This privacy policy (“Privacy Policy”) explains how CloudAlly Ltd. (“CloudAlly”, “we”, “our” or “us”) collect, use and share information about you. We have created this Privacy Policy in keeping with our commitment to protecting your privacy, to comply with global data protection laws and regulations, and to keep you informed about our personal information protection practices. This Privacy Policy applies to CloudAlly’s collection and use of personal information belonging to you or other persons, such as in the following use cases: (i) When you browse or visit our website, available at: cloudally.com (“Website”);

(ii) When you subscribe for a free trial to our services and web-based applications and when you subscribe for an account;

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

(iv) When you contact us (e.g. customer support, need help, submit a request)

(v) When you attend a marketing event and provide us with your personal data

(vi) When you exchange business cards with us

(vii) When we use the personal data of our customers (e.g. contact details)

(viii) When we use the personal data of our resellers, distributors, agents and/or finders (e.g. contact details)

(ix) When we use the personal data of our service providers (e.g. contact details)

(x) When you interact with us on our social media profiles (e.g., Facebook, Instagram, Twitter, LinkedIn)

We make every effort to provide a platform that would live up to the highest of user privacy standards. Please read this Privacy Policy carefully, so you can fully understand our practices in relation to personal data. “Personal data” means any information that can be used, alone or together with other data, to uniquely identify any living human being.

Important note: Nothing in this Privacy Policy is intended to limit in any way your statutory right, including your rights to a remedy or means of enforcement.

Table of contents:

1. What Information We Collect, Why We Collect It And How It Is Used

2. How We Protect And Retain Your Information

3. How We Share Your Personal Data

4. Storage Of Personal Data

5. Your Privacy Rights

6. Use By Children

7. Interaction With Third Party Products

8. Log Files

9. Analytic Tools

10. Your Choices

11. California Notices

12. Updates to our Privacy Policy

13. How to contact us

This Privacy Policy can be updated from time to time and, therefore, we ask you to check back periodically for the latest version of this Privacy Policy. If we implement significant changes to the use of your personal data in a manner different from that stated at the time of collection, we will notify you by posting a notice on our Website or by other means. Please check the “Last Updated” notice at the top of this to see when the Policy has been most recently updated. Your continued use of our Website and Products constitutes acceptance of any changes to this Policy.

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

When you browse, or visit, our Website, we collect data about you through Cookies, analytic tools and log files. A “cookie” is a small text file that may be used, for example, to collect information about activity on our 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. For more information, please read our cookie policy available at: https://cloudally.com/cookies.We collect this data in order to analyze trends, administer the Website, track users’ movement around the Website, and gather demographic information. We use anonymous identifiers in order for us to present you with customized information, and in order to track users. We also use Google Analytics to maintain and improve the Website and our products. We do not combine the information collected through the use of Google Analytics with personally identifiable information. We share this information with third party platforms, such as HubSpot (marketing automation), Salesforce (CRM), and Google Analytics.

When you sign up for a free trial to our service and when you sign up and subscribe for an account, you will provide us with your full name and your email address. We determine your IP address. We collect this information prior to or in connection with entering into a contract. We share this information with third party platforms, such as Salesforce, HubSpot, Salesforce, HotJar, and Google Analytics.

When you subscribe to our monthly newsletter, you will provide us with your email address. We collect this information to send you our newsletter and send you marketing communications. We share this information with third party platforms, such as HubSpot and Google Analytics.

When you contact us (e.g. customer support, need help, submit a request), you will provide us with the following information: full name, email address, country, and any messages or other information you wish to share with us. We use this information to answer your questions and to provide support (e.g. to solve problems, bugs or issues). We share this information with third party platforms, such as Salesforce, HubSpot, Google Analytics and ZenDesk. We also use your name and e-mail details that you provide us with in order to send you marketing communications.

When you attend a marketing event, you may provide us with your business cards and/or provide us with your personal data for marketing purposes. We collect personal data that you provide us with, such as your full name, e-mail address, phone number (optional), company name, job title, country, and any other information you may wish to share with us. We use this information to establish a business connection and to send you marketing communications. We share this information with third party platforms, Salesforce, HubSpot and Google Analytics.

When we use the Personal Data of our service providers, we collect the following Personal Data from our service providers: full name, email address, phone number, company name, job title, country, and any other data our service providers may choose to share with us. We collect this information in order to communicate with and perform the applicable agreement with our service providers. We share this information with third party platforms, such as Hubspot, Salesforce, Zooz, Green Invoice (processing of payments).

Please note that some of the abovementioned personal data will be used for detecting, taking steps to prevent, and prosecution of fraud or other illegal activity, to identify and repair errors, to conduct audits, and for security purposes. Personal Data may also be used to comply with applicable laws, with investigations performed by the relevant authorities, law enforcement purposes, and/or to exercise or defend legal claims. In certain cases, we may or will anonymize or de-identify your personal data. “Anonymous Information” means information which does not enable identification of an individual user, such as aggregated information about the use of our services. We may use Anonymous Information and/or disclose it to third parties without restrictions (for example, in order to improve our services and enhance your experience with them).

Finally, please note that we will retain the information described above for the shorter of such time as you send us a valid deletion request, we no longer need it and we proactively delete it, and in accordance with local data retention laws.

2. HOW WE PROTECT AND RETAIN YOUR INFORMATION

2.1. Security. We have implemented appropriate technical, organizational and security measures designed to protect your personal data. However, please note that we cannot guarantee that the information will not be compromised as a result of unauthorized penetration to our servers. 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.

2.2. Retention of your personal data. In addition to the retention periods mentioned above, 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.

3. HOW WE SHARE YOUR PERSONAL DATA

In addition to the recipients described above, we may also share your personal data as follows:

3.1. as needed to enforce CloudAlly’s Terms of Use, policies and any other contractual relationships with our customers;

3.2. when we have a good faith belief that the disclosure is necessary to prevent or respond to fraud, defend our website or products against possible attacks, or protect the property and safety of CloudAlly, our customers or the public;

3.3. as required by law, such as to comply with a subpoena, warrant, regulatory oversight or similar legal process;

3.4. in connection with any potential sale, transfer, merger, consolidation or other transaction involving all or part of our company.

3.5. to companies that provide services that help us with our business activities such as processing customer payments. These companies are authorized to use personal data only as necessary to provide these services to us; and

3.6. to companies that work with CloudAlly on various projects; for example, CloudAlly may share personal data for customer relationship management purposes, email marketing purposes, to our reselling partners, or with other companies whose products or services we think may be of interest to our customers in joint marketing and support efforts.

4. STORAGE OF PERSONAL DATA

4.1. Storage:

AWS – US (North Virginia), Canada (Central), Asia Pacific (Sydney), EU (Ireland), EU (Frankfurt) and UK (London).

4.2. Access from locations outside of the EU: If we access personal data that we store from outside the EU, we will do so only from a country covered by the European Commission’s Adequacy Decision . You can read more here: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en.

4.3. Internal transfers: Transfers within the CloudAlly group will be covered by an internal processing agreement entered into by members of the CloudAlly group (an intra-group agreement) which contractually obliges each member to ensure that personal data receives an adequate and consistent level of protection wherever it is transferred to.

4.4. External transfers: Where we transfer your personal data outside of EU/EEA (for example to third parties who provide us with services), we will obtain contractual commitments from them to protect your personal data.

5. YOUR PRIVACY RIGHTS.

Rights: You may have certain rights under applicable privacy laws (example: EU General Data Protection Regulation GDPR), such as accessing, correcting and deleting Personal Data, objecting to processing of Personal Data, withdrawing of consent to processing Personal Data. To the extent such privacy laws apply to you, we will respect your rights and comply with such laws.

You can exercise your rights by contacting us at support@cloudally.com. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly or inform you if we require further information in

order to fulfil your request. When processing your request, we may ask you for additional information to confirm or verify your identity and for security purposes. We reserve the right to charge an appropriate administrative fee where permitted by law. In the event that your request would adversely affect the rights and freedoms of others (for example, would impact the duty of confidentiality we owe to others) or if we are legally entitled to deal with your request in a different way than requested, we will address your request to the maximum extent possible, all-in accordance with applicable law.

6. USE BY CHILDREN

We do not offer our products or services for use by children and, therefore, we do not knowingly collect personal data from, and/or about children under the age of eighteen (18). If you are under the age of eighteen (18), do not provide any personal data to us without involvement of a parent or a guardian. In the event that we become aware that you provide personal data in violation of applicable privacy laws, we reserve the right to delete it. If you believe that we might have any such information, please contact us at: privacy@cloudally.com.

7. INTERACTION WITH THIRD PARTY PRODUCTS

We enable you to interact with 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.

8. LOG FILES

We use log files. The information inside the log files includes internet protocol (IP) addresses, type of browser, Internet Service Provider (ISP), date/time stamp, referring/exit pages, clicked pages and any other information your browser may send to us. We use such information to analyze trends, administer the Website, track users’ movement around the Website, and gather demographic information.

9. ANALYTIC TOOLS

9.1. 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. We do not combine the information collected through the use of Google Analytics with Personal Data we collect. 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/.

9.2. HubSpot. We use a software called “HubSpot”, an email marketing and analytics platform to understand the use of our services. HubSpot is exposed to unique identifiers and technical data, such as IP address of the internet service provider. The use of this data allows us to analyze our campaigns and performance, as well as your browsing habits and characteristics. HubSpot’s terms of use (available at: https://legal.hubspot.com/website-terms-of-use) and privacy policy (available at: https://legal.hubspot.com/privacy-policy ) also apply to the use of HubSpot.

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

10. Your Choices

You have certain choices about your personal data. Where you have consented to the processing of your personal data, 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 data regarding your activities on our services and for other legal purposes as described above. We will address any issue to the best of our ability as soon as possible. We will process such requests in accordance with applicable laws. To protect your privacy, we will take steps to verify your identity before fulfilling your request.

11. California Notices

11.1. California Privacy Rights. California Civil Code Section 1798.83 permits our customers who 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 an email to privacy@cloudally.com. Please note that we are only required to respond to one request per customer each year.

11.2. Deletion of Content from California Residents: If you are a California resident under the age of 18 and a registered user, California Business and Professions Code Section 22581 permits you to remove content or personal information you have publicly posted. If you wish to remove such content or personal information

and you specify which content or personal information you wish to be removed, we will do so in accordance with applicable law. Please be aware that after removal you may not be able to restore removed content. In addition, such removal does not ensure complete or comprehensive removal of the content or personal information you have posted and that there may be circumstances in which the law does not require us to enable removal of content.

11.3. California Do Not Track Notice: We do not currently respond or take any action with respect to web browser “do not track” signals or other mechanisms that provide consumers the ability to exercise choice regarding the collection of personally identifiable information about an individual consumer’s online activities over time and across third-party web sites or online services. We may allow third parties, such as companies that provide us with analytics tools, to collect personally identifiable information about an individual consumer’s online activities over time and across different web sites when a consumer uses the Site.

12. How to contact us

If you have any questions, concerns or complaints regarding our compliance with this notice and the data protection laws, or if you wish to exercise your rights, we encourage you to first contact us at privacy@cloudally.com.