SNTA Privacy and Data Protection Policy and Notice

Last Revised: March 26, 2025

S.N.T.A Ltd (“SNTA”, “we”, “us” or “our”) provides an Intelligence as a Service (Iaas) in the form of ‘reliability reports’ to its clients concerning their employees and potential employment candidates (“Reliability Reports”). These Reliability Reports are nearly based solely off of publicly-available information, such as social media and public reports, and focus on any activity of such employees or employment candidates connected with illegal, immoral or highly questionable behavior, such as hate speech, racism, criminal associations, terrorist sympathies, financial difficulties and other activity that may negatively reflect on the reliability or otherwise of the individual concerned (“Services”).

We are committed to protecting the personal information that is shared with us. SNTA respects the privacy of its former and current employees and employment candidates, directors, officers, management, representatives, clients, service providers, website visitors and any individuals whose data is collected and analyzed in connection with your interest or engagement with us, our provision of the Services or when accessing our website (these and any others with respect to whom we collect personal data shall collectively be referred to as the “Data Subjects” or “you”).

This Privacy and Data Protection Policy and Notice (“Privacy Policy”) explains the types of information we might collect from or about you, that we receive from you or that may be provided to us in the course of your interest in or engagement with us or interest in or use of our Services or when you visit our website. Please read this Privacy Policy carefully in order to understand our practices regarding the processing of your personal data.

1. INFORMATION ABOUT US

We are incorporated in the State of Israel (“Israel”) and our business address is 14 Arye Shenkar Street, Herziliya 472514, Israel.
For the purposes of the European Union’s (“EU”) General Data Protection Regulation 2016/679 (“GDPR”) and other applicable privacy laws, SNTA is a data controller (“Controller”) in relation to the personal data of our former and current employees and employment candidates, directors, officers, management, representatives, clients, service providers, website visitors and whistleblowers. Likewise, SNTA is a Business (as defined under the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (together, “CCPA”)), and other US state privacy laws, subject to their applicability to SNTA.
For the purpoes of the GDPR and other applicable privacy laws, SNTA is a data processor (“Processor”) in relation to your personal data processed in connection with our provision of the Services. Likewise, SNTA is a Service Provider (as defined under the CCPA and other US state privacy laws, subject to their applicability to SNTA). Therefore, when processing such personal data, we are doing so on behalf of our clients, who are Controllers of such personal data and such processing is governed by the applicable Data Processing Agreement (“DPA”) with the relevant Controller (i.e., client). If your personal data is provided to us by a client in connection with the provision of the Services, please contact our relevant client in order to receive further informaton regarding the processing of your personal data in connection with the Services.

2. INFORMATION WE COLLECT AND HOW WE COLLECT IT

Summary: We collect various categories of personal data in order to meet our contractual obligations and various legal obligations and legitimate interests, such as fraud prevention.

We collect data about you in connection with your engagement with us and in connection with our provision of the Services. We collect several categories of personal data (“Personal Data”) as described below:

1. Engagements with Employees and Consideration of Employment Candidates:

Sources of Personal Data

We obtain your Personal Data from you directly, for example, during the course of your employment, when you apply for a position with SNTA and submit an employment application or during an interview. We also obtain your Personal Data from our third-party service providers who analyze your candidacy for us.

Personal Data that We Collect and Process

Your name (first and last), social security or identification number, mailing address, email address, phone number, age, gender, salary, education, professional designation, personal hobbies and activities, medical history, employment history, credit history, resume details, references, interview notes, performance review notes, and emergency contact information.

You do not have any legal obligation to provide any information to us. However, we require the information mentioned above in order to fulfill our legal obligations in connection with your employment with us or in order to reasonably evaluate you as a candidate for employment with us. If you choose not to provide us with such information, then we may not be able to fulfill our legal obligations in connection with your employment or complete our evaluation and consideration of your candidacy.

Subject to the applicability of a specific privacy law (including CCPA) to SNTA, the aforementioned types of Personal Data that we collect from you correspond to the following categories of personal information collected by us within the past 12 months (depending on which other privacy laws may apply, it may be earlier than 12 months prior) in our role as a “business” (as defined in CCPA) or similar equivalent in other privacy laws:

• Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers;
• Any information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. “Personal information” does not include publicly available information that is lawfully made available to the general public from federal, state, or local government records;
• Characteristics of protected classifications under California or federal law;
• Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an internet website application, or advertisement;
• Professional or employment-related information;
• Education information; and
• Inferences drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Why Do We Collect Your Personal Data and What are the Lawful Bases?

Purpose for Processing	Lawful Basis
Fulfillment of our contractual obligations to you within the framework of your employment with us	Performance of a Contract
Evaluation of your candidacy for employment with us	Legitimate Interests
General business management	Legitimate Interests
Statutory reporting obligations	Legal Obligation

If you object to our use of your Personal Data for the aforementioned purposes, please contact us at [email protected].

Subject to the applicability of a specific privacy law (including CCPA) to SNTA, the following are business or commercial purposes for which we collect and disclose each category of Personal Data. Details about the information we collect for each category are provided above in the sub-section titled, “Personal Data that We Collect and Process”, of this Section 2.1 (Engagements with Employees and Consideration of Employment Candidates).

Categories of Personal Information	Business or Commercial Purposes
Identifiers	“Helping to ensure security and integrity to the extent the use of the consumer’s personal information is reasonably necessary and proportionate for these purposes.” “Performing services on behalf of the business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of the business.” “Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business.”
Personal Information
Characteristics of protected classifications
Professional or employment-related information
Education information
Inferences
Internet or other electronic network activity information	“Helping to ensure security and integrity to the extent the use of the consumer’s personal information is reasonably necessary and proportionate for these purposes.”

2. Engagements with Clients and Service Providers:

Sources of Personal Data

We may obtain your Personal Data from you directly or publicly-available sources, for example, your website or social media sites.

Personal Data that We Collect and Process

Your business name, name (first and last) of your representative, business mailing address, business email address, business phone number, business payment details, and job title of your representative. For the purposes of anti-money laundering requirements, we may also collect your date of birth, information from utility bills, copies of passports or identification cards, and nationality and/or citizenship.

You do not have any legal obligation to provide any information to us. However, we require the information mentioned above in order to fulfill your order or to process and respond to your inquiry, and to provide the Services. If you choose not to provide us with such information, then we may not be able to fulfill your order, respond to your inquiry or provide you with some or all of the Services.

Subject to the applicability of a specific privacy law (including CCPA) to SNTA, the aforementioned types of Personal Data that we collect from you correspond to the following categories of personal information collected by us within the past 12 months (depending on which other privacy laws may apply, it may be earlier than 12 months prior) in our role as a “business” (as defined in CCPA) or similar equivalent in other privacy laws:

• Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers;
• Any information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. “Personal information” does not include publicly available information that is lawfully made available to the general public from federal, state, or local government records;
• Characteristics of protected classifications under California or federal law;
• Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies;
• Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an internet website application, or advertisement;
• Professional or employment-related information; and
• Inferences drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Why Do We Collect Your Personal Data and What are the Lawful Bases?

Purpose for Processing	Lawful Basis
Fulfillment of our contractual obligations to you, such as fulfillment of your order(s)	Performance of a Contract
Establishment and management of our relationship with you	Legitimate Interests
Increasing internal awareness about how our products and services may be used	Legitimate Interests
General business management	Legitimate Interests
Security management	Legitimate Interests and Legal Obligation
Statutory reporting obligations	Legal Obligation

If you object to our use of your Personal Data for the aforementioned purposes, please contact us at [email protected].

Subject to the applicability of a specific privacy law (including CCPA) to SNTA, the following are CCPA business or commercial purposes for which we collect and disclose each category of Personal Data. Details about the information we collect for each category are provided above in the sub-section titled, “Personal Data that We Collect and Process”, of this Section 2.2 (Engagements with Clients and Service Providers).

Categories of Personal Information	Business or Commercial Purposes
Identifiers	“Helping to ensure security and integrity to the extent the use of the consumer’s personal information is reasonably necessary and proportionate for these purposes.” “Performing services on behalf of the business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of the business.”
Personal information
Characteristics of protected classifications
Professional or employment-related information
Inferences	“Helping to ensure security and integrity to the extent the use of the consumer’s personal information is reasonably necessary and proportionate for these purposes.” “Performing services on behalf of the business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of the business.” “Performing services on behalf of the business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of the business.” “Undertaking internal research for technological development and demonstration.” “Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business.”
Commercial information	“Helping to ensure security and integrity to the extent the use of the consumer’s personal information is reasonably necessary and proportionate for these purposes.” “Performing services on behalf of the business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of the business.” “Undertaking internal research for technological development and demonstration.” “Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business.”
Internet or other electronic network activity information	“Helping to ensure security and integrity to the extent the use of the consumer’s personal information is reasonably necessary and proportionate for these purposes.” “Debugging to identify and repair errors that impair existing intended functionality.” “Undertaking internal research for technological development and demonstration.” “Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business.”

3. Processing of Personal Data in Connection with the Provision of the Services:

Sources of Personal Data

We may obtain your Personal Data from our clients who have collected it from you directly or indirectly from publicly-available sources or third-party service providers who evaluate your candidacy.

Personal Data that We Collect and Process

Your name (first and last), email address, phone number, current employer or associated company, professional role and any publicly-available online content, including social media posts, pictures, videos, links and public reports.

You do not have any legal obligation to allow us to process this information. However, we require the information mentioned above in order to provide the Services. If you choose to restrict our processing of such information, then we may not be able to provide the Services.

Subject to the applicability of a specific privacy law (including CCPA) to SNTA, the aforementioned types of Personal Data that we collect from you correspond to the following categories of personal information collected by us within the past 12 months (depending on which other privacy laws may apply, it may be earlier than 12 months prior) in our role as a “business” (as defined in CCPA) or similar equivalent in other privacy laws:

• Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers;
• Any information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. “Personal information” does not include publicly available information that is lawfully made available to the general public from federal, state, or local government records;
• Characteristics of protected classifications under California or federal law;
• Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies;
• Biometric information;
• Audio, electronic, visual, thermal, olfactory, or similar information;
• Professional or employment-related information; and
• Inferences drawn from any of the information above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes.

Why Do We Collect Your Personal Data and What are the Lawful Bases?

Purpose for Processing	Lawful Basis
General business management	Legitimate Interests
Security management	Legitimate Interests and Legal Obligation
Statutory reporting obligations	Legal Obligation

If you object to our use of your Personal Data for the aforementioned purposes, please contact us at [email protected].

Subject to the applicability of a specific privacy law (including CCPA) to SNTA, the following are CCPA business or commercial purposes for which we collect and disclose each category of Personal Data. Details about the information we collect for each category are provided above in the sub-section titled, “Personal Data that We Collect and Process”, of this Section 2.3 (Processing of Personal Data in Connection with the Provision of the Services).

Categories of Personal Information	Business or Commercial Purposes
Identifiers	“Helping to ensure security and integrity to the extent the use of the consumer’s personal information is reasonably necessary and proportionate for these purposes.” “Performing services on behalf of the business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of the business.”
Personal information
Characteristics of protected classifications
Commercial information
Biometric information
Audio, electronic, visual, thermal, olfactory, or similar information
Professional or employment-related information
Inferences

Please note that any Personal Data processed as described in this Section 2.3 (Processing of Personal Data in Connection with the Provision of the Services) is processed by us in our role as a Processor on behalf of our clients in their role as a Controller of such Personal Data and in connection with our provision of the Services to them. As such, our clients, the Controllers, ultimately determine the legal basis for such processing and for what purpose(s).

4. Whistleblowing:

Sources of Personal Data

We may obtain your Personal Data from you directly, for example, when you submit a whistleblower report through our internal reporting channel, and/or another individual who submitted a whistleblower report referencing you through our internal reporting channel.

   Personal Data that We Collect and Process

Unless you submit a whistleblower report through our internal reporting channel anonymously and regardless of the source of the whistleblower report, your name, email address, and employee number are collected when a whistleblower report is submitted through our internal reporting channel.

You do not have any legal obligation to provide any information to us. However, we require the information mentioned above in order to respond to your whistleblower report. If you choose not to provide us with such information, then we may not be able to respond to your whistleblower report.

Subject to the applicability of a specific privacy law (including CCPA) to SNTA, the aforementioned types of Personal Data that we collect from you correspond to the following categories of personal information collected by us within the past 12 months (depending on which other privacy laws may apply, it may be earlier than 12 months prior) in our role as a “business” (as defined in CCPA) or similar equivalent in other privacy laws:

• Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers;
• Any information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. “Personal information” does not include publicly available information that is lawfully made available to the general public from federal, state, or local government records; and
• Professional or employment-related information.

Why Do We Collect Your Personal Data and What are the Lawful Bases?

Purpose of Collection	Lawful Basis
Compliance with whistleblowing standards and requirements	Legitimate Interests
Statutory reporting obligations	Legal Obligation

If you object to our use of your Personal Data for the aforementioned purposes, please contact us at [email protected].

Subject to the applicability of a specific privacy law (including CCPA) to SNTA, the following are CCPA business or commercial purposes for which we collect and disclose each category of Personal Data. Details about the information we collect for each category are provided above in the sub-section titled, “Personal Data that We Collect and Process”, of this Section 2.4 (Whistleblowing).

Categories of Personal Information	Business or Commercial Purposes
Identifiers	Providing an effective internal whistleblowing mechanism.
Personal information
Professional or employment-related information

5. Website Visitors:

Sources of Personal Data

We may obtain your Personal Data from you directly, for example, when you access our website, and/or third-party service providers who process your Personal Data on our behalf when you access our website.

Personal Data that We Collect and Process

Your Internet Protocol (IP) address, Uniform Resource Locator (URL), type of operating system, type of browser, browser plug-in types and versions, screen resolution, Flash version, time zone setting, ‘clickstream’, the period of time you accessed our website, and the methods used to browse away from our website.

You do not have any legal obligation to provide any information to us. However, we require the information mentioned above in order to respond to maintain and improve the operation of our website. If you choose not to provide us with such information, then your experience and ability to use and access our website may be hindered.

Subject to the applicability of a specific privacy law (including CCPA) to SNTA, the aforementioned types of Personal Data that we collect from you correspond to the following categories of personal information collected by us within the past 12 months (depending on which other privacy laws may apply, it may be earlier than 12 months prior) in our role as a “business” (as defined in CCPA) or similar equivalent in other privacy laws:

• Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers;
• Internet or other electronic network activity information, including browsing history, search history and information regarding a consumer’s interaction with an internet website, application or advertisement; and
• Inferences drawn from any of the information above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes.

Why Do We Collect Your Personal Data and What are the Lawful Bases?

Purpose of Processing	Lawful Basis
Tracking use of our website in order to enable optimization	Legitimate Interests

If you object to our use of your Personal Data for the aforementioned purposes, please contact us at [email protected].

Subject to the applicability of a specific privacy law (including CCPA) to SNTA, the following are CCPA business or commercial purposes for which we collect and disclose each category of Personal Data. Details about the information we collect for each category are provided above in the sub-section titled, “Personal Data that We Collect and Process”, of this Section 2.5 (Website Visitors).

Categories of Personal Information	Business or Commercial Purposes
Identifiers	“Debugging to identify and repair errors that impair existing intended functionality.” “Undertaking internal research for technological development and demonstration.” “Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business.” Website optimization.
Internet or other electronic network activity information
Inferences

3. SHARING DATA WITH THIRD PARTIES

Summary: We neither sell nor share Personal Data to third parties.

SNTA maintains an updated list of the categories of third parties to which it discloses Personal Data (available online [here]). The list is kept current and includes the categories of Personal Data shared, for what business or commercial purposes and where such third parties are located internationally. If you want to be notified of changes to the list by contacting us at [email protected].

As detailed further below in Section 5 (International Data Transfers), when we transfer Personal Data from the European Economic Area (“EEA”) or the United Kingdom of Great Britain and Northern Ireland (“UK”) outside of the aforementioned jurisdictions, such transfers will always take place under an approved transfer mechanism or adequacy decision, as applicable, such as the relevant Standard Contractual Clauses (SCCs), if required.

Mergers and Acquisitions: We will disclose your Personal Data to third parties if some or all of our shares or assets are acquired by a third party, including by way of a merger, share acquisition, asset purchase or any similar transaction in which case Personal Data will be one of the transferred assets. 

Legal and Regulatory Obligations: We transfer Personal Data to third parties if we are under a duty to disclose or share your Personal Data in order to comply with any legal, audit or compliance obligation in the course of any legal or regulatory proceeding or investigation, in order to enforce or apply our terms and other agreements with you or with a third party, or in order to assert or protect our rights, property or safety of SNTA, our clients or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection, credit risk reduction and in order to prevent cybercrime.

4. WHERE WE STORE YOUR DATA

Summary: We store your Personal Data across multiple jurisdictions globally.

We store your Personal Data on servers owned and controlled by SNTA or its affiliates or processed by third parties on behalf of SNTA, such as reputable cloud service providers (see Sections 3 (Sharing Data with Third Parties) and 5 (International Data Transfers) in this Privacy Policy). This includes, but is not limited to, in the United States of America (“USA”), the EU and the UK. 

5. INTERNATIONAL DATA TRANSFERS

Summary: We transfer Personal Data internationally with appropriate safeguards in place.

We transfer, store and process the types of Personal Data mentioned above in Section 2 (Information We Collect and How We Collect It) to locations outside of the EEA and the UK as mentioned above in Section 3 (Sharing Data with Third Parties) in order to facilitate the purposes mentioned above in Section 2 (Information We Collect and How We Collect It). This includes transfers to the Israel, where our headquarters is located, as well as other jurisdictions where our third-party service providers are located. A complete list of the jurisdictions of our third-party service providers where the Personal Data is transferred to is available online [here].

We transfer Personal Data to locations outside of the EEA and UK in order to:

• Store or backup the information;
• Enable us to fulfill our contractual commitments to you;
• Enable us to fulfill any legal, auditory, ethical or compliance obligations which require us to make such a transfer;
• Facilitate the operation of our business, where it is in our legitimate interest, and we have concluded that such interest is not overridden by your rights;
• Serve you across multiple jurisdictions; and
• Operate our affiliates in an efficient and optimal manner.

Where your Personal Data is transferred outside of the EEA or the UK, we will take reasonably necessary steps to ensure that your Personal Data is subject to appropriate safeguards, and that such Personal Data is treated securely and substantively in accordance with this Privacy Policy. Transfers from the EEA to Israel are made based on an adequacy ruling by the European Commission. Transfers from the EEA to the USA are made based on the EU-US Data Protection Framework or Standard Contractual Clauses (SCCs) published by the European Commission, as applicable. Transfers from the UK to the EEA or Israel are made based on the UK’s Adequacy Regulations. Transfers from the UK to the US or other non-adequate countries are made based on the UK’s International Data Transfer Addendum to the EU Commission Standard Contractual Clauses. For more information about these safeguards, please contact us at [email protected].

6. DATA RETENTION

Summary: We retain Personal Data in accordance with our data retention policy and as required to meet our obligations, protect our rights and manage our business. 

SNTA will retain Personal Data we process only for as long as required in order to fulfill each purpose for which such Personal Data is collected, all in accordance with our data retention policy, and as necessary to comply with our legal and other obligations, to resolve disputes and to enforce agreements. We will also retain Personal Data to meet any audit, compliance and business best-practices.

Personal Data that is no longer retained will be anonymized or deleted. Likewise, some metadata and statistical information, concerning the use of our website and the Services are not subject to the deletion procedures in this Privacy Policy and our data retention policy and will be retained by SNTA. We will not be able to identify you from this data. Some data may also be retained on our third-party service providers’ servers until deleted in accordance with their privacy policy and their retention policy, and in our backups until overwritten.

7. DATA COLLECTION FROM OUR WEBSITE AND FROM COOKIES

Summary: With your consent, we place cookies on your device. You control our use of cookies through a cookie management tool on our website or through your device or browser.

Our website uses cookies, pixel tags and other forms of identification and local storage (collectively, “cookies”) to distinguish you from other visitors of our website. This helps us to provide you with an optimal user experience and allows us to provide and improve our website.

Cookies are computer files containing small amounts of information which are downloaded to a user’s device when he/she visits a website. Cookies can then be sent back to the originating website on each subsequent visit or to another website that recognizes such cookie. In many cases, these cookies lead to the use of your device’s processing or storage capabilities. Some of these cookies are set by us while others are set by third parties. Some only last as long as your browser session while others can stay active on your device for longer periods of time.

Cookies fall into several distinct categories: (a) those that are essential for the website to function properly, such as enabling basic functions like page navigation, access to secure areas of the website and ensuring the website’s core functionalities operate correctly; (b) those that enhance the usability and performance of the website, such as remembering visitor preferences and settings; (c) those that are used to carry out website performance and audience metrics (‘analytics cookies’); and (d) those that are used for marketing and advertising, such as for tracking visitor behavior across websites in order to enable targeted advertising.

Functionality cookies (also called ‘essential cookies’) do not require your consent. These are the only type of cookies we use on our website. They are strictly necessary in order for our website to function properly, such as authenticating users, ensure security, provide core features and maintain a smooth performance without errors or interruptions. We do not use non-essential cookies, such as cookies for marketing and advertising.

Internet browsers allow you to change your cookies settings, for example, in order to block certain kinds of cookies or files. Therefore, you can block cookies by activating the settings on your browser that allow you to refuse the settings of all or some cookies. However, if you use your browser settings to block all cookies, you may not be able to access all or parts of our website due to the fact that some of the cookies you’ve chosen to block are essential cookies required to maintain the functionality of the website. More information about deleting and blocking cookies can be found online here. To consult the list of cookies we use on our website, please check your browser’s settings (see here for instructions) or view our cookie management tool.

8. SECURITY AND STORAGE OF DATA

Summary: We take data security very seriously, invest in security systems and train our staff. In the event of a breach, we make the appropriate notifications as required by law. 

We take great care in implementing, enforcing and maintaining the security of the Personal Data we process. SNTA implements, enforces and maintains security measures, technologies and policies to prevent the unauthorized or accidental access to or destruction, loss, modification, use or disclosure of Personal Data. We likewise take steps to monitor compliance of such policies on an ongoing basis. Likewise, we take at least industry standard steps to ensure our website and the Services are safe and to prevent unauthorized access to our databases. 

Please note, however, that no data security measures are perfect or impenetrable and we cannot guarantee that unauthorized access, leaks, viruses and other data security breaches will never occur. 

We endeavor to limit access to Personal Data to those of our personnel who require access in order to fulfill our obligations, including also under our agreements, and as described in this Privacy Policy, have been appropriately and periodically trained with respect to the requirements applicable to the processing, care and handling of the Personal Data, and are under confidentiality obligations as may be required under applicable law. 

We act in accordance with our policies and with applicable law to promptly notify the relevant authorities and Data Subjects in the event that any Personal Data is lost, stolen, modified or disclosed or where there has been any unauthorized access to it, all in accordance with applicable law and on the instructions of qualified authority. SNTA shall promptly take reasonable remedial measures.

9. DATA SUBJECT RIGHTS

Summary: Depending on the law applicable to your Personal Data, you may have various data subject rights, such as a right to access, erasure and rectification, as well as certain information rights. We will respect any lawful request to exercise such rights.

Data Subjects in certain jurisdictions, such as in the EU and the UK, have rights granted pursuant to local laws under certain circumstances and with certain exceptions, including:

• Access – the right to receive confirmation whether your Personal Data is being processed by us, what types of Personal Data, for what purposes, with whom is it or will it be shared (if at all) and for how long will it be stored.
• Rectification – the right to correct your Personal Data held by us that may be inaccurate or incomplete.
• Erasure – the right to have your Personal Data held by us deleted.
• Restriction of Processing – the right to require us to cease processing your Personal Data.
• Portability – the right to receive a copy of any of your Personal Data held by us in a convenient format and to have any of your Personal Data held by us transferred to a third party.
• Objection – the right to object to the processing of your Personal Data by us.
• Objection to Direct Marketing – the right to object to the processing of your Personal Data by us for the purposes of direct marketing, including profiling – this can be achieved by opting out using the unsubscribe/opt-out feature displayed in our communications with you.
• Objection to Automated Decision-Making – the right to refuse to have your Personal Data processed in connection with automated decision-making.
• Withdrawal of Consent – where we rely upon your consent in order to process your Personal Data, you have the right to withdraw such consent at any time.

In order to exercise any of your rights, you can contact us at [email protected]. Please note that SNTA may have to undertake a process to identify a Data Subject prior to facilitating the exercise of such Data Subject’s rights. SNTA may keep details of rights exercised for our own compliance and audit requirements. 

Please note that these rights only apply under certain circumstances and may be limited by law, as well as be subject to exceptions. For example, where accepting your request to exercise a right would adversely affect other individuals, expose our trade secrets or intellectual property, where there are overriding public interests, or where we are required by law to retain your Personal Data. In addition, Data Subjects’ rights cannot be exercised in a manner inconsistent with our rights, our employees’ and staff’s or third-parties’ rights. As such, reviews and assessments, documents and notes, including proprietary information or forms of intellectual property, cannot be accessed, erased or rectified by Data Subjects. In addition, these rights may not be exercisable where they relate to data that is not in a structured form, such as emails, or where other exceptions apply.

Data Subjects in the EU, the UK and other jurisdictions have the right to file a complaint with a local data protection supervisory authority, as well as pursue an effective judicial remedy.

10. US STATES’ PRIVACY RIGHTS

Summary: To the extent the CCPA applies, we neither sell nor share the personal information we collect for cross-contextual advertising purposes. California and other US state resident consumers have certain rights in relation to their personal information. They can exercise those rights by contacting us at [email protected].

This section provides additional details about the Personal Data we collect about consumers in the US states of California, Virginia, Colorado, Connecticut, Utah, Nevada and other applicable US states and the rights afforded to them, subject to applicability, under CCPA, the Virginia Consumer Data Protection Act, the Colorado Privacy Act, the Connecticut Data Privacy Act, the Utah Consumer Privacy Act, the Nevada Consumer Health Data Privacy Law and other applicable laws.

As detailed above in Section 2 (Information We Collect and How We Collect It) above, this Privacy Policy summarizes the Personal Data we have collected as a business over the last 12 months, for what business and commercial purposes and with whom we disclose this information. 

Please note that we neither sell nor share personal information to third parties.

Subject to certain limitations, CCPA and other applicable US state laws provide consumers certain rights, such as:

• the right to be provided with a notice of our practices regarding the collection, use, sale and sharing of personal information;
• the right to request a summary of the personal information we have collected about you, including a copy of the specific pieces of personal information collected;
• the right to delete the personal information we have collected about you;
• the right to opt-out (and opt-in later) of the sale of your personal information by us;
• the right to opt-in for the sale of your personal information by us (exclusive for minors);
• the right to not be discriminated against due to the exercise of one’s rights;
• a private right to action when your unencrypted or unredacted personal information is breached;
• the right to limit our collection and processing of your personal information;
• the right to opt-out of the use and access of your personal information for automated decision-making technologies;
• the right to restrict our collection and processing of your sensitive personal information; and
• the right to correct your personal information.

To make such requests, please contact us at [email protected]. Government identification may be required. You can also designate an authorized agent to exercise these rights on your behalf. Please note that your entitlement to exercise any of the aforementioned rights is additionally subject to the applicability of such specific privacy law to SNTA that grants such right.

11. DO NOT TRACK SIGNALS

Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers in order to inform websites that they do not wish to be tracked. We honor DNT signals.

12. CHANGES TO THIS PRIVACY POLICY

The terms of this Privacy Policy will govern the provision of the Services and any data collected in connection with them and SNTA’s contractual obligations. SNTA may amend or update this Privacy Policy from time to time. The most current version of this Privacy Policy will be available at: www.sntaltd.com. Changes to this Privacy Policy are effective as of the date stated above as “Last Revised” and your continued engagement with us or use of the Services will constitute your active acceptance of the changes to the terms of this Privacy Policy. 

13. CONTACT US

SNTA aims to process only adequate, accurate and relevant data limited to the needs and purposes for which it is gathered. We also aim to store data only for the time period necessary in order to fulfill the purpose for which the data is gathered. SNTA only collects data in connection with a specific lawful purpose and only processes data in accordance with this Privacy Policy. Our policies and practices are constantly evolving and improving and we invite any suggestions for improvements, questions, complaints or comments concerning this Privacy Policy. You are welcome to contact us (details below) and we will make an effort to reply within a reasonable timeframe.

SNTA may be contacted concerning this Privacy Policy at [email protected].

SNTA’s Data Protection Officer, MyEDPO Israel Ltd, company no. 514747609, may be contacted concerning this Privacy Policy at [email protected] or +44-203-870-3376. Its useful legal representative is Arye Schreiber, its offices are located at 12 HaMa’apilim Street, Unit 3, Jerusalem 9358801, Israel, and its website is located here.