2. Grounds for the Use of Your Information

We collect, process and use your information for the purposes described in this Privacy Policy, based at least on one of the following legal grounds:

• With your consent: We ask for your agreement to process your information for specific purposes and you have the right to withdraw your consent at any time. If you wish to withdraw your consent, please contact us via info@arugga.com.

• When performing our services and providing them to you under the TOU: We collect and process your Personal Information in order to provide you with the Service, following your acceptance of the Terms; to maintain and improve our Service; to develop new services and features for our Users; and to personalize the Services in order to ensure a better user experience.

• Our Legitimate interests: We process your information for our legitimate interests while applying appropriate safeguards that protect your privacy. This means that we process your information for things like detecting, preventing, or otherwise addressing fraud, abuse, security, usability, functionality or technical issues with our services, protecting against harm to the rights, property or safety of our properties, our Users, or the public as required or permitted by law; enforcing legal claims, including investigation of potential violations of this Privacy Policy.

• Under Applicable Law: We process your information in order to comply and/or fulfil our obligations under applicable laws, regulations, guidelines, industry standards, contractual requirements, legal process, subpoena or governmental request, as well as our Terms of Use.

More Specifically, we may use information that we collect about you for the following purposes:

• To provide, operate and improve our Services and manage our business;

• To generate analysis and insights for our Users and to better understand how they use our Services;

• To send you updates, notices, notifications, announcements, and additional information related to the Service;

• To create cumulative statistical data and other cumulative information and/or other conclusive information that is non-personal, in which we and/or our business partners might make use of in order to operate and improve our Services;

• To perform functions or services as otherwise described to you at the time of collection;

• To prevent, detect, mitigate, and investigate fraud, security breaches or other potentially prohibited or illegal activities;

• To comply with any applicable rule or regulation and/or respond to or defend against legal proceedings brought against us or our affiliates.

3. Sharing Information with Third Parties

We keep the information processed by us in strict confidence and only share your information with third parties in very limited circumstances and for very specific purposes, as described below:

• Third Party Services: We are partnering with a number of selected service providers, whose services and solutions complement, facilitate and enhance our own. These include hosting, database and web development platform (e.g., Squarespace and Google Drive), data analytics services (e.g. Google Analytics), systems that analyze crashes, functionality and usability and our business, legal and financial advisors (collectively, "Third Party Service Providers").

Such Third-Party Service Providers may receive or otherwise have access to your Personal Information, depending on each of their particular roles and purposes in facilitating and enhancing the Service, and may only use your Personal Information for such purposes. Such disclosure or access is strictly subject to the recipient's or user's undertaking of confidentiality obligations, and the prevention of any independent right to use this data except as required to help us provide you the Service.

• Law enforcement, legal proceedings, and as authorized by law: We may disclose or otherwise allow access to Personal Information pursuant to a legal requirement or request, such as a subpoena, search warrant or court order, or in compliance with applicable laws and regulations. Such disclosure or access may occur with or without notice to you, if we have a good faith belief that we are legally required to do so, or that disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing.

• Protecting Rights and Safety: We may share your Personal Information with others, with or without notice to you, in cases of emergency or if we believe in good faith that this will help protect the rights, property or personal safety of our company, any of our Users, or any members of the general public.

• Our Staff: We may share Personal Information internally with our staff at Arugga, for the purposes described in this Privacy Policy. Should we undergo any change in control, including by means of merger, acquisition or purchase of substantially all of its assets, your Personal Information may be shared with the parties involved in such event. If we believe that such change in control might materially affect your Personal Information then stored with us, we will notify you of this event and the choices you may have via e-mail and/or prominent notice on our Website and/or Services.

For the avoidance of doubt, we may share your Personal Information in additional manners, pursuant to your explicit approval, or if we are legally obligated to do so. Additionally, we may transfer, share or otherwise use Non-personal (including anonymized, statistical or aggregated) Information in our sole discretion and without the need for further approval.

4. Data Storage and Retention

Your information will be maintained, processed and stored by us and our authorized affiliates (as applicable) in secured cloud storage, provided by our Third-Party Service Providers.

While the data protection laws in jurisdictions where the information is physically stored may be different than the laws of your residence or location, please know that we, our affiliates and our service providers that store or process your Personal Information on our behalf are each committed to keeping it protected and secured, pursuant to this Privacy Policy and industry standards, regardless of any lesser legal requirements that may apply in a particular jurisdiction. You hereby accept the place of storage and the transfer of information as described above.

We retain the Personal Information we collect or receive from you only for as long as your registered account exists in our system and as needed in order to provide you with the Services and as otherwise necessary to comply with applicable laws and regulations. If you withdraw your consent to us processing your Personal Information, including by deleting your account, we will delete your Personal Information from our systems (except to the extent such data in whole or in part is required to comply with any applicable rule or regulation and/or to respond to or defend against legal proceeding bought against us or our affiliates).

5. Using Cookies and Other Tracking Technologies

We may use certain monitoring and tracking technologies to understand how you use our Services, including ones offered by Third Party Service Providers. These technologies are used in order to maintain, provide and improve our Services on an ongoing basis, and in order to provide a better experience to our Users. For example, these technologies enable us to: (i) keep track of and “remember” our Users’ preferences and authenticated sessions, (ii) secure our Services by detecting abnormal behaviors, (iii) identify technical issues and improve the overall performance of our Services, (iv) and create and monitor analytics. For more information, please follow the link to our Cookie Policy: [Arugga: Pls add link to Cookie Policy].

6. Direct Marketing

You hereby agree that we may use your contact details for the purpose of informing you regarding our products and services which may interest you and commercial updates about Arugga’s events and news appearances, and to send to your other marketing material, transmitted to the e-mail address you have provided. You may withdraw your consent via sending a written notice to Arugga by email to the following address: info@arugga.com.

7. Job Candidates:

The Company welcomes all qualified Candidates to apply to any of the open positions posted on our website, Facebook, LinkedIn, by sending us their contact details and CV (“Candidates Information”). We are committed to keep Candidates’ Information private and use it solely for our internal recruitment purposes (including for identifying Candidates, evaluating their applications, making hiring and employment decisions, and contacting Candidates by phone or in writing).

Please note that the Company may retain Candidates Information submitted to it even after the applied position has been filled or closed. This is done so we could re-consider Candidates for other positions and opportunities at the Company; so, we could use their Candidates Information as reference for future applications submitted by them; and in case the Candidate is hired, for additional employment and business purposes related to their work. If you previously submitted your Candidates Information to the Company, and now wish to access it, update it or have it deleted from our systems, please contact us at careers@arugga.com or info@arugga.com.

8. Minors and Third-Party Information Provided by You

To access the Services, you must be over the age of sixteen (16). Arugga does not knowingly collect Personal Information from children under the age of sixteen (16) and does not wish to do so. We reserve the right to request proof of age at any stage so that we can verify that minors under the age of sixteen (16) are not using the Service. In the event that it comes to our attention that a person under the age of sixteen (16) is using the Services, we may prohibit and block such User from using the Services and will make all efforts to promptly delete any Personal Information with respect to such User.

If you are submitting to the Services any personal information pertaining to any minor child, you hereby represent and warrant that you have received all the necessary legal consents or approvals or that you are the parent or legal guardian and have the actual authority and legal right to upload, submit, disclose or otherwise share the Non-personal Information and/or Personal Information and/or any other form of sensitive information, on the minor’s behalf.

If you are submitting to the Services any personal information pertaining to any third party, you hereby represent and warrant and have received all the necessary legal consents or approvals and have the actual authority and legal right to upload, submit, disclose or otherwise share the Non-personal Information and/or Personal Information and/or any other form of sensitive information, on the third party’s behalf.

9. Data Security

We take great care in implementing and maintaining the security of the Services and of your Personal Information. We employ industry standard procedures and policies to ensure the safety of our your information, reduce the risks stemming from loss of information and prevent unauthorized use of any such information. However, we do not and cannot guarantee that unauthorized access will never occur and reiterate that no measure can provide absolute information security.

10. Updating, Obtaining a Copy of or Deleting Your Information

If the law applicable to you grants you such rights, you may ask to access, correct, or delete your Personal Information that is stored in our systems. You may also ask for our confirmation as to whether or not we process your Personal Information, and request that we suspend the use of any Personal Information whose accuracy you contest while we verify the status of that data. Subject the limitations in law, you may also be entitled to obtain the Personal Information you directly provided us (excluding data we obtained from other sources) in a machine-readable format.

If you wish to exercise any of these rights, contact us with an explicit request at our Support Line at info@arugga.com. When handling these requests, we may ask for additional information to confirm your identity and your request. Please note, upon request to delete your Personal Information, we may retain such data in whole or in part to comply with any applicable rule or regulation and/or to respond to or defend against legal proceedings brought against us or our affiliates.

To find out whether these rights apply to you and for any other privacy-related matters, you can contact your local data protection authority if you have concerns regarding your rights under local law.

11. General

The terms of this Privacy Policy will govern the use of the Services and any information collected therein. Arugga reserves the right to change this Privacy Policy at any time, so please re-visit this page frequently. We will provide notice of substantial changes of this Privacy Policy on the homepage of the Website and/or we will send you an e-mail regarding such changes to the e-mail address that you may have provided to us. Such substantial changes will take effect seven (7) days after such notice was provided on our Website or sent by email. Otherwise, all other changes to this Privacy Policy are effective as of the stated “Last Revised” date and your continued use of the Website after the Last Revised date will constitute acceptance of, and agreement to be bound by, those changes.

This Privacy Policy, its interpretation, and any claims and disputes related hereto, shall be governed by the laws of the State of Israel, without respect to its criminal law principles. Any and all such claims and disputes shall be brought in, and you hereby consent to them being litigated in and decided exclusively by a court of competent jurisdiction located in Tel Aviv, Israel.

This Privacy Policy was written in English and may be translated into other languages for your convenience. If a translated (non-English) version of this Privacy Policy conflicts in any way with the English version, the provisions of the English version shall prevail.

12. Contact US

If you have any questions (or comments) concerning this Privacy Policy, you are welcome to send us an email at info@arugga.com, and we will make an effort to reply within a reasonable timeframe.