Privacy Policy

1. Data Collection

When we use the term "personal data" (or "personal information" under certain data protection laws such as the California Consumer Privacy Act (CCPA)) in this Privacy Policy, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to an individual or household. It does not include aggregated, de-identified or anonymized information that is maintained in a form that is not reasonably capable of being associated with or linked to an individual.

Specifically, we collect or generate the following types of personal data through the Services:

• Contact details: such as name, email address, phone number and address.
• Communication content: Personal Data collected from direct communications with us (e.g. personal data contained in any forms and inquiries that you may submit to us; records of calls and chat conversations with customer service and support, sales or procurement; feedback and testimonials received).
• Account details: such as log-in credentials, including shipping address and payment method and amount, your purchasing activity, including interests and order history.
• Billing Information: payment and billing information, including billing address
• Your content: Personal data in content uploaded by you to the Editor (e.g., images and text with Personal Data) including any text with Personal Data in your interactions with the Editor AI chat feature. For clarification, the Editor is where you can create designs using our services.
• Usage data: including activity logs, inferred or presumed data generated from your use of the Services (e.g. your behaviour in the platform; design choices and AI generated preferences or trends in Editor), viewing/browsing history on our website.
• Device and Network Activity data: your IP address and non-precise location derived from it, and device information (including operating system, device ID, browser version, language settings used), cookies and pixels installed on your device.

We collect the above personal data either through your interaction with us and our Services, automatically through cookies and other tracking technologies (as further detailed in Section 6 below), from our Service Providers (as further detailed in Section 5 below), or through third party services, social media, and other business initiatives.

For the purposes of the California Consumer Privacy Act ("CCPA"), in the last twelve (12) months, we have collected the following categories of personal information, as defined in the CCPA: identifiers; commercial information; customer record information; internet or other electronic network activity information; geolocation data; visual or similar information and inferences.

2. Data Uses & Business Purposes

Specifically, we collected and used personal data in the last twelve (12) months for the following purposes:

• To facilitate, operate, enhance, and provide usage of our Services.
• To provide you with optimal assistance and support, including analysing and improving our customer support services.
• To develop, customize and improve the Services and enhance the user experience, including based on common or personal preferences, experiences, difficulties and feedback, including through the utilization and optimization of Artificial Intelligence and Machine Learning capabilities.
• To provide, enhance, and optimize the AI features within our Services.
• To contact you with general or personalized service-related messages (such as password-retrieval or billing); or with promotional messages that may be of specific interest to you (as further described in Section 7 below); and to facilitate, sponsor and offer certain events and promotions.
• To support and enhance our data security measures, including for the purposes of preventing and mitigating the risks of fraud, error or any illegal or prohibited activity.
• To create aggregated statistical data, inferred non-personal data or anonymized or pseudonymized data (rendered non-personal), which we or our business partners may use to provide and improve our respective Services or for any other business purpose.
• To enforce our Terms, resolve disputes, and protect our business interests and the interests and rights of third parties.
• To comply with our contractual and legal obligations and requirements, and maintain our compliance with applicable laws, regulations and standards.

If you interact with us from or reside or are using the Services in a territory governed by privacy laws which determine that consent is the only or most appropriate legal basis for the processing of personal data as described in this Privacy Policy (either in general, based on the types of personal data you expect or elect to process or have processed by us or via the Services, or due to the nature of such processing), your continued interaction with us and/or use of our Services means that you have had the opportunity to read and that you accept this Privacy Policy and will be deemed as your consent to the processing of your personal data for all purposes detailed in this Privacy Policy, unless applicable law requires a different form of consent. If you wish to withdraw such consent, please contact us at support@dappas.com.

3. Data Location

We and our Service Providers (defined below) maintain, store and process personal data in the United States, Israel, and other locations as reasonably necessary for the proper performance and delivery of our Services, or as may be required by law.

While privacy laws may vary between jurisdictions, Dappas and its affiliates and Service Providers are each committed to protect personal data in accordance with this Privacy Policy, customary industry standards, and such appropriate lawful mechanisms and contractual terms requiring adequate data protection, regardless of any lesser legal requirements that may apply in the jurisdiction to which such data is transferred. In jurisdictions where there are limits on the cross-border transfer of personal data we will adopt lawful and applicable transfer mechanisms, as necessary.

4. Data Retention

We retain personal data for as long as we deem it as reasonably necessary in order to maintain and expand our relationship and provide you with our Services and offerings; in order to comply with our legal and contractual obligations; or to protect ourselves from any potential disputes (i.e., as required by laws applicable to log-keeping, records and bookkeeping, and in order to have proof and evidence concerning our relationship, should any legal issues arise following your discontinuance of use), all in accordance with our data retention policy.

To determine the appropriate retention period, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether those purposes can be achieved through other means, as well as applicable legal requirements.

Please note that we do not retain your payment information, it is transferred directly to the relevant Payment Service Provider. We only retain a token of such payment information (which cannot be used to reidentify it) and the chosen payment method.

You also have the right to request the deletion of your personal data at any time, as further described in Section 9 below.

If you have any questions about our data retention policy, please contact us at support@dappas.com.

5. Data Disclosure

We may disclose your personal data in the following instances:

• Legal Compliance: in exceptional circumstances, we may disclose or allow government and law enforcement officials access to your personal data, in response to a subpoena, search warrant or court order (or similar requirement), or in compliance with applicable laws and regulations, with or without notice to you. Such disclosure or access may occur if we believe in good faith that: (a) we are legally compelled to do so; (b) disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing; or (c) such disclosure is required to protect our legitimate business interests, including the security or integrity of our Services.
• Service Providers:we engage selected third-party companies and individuals to perform services on our behalf or complementary to our own. Such service providers may include hosting services, manufacturing, printing and shipping services, data security services, order (routing and fulfillment) management services, billing and payment processing services, web content creation, AI tools and features, fraud detection and prevention services, web and product analytics, e-mail distribution and monitoring services, session or activity recording services, chatbot services, performance measurement, data optimization and marketing services, social and advertising networks, event production and hosting services, e-mail, voicemails, support, enablement and customer relation management systems, and our legal, financial and compliance advisors (collectively, "Service Providers"). Our Service Providers may have access to personal data, depending on each of their specific roles and purposes in facilitating and enhancing our Services, and may only use the data as determined in our agreements with them.
• Shopify: we use Shopify to power our online store and payment processing. You can read more about how Shopify uses your Personal Information here: https://www.shopify.com/legal/privacy
• Sharing your Feedback or Recommendations: If you submit a public review or feedback, note that we may (at our discretion) store and present your review to other users of our Services. If you wish to remove your public review, please contact us at support@dappas.com. If you choose to send others an e-mail or message recommending and inviting them to use the Services, we will use the contact information you provide us to automatically send such invitation e-mail or message on your behalf. Your name and e-mail address may be included in the invitation e-mail or message.
• Protecting Rights and Safety: we may share your personal data with others if we believe in good faith that this will help protect the rights, property or personal safety of Dappas, any of our users, visitors, or any members of the general public.
• Third-Party Websites and Services:our Services may include links to third-party websites, and integrations with third-party services. Such websites and third-party services, and any information you process, submit, transmit or otherwise use with such websites and third-party services, are beyond the scope of Dappas' Terms and Privacy Policy and will therefore be governed by such third-party's terms and privacy practices and policies, and not by this Privacy Policy. We encourage you to carefully read the terms and privacy policies of such websites and third-party services.
• Subsidiaries and Affiliated Companies; Change of Control: we may share personal data internally with our affiliated companies (including Dappas IT Ltd (IL) and Dappas IT Inc (US). In addition, should Dappas undergo any change in control or ownership, including by means of merger, acquisition or purchase of its assets, your personal data may be shared (to the extent necessary and customary) with the parties involved in such an event. If we believe that such an event might materially affect your personal data then stored with us, we will notify you of this event and the choices you may have via any of the means of communication available to us.
• Additional Sharing: we may share your personal data in additional manners, pursuant to your request or explicit approval, or if we are legally obligated to do so, or if we have successfully rendered such data non-personal, non-identifiable and anonymous. We may transfer, share or otherwise use non-personal and non-identifiable data at our sole discretion and without the need for further approval.
• Event Sponsors:If you attend an event or webinar organized by us, or download or access an asset on our Services related to such an event, webinar or other activity involving third-party sponsors or presenters, we may share your personal data with them. In these circumstances, your personal data collected for and in this context will also be subject to the sponsors' privacy statements.

For the purposes of the CCPA, in the past twelve (12) months, we may have disclosed the following categories of personal information to the recipients listed above: identifiers; commercial information; customer record information; internet or other electronic network activity information; geolocation data; visual or similar information and inferences. We did so in pursuit of the business and commercial purposes described in Section 2 above.

6. Cookies and Tracking Technologies

Our website utilizes "cookies", anonymous identifiers, pixels, container tags and other technologies in order to provide and monitor them, ensure that they perform properly, analyse our performance and marketing activities, for product development and improvements, and to personalize your experience.

To learn more about our practices concerning cookies and online tracking, please visit our Cookie Policy.

7. Communications

We engage in service and promotional communications, through social media, e-mail, phone, surveys, SMS and notifications.

Service Communications

We may contact you with important information regarding our Services. For example, we may send you notifications (through any of the means available to us) of order summaries and shipping updates, to inform you of changes or updates to our Services, billing and account issues, etc. Please note that you will not be able to opt-out of receiving certain service communications which are integral to provision of the Services (like shipment updates or billing notices, payment issues etc.).

Promotional Communications

Subject to applicable regulations, we may also notify you about new features, current offerings, events, special opportunities or any other information we think you will find valuable. We may provide such notices through any available contact means (e.g., SMS or e-mail), through the Services, or through our marketing campaigns on any other sites or platforms.

If you wish not to receive such promotional communications, you may notify Dappas at any time by e-mailing us at support@dappas.comor by following the "unsubscribe" link contained in the promotional communications you receive.

8. Data Security

In order to protect personal data held with us, we and our Service Providers implement industry standard physical, procedural and technical measures designed to secure personal data and minimize the risks of theft, damage, loss of information, or unauthorized access or use of information. However, we cannot guarantee that our Services will be immune from any wrongdoings, malfunctions, unlawful interceptions or access, or other kinds of abuse and misuse. If there is any unexpected activity or inaccurate information or if you have reason to believe that your information is no longer secure, or if you have any questions about our security, please contact us by e-mail at support@dappas.com.

9. Data Subject Rights

Individuals have rights concerning their personal data. Please contact us by e-mail at support@dappas.comif you wish to exercise your privacy rights under any applicable law, including the CCPA and the Israeli Protection of Privacy Law 5741-1981 (the "PPL").

Such rights include, to the extent available to you under the laws which apply to you, but are not limited to: the right to know/request access to (specific pieces of personal data collected; categories of personal data collected; categories of sources from whom the personal data was collected; purpose of collecting personal data; categories of third parties with whom we have shared personal data), to request rectification or erasure of your personal data held with Dappas, or to restrict or object to such personal data processing (including, for US states residents, the right to direct us not to "sell" or "share" your personal information, or process it for "targeted advertising", as explained below), to obtain a copy or port such personal data, or the right to equal services and prices (e.g. freedom from discrimination).

To the extent applicable to you, you may also designate an authorized agent, in writing or through a power of attorney, to request to exercise your privacy rights on your behalf. The authorized agent may submit a request to exercise these rights by emailing us.

When you or an authorized agent ask us to exercise any of your rights under this Privacy Policy or applicable law, we may request you to provide us with certain additional information to verify your identity, prevent the disclosure of personal data relating to other individuals, and better understand the nature and scope of your request. Such additional data will be then retained by us for legal purposes (e.g. as proof of the identity of the person submitting the request, or proof of request fulfillment), in accordance with Section 4 above.

You may also have the right to lodge a complaint with the relevant privacy protection authority, applicable to the processing of your personal data.

10. Sale/Sharing for Targeted Advertising

Under some US data protection laws, like the California Consumer Privacy Act (CCPA), our disclosure of certain internet activity and device information to third parties may be considered a "sale" or "sharing" of personal information. We do so in pursuit of the business and commercial purposes described in Section 2 above.

For the purposes of the CCPA, in the last twelve (12) months we have "sold" or "shared" internet or other electronic network activity information, geolocation data, and commercial Information with our analytics and advertising partners. Dappas has not knowingly sold or shared the personal information of individuals under the age of 16.

For the purposes of the California Invasion of Privacy Act (CIPA), we will only activate cookies that may result in a "sale" and/or "sharing" of your personal information if you have directed us to do so by opting in to all of our cookies through our cookie banner.

To the extent the opt-in activation of such cookies is considered a "sale" or "sharing" of your personal information under the CCPA, you may exercise your right to opt out again at any time in the following ways (cumulative):

• Click the cookie widget icon on the left side of each page of our website, toggle on the "Do Not Sell or Share My Personal Information", then click the "Continue" button.
• Please note: If you visit us from a different device or browser, or clear Cookies, then you need to return to this screen to re-select your preferences.
• Set the Global Privacy Control (GPC) for each participating browser system that you use to opt out of the use of third-party advertisement, analytics or other cookies (instructions on how to download and use GPC are available here).

11. Additional Information and Contact Details

Updates and amendments: we may update and amend this Privacy Policy from time to time by posting an amended version on our website. The amended version will be effective as of the date it is published. We will provide prior notice if we believe any substantial changes are involved via any of the communication means available to us. After such notice period, all amendments shall be deemed accepted by you.

External links: while our Services may contain links to other websites or services, we are not responsible for their privacy practices and we encourage you to pay attention and to read the privacy policies of each and every website and service you visit. This Privacy Policy applies only to our Services.

Our Services are not designed to attract children under the age of 16: we do not knowingly collect personal data from children and do not wish to do so. If we learn that a child is using the Services, we will attempt to prohibit and block such use and to promptly delete any personal data stored with us which we deem to relate to such child. If you believe that we might have any such data, please contact us at support@dappas.com.

US Privacy Matters: if you have any questions or inquiries regarding our US privacy practices, or would like to exercise your rights under any applicable US state privacy laws, you can contact us by email at support@dappas.com.

Database Controller:For the purposes of Israel's Protection of Privacy Law, Dappas IT Ltd. serves as the "Database Controller" responsible for the personal data processed in connection with our Services, and may be contacted at support@dappas.com.

Questions, Concerns or Complaints: if you have any comments or questions regarding our Privacy Policy, or if you have any concerns regarding your personal data held with us, or if you wish to make a complaint about how your personal data is being processed by Dappas, you can contact us at support@dappas.com.