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Consumer App Privacy Policy

Cliamcell Privacy Policy

Last updated: July 30, 2019

1. Introduction

Climacell, Inc. ("us", "we" or "Company") respect the privacy of our users (each, "you" or "User") and are committed to protect the privacy of Users who access, download, install or register to our mobile application (the "Application"), or any other online services we provide (collectively: the "Services"). The Company has prepared this Privacy Policy to outline our practices with respect to collecting, using and disclosing your information when you use the Services.

Unfortunately, the Services are currently not available to users in the EEC who are under 16 years old. If you are a resident of the EEC and are not at least 16 years old, do not use the Services and do not provide us with any personal data relating to you. We reserve the right to access and verify any Personal Information collected from you by us. In the event that we become aware that an individual under the age of 16 has shared any information, we will discard such information. If you have any reason to believe that a minor has shared any information with us, it will be advisable to contact us at: support@climacell.co.

We encourage you to read the Privacy Policy carefully and use it to make informed decisions. By using the Services, you agree to the terms of this Privacy Policy and your continued use of the Services constitutes your ongoing agreement to the Privacy Policy. If you do not agree with this Privacy Policy, please do not use the Services and do not provide us with any information.

The Privacy Policy is a part of the Terms of Service and is incorporated therein by reference.

In this Privacy Policy you will read about, among other things:

▪ What type of information we collect
▪ Mobile analysis and Google Analytics
▪ How we use the information
▪ With whom we share the information and for what purpose
▪ For how long we retain the information
▪ Your privacy rights
▪ How we protect your information
▪ International Transfers
▪ Marketing
▪ How to contact us

2. What type of information we collect

We may collect two types of data and information from our Users.

The first type of information is un-identified and non-identifiable information pertaining to you, which may be made available or gathered via your use of the Services ("Non-personal Information"). We are not aware of the identity from which the Non-personal Information is collected. Non-personal Information which is collected may include your aggregated usage information and technical information transmitted by your device, including certain software and hardware information about your device (e.g., the device you use, the type of browser and operating system your device uses, language preference, access time and the website's domain name from which you linked to the Services, etc.), in order to enhance the functionality of the Services. We may also collect information about your activity on the Services (e.g., clicks, actions, online browsing, etc.).

The second type of information is individually identifiable information, namely information that identifies an individual or may with reasonable effort identify an individual ("Personal Information"). Such information may include:

• Account Information: When you sign-up and register to the Services, you will be asked to provide us certain details about yourself. When you register to the Services through the Application, we may collect from you the following information: full name, phone number, email address, as well as any other information you agreed to share with us.

• Voluntarily Information: We may collect information which you provide us voluntarily. For instance, when you respond to communications from us, communicate with us via email or share additional information about yourself through your use of the Services. We may also collect the feedback, suggestions, complaints and reports which you send to us. Please note that we may also collect complaints about you from other Users, which may include your Personal Information.

• Device Information: We may collect Personal Information from your device. Such information may include geolocation data, IP address, unique identifiers, as well as other information which relates to your activity through the Services.

For avoidance of doubt, if we combine Personal Information with Non-personal Information, the combined information will be treated as Personal Information as long as it remains combined.

3. Mobile analysis and Google Analytics

We may use various tracking technologies or methods of web and mobile analysis (e.g., Mixpanel, Pixels, etc.) to gather, store, and track certain information related with your access to and activity through the Services.

We may also use a tool called Google Analytics to collect information about your use of the Services. Google Analytics collects information such as how often users access the Services, what pages they visit when they do so, etc. We use the information we get from Google Analytics only to improve our Services. Google Analytics collects the IP address assigned to you on the date you visit sites, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Google’s ability to use and share information collected by Google Analytics about your visits to this site is restricted by the Google Analytics Terms of Service and the Google Privacy Policy. For information about opting-out of Google Analytics cookies, click here.

4. How we use the information

We use and share Personal Information in the manners described in this Privacy Policy. In addition to the purposes listed above, the information we collect, which may include your Personal Information, is used for the following purposes:

• To set up your account and to provide the Services;

• To allow you to share and view content shared on the Services;

• To identify and authenticate your access to certain features of the Services;

• To send you relevant push notifications, which are based on different activities offered by the Services, such as: weather alerts, etc.

• To communicate with you and to keep you informed of our latest updates (e.g., via text messages and/or email massages);

• To market our website, products and the Services;

• To perform a research or to conduct analytics in order to improve and customize the Services to your needs and interests;

• To support and troubleshoot the Services and to respond to your queries;

• To investigate and resolve disputes in connection with your use of the Services;

• To detect and prevent fraudulent and illegal activity or any other type of activity that may jeopardize or negatively affect the integrity of the Services; and

• To investigate violations and enforce our policies, and as required by law, regulation or other governmental authority, or to comply with a subpoena or similar legal process or respond to a government request.

5. With whom we share the information and for what purpose

We do not rent, sell, or share your Personal Information with third-parties except as described in this Privacy Policy.

We may share Personal Information with the following recipients: (i) our subsidiaries; (ii) affiliated companies; (iii) subcontractors and other third-party service providers (e.g., Drift, HubSpot, SupportYourApp); (iv) auditors or advisers of our business processes; and (v) any potential purchasers or investors in the Company.

In addition to the purposes listed in this Privacy Policy, we may share Personal Information with our recipients for any of the following purposes: (i) storing or processing Personal Information on our behalf (e.g., cloud computing service providers – Google Cloud (GCP) and Amazon Cloud Services (AWS)); (ii) processing such information to assist us with our business operations; (iii) performing research, technical diagnostics, personalization and analytics and (iv) communicating promotional and informational materials, in accordance with our marketing policy (see below under "Marketing").

We may also disclose Personal Information, or any information you submitted via the Services if we have a good faith belief that disclosure of such information is helpful or reasonably necessary to: (i) comply with any applicable law, regulation, legal process or governmental request; (ii) enforce our policies, including investigations of potential violations thereof; (iii) investigate, detect, prevent, or take action regarding illegal activities or other wrongdoing, suspected fraud or security issues; (iv) to establish or exercise our rights to defend against legal claims; (v) prevent harm to the rights, property or safety of us, our affiliates, our Users, yourself or any third-party; (vi) for the purpose of collaborating with law enforcement agencies; and (vii) in case we find it necessary in order to enforce intellectual property or other legal rights.

6. Third-party collection of information

Our Privacy Policy only addresses the use and disclosure of information we collect from you. To the extent that you disclose your information to other parties via the Services (e.g., by clicking on a link to any other website or location) or via other sites throughout the Internet, different rules may apply to their use or disclosure of the information you disclose to them.

You acknowledge that we are not responsible for the products, services, or descriptions of products or services that you receive from third-party sites or to the content or privacy practices of those sites, and that this Privacy Policy does not apply to any such third-party products and services. You are knowingly and voluntarily assuming all risks of using third-party sites to purchase products and services. You agree that we shall have no liability whatsoever with respect to such third-party sites and your usage of them.

7. Your privacy rights

We respect your privacy rights and therefore you may contact us at any time and request: (i) to access, delete, change or update any Personal Information relating to you (for example, if you believe that your Personal Information is incorrect, you may ask to have it corrected or deleted); or (ii) that we will cease any further use of your Personal Information (for example, you may ask that we will stop using or sharing your Personal Information with third-parties) or that we shall remove your Personal Information (subject to any other legal obligation that may require us to keep the information).

If you wish to raise a complaint on how we have handled your Personal Information, please contact us directly at: support@climacell.co.

If you are not satisfied with our response or believe we are collecting or processing your Personal Information not in accordance with the laws, you can complain to the applicable data protection authority.

8. For how long we retain the information

Please note that unless you instruct us otherwise and to the extent permitted by applicable law, we will retain personal information about you for the period of time appropriate for us to fulfill the purposes outlined in this policy or as necessary to comply with our legal obligations, resolve disputes or enforce our agreements, whichever is longer. We may delete information from our systems, without notice to you, once we deem it is no longer necessary for the purposes set forth above.

We may rectify, replenish or remove incomplete or inaccurate information, at any time and at our own discretion.

9. How we protect your information

We take great care in implementing and maintaining the security of the Services and your information. We employ industry standard procedures and policies to ensure the safety of your information, and prevent unauthorized use of any such information. Although we take reasonable steps to safeguard information, we cannot be responsible for the acts of those who gain unauthorized access or abuse the Services, and we make no warranty, express, implied or otherwise, that we will prevent such access.

If you feel that your privacy was treated not in accordance with our Privacy Policy, or if any person attempted to abuse the Services or acted in an inappropriate manner, please contact us directly at support@climacell.co.

10. Corporate transaction

We may share information, including Personal Information, in the event of a corporate transaction (e.g., sale of a substantial part of our business, merger, consolidation or asset sale of an asset or transfer in the operation thereof) of the Company. In the event of the above, the acquiring company or transferee will assume the rights and obligations as described in this Privacy Policy.

11. Updates or amendments to the Privacy Policy

We may revise this Privacy Policy from time to time, in our sole discretion, and the most current version will always be posted on our website (www.climacell.co/legal) or Application (as reflected in the "Last Revised" heading). In the event of a material change to the Privacy Policy, we will notify you through the Services or

via email, or you may be notified within the Application. We encourage you to review this Privacy Policy regularly for any changes.

Your continued use of the Services, following the notification of such amendments, constitutes your acknowledgement of such amendments to the Privacy Policy and your agreement to be bound by the terms of such amendments.

12. International Transfers

Your Personal Information may also be transferred to countries which are not part of the European Union, namely Israel and the USA for storage and for the management of our services, including at our headquarters. In order to ensure an adequate level of security of your personal data in these countries, we provide and maintain the following guarantees: transfer to countries subject to an EC adequacy decision, SCC, and/or privacy shield certification. You hereby consent to the transfer of Personal Information to countries outside the European Union.

13. Marketing

We may use your Personal Information, such as your full name, email address, etc. ourselves or by using our third-party subcontractors for the purpose of providing you with promotional materials, concerning the Services.

Out of respect to your right to privacy we provide you within such marketing materials with means to decline receiving further marketing offers from us. In addition, at any time, you may request to unsubscribe and discontinue receiving marketing offers by sending us a blank message with the word "remove" to support@climacell.co.

Please note that even if you unsubscribe from our marketing mailing list, we may continue to send you service-related updates and notifications.

14. How to contact us

If you have any general questions regarding the Services or the information that we collect about you and how we use it, please contact us at support@climacell.co

15. Information about us

The details of the Company are as follows:
Climacell, Inc. 280 Summer St. 8th Floor Boston, MA 02210 USA