Loyaltie is a platform that help businesses start and grow by establishing recurringrevenue streams (“Loyaltie,” “we,” “us,” and “our” refer to Seven Round VenturesLtd.). Loyaltie enables an individual, entity or an organization (the “Creator”) tocreate a web page (“Loyaltie Site”) to offer and sell goods and/or services on arecurring   basis   to   users   (“Members”   and   a   “Membership”).   The   Services   (asdefined   below)   include   features   to   facilitate   payments,   revenue   predictions,marketing and community engagement.Privacy and security are very important to us at Loyaltie. This Privacy Notice(“Notice”) is meant to help you (the “end user”) understand how we at Loyaltiecollect, use, and share your data when you use our services on which we make thisNotice available – for example, when you use Loyaltie as a Creator to offer goods orservices, or when subscribe as a Member to purchase goods or services on arecurring basis (collectively, the “Services”). Before you use or submit any information through, or in connection with, theServices, please carefully review this Notice. By using any part of the Services, youacknowledge that you have read, understood and agree to the collection, use, anddisclosure of your information as outlined in this Notice.

Personal Information We Collect

Loyaltie collects personal information in several ways, primarily:

• When Creators or Members provide personal information directly to us (suchas when setting up an account or a Loyaltie Site);
• When we passively collect personal information from you (such as from yourinteraction with our website); and
• From other parties (such as Loyaltie’s payment provider).

Information You Provide Loyaltie

This is information that you provide us through text fields, such as your name,payment information, and contact details. The information of this type that werequire   you   to   provide   differs   depending   on   whether   you   create   an   account,become a Creator, purchase a Membership or other offering, otherwise engagewith a Creator, and typically includes:

• first and last name/surname;
• email address;
• phone number;
• username;
• password; and/or
• county and state/province of residence.

You may also have the option to sign up for Loyaltie using a Facebook, Google, or Apple account. We will ask for permission to access basic information from your Facebook, Google, or Apple account, such as your userID, full name, email address, and profile picture. You can choose to stop sharing that information with us at any time by going to Facebook, Google, or Apple to remove Loyaltie’s access to that account and your ability to use it to log in to Loyaltie. In order to use an account with one of these companies to sign up for Loyaltie, these companies may require you to share personal data with them, including information about your usage of Loyaltie. As applicable to you, please consult the Facebook, Google, and Apple privacy policies to learn more about that.

You may also have the option to add more information to your Loyaltie account,such as a location, social media links, and an “about me” section, which we storealong with the other information that we collect.

Members

A Member is someone who subscribes and/or makes a recurring purchase from aCreator on Loyaltie. We collect and process information about the Creators yousubscribe to and/or the Memberships and other offerings you purchase, and whatgoods or services you receive. If you, as a Member, purchase a Membership with aphysical product or good, then you will be asked to optionally provide your shippinginformation, which may include your address, phone number and contact details.We may also derive your location from your self-disclosed country, your IP address,and/or your payment card.

As   a   Member,   you   will  be  asked  to   provide  your  payment  information   to   ourpayment partner, Stripe, Inc (“Stripe”). Loyaltie partners with Stripe for paymentprocessing, and the payment information you submit is collected and used byStripe in accordance with their privacy practices (read Stripe’s Privacy Policy).Loyaltie only stores the last four digits of your credit card or bank account (asapplicable), expiration date, and country, which we require for tax, regulatory, andsecurity purposes. We do not store full payment card or bank account details.

Creators

A creator is someone who creates a Loyaltie Site on Loyaltie to engage with end-users   and   offer   memberships   for   recurring   purchase   of   goods   or   services.   Tobecome a creator, you must create a Loyaltie Site that describes what you arecreating or producing and any goods or services you are offering to Members. Youmay also be required to provide your bank account or credit card information toprocess payouts. You must also provide us with additional information for taxpurposes. Depending on your location and the type of creations that you create,you may have to provide Loyaltie some combination of the following:

• business name;
• address;
• country of citizenship;
• tax   identification   number,   company   registration   number,   and/or   VATnumber;
• date of birth;
• bank account information; and/or
• copies of your ID card and proof of residency.

Additional Information We Collect

Automatically Collected Information

We   automatically   receive   information   when   you   view   Loyaltie   Site’s   on   orotherwise interact with our website, even if you have not created an account. Forexample, when you visit loyaltie.com, view or interact with a Loyaltie embed onanother website or, sign into Loyaltie’s services, or view or interact with an emailfrom Loyaltie, we may automatically receive information about you, including:

• your IP address;
• your approximate location (typically derived from your IP address);
• your browser and/or device type;
• your operating system;
• your language settings;
• the referring web page (including parameters contained therein);
• your mobile carrier;
• device information (including device and application IDs);
• your search terms;
• the links you click;
• the pages you visit;
• session length, dwell time, and duration of media experiences (includingview time); and/or
• cookie information (further detailed in our Cookie Policy).

Information from Third-Party Accounts

After creating a Loyaltie account, you may be able to connect your social mediaaccount(s) (e.g. Twitter, Facebook, YouTube, TikTok, and Twitch) with Loyaltie, andin that case we may collect and store some information related to those accounts,including:

• profile information, including userID, username, page name, and/or profilepicture;
• follower and/or subscriber counts;
• relationship graph, including accounts you follow and that follow you;
• post and/or upload counts; and/or
• view, like, and/or comment counts.

When you connect such a third-party account to your Loyaltie account, that third-party service will typically present a page that describes the information that Loyaltie can access and/or permissions you are granting to Loyaltie to take actions on your behalf. At any time, you may be able to revoke Loyaltie’s access to those accounts using the respective third party’s settings page.

How We Use Information

As applicable, we use the information we collect to:

• comply with industry requirements, self-regulatory guidelines, state law, and international laws, including tax reporting requirements;
• verify your identity to comply with industry requirements, self-regulatory guidelines, state law, and international laws;
• enable you to sign in to your account;
• enable you to subscribe to Creators and/or purchase Memberships on Loyaltie;
• process payments and payouts;
• apply VAT and/or sales tax;
• deliver Membership goods and/or services;
• send physical merchandise to your shipping address;
• send you messages and notifications, email, and SMS/MMS as controlled by your notification preferences;
• provide you with information about Loyaltie, Loyaltie products, and your Memberships and subscriptions on Loyaltie;
• provide you with customer support and reply to your questions;
• promote your Loyaltie Site for greater discoverability;
• personalize the Loyaltie experience market Loyaltie products and services to you or to audiences similar to you,including via personalized advertising (also referred to as online behavioraladvertising or interest-based advertising) as controlled by your marketingpreferences;
• understand and analyze how you use the service;
• conduct research and development to improve Loyaltie and develop ourproducts and their features;
• and/or prevent   fraud,   abuse,   and   illegal   activities   on   Loyaltie,   including   usingautomated processing and manual review;

Information Shared with Creators

By subscribing, purchasing a Membership or offering on Loyaltie, or otherwiseengaging with or becoming a Member of a Creator, you agree to share personaldata with that Creator that may include:

• your full name in your Loyaltie profile;
• your email address;
• your other Loyaltie profile information, including your avatar image;
• your   physical   address,   city,   state/province,   and   country   if   you   select   aMembership with a physical product and choose to provide your shippinginformation;
• your phone number, when you have signed up to support a creator whoengages with you via text messages, if you select a Membership with aphysical product and choose to provide your shipping information, or whenyou have signed up for event notifications via text;
• information about your Membership, including amount and start date butnot your full payment card information;
• andsome aggregated data about how you use Loyaltie.

When you use Loyaltie to send a message to another user, including a Creator, the contents of that message will be shared with the recipients you select.

Creators are required to keep Members’ personal information confidential and may only   use  Members’   personal  information   they   receive  as   strictly   necessary   to deliver their goods or services or communicate Members directly. Creators may not sell any personal information or use it for targeted advertising purposes.

Loyaltie reserves the right to take disciplinary action(s), including suspension, for any Creator or Member found to be in violation of any requirement or limitation set out in this Notice.

Information Shared with Third Parties

We never sell your information to third parties. Other than information that isshared with Creators, or displayed on public sections of our website, we will onlyshare data with third parties under the following circumstances:

• Loyaltie’s service providers: these are companies that are contractuallyengaged   with   us   to   provide   us   with   services,   including   cloud   hosting,content   distribution,   security,   order   fulfillment,   email   and   documentmanagement,   internal   communication/chat,   analytics,   credit   cardprocessing, multi-currency settlement solutions, and fraud detection andprevention. We may share your personal data with such service providerssubject to obligations consistent with this Privacy Notice and any otherappropriate confidentiality and security measures, and on the condition thatthese third parties use your personal data only on Loyaltie’s behalf andpursuant to our instructions (service providers may use other non-personaldata for their own benefit).
• Government and law enforcement agencies
• Tax reporting: to satisfy obligations to report information to tax authorities,including reporting information about creators’ earnings on Loyaltie, taxidentification information, and information related to transactional taxessuch as Valued Added Tax, Goods and Services Tax, other local service orsales taxes in non-US locations, and state sales tax in the United States.
• Legal process and law enforcement: to protect the security or integrity ofLoyaltie, as well as to protect the rights, property, and safety of Loyaltie, itsemployees, users, creators, or others, or if we believe that disclosure isreasonably necessary to comply with a law, regulation, or other valid legalprocess   (e.g.   subpoenas   or   warrants   served   on   Loyaltie).   When   legallypermitted   to   do   so,   and   under   appropriate   circumstances,   Loyaltie   willendeavor to notify you (typically by email) when we intend to release yourdata pursuant to a valid government request, law-enforcement request, orother legal process.
• Any   third   parties   connected   with   the   sale,   merger,   bankruptcy,   sale   ofassets,   or   reorganization   of   our   company:   in   such   a   circumstance   thepromises in this Privacy Notice apply to any data transferred to a new entity.

Your Privacy Rights and Choices

If at any time, you believe that your personal information has been used inviolation of this Notice, you may report your concerns to us by emailingsupport@loyaltie.com.

Privacy Rights under Certain Laws.

Users in certain locations, such as the European Economic Area, United Kingdom,and   California,   are   given   certain   privacy   rights   regarding   their   personalinformation. These rights include the right to know what personal information weprocess about you and to request access to, correction of, and deletion of yourpersonal information. You also may have the right to ask for a portable copy of yourpersonal information or to object to or ask that we restrict our processing of yourpersonal   information.   If   we   rely   on   your   consent   for   personal   informationprocessing,   you   may   withdraw   your   consent   at   any   time.   Loyaltie   will   notdiscriminate against any user for exercising privacy rights provided by applicablelaw.

If you would like further information regarding your legal rights under applicabledata privacy law or would like to exercise any of them that are relevant to you,contact us at support@loyaltie.com. In your email, please include your full name,username, zip code or postal code, the email address at which you prefer to becontacted and, if different, the email address associated with your   Loyaltieaccount, and the privacy right(s) you are requesting, such as the deletion ofinformation related to a particular transaction or the correction of specificinformation about you. For your own privacy and security, at our discretion, wemay require you to provide your identity before providing the requestedinformation. Please note that Loyaltie may take up to 30 days after identityverification to fulfill such requests. Please monitor your incoming emailcorrespondence in case we have follow-up questions regarding your privacy request.

Marketing Opt Out

Each   email   marketing   communication   we   send   you   will   contain   instructionspermitting  you   to   “opt   out”  of  receiving future  marketing   communications.   Inaddition,   if   at   any   time   you   wish   not   to   receive   any   future   marketingcommunications or you wish to have your name deleted from our mailing lists,please contact us at the email address support@loyaltie.com. If you opt out ofreceiving marketing communications or other information we think may interestyou, we can still send you emails about your account or any Services you haverequested or received from us.

Cross Border Data Transfers

Loyaltie is a global organization headquartered in Israel, which processes yourinformation   in   servers   in   a   number   of   countries,   including   the   United   States.Loyaltie has implemented other appropriate cross-border transfer solutions, suchas Standard Contractual Clauses approved by appropriate regulatory authorities,to provide adequate protection for transfers of certain personal data from theEuropean Economic Area, United Kingdom, and Switzerland to the United States.

Our Legal Bases for Processing Personal Information

When applicable under foreign data protection laws, such as the European Union’s General Data Protection Regulation, Loyaltie relies on the following legal bases for processing personal information:

• Obligations to You. We use your personal information to give you informationabout the Membership you create or purchase, to enable Creators to launchand display their Memberships, and to allow Members to find and purchasethem.
• Our Legal Requirements. Sometimes laws, regulations, and other bindinglegal obligations say we need to collect and use your personal information.For example, tax laws require us to retain records of pledges and paymentsmade through our Services.
• Our Legitimate Interests. This is a legal term in data protection law thatmeans   that   Loyaltie   has   a   good   and   fair   reason   to   use   your   personalinformation, and we do so in ways that are balanced with your interests andrights. For example, we might rely on our legitimate interests when weprocess personal information to protect the security and integrity of ourwebsite or when we personalize information users see on Loyaltie to helpour  users  find  the  information  they  want quickly.  When  we  rely  on  ourlegitimate interests, we take into account the effects that these actionsmight have on you. If you have questions about our decisions regarding ourlegitimate interests, you may contact us.
• Your Consent. We may ask for your consent for certain personal informationprocessing. For example, we may rely on your consent to use non-essentialcookies   or   to   provide   you   with   marketing   communications.   When   youconsent, you may withdraw your consent at any time by contacting us atsupport@loyaltie.com.

Data Retention

Loyaltie stores your personal data until it is no longer necessary to provide theServices,   or   until   you   ask   us   to   delete   it.   We   may   continue   to   retain   someinformation even after you delete your account if we are required to do so in orderto comply with applicable laws.

Complaints

We   take   your   privacy   queries   seriously,   and   are   committed   to   resolving   anycomplaints that may arise about our collection or use of your data. If you believeyour   privacy   rights   have   been   infringed,   we   encourage   you   to   contact   us   atsupport@loyaltie.com. You may also have the right to complain to the appropriatedata protection supervisory authority.

Contact Us

To contact our Data Protection Team with questions about this Notice wherever you are based, whether in the EU or internationally, please email support@loyaltie.com.

You can contact us in writing at:

Seven Round Ventures Ltd. Haganim 20

Tzofit, 4492500

Israel