PRELIMINARY This Privacy Policy explains our privacy practices for processing Personal Data on our Website / Application and Services. We may process your Personal Data when you visit and browse our Website and use our Application and Services, 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 / Application or Services. By browsing this Website and/or use our Application and Services, 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 / Application and/or the Services. If you have further questions or concerns regarding this policy please contact us at: support@symania.com.

PRIVACY POLICY

URU Sec Ltd. (“Symania”, “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 and users of our Website / Application (or “you”) of our policies and procedures regarding the collection, use and disclosure of information we receive when you use the Website / Application and/or the Services.

1. Definitions:

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

“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 the Services of Authentication.

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

“Website / Application” means our public Website available at www.symania.com and our Application available at Google Play and App Store 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 / Application and/or Services. This Privacy Policy does not apply to our other services that may have separate privacy policies that do 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 / Application or using our Services, 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.

The Personal Data That We Collect or Generate If you browse our Website / Application and/or use of Services, 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 / Application and/or the interface of the Services in the following ways:

a) Information that your browser and/or device 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 / Application and/or Services. We use these tools to help us improve our Website / Application 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 / Application and the Services;

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

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 / Application and the Services; 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 / Application and the Services based on users’ preferences, experiences and difficulties;

f) to communicate with you and contact you to obtain feedback from you regarding the Website / Application and the Services;

g) to disclose to third party vendors, service providers, contractors or agents who perform functions on our behalf with respect to the Website / Application and the Services;

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 / Application and the Services; 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 / Application or the Services. 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 / Application or the Services. You may exercise your choice or request further information, by contacting us at: support@symania.com. 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 / Application or the Services;

c) monitor and analyze use of the Website / Application and the Services and for the technical administration and troubleshooting of the use of the Website / Application and the Services; 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. provided that any such third party will commit to protect your privacy as required under the Applicable Laws and this Policy.

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 / Application.

9. Your Rights; “Do Not Track” Requests

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: support@symania.com 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. Given the complexity and technical challenges associated with enforcing “do not track” requests, we generally do not comply with such requests. 10. Data Security

We take the safeguarding of the Personal and Non Personal Data very seriously, and 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 / Application and the Services will be immune from any wrongdoings, malfunctions, unlawful interceptions or access, or other kinds of abuse and misuse.

We also regularly monitor our systems for possible vulnerabilities and attacks, and regularly seek new ways and for further enhancing the security of our Website / Application and Services and protection of our users’ privacy.

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 / Application or the Services, do not reply and please contact us at support@symania.com.

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 / Application, 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 / Application and/or the Services 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 / Application or the Services.

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 / Application, 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 / Application 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 / Application.

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: support@symania.com.

If you have any concerns relating to this Policy, please contact us and we will make good-faith efforts to address your concerns. We are usually able to resolve privacy questions or concerns promptly and effectively. If you are not satisfied with the response you receive from us, you may escalate concerns to the applicable privacy regulator in your jurisdiction. Upon request, we will provide you with the contact information for that regulator.

Copyright © 2020, URU Sec Ltd. All rights reserved.

Last Updated: January 26, 2021