DRILL L.S. NEUROMARKETING ISRAEL LTD.
PRIVACY POLICY

This Privacy Policy explains our privacy practices for processing Personal Data on
our Website. We may process your Personal Data when you visit and browse our
Website, as described in this Policy.

All capitalized terms shall have the meanings as defined below.

We are committed to protecting your privacy and processing your Personal Data fairly
and lawfully in compliance with applicable data protections laws. You can access our
full Privacy Policy below to help you understand better how we collect and use your
Personal Data. In it, we explain in more detail the types of Personal Data we collect,
how we collect it, what is the legal basis of collection, what we may use it for, who
we may share it with, what our retention periods are and what are your rights in
relation to the Personal Data we collect.

Within the Privacy Policy you will find some specific examples of why and how we
use your Personal Data.

Read this policy and make sure you fully understand our practices in relation to your
Personal Data, before you access or use the Website. By browsing this Website,
you consent to the processing of your Personal Data as detailed in this Privacy Policy. If
you have read this Privacy Policy, and remain opposed to our practices, you must
immediately discontinue all use of the Website.  If you have further questions
or concerns regarding this policy please contact us at: https://shopperai.ai/.

PRIVACY POLICY

Drill L.S. Neuromarketing Israel Ltd. (“Drill”, “we”, “our” or “us”) provides this
Privacy Policy, as will be updated from time to time (our “Policy” or “Privacy Policy”)
to inform the Visitors of our Website (or “you”) of our policies and
procedures regarding the collection, use and disclosure of information we receive
when you use the Website. 1. Definitions:

“Applicable Laws” shall mean any applicable privacy or other law, to the extent
applicable to Drill.

“Personal Data” means individually identifiable information, namely information
that identifies an individual or may with reasonable efforts cause the identification of
an individual.

“Non-Personal Data” means information that does not personally identify you and
does not reveal your specific identity as an individual, such as anonymized
information.

“Services” means an analysis performed by "ShopperAI" system of Drill to help
businesses monitor real-time implied customer responses and receive updated and
reliable insights that can influence earnings and increase sales.

“you” means visitors of our Website and/or users of our Services.

“Website” means our public website available at https://shopperai.ai/ providing
information regarding the services we provide to clients.

This Policy was originally written in English. If you are reading a translation and it
conflicts with the English version, please note that the English version prevails.

2. When Does This Privacy Policy Apply

This Privacy Policy applies to Personal Data about you that we collect, use or
otherwise process regarding your relationship with us as a user of our Website.
This Privacy Policy does not apply to our Services that may have separate privacy policies
that may not incorporate this Policy.

3. The Types Of Personal Data That We Collect

Personal Data That You Provide To Us

Information provided through the “Contact Us” form: While browsing our Website,
you may provide us Personal Data if you wish us to contact you and provide more
information regarding our Services, including: full name, email, company phone
number and/or personal phone number, position in workplace and name of workplace,
company and/or personal address including city, state/ region, postal code (“Contact
Details”). You may choose to provide us additional Personal Data through the “free
text” section in our contact form. Please do not provide further Personal Data than is
required for us to contact you [Sivan: Please check the yellow part and delete the
irrelevant information].

The Personal Data That We Collect or Generate

If you browse our Website, we may collect your Personal Data.

4. The Types Of Non-Personal Data That We Collect Or Generate

In addition to the categories of Personal Data described above, we may also process
further anonymized information and data that is not processed by reference to a
specific individual. We may collect this Non-Personal Data through the Website in
the following ways:

a) Information that your browser sends (“Log Data”). This Log Data may include,
but is not limited to, non-identifying information regarding your device,
operating system, internet browser type, screen resolution, language and
keyboard settings, internet service provider, the web page you were visiting and
information you search, etc.

b) We may use automated devices and applications to evaluate usage of our
Website. We use these tools to help us improve our Website and Services,
performance and user experience. We may also engage third parties to track
and analyze data or provide other services on our behalf Such third parties may
combine the information that we provide about you with other information that
they have collected from other sources. This Policy does not cover such third
parties’ use of the data and such use is governed by such third parties’ privacy
policies. For more information, please see Section ‎7 “Sharing Information
with Others” below.

5. How We Use Personal Data

Personal Data is used for the following primary purposes (as may be updated from
time to time):

a) to provide and operate the Website;

b) to monitor and analyze use of the Website and study and analyze the
functionality of the Website;

c) to provide service announcements and notices, promotional messages and
market the our services;

d) to enforce our Terms of Use, policies and other contractual arrangements and
prevent misuse of the Website; and to comply with court orders and warrants
and to take any action in any legal dispute and proceeding;

e) to better understand your needs, both on an aggregated and individualized
basis, in order to further develop, customize and improve our Website based
on users’ preferences, experiences and difficulties;

f) to communicate with you and contact you to obtain feedback from you
regarding the Website;
g) to disclose to third party vendors, service providers, contractors or agents who
perform functions on our behalf with respect to the Website;
h) to create aggregated statistical data and other aggregated and/or inferred Non-
Personal Data, which we or our business partners may use to provide and
improve our Website; and

i) as otherwise authorized by you.

We may use your email address you provided us to contact you when necessary,
including in order to send you reminders, offers and to provide you information and
notices about the Website. At any time, you may choose (opt out) whether your
Personal Data is to be used for sending such marketing materials which are not an
essential part of the usage of the Website. You may exercise your choice or request
further information, by contacting us at: shopperai.ai/ .

6. How We Use Non-Personal Data

We may use information that is Non-Personal Data for the same purposes we use
Personal Data (where applicable) and in addition in order to:

a) compile anonymous or aggregate information;

b) disclose to third party vendors, service providers, contractors or agents who
perform tasks on our behalf in connection with the Website ;

c) monitor and analyze use of the Website and for the technical administration and
troubleshooting of the use of the Website; and

d) provide us with statistical data.


7. Sharing Information With Others

We do not sell, rent or lease your Personal Data. We may share your Personal Data
with our, service providers and other third parties, if necessary to fulfil the purposes
for collecting and processing the information, such as cloud vendors, subcontractors
providing us Processing services, etc.

Additionally, a merger, acquisition or any other structural change may require us to
transfer your Personal Data to another entity, provided that the receiving entity will
comply with this Policy.

We may need to disclose Personal Data in response to lawful requests by public
authorities or law enforcement officials, including meeting national security or law
enforcement requirements. We cooperate with government and law enforcement
officials to enforce and comply with the law.

8. Transfer Of Data Outside Your Territory

We may store, process or maintain information in various sites worldwide, including
through cloud based service providers worldwide. We may transfer your Personal
Data to our subsidiaries or third parties in locations around the world for the purposes
described in this Privacy Policy. Wherever your personal information is transferred,
stored or processed by us, we will take reasonable steps to safeguard the privacy of
your personal information.

If you are located in a jurisdiction where transfer of your Personal Data to another
jurisdiction requires your consent, then you provide us your express and unambiguous
consent to such transfer or the storage, processing or maintenance of the information
in other jurisdictions by using the Website.

9. Your Rights

In all of the above cases in which we collect, use or store your Personal Data, you
may have certain rights set out in the laws of your jurisdiction and, in most cases, you
can exercise them free of charge. To the extent required by Applicable Law, you may
contact us at:  shopperai.ai/ and request to know what Personal Data
we keep about you, in which case we will make good-faith efforts to locate the data
that you request to access.

When you ask us to exercise any of your rights under this Policy and Applicable Law,
we may need to ask you to provide us certain credentials to make sure that you are
who you claim you are, to avoid disclosure to you of Personal Data related to others
and to ask you questions to better understand the nature and scope of data that you
request to access.

We may redact from the data which we will make available to you, any Personal Data
related to others and/or as required by Applicable Law.

10. Data Security

We use a variety of industry standard systems, applications and procedures to protect
the information from loss, theft, damage or unauthorized use or access. However,
although we make efforts to protect your privacy, we cannot guarantee that the
Website will be immune from any wrongdoings, malfunctions, unlawful interceptions
or access, or other kinds of abuse and misuse.

You should take steps to protect against unauthorized access to your password, phone,
and computer by, among other things, signing off after using a shared computer,
choosing a robust password that nobody else knows or can easily guess, and keeping
your log-in and password private. In addition, you should take steps to protect against
unauthorized access to Personal Data stored on your premises as well as defining
limited access rights to such information on a need to know basis.

If you receive an e-mail asking you to update your information with respect to the
Website, do not reply and please contact us at shopperai.ai/.

11. Data Retention

We retain different types of information for different periods, depending on the
purposes for processing the data. We may retain Personal Data for as long as
necessary in order to support our legitimate business purposes, for example, for
storing data, for documentation, for cyber-security management purposes, legal
proceedings and tax issues.

We may store aggregated Non Personal Data without time limit. In any case, as long as
you use the Website, we will keep information about you, unless we are legally
required to delete it, or if you exercise your rights to delete the information.

12. Our Policy Toward Children

Our Website are not meant to be used by or for persons under 18, as such, we do not
knowingly collect Personal Data from minors younger than 18. If this age requirement
is not met, you are required to obtain the consent of the parent or guardian to provide
and process information in accordance with this Policy; lacking such consent, please
do not use the Website.

13. Changes To This Privacy Policy

We may change the terms of this Privacy Policy from time to time by posting notice
on our Website, with a seven (7) day advance notice. However, substantial changes
will be effective thirty (30) days after the notice was initially posted. We will make an
effort to inform you of substantial changes through the channels of communication
generally used in such circumstances.

If we need to adapt the Policy to legal requirements, the amended Policy will become
effective immediately or as required.

Your continued use of the Website following such notice shall constitute your consent
to any changes made and a waiver of any claim or demand in relation to such
changes. If you do not agree to the new or different terms, you should not use and are
free to discontinue using the Website.

14. Applicable Law And Dispute Resolution

This Privacy Policy shall be governed by and construed in
accordance with the laws of the State of Israel, without regard to its
conflict of law provisions. 

The courts located in the city of Tel-Aviv, Israel, shall have exclusive jurisdiction
over all disputes and proceedings arising from this Privacy Policy.

15. Contact Us

For further information about this Policy, please contact us at
shopperai.ai/.

If you have any concerns relating to this Policy, please contact us and we will make
good-faith efforts to address your concerns.

Copyright © 2022, Drill L.S. Neuromarketing Israel Ltd.. All rights reserved.

Last Updated: December 21, 2022