APPREEL PRIVACY POLICY

This Privacy Policy ("Privacy Policy"), is an integral part of our End User License Agreement ("EULA"), and governs the processing and transfer of personal data collected or processed by Appreel Shrot Drama Ltd. ("Company", "we", "us" or "our") when you accessing or using our mobile application or our services, all as detailed in the applicable EULA (respectively the "App" and "Service").

Any capitalized terms not defined herein shall have the meaning ascribed to them in the EULA.

This Privacy Policy explains what data we may collect from you, how such data may be used or shared with others, how we safeguard it and how you may exercise your rights related to your Personal Data (as defined below), among others, and where applicable, as required according to the EU General Data Protection Regulation ("GDPR"), the California Consumer Privacy Act ("CCPA") and other US states.

If you have any questions regarding this Privacy Policy or our data practices, you are welcome to contact us at: support@appreel.tv

This Privacy Policy explains our data collection practices that are applicable to any users of our App or our Services ("you" or "your").

POLICY AMENDMENTS:

We may update this Policy from time to time at our discretion. The latest version will always be available on our website or through the App setting, with the "Last Modified" date indicating the most recent changes. If we make material changes, we will notify you as required by applicable law and, where necessary, seek your consent. Unless otherwise specified, amendments to this Policy will take effect 30 days after the updated Policy is posted. We encourage you to review this Policy periodically to stay informed about our privacy practices.

CONTACT INFORMATION AND DATA CONTROLLER INFORMATION:

Appreel Shrot Drama Ltd incorporated under the laws of Israel, and it is the controller of your Personal Data.

You may contact us and our DPO: support@appreel.tv

DATA SETS WE COLLECT AND FOR WHAT PURPOSE:

You can find here information regarding the purposes for which we process your personal data as well as our lawful basis for processing, the definition of "personal" and "non-personal" data, and how it is technically processed.

Non-Personal Data

When you interact with our website and Services, we may collect aggregated, non-personal, non-identifiable information ("Non-Personal Data"). This information is collected without identifying the specific user from whom it originates. Non-Personal Data may include aggregated usage statistics and technical data transmitted by your device, such as browser or device type, language preference, time and date of access, country location, and similar information.

Personal Data

We may also collect, directly or indirectly, individually identifiable information from you during your access to or interaction with the website or Services ("Personal Data"). Personal Data is information that identifies or can reasonably be used to identify an individual. The specific types of Personal Data we collect, along with the purposes for which we process it and the legal bases for such processing, are detailed in the table below.

We do not knowingly collect or process any Personal Data that constitutes or reveals racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, health data, or data concerning a person's sex life or sexual orientation ("Special Categories of Personal Data").

Please note that the specific processing activities for each purpose of use and lawful basis described in the table above may vary. These activities typically include automated operations such as collection, storage, use, transmission, erasure, or destruction of data. Transfers of personal data to third countries, as further explained in the Data Transfer Section, are conducted under the same lawful bases outlined in the table above.

Additionally, we may use certain Personal Data to prevent prohibited or illegal activities, fraud, misappropriation, infringement, identity theft, or any other misuse of the Services, and to enforce our Terms. We also process Personal Data to protect the security and integrity of our databases and Services, and to take precautions against legal liability. This processing is carried out based on our legitimate interests.

We may collect various categories of Personal Data and Non-Personal Data from you, depending on how you interact with the Services offered through our website and Platform, as described above. If we combine Personal Data with Non-Personal Data, the combined data will be treated as Personal Data for as long as it remains combined.

HOW WE COLLECT YOUR INFORMATION:

Depending on the nature of your interaction with us, we may collect the above detailed information from you, as follows:

• Automatically, We process this information based on your consent provided through the organic in-app permissions in order to execute our contract with you and provide you with our services.
• When you voluntarily choose to provide us with information, such as when you contact us, all as detailed in this Policy.
• Provided from third-parties.

SDK & TRACKING TECHNOLOGIES:

Our Services and some of our Service Providers utilize "cookies" or "software development kits ("SDK")" anonymous identifiers and other tracking technologies (collectively, "Tracking Technologies") which help us provide and improve our Services, personalize your experience and monitor the performance of our activities and campaigns, as well as the usage of our Apps and Services as a whole.

The specific SDK we currently use, the purpose of the SDK, their privacy policy and opt-out controls are set forth in the table below:

DATA SHARING – CATEGORIES OF RECIPIENTS WE SHARE PERSONAL DATA WITH:

We share your data with third parties, including our partners or service providers that help us provide our Services. You can find here information about the categories of such third-party recipients.

When we share information with services providers and partners, we ensure they only have access to such information that is strictly necessary for us to provide the Services. These parties are required to secure the data they receive and to use the data for pre-agreed purposes only while ensuring compliance with all applicable data protection regulations (such service providers may use other non-personal data for their own benefit).

DATA RETENTION:

In general, we retain the Personal Data we collect for as long as it is necessary to fulfill the purposes described in this Policy, in accordance with applicable laws and regulations. The retention period may vary depending on the nature of the data, the context in which it was collected, and the specific purposes for which it is processed. We regularly review the Personal Data we hold to ensure it is still required for the stated purposes and to comply with our legal obligations. Where applicable, you may exercise your right to request deletion or express your preference to opt out of certain data processing activities, and we will honor such requests in accordance with applicable law. If your Personal Data is no longer needed for the purposes for which it was collected, we will either securely delete or anonymize your data, unless we are required to retain it for legitimate business or legal reasons.

There are certain circumstances in which we may retain your Personal Data for extended periods, including but not limited to: (i) where retention is required by legal, regulatory, tax, or accounting obligations; (ii) where it is necessary to maintain an accurate record of your interactions with us, particularly in the event of complaints, disputes, or investigations; (iii) where we reasonably believe there is a prospect of litigation or other legal proceedings related to your Personal Data or our relationship with you; or (iv) where retention is necessary to protect our rights, property, or the safety of our users or others. Please note that, except as required by applicable law, we are not obligated to retain your Personal Data for any specific period, and we reserve the right to delete or anonymize your data at our discretion and without prior notice to you. Our data retention practices are designed to ensure that Personal Data is not kept longer than necessary and is handled in accordance with our legal and regulatory obligations.

SECURITY MEASURES:

We are deeply committed to safeguarding the security and confidentiality of your information. To this end, we implement a comprehensive range of physical, technical, and administrative security measures designed to protect your data from unauthorized access, misuse, disclosure, alteration, unlawful destruction, or accidental loss. Our security protocols are regularly reviewed and updated to ensure compliance with applicable regulations and industry best practices. These measures may include, but are not limited to, secure data storage, encryption of sensitive information both in transit and at rest, multi-factor authentication, regular security audits, access controls, and staff training on data protection. We also maintain incident response procedures to promptly address any actual or suspected security breaches. While we strive to use commercially acceptable means to protect your Personal Data, please be aware that no method of transmission over the Internet or method of electronic storage is completely secure. As such, we cannot guarantee absolute security, but we are dedicated to continuously improving our security practices to mitigate risks and protect your information to the greatest extent possible.

If you believe that your privacy has not been handled appropriately, or if you suspect a breach of our Privacy Policy, we encourage you to contact us immediately at our designated email address. Additionally, if you become aware of any attempt by a third party to gain unauthorized access to your Personal Data or to compromise the security of our Services, please notify us without delay. Upon receiving your report, we will investigate the matter thoroughly and take appropriate action to address your concerns. If we discover a security incident that affects your Personal Data, we will make reasonable efforts to notify you promptly, as well as any relevant authorities as required by applicable law. Our notification will include information about the nature of the breach, the data potentially affected, and the steps we are taking to mitigate any potential harm. We are committed to maintaining open communication with our users and to taking all necessary measures to protect your privacy and the integrity of your information.

INTERNATIONAL DATA TRANSFER:

We use Google Cloud which are located in EU, US and Asia. Further, certain processing activities are conducted in Israel, or other countries. In the event of data transfer out of your jurisdiction, we will take appropriate measures to ensure that your Personal Data receives an adequate level of protection as required under applicable law. Further, when Personal Data collected within the EU is transferred outside the EU (and not to a recipient in a country that the European Commission has decided provides adequate protection) it shall be transferred under the provisions of the standard contractual clauses approved by the European Union. If you would like to understand more about these arrangements and your rights in connection therewith, please contact us at our email.

USER RIGHTS

According to data protection and privacy laws may grant you with certain rights with regards to your Personal Data, all according to your jurisdiction. The rights may include one or all of the following: (i) request to amend your Personal Data we store accessing; (ii) review and access your Personal Data that we hold; (iii) request to delete your Personal Data that we hold (as long as we do not have a legitimate reason for retaining the data); (iv) restrict or object to the process your Personal Data; (v) exercise your right of data portability (vi) contact to a supervisory authority in your jurisdiction and file a complaint; and (vii) withdraw consent (to the extent applicable). If you wish to submit a request to exercise your rights, please contact us at: support@appreel.tv

When you contact us and request to exercise your rights regarding your Personal Data, we will require certain information from you in order to verify your identity and locate your data and that the process of locating and deleting the data may take reasonable time and effort, as required or permitted under applicable law. Data privacy and related laws in your jurisdiction may provide you with different or additional rights related to the data we collect from you, which may also apply.

You have the right to lodge a complaint with the EU Member State supervisory authority if you are not satisfied with the way in which we handled the complaint.

OPT OUT OPTIONS

Interest-Based Advertising ("IBA"): We do not sell your Personal Data. Some of our Apps may include providing you with advertisements therefor we may "share" your Personal Data with third parties for personalized advertising purposes. If you wish to opt-out from the sharing of your personal data with third parties for the purpose of cross-contextual interest-based advertising there are many way to do so, as further detailed below. Please note that even if you opt-out you may still see personalized ads based on information other companies and ad networks have collected about you, if you have not opted out of sharing with them.

For IBA opt out options on desktop and mobile websites, please visit:

• Digital Advertising Alliance (US) https://www.aboutads.info/choices/
• Digital Advertising Alliance (Canada) https://youradchoices.ca/en/tools
• Digital Advertising Alliance (EU) https://www.youronlinechoices.com/
• Network Advertising Initiative https://optout.networkadvertising.org/?c=1

ELIGIBILITY AND CHILDREN PRIVACY:

The Services are not intended for use by children (the phrase "child" shall mean an individual that is under the age defined by applicable law, which concerning the EEA is under the age of 16, and with respect to the US, under the age of 13), and we do not knowingly process children's information. We will discard any information we receive from a user that is considered a "child" immediately upon discovering that such a user shared information with us. Please contact us at: support@appreel.tv if you have reason to believe that a child has shared any information with us.

ADDITIONAL NOTICE TO US RESIDENTS

Residents of certain U.S. states (depending on the applicable state law, acting as an individual or in the household context only and not in a commercial or employment context, as a job applicant or as a beneficiary of someone acting in an employment context or as representative of a business), may have additional rights under applicable privacy laws and be entitled to additional disclosures.

"Personal Data" under applicable US privacy laws, generally means any information that is linked or reasonably linkable to an identified or identifiable individual (and usually does not include publicly available information that is lawfully made available from government records, or that a consumer has otherwise made available to the public; de-identified or aggregated consumer information; or information excluded from the states laws scope.

"Sensitive Data" includes data revealing racial, ethnic or national origin; religious beliefs; information regarding an individual's medical history, mental or physical health condition, diagnosis or medical treatment; neural data; status as transgender or non-binary; sex life or sexual orientation; status as a victim of a crime; citizenship or immigration status; genetic or biometric data; Personal Data collected from a known child; and precise geolocation data.

We are required to provide you with a clear and accessible privacy notice that includes the categories of Personal Data processed, including any Sensitive Data, the purpose of processing, the categories of Personal Data shared with third parties, the categories of third parties with whom Personal Data is shared, the categories of Personal Data that is sold or used for targeted advertising, if any, the categories of third parties to whom the Personal Data is sold, if any, a list of your data rights and instructions for exercising those rights and appealing decisions, and out contact information. This information is detailed under this Privacy Policy and further below.

Categories of Personal Data & Categories of Third Parties with Whom Personal Data is Shared:

Under the Privacy Policy, we describe our collection and processing of Personal Data, the categories of Personal Data that are collected or processed, and the purposes for which Personal Data is processed, stored or used. We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated, or incompatible purposes without obtaining your consent, unless we are otherwise entitled, required or permitted under applicable laws.

Additionally, this Privacy Policy, details and discloses the categories of third parties we share Personal Data with for a business purposes.

"Sale" of Personal Data:

Under US privacy laws, in principle, the term "sale" refers to disclosing or making available Personal Data to a third-party in exchange for monetary or other valuable consideration, including for targeted advertising purposes. We do not "sell" information as this term is commonly understood, meaning - we do not, and will not, disclose your Personal Data in direct exchange for money or some other form of payment. As detailed above we may share and disclose your Personal Data with Advertisers in order to provide you with ads and for targeted advertising purposes.

Consumer Rights Related to Their Personal Data:

Residents of certain U.S. states may have additional rights under applicable privacy laws, subject to certain limitations, which may include:

• Right to Delete. You have the right to request us to delete the personal information we have collected about you.
• Right to Correct. You have the right to request us to correct inaccurate personal information we maintain about you.
• Right to Confirm Processing, Know and Access. You have the right to confirm whether we are processing your personal information and know and access the personal information we have collected about you, including the categories of personal information, the categories of sources from which the personal information is collected, the business or commercial purpose for collecting, selling, or sharing personal information, the categories of personal information and service providers, contractors and third parties to whom we disclosed personal information, and the specific pieces of personal information we have collected about you. You have the right to receive this information in a format, to the extent technically feasible, that is portable, usable, and allows you to transmit the personal information to a person without impediment or hindrance.
• List of Specific Third Parties: You have the right, at our option, to receive a list of the specific third parties, other than natural persons, to which we have disclosed either: (1) your personal information or (2) any personal information.
• Rights Related to Profiling. You have the right to opt out of the processing of your personal information for profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer. However, this right does not apply because we do not engage in profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer.
• Rights Related to Sharing for Targeted and Cross-Context Behavioral Advertising or Sale. You have the right to opt out of the sharing of your personal information for targeted or cross-context behavioral advertising or the sale of your personal information.
• Rights Related to Sensitive Personal Information or Data. Data privacy laws may provide additional protection for sensitive personal information or data. However, this right does not apply because we do not process sensitive personal information or data.
• Right to No Discrimination. You have the right not to be discriminated against for exercising any of your privacy rights. This includes us not: (a) denying you goods or services; (b) charging you different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; (c) providing you a different level or quality of goods or services; (d) suggesting to you that you will receive a different price or rate for goods or services or a different level or quality of goods or services; and (e) retaliating against you for exercising your privacy rights.
• Right to Appeal. If we decline to take action in response to your exercise of a privacy right, we will inform you of the reason for denying your request and provide you instructions on how to appeal the decision.

Exercising Consumer Privacy Rights:

You may submit a request to exercise most of your privacy rights under U.S. state privacy laws by sending an email to: support@appreel.tv

For certain rights, we will take steps to verify your identity and your request by matching the information provided by you with the information we have in our records. In some cases, we may request additional information to verify your identity, or where necessary to process your request. If we are unable to verify your identity after a good faith attempt, we may deny the request and, if so, will explain the basis for denial and how to remedy any deficiencies, where applicable.

Appealing

You may appeal a denial of your privacy right requests by emailing us at support@appreel.tv. Within 45 days of receipt of an appeal, we will inform you in writing of any action taken in response to the appeal, including a written explanation of the reasons for the decisions. If we deny your appeal, you may submit a complaint to the Attorney General of your state.

Authorized Agents

If permitted or required by applicable law, you may exercise your privacy rights through an authorized agent (which may include a guardian or conservator). If we receive your request from an authorized agent, we may ask for evidence that you have provided such agent with a power of attorney or that the agent otherwise has valid written authority to submit requests to exercise rights on your behalf. If you are an authorized agent seeking to make a request, please contact us at support@appreel.tv.

Shine the Light Law Disclosure for California Residents

California law permits residents of California to request certain details about how their information is shared with third parties for direct marketing purposes. If you are a California resident and would like to make such a request, please email us at: support@appreel.tv