In order to ensure transparency and give you more control over your personal information, this privacy policy (“Privacy Policy”) governs how we, Anzu Virtual Reality Ltd. and its affiliates (together, “Anzu” “we”, “our” or “us”) use, collect and store personal data we collect or receive from or about you (“you”) such as in the following use cases:

(i) When you browse or visit our website, https://anzu.io/ (“Website”)

(ii) When you make use of, or interact with, our Website

a. When you subscribe to our newsletter

b. When we process your job application

c. When you contact us (e.g. customer support, need help, get in touch, and submit a request).

(iii) When you are a Publisher and you create an account, log in and make use of the dashboard environment, market place and/or any other software that we provide (“Services”) for its intended use (e.g., advertising and the execution of empowered marketing campaigns), https://publishers.anzu.io/

(iv) When the Anzu SDK is  initiated by the Publisher's game on a User device

(v) When you attend a marketing events and provide us with Personal Data and/or exchange business cards with us

(vi) When we use the Personal Data of our service providers and suppliers

(vii) When we use the Personal Data of the Advertisers

(viii) When we use the Personal Data of the Publisher and Partner

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

We greatly respect your privacy, which is why we make every effort to provide you with meaningful information concerning our processing of your Personal Data and about our data protection practices in general. Please read this Privacy Policy carefully, so you can fully understand our practices in relation to personal data. “Personal Data” or “Personal Information” means any information that can be used, alone or together with other data, to uniquely identify any living human being. Please note that this is a master privacy policy and some of its provisions only apply to individuals in certain jurisdictions. For example, the legal basis in the table below is only relevant for GDPR-protected individuals.

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. Period of Storage of Collected Personal Data

3. How we Protect your Personal Data

4. How we Share your Personal Data

5. Additional Information regarding Transfers of Personal Data

6. Your Privacy Rights; How to Delete your Account

7. Use by Children

8. Interaction with Third Party Products

9. Log files

10. Analytics tools

11. Specific Provisions Applicable Under California Privacy Law

12. Contact us

Anzu offers specialized and innovative solutions and concepts for modern advertising and the execution of empowered marketing campaigns (the “Services”). Ad creative files that are parsed, rendered and displayed to Users in places defined by the publisher, such as, in a game or app (the “Ad” or “Advertisement”). For purposes of clarity, the publisher is an entity or individuals that develop computer games (the “Publisher”, “Customer”).

Anzu´s partners are companies that provide advertisements, demand side platforms, advertising networks, or other advertising demand sources that bid on ad inventory through the Anuz´s advertising exchange and serve ads, and those partners will assist Anzu to provide a monetization service and other connected Services. Also, through our services, we allow third party advertising partners to set technologies and other tracking tools to collect information regarding your activities and your device (e.g., your IP address, identifiers, page(s) visited, location, time of day) (the “Partner” or “Advertisers”).

For more information read the above table in Section 1 and Anzu's Partners and Advertisers list  https://anzu.io/sub-processor-list/

Anzu displays contextual Ads, behavioral Ads and safe-mode Ads. The types of Ads that the User will be allowed to receive and the types of Personal Data that can be used as part of the advertising and reporting processes are decided by the Publisher using the API provided by the Anzu's SDK and the settings sets by the Publisher in the Anzu's dashboard for Publishers. If you are an individual, receiving Ads as a result of our relationship with Customer (the "User(s)"), please note that the Customer is the responsible party for obtaining the required consents and complying with any applicable laws or regulations.

This Privacy Policy is a part of our Terms and Conditions https://anzu.io/terms/, and should be read in conjunction with them. 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.

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

Data we collect		Why is the personal data collected and for what purposes?	Legal basis (GDPR only, if applicable)	Third parties with whom we share your Personal Data	Consequences of not providing the personal data
When you browse or visit our Website
Cookies, analytic tools and log files For more information, please read our cookies policy https://anzu.io/cookie-policy/		● For the Website to function properly ● To  analyze and improve the Website ● For debugging purposes and to resolve technical problems ● To improve user experience	Consent Legitimate interest (e.g., to improve your user experience)	3^rd party platforms such as for the following purposes: · Upress (Website Hosting) · Google Analytics (analytic tool)	Cannot collect and store the information. Cannot improve your user experience. Certain Website features may not be available Cannot make re-targeting
When you make use of, or interact with, our Website
When you subscribe to our newsletter
● Email address ● Full name		● To add you to our mailing list and keep you updated of new services, features and functionalities as well as updates about Anzu ● To send you marketing communications	Consent	3^rd party platforms such as for the following purposes: · Google Analytics (Analytic tool) · Google G-suit (email and business software tools) · Mixmax (email tool) · Pipdrive (CRM provider) · MailChimp (email delivery provider) · Upress (Website Hosting)	Cannot add you to our mailing list and keep you updated Cannot send you marketing communications
When we process your job application
● Full name ● Email address ● Phone number ● CV and cover letter ● IP address ● Geolocation ● Usage pattern ● Any other information you decide to provide/supply us with		● To process your job application ● To assess the candidate	Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract. Legitimate interest (e.g. to process job applications)	3^rd party platforms such as for the following purposes: · Google Analytics (Analytic tool) · Google G-suit (email and business software tools) · Mixmax (email tool) · Pipdrive (CRM provider) · MailChimp (email delivery provider) · Upress (Website Hosting)	Cannot process your job application Cannot assess your suitability as a candidate
When you contact us (e.g. customer support, help, get in touch, submit a request)
● Full name ● Email  address ● Title ● Company name ● Reason for inquiry ● Comments ● IP address ● Geolocation ● Usage pattern ● Any other information you decide to provide/supply us with		● To process and answer questions ● To provide support (e.g., to solve problems, bugs or issues) and handle your complaints and/or feedback ● To customize your experience NOTE: We do ask that you do not provide us with any personal information (other than the information required in the form, which we need to respond to your queries) for such purposes.	Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract. Legitimate interest (e.g., respond to a query sent by you)	· 3^rd party platforms such as for the following purposes:Google Analytics (Analytic tool) · Google G-suit (email and business software tools) · Mixmax (email tool) · Pipdrive (CRM provider) · MailChimp (email delivery provider) · Upress (Website Hosting)	Cannot assist you and respond your query Cannot provide support and handle your complaints and/or feedback Cannot customize your experience
● Full name ● Email address		● To send you marketing communications	Consent	3^rd party platforms such as for the following purposes: · Google Analytics (Analytic tool) · Google G-suit (email and business software tools) · Mixmax (email tool) · Pipdrive (CRM provider) · MailChimp (email delivery provider) · Upress (Website Hosting)	Cannot send you marketing communications
When you are a Publisher and you create an account, log in and make use of the Anzu Services for its intended use
● Admin full name ● Admin email address ● Admin phone number ● Full name, email, phone number and permission settings for regular users of Anzu´s dashboard ● Company name ● IP address ● Geolocation ● Usage pattern ● Any other information you decide to provide/supply us with		● To allow you to create an account and log in ● To allow you to create regular users ● To perform/execute the agreement ● To grant you access to the Services For avoidance of doubt, all of the purposes stated before for regular users, also apply to the Admin users in addition to the mentioned hereby.	Processing is necessary for the performance of a contract to which our customer is a party or in order to take steps at the request of the data subject prior to entering into a contract Legitimate interest (e.g. to allow you to create an account)	3^rd party platforms such as for the following purposes: · Amazon (Cloud) · Hotjar (Analytic tool) · Google Cloud (Cloud) · Google G-suit (email and business software tools) · Mixmax (email tool) · Pipdrive (CRM provider) · MailChimp (email delivery provider)	Cannot allow you to create an account and log in Cannot allow you to create regular users Cannot perform/execute the agreement Cannot grant you access to the Services Cannot allow you to make use of our Services
● Full Name of the user ● Email address of the user ● Phone number of the user ● IP address ● Geolocation based on IP address ● Usage pattern ● Browser user agent - ● Campaign data ● advertising activity events - Event analytics data ● Financial key performance indicators ● Log information / usage pattern ● Any other information you decide to provide/supply us with		● To provide you the Services ● To fulfill your requests for our services and for related activities (e.g., account management, support and to provide other Services related to your relationship with Anzu) ● To allow you to manage your ad placement inventory, to review reports/analytics,   list new apps, update ad placement configuration, create campaigns for internal promotions, manage black/white lists, review ads shown to users, and setting bid floor prices ● To serve and optimize advertisements ● To generate advertisements tracking reports ● To analyze performance, improve your user experience and resolve technical problems ● To improve the Service ● To calculate and pay revenue share according to your contract with us ● To communicate with you (service-related communications)	Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract. Legitimate interest (e.g., to provide you with the services)	3^rd party platforms such as for the following purposes: · Amazon (Cloud) · Hotjar (Analytic tool) · Google Cloud (Cloud) · Google G-suit (email and business software tools) · Mixmax (email tool) · Pipdrive (CRM provider) · MailChimp (email delivery provider)	Cannot  provide you the Services Cannot fulfill your requests for our services and for related activities Cannot allow you to manage your ad placement inventory, to review reports/analytics, list new apps, update ad placement configuration, create campaigns for internal promotions, manage black/white lists, review ads shown to users, and setting bid floor prices. Cannot serve and optimize advertisements Cannot generate advertisements tracking reports Cannot analyze performance, improve your user experience and resolve technical problems Cannot improve the Service Cannot calculate payment and send it Cannot communicate with you (service-related communications)
● Full name ● Email address		To send you marketing communications	Consent	3^rd party platforms such as for the following purposes: Google G-suit Mixmax email tool Pipdrive CRM SaaS provider MailChimp mass email delivery provider	Cannot send you marketing communications
When the Anzu SDK is initiated by the Publisher's game on a User device
● IP address ● User agent ● Estimated location data from IP	To understand which type of Ads we should display to the User (e.g., Consent under GDPR, COPPA) once activated Anzu's services by the Publisher Important note: In some cases we chop the IP address to store it in a manner not identifiable and we do not share it with the Advertisers (e.g., GDPR user that did not provide consent to the Customer, or a COPPA User)		Compliance with a legal obligation (e.g. to understand which type of Ad we will need to display you). Legitimate interest (e.g., to  understand which type of Ads we should display to you)	3^rd party platforms such as for the following purposes: · Amazon AWS (cloud) · Google Cloud (cloud)		Cannot understand which type of Ads we should display you, per Publisher´s request Cannot chop the IP address to store it in a manner not identifiable
When we serve a User an Ad on the Publisher’s game or application
BEHAVIORAL ADVERTISEMENT ● IP address ● Advertising identifier (e.g., IDFA, Google Ad ID) or other device identifier ● Limit ad tracking status ● The user's  estimated  location data estimated by IP address that includes: country, city, zip, metro code, lat, lon ● The detected language of the user's device ● Basic device information (desktop/mobile, manufacturer, model, operating system, operating system version, user agent, lmt flag, location type, screen width and height in pixels) ● Connection type, ISP and carrier name ● The device precise GPS data of latitude  and longitude (in case permitted by the publisher) ● Randomly generated Anzu user ID per game/app ● Analytics data (session start, session end, click and etc) ● Any other Personal Data that the Publisher decided to share with us Note: In certain cases, some information, such us, Ads' media files or frequency of times that an User saw an Ad (to the extent that includes Personal Data) will be stored in the User's device (local storage) for the purpose of managing advertising campaigns and displaying Ads.		● To serve the User personalized Ads ● Store and/or access information on a device ● Select and serve personalized ads  when the User makes use of the Publisher´s game or application ● Measure ad performance ● Apply market research to generate audience insights ● Ensure security, prevent fraud, and debug ● Match and combine offline data sources ● To develop, update, fix and improve our products and Services NOTE: If you are a User (as defined above), note that in most cases we act as a data processor and, therefore, our Customer is the data controller in relation to these activities. You should contact the Customer for any privacy-related questions.	In limited contexts where we are/act as a separate data controller: · In order for Anzu to process your Personal Data in the context of our Services, you normally will have already consented to data processing (please note that when Anzu does not have a relationship directly with you, the Publisher will ask you to consent and complying with any applicable laws or regulations for Anzu to collect your information and serve you with the Ads). · Performance of a contract with the Publisher · Legitimate interest (processing per publishers’ instructions, performance of the relevant instruction or contract)	3^rd party platforms such as for the following purposes: · Amazon AWS (cloud) · Google Cloud (cloud) · Advertisers -  advertisers that sign an IO with Anzu and buy ads directly from Anzu on Anzu platform or indirectly through Anzu advertising demand partners · Advertising Demand Partners - vendors that buy Anzu ad inventory or facilitate this process for advertisers that want to buy Anzu inventory · Data Partners - vendors that get data from Anzu and provide additional data that help advertising demand partners to choose the best ad for each user · Fraud and Measurement Partners - vendors that get data from Anzu to show the effectiveness and value of Anzu advertising activities · Anzu processors and sub processors - vendors that help Anzu provision, operate, perform and improve Anzu services	Cannot serve the User personalized Ads when the User makes use of the Publisher´s game or application Cannot monitor, analyze and optimize the User's use of our Services, including analyzing seasonal and annual usage trends, and providing the User and our business partners with new functionality and features Cannot measure ad performance Cannot apply market research to generate audience insights Cannot match and combine offline data sources with the Personal Data that Anzu receives from the User Cannot develop, update, fix and improve our products and Services
CONTEXTUAL ADVERTISEMENT ● IP address ● Limit ad tracking status ● The user's estimated location data estimated by the IP address that includes: country, city, zip, metro code, latitude, longitude ● The detected language of the user's device ● Basic device information (desktop/mobile, manufacturer, model, operating system, operating system version, user agent, limited tracking flag, location type, screen width and height in pixels) ● Connection type, ISP and carrier name ● Randomly generated Anzu user ID per game/app ● Analytics data (session start, session end, click and etc.) ● Any other Personal Data that the Publisher decided to share with us Note: In certain cases, some information, such us, Ads' media files or frequency of times that an User saw an Ad (to the extent that includes Personal Data) will be stored in the User's device (local storage) for the purpose of managing advertising campaigns and displaying Ads.		● To serve the User contextual Ads ● Store and/or access information on a device ● Select and serve contextual ads  when the User makes use of the Publisher´s game or application ● Measure ad performance ● Apply market research to generate audience insights ● Ensure security, prevent fraud, and debug ● Match and combine offline data sources ● To develop, update, fix and improve our products and Services NOTE: If you are a User (as defined above), note that in most cases we act as a data processor and, therefore, our Customer is the data controller in relation to these activities. You should contact the Customer for any privacy-related questions.	In limited contexts where we are/act as a separate data controller: · In order for Anzu to process your Personal Data in the context of our Services, you normally will have already consented to data processing (please note that when Anzu does not have a relationship directly with you, the Publisher will ask you to consent and complying with any applicable laws or regulations for Anzu to collect your information and serve you with the Ads). · Performance of a contract with the Publisher · Legitimate interest (processing per publishers’ instructions, performance of the relevant instruction or contract)	· Amazon AWS (cloud) · Google Cloud (cloud) · Advertisers -  advertisers that sign an IO with Anzu and buy ads directly from Anzu on Anzu platform or indirectly through Anzu advertising demand partners · Advertising Demand Partners - vendors that buy Anzu ad inventory or facilitate this process for advertisers that want to buy Anzu inventory · Data Partners - vendors that get data from Anzu and provide additional data that help advertising demand partners to choose the best ad for each user · Fraud and Measurement Partners - vendors that get data from Anzu to show the effectiveness and value of Anzu advertising activities · Anzu processors and sub processors - vendors that help Anzu provision, operate, perform and improve Anzu services	Cannot serve the User contextual Ads when the User makes use of the Publisher´s game or application Cannot monitor, analyze and optimize the User's use of our Services, including analyzing seasonal and annual usage trends, and providing the User and our business partners with new functionality and features Cannot measure ad performance Cannot apply market research to generate audience insights Cannot match and combine offline data sources with the Personal Data that Anzu receives from the User Cannot develop, update, fix and improve our products and Services
SAFE-MODE (NO PERSONAL DATA IS INVOLVED) ● IP address with the lowest 8 bits removed for IPv4 and lowest 32 bits removed for IPv6 ● Limit ad tracking status ● The user's estimated location data estimated by the truncated IP address that includes: country, city ● The detected language of the user's device ● Basic device information (desktop/mobile, manufacturer, model, operating system, operating system version, user agent,  limited tracking flag, location type, screen width and height in pixels) ● Connection type, ISP and carrier name ● Randomly generated Anzu user ID per game/app ● Analytics data (e.g., session start, session end, click) Note: In certain cases, some information, such us, Ads' media files or frequency of times that an User saw an Ad (to the extent that includes Personal Data) will be stored in the User's device (local storage) for the purpose of managing advertising campaigns and displaying Ads.		● To serve the User contextual Ads ● Store and/or access information on a device ● Select and serve contextual ads  when the User makes use of the Publisher´s game or application ● Measure ad performance ● Apply market research to generate audience insights ● Ensure security, prevent fraud, and debug ● Match and combine offline data sources ● To develop, update, fix and improve our products and Services	N/A since there is no collection of Personal Data	3^rd party platforms such as for the following purposes: · Amazon AWS (cloud) · Google Cloud (cloud) · Advertisers -  advertisers that sign an IO with Anzu and buy ads directly from Anzu on Anzu platform or indirectly through Anzu advertising demand partners · Advertising Demand Partners - vendors that buy Anzu ad inventory or facilitate this process for advertisers that want to buy Anzu inventory · Fraud and Measurement Partners - vendors that get data from Anzu to show the effectiveness and value of Anzu advertising activities	Cannot serve the User advertisement  (contextual Ads – without having access to Personal Data) when the User makes use of the Publisher´s game or application Cannot monitor, analyze and optimize the User's use of our Services, including analyzing seasonal and annual usage trends, and providing the User and our business partners with new functionality and features Cannot measure ad performance Cannot apply market research to generate audience insights Cannot develop, update, fix and improve our products and Services
When you attend a marketing events and provide us with Personal Data and/or exchange business cards with us
● Full name ● Email address ● Company name ● Job position ● Phone numbers ● Any other data you decide to provide/supply us with		● To establish a business connection ● To send marketing communications	Consent Legitimate interest (e.g. send you more information about Anzu)	3^rd party platforms such as for the following purposes: · Google G-suit (email and business software tools) · Mixmax (email tool) · Pipdrive (CRM provider) · MailChimp (email delivery provider)	Cannot establish a business connection Cannot send marketing communications
When we use the Personal Data of our service providers and suppliers
● Full name ● Email address ● Company name ● Job position ● Phone numbers ● Any other data you decide to provide/supply us with		● To contact our service providers ● To perform the applicable agreement ● To communicate with you (e.g., service-related communications)	Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract. Legitimate interest (e.g. perform the contract, send contract-related communications)	3^rd party platforms such as for the following purposes: · Google G-suit (email and business software tools) · Mixmax (email tool) · Pipdrive (CRM provider) · MailChimp (email delivery provider)	Cannot communicate with you Cannot perform the applicable agreement
● Full name ● Email address ●		● To send you marketing communications, updates, upgrades and other relevant information	Consent	3^rd party platforms such as for the following purposes: · Google G-suit (email and business software tools) · Mixmax (email tool) · Pipdrive (CRM provider) · MailChimp (email delivery provider)	Cannot send you marketing communications
When we use the Personal Data of the Advertiser
● Full name ● Email address ● Company name company incorporation number and other details about the company ● Job position ● Phone numbers ● Payment information (i.e. bank account number and/or credit card details) ● Any other data you decide to provide/supply us with		● To contact our Advertiser ● To perform the applicable agreement	Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract. Legitimate interest (e.g. perform the contract, send contract-related communications)	3^rd party platforms such as for the following purposes: · Amazon (Cloud) · Google Analytics (Analytic tool) · Google Cloud (Cloud) · Google G-suit (email and business software tools) · Mixmax (email tool) · Pipdrive (CRM provider) · MailChimp (email delivery provider)	Cannot communicate with you Cannot perform the applicable agreement
● Full name ● Email address		● To send you marketing communications, updates, upgrades and other relevant information	Consent	· 3^rd party platforms such as for the following purposes:Google G-suit (email and business software tools) · Mixmax (email tool) · Pipdrive (CRM provider) · MailChimp (email delivery provider)	Cannot send you marketing communications
When we use the Personal Data of the Publisher and Partner
● Full name ● Email address ● Company name ● Company details, including address ● Job position ● Phone number ● Company incorporation number ● Billing information ● Any other data you decide to provide/supply us with		● To provide our products and services ● To perform the applicable agreement ● To communicate with the Publisher ● To calculate the billing activities	Processing is necessary for the performance of a contract to which our customer is a party. Compliance with a legal obligation (e.g. tax laws, bookkeeping laws, etc.). Legitimate interest (e.g. send you contract-related communications)	3^rd party platforms such as for the following purposes: · Amazon (Cloud) · Google Analytics (Analytic tool) · Google Cloud (Cloud) · Google G-suit (email and business software tools) · Mixmax (email tool) · Pipdrive (CRM provider) · MailChimp (email delivery provider)	Cannot provide the services and/or our products Cannot perform the agreement Cannot communicate with you Cannot calculate the billing activities
● Full name ● Email address		● To send you marketing communications	Consent	· 3^rd party platforms such as for the following purposes:Google G-suit (email and business software tools) · Mixmax (email tool) · Pipdrive (CRM provider) · MailChimp (email delivery provider)	Cannot send you marketing communications
When you interact with us on our social media profiles (e.g., Facebook, Instagram, Twitter, LinkedIn)
● Full name ● Social media handle ● Any other data you decide to provide/supply		● To reply and/or respond to your request or question ● To establish a business connection and/or to send you more information about Anzu (when requested by you)	Consent Legitimate interest (e.g. send you more information about Anzu)	3^rd party platforms such as for the following purposes: · Google G-suit (email and business software tools) · Mixmax (email tool) · Pipdrive (CRM provider) · MailChimp (email delivery provider)	Cannot reply or respond to your request

Finally, 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. Our legal basis in these cases is for compliance with a legal obligation (e.g., fraud detection, security and/or debug). 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).

2.        PERIOD OF STORAGE OF COLLECTED PERSONAL DATA

Personal Data. Your Personal Data will be stored until we: (i) no longer need the information and proactively delete it; or (ii) you send a valid deletion request.  Please note that we may retain it for a longer or shorter period in accordance with data retention laws.

Retention of your personal data. In addition to the retention periods mentioned in this section, 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. We have an internal data retention policy to ensure that we do not retain your personal data perpetually.

Website cookies. Regarding retention of cookies, you can read more in our cookie policy https://anzu.io/cookie-policy/

3. HOW WE PROTECT YOUR PERSONAL DATA

Anzu advertising solution is ISO/IEC 27001:2013 certified and accordingly, we use appropriate technical, organizational and administrative security measures to protect any information we hold in our records from you. However, please note that we cannot guarantee that the Personal Information will not be compromised as a result of unauthorized penetration to our servers. Among other practices, your account is protected by a password for your privacy and security. You must prevent unauthorized access to your account and Personal Information by selecting and protecting your password appropriately and limiting access to your computer or device and browser by signing off after you have finished accessing your account.

4.  HOW WE SHARE YOUR PERSONAL DATA

In addition to the recipients described in Section 1, we may share your information as follows:

4.1 To the extent necessary, with regulators, to comply with all applicable laws, regulations and rules, and requests of law enforcement, regulatory and other governmental agencies or if required to do so by court order;

4.2 If, in the future, we sell or transfer some or all of our business or assets to a third party, we will (to the minimum extent required) disclose information to a potential or actual third party purchaser of our business or assets. In the event that we are acquired by or merged with a third party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer or assign Personal Data in connection with the foregoing events.

4.3 Where you have provided your consent to us sharing the Personal Data (e.g., where you provide us with marketing consents or opt-in to optional additional services or functionality); and

4.4 Where we receive requests for information from law enforcement or regulators, we carefully validate these requests before any Personal Data is disclosed.

4.5 Where you have provided your consent to us sharing or transferring your personal data (e.g., where you provide us with marketing consents or opt-in to optional additional services or functionality).

If you want to receive the list of the current recipients of your personal data, please make your request by contacting us to privacy@anzu.io.

5. ADDITIONAL INFORMATION REGARDING TRANSFERS OF PERSONAL DATA

· Storage: AWS with servers located in the US, and Google with servers located in the US.

· Access from Israel: Access from Israel is covered by the European Commission’s Adequacy Decision regarding Israel. 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.

· Internal transfers: Transfers within the Anzu group will be covered by an internal processing agreement entered into by members of the Anzu 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.  

· 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.

6. YOUR PRIVACY RIGHTS; HOW TO DELETE YOUR ACCOUNT

6.1. Rights: The following rights (which may be subject to certain exemptions or derogations) shall apply to certain individuals (some of which only apply to individuals protected by the GDPR):

· You have the right to request that we rectify any personal data we hold that is inaccurate or misleading;

· You have the right to request the erasure/deletion of your personal data (e.g. from our records). Please note that there may be circumstances in which we are required to retain your personal data, for example for the establishment, exercise or defense of legal claims;

· You have the right to object, to or to request restriction, of the processing;

· You have the right to data portability. This means that you may have the right to receive your personal data in a structured, commonly used and machine-readable format, and that you have the right to transmit that data to another controller;

· You have the right to object to profiling;

· You have the right to withdraw your consent at any time. Please note that there may be circumstances in which we are entitled to continue processing your data, in particular if the processing is required to meet our legal and regulatory obligations. Also, please  note that the withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal;

· You also have a right to request certain details of the basis on which your personal data is transferred outside the European Economic Area, but data transfer agreements and/or other details may need to be partially redacted for reasons of commercial confidentiality;

· You have a right to lodge a complaint with your local data protection supervisory authority (i.e., your place of habitual residence, place or work or place of alleged infringement) at any time or before the relevant institutions in your place of residence. We ask that you please attempt to resolve any issues with us before you contact your local supervisory authority and/or relevant institution.

You can exercise your rights by contacting us at privacy@anzu.io. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly in accordance with applicable law 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, before processing and/or honoring your request. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive. 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 initial requested, we will address your request to the maximum extent possible, all in accordance with applicable law.

6.2. Deleting your account: Should you ever decide to delete your account, you may do so by emailing: privacy@anzu.io. If you terminate your account, any association between your account and personal data we store will no longer be accessible through your account.

7. USE BY CHILDREN  

Website: We do not offer our products or services specifically intended 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. 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@anzu.io.  

Services: The Ads could be displayed to children protected by specific laws, including, COPPA and GDPR. When Anzu controls the Personal Data of such children, Anzu delegates Anzu's obligations regarding consent to the Publisher. For any privacy/related question and or to obtain more information you should contact the Publisher. 

8. INTERACTION WITH THIRD PARTY PRODUCTS AND PARTNERS

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.

9. 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.

10. ANALYTIC TOOLS

Anzu uses in its Website the following tools.

● 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 information. 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/.

● Hotjar. The Website uses Hotjar in order to better understand our users’ needs and to optimize this service and experience. Hotjar is a technology service that helps us better understand our users experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables us to build and maintain our service with user feedback. Hotjar uses cookies and other technologies to collect data on our users’ behavior and their devices (in particular device's IP address (captured and stored only in anonymized form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), preferred language used to display our Website). Hotjar stores this information in a pseudonymized user profile. Neither Hotjar nor we will ever use this information to identify individual users or to match it with further data on an individual user. For further details, please see Hotjar’s privacy policy at https://www.hotjar.com/legal/policies/privacy. You can opt-out to the creation of a user profile, Hotjar’s storing of data about your usage of our Website and Hotjar’s use of tracking cookies on other websites on this link https://www.hotjar.com/legal/compliance/opt-out.

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

You may stop or restrict the placement of technologies on your device or remove them by adjusting your preferences as your browser or device permits.  The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs.  You can access these and learn more about targeted advertising and consumer choice and privacy, at www.networkadvertising.org/managing/opt_out.asp, http://www.youronlinechoices.eu/, https://youradchoices.ca/choices/, and www.aboutads.info/choices/.   To separately make choices for mobile apps on a mobile device, you can download DAA’s AppChoices application from your device’s app store.  Alternatively, for some devices you may use your device’s platform controls in your settings to exercise choice.

11. SPECIFIC PROVISIONS APPLICABLE UNDER CALIFORNIA PRIVACY LAW

11.1. California Access 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@anzu.io. Please note that we will respond to one request per customer each year, unless otherwise required by law.

11.2. Our California Do Not Track Notice: Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. We may collect personally identifiable information about an individual consumer’s online activities over time and across different web sites when a consumer uses the Services. If you choose to operate your web browser “do not track” signals or any other mechanism that provides consumers the ability to exercise choice regarding the collection of such information, we will abide by your request and stop collecting such information. We do not allow third parties such as 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 Services.

11.3. 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 data you have posted and that there may be circumstances in which the law does not require us to enable removal of content.

12. 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@anzu.io

TO THE MAXIMUM EXTENT PERMIITED BY LAW, YOU UNDERSTAND AND AGREE THAT ANZU’S LIABILITY FROM ANY DISPUTE OVER PRIVACY OR THIS PRIVACY POLICY WILL BE LIMITED AS SET FORTH IN THE TERMS AND CONDITIONS OF OUR APPLICABLE WEBSITE TERMS AND CONDITIONS.

Last Updated: 30/09/2020