DATALEAD

PRIVACY POLICY

DataLead Ltd. ("Datalead", "Us" or "We"), respects its users' privacy and is committed to protect your personal information. This policy describes how we collect and use your personal information. We will collect your personal information to provide services that you request, inter alia, through our website ("Website"), when you choose to provide us with your personal information, for example when you decide to contact us for additional information. This policy also applies to individuals on which DataLead processes publicly available data.

Please be aware that this Privacy Policy does not apply to the practices of any third parties to whom the Company may disclose personal information pursuant to the terms of this Privacy Policy.

The Information We Collect and How We Collect and Use Information

Personal information means any information that may be used to identify an individual, including, but not limited to, full name, ID number, age, contact information, physical addresses, birth date, title, financial information and consumption and behaviour habits, as well as any information provided by you via your use of the services or when you interact with Us.

Datalead's technology, its services and products focus on aggregate collection and analysis of publicly available information and data from several open access web sources and platforms ("Publicly Available Data") and provide corresponding analyses and reports. DataLead collects and processes Publicly Available Data about individuals and entities, from open sources, which include, but not limited to, search engines, social networks, professional networks, stock exchanges, public registrations, government registrations and/or databases which are publicly available and any other legitimate publicly available source. Also, as specified above, we will collect any personal information that you may be required to provide us while using the Website.

We will collect personal information by lawful and fair means and, where appropriate, with the knowledge or consent of the individual concerned. Before or at the time of collecting personal information, we will identify the purposes for which information is being collected. We will collect and use personal information solely for fulfilling those purposes specified by us and for other ancillary purposes, unless we obtain the consent of the individual concerned or as required by law.

We may also collect cookies subject to our Cookie Policy available at the link. You can always change your cookie preferences using your web browser and the instructions in the Cookie Policy.

We may also collect and use other analytics tools to collect information about the use of our Website and types of technical data in the context of the use of our Website, including information about your computer or mobile device or any other device and system, software, location data, time zone, Internet Protocol (IP) address, language preference etc.

In addition, you acknowledge that you are not required under applicable law to provide us with any of your personal information, and that if you provide such information, it's at your own free will and consent.

Legal Basis for Processing

We will use personal information to provide and improve our services to our customers and others and meet our contractual, ethical and legal obligations, including for example:

1. Need to carry out the above processing of information, which is in anticipation of entering into engagements or as part of the performance of existing engagements with you or the organization you work for, for example for providing Datalead's services including for the purpose of customer support and inquiries.
2. To the extent that we use the personal information for our internal business purposes, research and development, advertising or promotional activities, we obtain your consent as part of signing this Privacy Policy.
3. Processing which is necessary for the purposes of the legitimate interests pursued by Datalead or by a third party of providing an efficient and wide-ranging service to customers, for example:
   1. Replying to your queries, troubleshooting problems, detecting and protecting against error, fraud or other criminal activity;
   2. To the extent that we use the personal information for analysing statistics, the basis for collection of data is our legitimate interest to conduct such improvements and analysis.
   3. To the extent that we use the personal information for the purposes of providing Datalead's services, the basis for collection of data is our legitimate interest to offer commercial services for our customers. Legitimate interests are generally of a legal or commercial nature and refer to instances in which DataLead has a vital interest that could not be achieved otherwise. In the context of collecting and processing Publicly Available Data, it is Datalead's legitimate interest to process such data for the purpose of providing its customers with services and products. It is Datalead's position that the legitimate interest in the collection and processing of such Publicly Available Data is not overridden by the rights of the data subject, mainly due to the fact that the processing of such Publicly Available Data is trivial and does not pose a significant risk to the rights and freedoms of the data subjects. This is also supported by the fact that such Publicly Available Data and is, evidently, made publicly available by the data subjects themselves and is available for review by any internet user. Therefore, subject to the safeguards applied to such Publicly Available Data, DataLead bases its collection and processing of such Publicly Available Data, to the extent that the underlying datasets include any personal information, on its legitimate interest.

Information Sharing and Disclosure

Publicly Available Data may be shared with our customers for the purpose of providing our services and products.

Also, we may share your personal information with other companies or people under any of the following circumstances:

• When we have your consent to share the information;
• We need to send the information to third parties who work on behalf of Datalead or with Datalead to provide a product or service (we will only provide those companies the information they need to for the services, and they are prohibited from using that information for any other purpose);
• In the event of sale or transfer of all or substantially all of Datalead or any Datalead affiliate's shares or assets, in cases of mergers or in case of negotiations with respect to the foregoing;
• Where needed for corporate audits or to investigate or respond to a complaint or security threat, to prevent illegal uses of our services, to defend ourselves against third party claims and assist in fraud prevention or investigation; and/or
• We will also disclose your personal information if required to do so by law, or in urgent circumstances, to protect personal safety, the public or our Website.

We will not sell or otherwise transfer the personally identifiable information you provide to Us at our Website to any third parties for their own direct marketing use unless we provide clear notice to you and obtain your explicit consent for your data to be shared in this manner.

For the above purposes, personal information may be transferred to recipients in countries around the world (which may be located outside the EU/EEA, European Economic Area) which in some cases may have a lower level of protection than that within the EU/EEA. When transferring personal data to countries outside the EU/EEA, to jurisdictions that did not receive an adequacy decision by the European Commission, we use standard contractual clauses approved by the European Commission to ensure a sufficient level of protection for your personal information. The standard contractual clauses can be found via the following link: http://ec.europa.eu/justice/data-protection/international-transfers/transfer/index_en.htm.

Data Retention

Datalead stores the personal information as long as it is necessary to fulfil the purpose for which the data has been collected. This means that Datalead deletes your personal information when such information is no longer necessary, unless we have a legitimate interest to retain such data for longer periods or are required to do so by any applicable law. Statistics which has been anonymised may be saved thereafter.

Data Subject Rights

If you are a resident of the EU/EEA, you may at any time request the rectification or erasure of your personal information. Please note however that deletion could mean that DataLead cannot provide you any requested services. You have the right to request a copy of your personal information from our record. You have the right to request a limitation of the use of your personal information (for example if you deem the information to be incorrect) or the termination of use of your personal information (for example as regards the use of the information to improve our services).

Rights of California Residents under the California Consumer Privacy Act (the "CCPA")

Right to Access Personal Information Collected, Disclosed or Sold:

You have the right to ask Us to disclose to you certain information regarding our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (as described below), we will disclose to you:

• The categories of personal information we sold about you;
• The categories of personal information we disclosed about you;
• The categories of sources for the personal information we collected about you;
• Our business or commercial purpose for collecting or selling that personal information;
• The categories of third parties with whom we shared that personal information;
• The specific pieces of personal information we collected about you; and/or
• If we sold or disclosed your personal information for a "business or commercial purpose", as defined in the CCPA, lists of sales, identifying the categories of personal information that each category of recipient purchased or obtained.

Right to Request Deletion of Personal Information

You have the right to request that we delete any of your personal information that we collected from you, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete, and direct our service providers to delete, your personal information from our records, unless an exception applies.

We may deny your request to delete your personal information if retaining the information is necessary for Us or our service providers to:

1. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;
2. Debug or identify and repair errors that impair existing intended functionality;
3. Exercise free speech, ensure the right of another consumer to exercise that consumer's right of free speech, or exercise another right provided for by law;
4. Comply with the California Electronic Communications Privacy Act;
5. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, if you have provided informed consent;
6. Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with Us;
7. Comply with a legal obligation; and/or
8. Make other internal and lawful uses of the personal information that are compatible with the context in which you provided such information.

Right to Non-Discrimination

We will not discriminate against you for exercising any of your rights under the CCPA. Unless permitted by the CCPA, we will not:

1. Deny you goods or services;
2. Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
3. Provide you a different level or quality of goods or services; or
4. Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Right to Opt-out of the Sale of Personal Data

You have the right to opt-out of the sale of personal data we have collected about you.

1. Deny you goods or services;
2. Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
3. Provide you a different level or quality of goods or services; or
4. Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

California Shine the Light Law

California Civil Code Section 1798.83 permits our visitors who are California residents to request certain information regarding our disclosure of personal data to third parties for their direct marketing purposes. To make such a request, please contact Our Customer Service.

Data Security

Datalead safeguards the security of the data you send Us with physical, electronic, and managerial procedures, taking into consideration the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of processing your personal information. While we strive to protect your personal information, we cannot ensure the security of the information you transmit to Us, and so we urge you to take every precaution to protect your personal data when you are on the Internet.

Changes to this Privacy Policy

Datalead will amend this policy from time to time. If we make any substantial changes in the way we use your personal information we will make that information available by posting a notice on this site.

Privacy Inquiries

Datalead is responsible for the processing of your personal data, and requests to exercise your rights as stated above shall be addressed to support@datalead.ai

If you are a resident of the EU/EEA and have a complaint regarding the processing of your personal data by DataLead you are entitled to report such dissatisfaction to the applicable supervisory authority in your country of residence.

If you have any questions or queries about this Privacy Policy or our services in general, please do not hesitate to contact Us: support@datalead.ai