non-Personal Information through automatic means, for instance by using industry-wide technologies such as cookies (a string of information that can be stored on Your device, if Your device is set to permit storage of cookies), or other similar tracking technologies, which store certain local information on Your device to help Us learn more about how You use Our Website and enhance Your experience. We may use third-party service providers in order to process such information.

Cookies are alphanumeric identifiers that are transferred to and stored in Your electronic device through Your web browser for record-keeping purposes. Some cookies allow making it easier for You to navigate, while others are used to enable a faster log-in process or to allow Us to track Your activities.

We use cookies to ensure You get the best experience on the Website. You can choose to enable or disable Cookies in Your internet browser or delete them. If You choose to enable or delete them, it may have an impact on Your User experience on the Website for example You may not be able to use certain features on Our Website.

7. DATA RETENTION & SECURITY

We may retain all or any part of the information We collect or that you share with Us for as long as required for the provision of Our services through the Website or if it is necessary to fulfil the purpose for which the information has been collected. In addition, We may also retain such information for as long as required to comply with Our legal or business requirements or obligations, to resolve disputes, to enforce Our T&C, all as permitted under any applicable laws. Statistics and analysis which have been anonymised may be saved thereafter and may remain on Our servers indefinitely.

We will take commercially reasonable measures in providing secure transmission of your information across the internet to Our servers, and in securing the data which relates your information while at rest, as applicable.

We may use Cloud Service Providers for Our servers and\or storage, which are located within the EU/EEA, or in a location where the EU has determined that it is acceptable to store such information in accordance with an adequacy decision. In such cases, We rely on the security measures taken by such providers for the physical security, the integrity, redundancy and the data protection of the data which relates your information. You acknowledge and agree to such transfer and/or storage of Personal Information, and We undertake to take the necessary measures to ensure a sufficient level of protection in accordance with applicable laws.

However, you should be aware that there is always certain risk involved in transmitting information over the internet and that there is also some risk that others could find a way to thwart Our and/or the Cloud Service Provider security systems. As a result, while We strive to protect your information, We cannot ensure the security and privacy of your Personal Information or other content you may have provided while using Our Website, and you do so at your own risk and free will. We encourage you to exercise discretion regarding the Personal Information you choose to disclose.

8. DATA SUBJECT RIGHTS

You may at any time request a review, rectification (including correction and update), portability and erasure of your Personal Information. Please note however that deletion of certain Personal Information may result in the inability to provide you with any of Our services and/or process your applications/inquiries. You also have the right to request a copy of your Personal Information from Our records and/or to request a limitation of the use of your Personal Information or the termination of use of your Personal Information.

If you wish to act in accordance with the above, you can send Us an e-mail with your request to: support-us@bilton.tech and We will make reasonable efforts to respond within a reasonable period of time, and pursuant to any applicable laws.

If you choose to exercise any of these rights, We will not discriminate against you in any way. If you exercise certain rights, understand that you may be unable to use or access certain features of the Website or Our services or properties .

If We do not grant your consumer request, you may have the right to appeal that denial .

DO WE COLLECT INFORMATION FROM MINORS ?

9. We do not knowingly solicit data from or market to children under 18 years of age. By using the Website, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Website. If We learn that Personal Information from users less than 18 years of age has been collected, We will deactivate the account and take reasonable measures to promptly delete such data from Our records. If you become aware of any data We may have collected from children under age 18, please contact Us at support-us@bilton.tech.

10. PRIVACY INQUIRIES

If you have any questions or queries about this Privacy Policy or regarding the way or manner We collect or process Personal Information, you may contact Us via e-mail at: support-us@bilton.tech.

11. ADDITIONAL CALIFORNIA PRIVACY DISCLOSURES

These Additional California Privacy Disclosures supplement the information contained in this Privacy Policy. These Disclosures apply only to Our processing of your Personal Information for individuals residing in California and should be understood to apply to such residents as a supplement to the Privacy Policy.

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits Our users who are California residents to request and obtain from Us, once a year and free of charge, information about categories of Personal Information (if any) We disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which We disclosed Personal Information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to Us using the contact information provided below.

We do not collect Sensitive Personal Information

If you are a California resident, you may be entitled to certain rights (in addition to those in the Privacy Policy above). These rights are described below :

Right to know regarding sale of Personal Information: You have the right to know whether We sell your Personal Information to third parties; the categories of Personal Information that We sold or disclosed for a business purpose; the categories of third parties to whom the Personal Information was sold or disclosed for a business purpose; and the business or commercial purpose for collecting or selling Personal Information .

Right to opt out of sale or sharing of your Personal Information: You have the right to opt out of the sale or sharing of your Personal Information. You can opt out from the collection and sharing of your Performance and Targeting Cookies as described in the “COOKIES” section in the Privacy Policy. Upon receiving a request to opt-out, We will act upon the request as soon as feasibly possible, but no laterthan 15 days from the date of the request submission .

Last updated: November 2024