Privacy Policy

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In order to ensure transparency and give you more control over your personal information, this privacy policy (“Privacy Policy”) governs how we, Zenner Inc. and/or, where applicable, one of its group companies (together, “Zenner” “we”, “our” or “us”) use, collect and store personal data we collect or receive from or about you (“you”) such as in the following use cases:


(i) When you browse or visit our website, www.zenner.ai (“Website”)
(ii) When you make use of, or interact with, our Website
a. When you subscribe to our newsletter
b. When you contact us (customer support, need help, submit a request)
(iii) When you interact with us, through e-mails and/or text messages, in connection with your trip
(iv) When we book a flight on your behalf
(v) When you attend a marketing event (and provide us with your Personal Data) and/or exchange business cards with us
(vi) When we acquire your Personal Data from third-party sources (e.g., from a travel agency)
(vii) When we use the Personal Data of our customers (e.g. contact details)
(viii) When we use the Personal Data of our service providers (e.g. contact details)
(ix) When you interact with us on our social media profiles (e.g., Facebook, Instagram, Twitter, LinkedIn)

We greatly respect your privacy, which is why we make every effort to provide a platform that would live up to the highest of user privacy standards. Please read this Privacy Policy carefully, so you can fully understand our practices in relation to personal data. “Personal Data” or “Personal Information” means any information that can be used, alone or together with other data, to uniquely identify any living human being. Please note that this is a master privacy policy and some of its provisions only apply to individuals in certain jurisdictions. For example, the legal basis in the table below is only relevant for GDPR-protected individuals. We need your Personal Information in order to deliver Zenner Core Services (defined below). For example, if we do not know your email address or phone number, we cannot send you alerts and updates about your travel or if we do not know your name and date of birth, we cannot purchase for you a new flight ticket.

You are not legally obligated to provide us Personal Information, and you hereby confirm that providing us personal information is at your own free will, but if you do not provide us with your Personal Information we will not be able to perform and provide certain services, features, content and functionalities to you as further detailed in this Privacy Policy. You are always in control of what Personal Information you provide us, and we aim to be transparent about why we collect, and what we will do with that Personal Information. In short:

• We need your Personal Information in order to deliver Zenner Core Services and other related services to you.
• We also collect analytics about your usage of the product in order to improve your experience.
• You can share information with us in order to receive marketing materials.

• We will only transmit data to third parties where it is required to do so in order to deliver our Core Services and other related services or as otherwise stated in this Privacy Policy.

We will not sell or monetize your data in any way that is not related to Zenner offering, nor will we knowingly allow other companies to do so. Important note: Nothing in this Privacy Policy is intended to limit in any way your statutory right, including your rights to a remedy or means of enforcement.

Table of contents:

1. What information we collect, why we collect it, and how it is used
2. How we protect and retain your Personal Data
3. How we share your Personal Data
4. Additional information regarding transfers of Personal Data
5. Your privacy rights. How to delete your account
6. Use by children
7. Interaction with third party products
8. Log files
9. Analytic tools
10. Specific provisions applicable under California privacy law
11. Contact us

This Privacy Policy can be updated from time to time and, therefore, we ask you to check back periodically for the latest version of this Privacy Policy. If we implement significant changes to the use of your Personal Data in a manner different from that stated at the time of collection, we will notify you by posting a notice on our Website or by other means.

1. WHAT INFORMATION WE COLLECT, WHY WE COLLECT IT, AND HOW IT IS USED

Specific Personal Data we collect
Why is the Personal Data
collected and for what purposes?
Legal basis (GDPR only, if applicable)
Third parties with whom we share your Personal
Data
Consequences of
not providing the
Personal Data
Retention period
When you browse or visit our Website
Cookies, analytic tools and log files

For more information,
please read our cookies policy
We use performance/ analytics
cookies to analyze how the Website is accessed, used, or
is performing. We do this in order to provide you with a personalized and improved user experience and to
maintain, operate and continually improve the Website
Consent
Google analytics

Front and Intercom –
Communication platforms
For more information,
please read our cookies policy
Certain Website
features may not be
available

Read more about the
purposes of each
When you subscribe to our newsletter
• Email address
• Name
• Company Name
To send you marketing
communications
• To send you more
information about
Zenner
Consent Legitimate

interest (e.g., to send you more information
about Zenner)
3rd party platforms such as for the following purposes:

SendGrid – Email service provider
Your Personal data will be stored until we no longer need the information and
proactively delete it or you send a valid deletion request. Please note that
we will retain it for a
longer or shorter period in accordance with data retention laws
Cannot send you
marketing communications

Cannot send you
more information
about Zenner
When you contact us (customer support, need help, submit a request)
• Full name
• Email address
• Any other information
that you decide to
provide/supply us
• To answer your
question(s)/request(s)
• To provide support
services
• To customize your
experience
Performance of a contract to which the data subject is
party or in order to take steps at the request of the
data subject prior to
entering into a contract Legitimate interest (e.g. provide support and answer your questions)
3 rd party platforms such as for the following purposes:

• Google Cloud Platform - Storage

• Front and Intercom
Communication platform
Your Personal Data
will be stored until we no longer need the information and
proactively delete it or you send a valid
deletion request. Please note that we will retain it for a longer or shorter period in accordance with data retention laws
Cannot answer your
question(s)/request(s)

Cannot provide
support services

Cannot customize your experience
• Full name
• Email address
• To send you marketing
communications
Consent
Cannot send you
marketing
communications
When you interact with us, through e-mails and/or text messages, in connection with your trip
• Full name
• Email address
• Phone number
Date of your flight
• Your flight number
• Any information that you decide to provide us
To offer real-time
tracking and solutions in connection with your

trip (e.g., detection of
flight cancellations and delays)
• To send SMS/email
notifications on the
flight you specified and any information on its changes, delays, time of
check-in, departure,
take-off or other parts associated with the flight

• To send you tips,
information,
recommendations and special offers in
connection with your
trip

• To offer rebooking
options

All the purposes together shall be referred as "the Core Services".
Performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract Legitimate interest (e.g. to send you communications
in connection with your trip)
3 rd party platforms such as for the following purposes:

Front – Communication
platform
Google Cloud Platform -
Storage

We will share your
personal data with the following third parties if you use them in order to

contact us:

WhatsApp –
Communication channel

Twilio Communication
channel

Facebook –
Communication channel
Your Personal Data
will be kept until you
have not interacted with us for 90 days or
you send a valid
deletion request. Please note that we will retain it for a longer or shorter period in
accordance with
applicable laws and
regulations
Cannot offer real-time tracking and solutions in connection with
your trip

Cannot send SMS/email notifications on the
flight

you specified
and any information on its changes, delays, time of check-in, departure, take-off or other parts associated with the flight

Cannot send you tips,
information,
recommendations and special offers in
connection with your
trip

Cannot offer
rebooking options
Cannot provide our
services
When we book a flight on your behalf
• Passport details

• Payment information

If you provide us with any data on behalf of other person, you should ensure that such person (i) requested these
services and is aware that we render them in his/her interest and (ii) agree that we process his/her personal data for these services.
• To book a replacement
flight on your behalf

• To allow you to pay for you replacement flight
Performance of a contract to which the data subject is
party or in order to take steps at the request of the
data subject prior to
entering into a contract
3 rd party platforms such as for the following purposes:

Google Cloud Platform -

Storage Airline companies – To book plane tickets
Your Personal Data
will be kept until you
have not interacted
with us for 90 days or
you send a valid
deletion request.

Please note that we will retain it for a longer or shorter period in accordance with applicable laws and regulations.
Cannot book a
replacement flight on
your behalf

Cannot allow you to
pay for your
replacement flight
When you attend a marketing event (and provide us with your Personal Data) and/or exchange business cards with us
• Full name
• Email address
• Phone number
• Title
• Company name
• Any other information
that you decide to
provide/supply us
with
• To initiate a business
communication and
establish and business
relationship
Consent

Legitimate interest (e.g., in contacting you after you
showed interest in our products and services).
3 rd party platforms such as for the following purposes:

Google Cloud Platform -
Storage

Twilio – Communication
channel

Front – Communication
platform
Your Personal Data will be stored until we no longer need the information and
proactively delete it or you send a valid deletion request.

Please note that
we will retain it for a
longer or shorter period in accordance with data retention laws
Cannot initiate a
business
communication and
establish and
business relationship
When we acquire your Personal Data from third-party sources (e.g., from a travel agency)
• Full name
• Email address
• Phone number
• Date of your flight
• Your flight number
• Any information that you decide to provide
us
• To provide our Core
Services to you

• To provide, if needed,
complementary services such as flight booking
Performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract Legitimate interest (e.g. to
provide our services)
3 rd party platforms such as for the following purposes:

Front – Communication
platform

Google Cloud Platform -
Storage

We will share your
personal data with the following third parties if you use them in order to
contact us:

WhatsApp –
Communication channel

Twilio – Communication
channel

Facebook –
Communication channel
Your Personal Data will be kept until you have not interacted with us for 90 days or you send a valid deletion request.
Please note that we will retain it for a longer or shorter period in accordance with applicable laws and regulations
Cannot provide the
Services

Cannot provide
complementary
services
When we use the Personal Data of our customers (e.g. contact details)
• Full Name
• Business email
• Company name
• Job title
• Phone number
• Any other data you
decide to
provide/supply
• To provide our services
• To perform the
applicable agreement
• To comply with legal
requirements
• To communicate with our customers
Processing is necessary for
the performance of a
contract to which our
customer is a party.
Compliance with a legal obligation (e.g. tax laws, bookkeeping laws, etc.). Legitimate interest (e.g.
send you contract-related communications)
3rd party platforms such as for the following purposes:

Google Cloud Platform -
Storage
Your Personal Data will be stored until we no longer need the information and
proactively delete it or you send a valid deletion request.

Please note that
we will retain it for a
longer or shorter period in accordance with data retention laws
Cannot provide our
services

Cannot perform the
agreement

Cannot comply with
relevant legal
requirements

Cannot communicate
with you
When we use the Personal Data of our service providers (e.g. contact details)
• Full name
• Email address
• Company name
• Phone number
• Address
• Any other information
that you decide to
provide/supply us
• To contact our service
providers
• To perform the
applicable agreement
Processing is necessary for
the performance of a
contract to which the data subject is party or in order to take steps at the request
of the data subject prior to entering into a contract (i.e. services agreement).
Legitimate interest (e.g. perform the contract, send
contract-related
communications).
3rd party platforms such as for the following purposes:

Google Cloud Platform -
Storage
Your Personal Data will be stored until we no longer need the information and
proactively delete it or you send a valid deletion request.

Please note that
we will retain it for a
longer or shorter period in accordance with data retention laws
Cannot contact our
service providers

Cannot perform the
applicable agreement
When you interact with us on our social media profiles (e.g., Facebook, Instagram, Twitter, LinkedIn)
• Full Name
• Email address
• Company name
• Job title
• Phone number
• Social media identifier
• Any other data you
decide to
provide/supply
To reply and/or respond to your request or
question
Legitimate interest (e.g. to respond your questions)
3 rd party platforms such as for the following purposes:

Front and Intercom -
Communication platforms

Twilio - Communication
channel
Your Personal Data will be stored until we no longer need the information and
proactively delete it or you send a valid deletion request.

Please note that
we will retain it for a
longer or shorter period in accordance with data retention laws
Cannot reply or
respond to your
request

Finally, please note that some of the above mentioned Personal Data will be used for detecting, taking steps to prevent, and prosecution of fraud or other illegal activity, to identify and repair errors, to conduct audits, and for security purposes. Personal Data may also be used to comply with applicable laws, with investigations performed by the relevant authorities, law enforcement purposes, and/or to exercise or defend legal claims. In certain cases, we may or will anonymize or de-identify your Personal Data. “Anonymous Information” means information which does not enable identification of an individual user, such as aggregated information about the use of our services. We may use Anonymous Information and/or disclose it to third parties without restrictions (for example, in order to improve our services and enhance your experience with them).

2. HOW WE PROTECT AND RETAIN YOUR PERSONAL DATA

2.1. Security.

We have implemented appropriate technical, organizational and security measures designed to protect your Personal Data. However, please note that we cannot guarantee that the information will not be compromised as a result of unauthorized penetration to our servers. As the security of information depends in par on the security of the computer, device or network you use to communicate with us and the security you use to protect your user IDs and passwords, please make sure to take appropriate measures to protect this information.

2.2. Retention of your Personal Data.

In addition to the retention periods mentioned above, in some circumstances we may store your Personal Data for longer periods of time, for example (i) where we are required to do so in accordance with legal, regulatory, tax or accounting requirements, or (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, or (iii) if we reasonably believe there is a prospect of litigation relating to your Personal Data or dealings. We have an internal data retention policy to ensure that we do not retain your Personal Data perpetually. Regarding retention of cookies, you can read more
in our cookie policy http://www.zenner.ai/cookies/.

3. HOW WE SHARE YOUR PERSONAL DATA


In addition to the recipients described above, we may share your Personal Data as follows:

3.1. With our hosting providers;

3.2. With our service providers, such as service providers providing us with cloud storage services;

3.3. With our staff and other entities within our group.

3.4. With our business partners and other third parties with whom we share your personal data in order to provide the Core Services and other related services (e.g., airlines,
hotels or travel agencies).

3.5. To the extent necessary, with regulators, courts or competent authorities, to comply with applicable laws, regulations and rules (including, without limitation, federal, state or local laws), and requests of law enforcement, regulatory and other governmental agencies or if required to do so by court order;

3.6. If, in the future, we sell or transfer, or we consider selling or transferring, some or all of our business, shares or assets to a third party, we will disclose your Personal Data to such third party (whether actual or potential) in connection with the foregoing events;

3.7. In the event that we are acquired by, or merged with, a third party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer, disclose or assign your Personal Data in connection with the foregoing events; and/or

3.8. Where you have provided your consent to us sharing or transferring your Personal Data (e.g., where you provide us with marketing consents or opt-in to optional additional services or functionality). If you want to receive the full list of the current recipients of your Personal Data, please make your request by contacting us to privacy@zenner.ai.

4. ADDITIONAL INFORMATION REGARDING TRANSFERS OF PERSONAL DATA

4.1. Storage: Google Cloud Platform – servers located in the US Central Region.

4.2. Access from Israel: Access from Israel is covered by the European Commission’s Adequacy Decision regarding Israel. You can read more here:
https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en.

4.3. External transfers: Where we transfer your Personal Data outside of EU/EEA (for example to third parties who provide us with services), we will obtain contractual commitments from them to protect your Personal Data.

5. YOUR PRIVACY RIGHTS. HOW TO DELETE YOUR ACCOUNT

5.1. Rights: The following rights (which may be subject to certain exemptions or derogations) shall apply to certain individuals (some of which only apply to individuals protected by the GDPR):
o You have a right to access Personal Data held about you. Your right of access may normally be exercised free of charge, however we reserve the right to charge an appropriate administrative fee where permitted by applicable law;
o You have the right to request that we rectify any Personal Data we hold that is inaccurate or misleading;
o You have the right to request the erasure/deletion of your Personal Data (e.g. from our records). Please note that there may be circumstances in which we are required to retain your Personal Data, for example for the establishment, exercise or defense of legal claims;
o You have the right to object, to or to request restriction, of the processing;

o You have the right to data portability. This means that you may have the right to receive your Personal Data in a structured, commonly used and machine- readable format, and that you have the right to transmit that data to another controller;

o You have the right to object to profiling;
o You have the right to withdraw your consent at any time. Please note that there may be circumstances in which we are entitled to continue processing your data, in particular if the processing is required to meet our legal and regulatory obligations. Also, please note that the withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal;
o You also have a right to request certain details of the basis on which your Personal Data is transferred outside the European Economic Area, but data transfer agreements and/or other details may need to be partially redacted for reasons of commercial confidentiality ;
o You have a right to lodge a complaint with your local data protection supervisory authority (i.e., your place of habitual residence, place or work or place of alleged infringement) at any time or before the relevant institutions in your place of residence. We ask that you please attempt to resolve any issues with us before you contact your local supervisory authority and/or relevant institution.

5.2. You can exercise your rights by contacting us at privacy@zenner.ai. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly in accordance with applicable law or inform you if we require further information in order to fulfil your request. When processing your request, we may ask you for additional information to confirm or verify your identity and for security purposes, before processing and/or honoring your request. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive. In the event that your request would adversely affect the rights and freedoms of others (for example, would impact the duty of confidentiality we owe to others) or if we are legally entitled to deal with your request in a different way than initial requested, we will address your request to the maximum extent possible, all in accordance with applicable law.

6. USE BY CHILDREN

We do not offer our products or services for use by children and, therefore, we do not knowingly collect Personal Data from, and/or about children under the age of eighteen (18). If you are under the age of eighteen (18), do not provide any Personal Data to us without involvement of a parent or a guardian. For the purposes of the GDPR, we do not intend to offer information society services directly to children. In the event that we become aware that you provide Personal Data in violation of applicable privacy laws, we reserve the right to delete it. If you believe that we might have any such information, please contact us at privacy@zenner.ai.

7. INTERACTION WITH THIRD PARTY PRODUCTS

We enable you to interact with third party websites, mobile software applications and products or services that are not owned or controlled by us (each a “Third-Party Service”). We are not responsible for the privacy practices or the content of such Third-Party Services. Please be aware that Third Party Services can collect Personal Data from you. Accordingly, we encourage you to read the terms and conditions and privacy policies of each Third-Party Service.

8. LOG FILES

We use log files. The information inside the log files includes internet protocol (IP) addresses, type of browser, Internet Service Provider (ISP), date/time stamp, referring/exit pages, clicked pages and any other information your browser may send to us. We use such information to analyze trends, administer the Website, track users’ movement around the Website, and gather demographic information.

9. ANALYTIC TOOLS

• Google Analytics.

The Website uses a tool called “Google Analytics” to collect information about use of the Website. Google Analytics collects information such as how often users visit this Website, what pages they visit when they do so, and what other websites they used prior to coming to this Website. We use the information we get from Google Analytics to maintain and improve the Website and our products. We do not combine the information collected through the use of Google Analytics with personal information we collect. Google’s ability to use and share information collected by Google Analytics about your visits to this Website is restricted by the Google Analytics Terms of Service, available at here, and the Google Privacy Policy, available at http://www.google.com/policies/privacy/. You may learn more about how Google collects and processes data specifically in connection with Google Analytics at http://www.google.com/policies/privacy/partners/. You may prevent your data from being used by Google Analytics by downloading and installing the Google Analytics Opt-out Browser Add-on, available at https://tools.google.com/dlpage/gaoptout/. We reserve the right to remove or add new analytic tools.

10. SPECIFIC PROVISIONS APPLICABLE UNDER CALIFORNIA PRIVACY LAW

10.1. Do Not Track Notice. Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers, but we may allow third parties, such as companies that provide us with analytics tools, to collect personally identifiable information about an individual consumer’s online activities over time and across different web sites when a consumer uses the Services.

10.2. Deletion of Content from California Residents. If you are a California resident under the age of 18 and a registered user, California Business and Professions Code Section 22581 permits you to remove content or personal information you have publicly posted. If you wish to remove such content or personal information and you specify which content or personal information you wish to be removed, we will do so in accordance with applicable law. Please be aware that after removal you may not be able to restore removed content. In addition, such removal does not ensure complete or comprehensive removal of the content or personal information you have posted and that there may be circumstances in which the law does not require us to enable removal of content .

10.3. Your Choices. You have certain choices about your Personal Information. Where you have consented to the processing of your Personal Information, you may withdraw that consent at any time and prevent further processing by contacting us as described in this Privacy Policy. Even if you opt out, we may still collect and us non-Personal Information regarding your activities on our services and for other legal purposes as described above. While we cannot guarantee privacy perfection, we will address any requests to the best of our ability as soon as possible. We will process such requests in accordance with applicable laws.

11. CONTACT US

If you have any questions, concerns or complaints regarding our compliance with this notice and the data protection laws, or if you wish to exercise your rights, we encourage you to first contact us at privacy@zenner.ai.