Overtok Privacy Policy
Last Revised: January 21, 2019

Overtok Ltd. (“Company”, “our”, “we” or “us”) provides its customers and users (“you”, “User”, “your”) a
proprietary technology enabling mobile and web end-users real-time communication means to connect
with mobile and web operators who use the Overtok service via an its proprietary API which is embedded
into their Customer Properties, we also provide you with our website, www.overtok.com (collectively, the “Services”).
This Privacy Policy (the “Privacy Policy”) is intended to describe our practices regarding the information we may
collect or to which we may have access, through your use of our Services and the manners in which we may use
such information, and the choices and rights available to you.

Please read carefully this Privacy Policy before accessing and using our Services.
By Accessing or using our service you are accepting the practices described in this Privacy Policy.
If you disagree to any term provided herein, you may not access or use the Services.
Please note: you are not obligated by law to provide us with any Personal Information.

1. WHAT INFORMATION DO WE COLLECT?

a. First – What is personal information?
Personal information is individually identifiable information, namely information that identifies an
individual or may with reasonable efforts or together with additional information we have access to,
enable the identification of an individual, or may be of private or sensitive nature information relating
to an identified or identifiable natural person. Identification of an individual also includes association
of such individual with a persistent identifier such as a name, an identification number, persistent
cookie identifier etc.
Personal information does not include information that has been anonymized or aggregated so that it
can no longer be used to identify a specific natural person.

b. We collect personal information from you when you use or interact with our Services
We collect personal information from you and any devices (including mobile devices) you use when
you: use or access our Services, register for an account with us, provide us information on a web form,
update or add information to your account, or through correspondence you and we conduct with each
other.

More specifically we collect and use the following categories and types of information:

> Personal information you give us when you use our Services

Generally this category refers to any information, data or content you actively and voluntarily create or
provide through our Services.

* Contact information such as your name, email and physical addresses, or telephone number when you
fill our online form or register for an account with us or when you update your accounts details.

* Information you provide during a transaction, or other transaction-based content that you generate or
that is connected to your use of the Service as a result of a transaction you are involved in.

* Information you provide in the course of video/text/audio conversations conducted by you or someone
on your behalf or which you or someone on your behalf participates in via the Services, including
recordings of such video/text/audio conversations.

* Other content that you generate, or your actions in your use of the Services.

* Financial information you provide for the purpose of paying the fees in connection with the services
(such as credit card or bank account numbers).

* Information you voluntarily provide to the Services for the purpose personalization of your interface
with the Services such as age, gender, preferences etc.

* You may also provide us information through your use of certain functionalities we make available to
you through the Services such as chats, support services, or when you otherwise communicate with us
regarding our Services

* Information we are required or authorized by applicable national laws to require you to provide us in
order to authenticate or identify you or to verify the information we have collected.

> Personal information we collect automatically when you use our Services

* We collect information about your interaction with our Services, in certain cases about our
communications with you. This is information we receive from devices (including mobile devices) and
software you use when you access our Services. This information could include the following: Device
ID or unique identifier, device type, ID for advertising, unique device token, operating system,
information regarding your clicks, views and engagement with our advertisements and Services,
information concerning your traffic to and from the Services, your referral URL, ad data, your IP
address, your browsing history, and your web log information.

* Information about your transaction with the Services such as, call duration, number of calls/texts,
phone numbers calls/texts are to and from.

* Location information, including location information from your mobile device or as can be derived
from your IP address.

We perform such automatic collection through use of cookies, web beacons, unique identifiers, and
similar technologies which allow us to collect information about the pages and screens you view, the
links you click, and other actions you take when using our Services, within our advertising or email
content, as further detailed in section ‎7 .

Please take into consideration that certain portions of such abovementioned information may also be
collected from your device or software, when the Services are running in the background, i.e. when
they have been launched but are not used.

Please keep in mind that most mobile devices and auxiliary software, allow you to control or disable
the use of certain collectable information including location services, by any application, in the
device’s settings menu.

> Personal information collected from other sources

* We may also collect personal information concerning you, from third parties who have assured us that
they have obtained your consent for such provision of information or that you have freely and publicly
provided.

* If you give us personal information about someone else, you must do so only with that person’s
express authorization. You should inform them how we collect, use, disclose, and retain their personal
information according to this Privacy Policy.

* TO THE EXTENT THAT YOU PROVIDE TO US ANY PERSONAL INFORMATION
IN CONNECTION WITH ANY THIRD PARTY, INCLUDING ANY OF YOUR
CUSTOMERS OR END-USERS (COLLECTIVELY, THE “END USERS”) AND ANY
PERSON WHOSE INFORMATION IS PROVIDED AS PART OF
VIDEO/TEXT/AUDIO CONVERSATIONS OR OTHERWISE THROUGH YOUR
USE OF THE SERVICES OR YOUR PROVISIONS OF THE SERVICES TO YOUR
END USERS, YOU ARE SOLELY RESPONSIBLE TO RECEIVE AND HEREBY
REPRESENT AND UNDERTAKE TOWARDS OVERTOK THAT YOU HAVE
RECEIVED THE CONSENT, AUTHORITY, PERMISSION AND APPROVAL OF
SUCH PERSON AND PROVIDED THEM WITH SUFFICIENT DISCLOSURES, TO
ALLOW THE USE OF SUCH PERSONAL INFORMATION, AND TO ALLOW

OVERTOK TO ACCESS, STORE, COLLECT, ANALYZE AND PROCESS SUCH
PERSONAL INFORMATION FOR SUCH PURPOSES AS DETAILED HEREIN.
* PLEASE NOTE THAT IN CONNECTION WITH THE RECORDING OF THE
VIDEO/AUDIO CONVERSATIONS YOU CONDUCT OR PARTICIPATE IN
THROUGH YOUR USE OF THE SERVICES, THERE ARE NOTIFICATION AND
CONSENTS REQUIREMENTS, NECESSARY OR ADVISABLE UNDER
APPLICABLE LAW. SUCH REQUIREMENTS MAY VARY FROM STATE TO
STATE, AND COUNTRY TO COUNTRY. YOU ARE SOLELY RESPONSIBLE FOR
COMPLYING WITH ANY AND ALL APPLICABLE LAWS IN CONNECTION
WITH YOUR USE OF THE RECORDING FEATURE.

2. How Do we Use Your Personal Information

Legal basis for use

We collect, process and use your information for the purposes described in this Privacy Policy, based at
least on one of the following legal grounds:

* With your consent: We ask for your agreement to process your information for specific purposes and you
have the right to withdraw your consent at any time. For example, we ask for your consent to provide you
with personalized content and ads through the use of cookies;

* When Performing this Agreement: We collect and process your Personal Information in order to provide
you with the Service, following your acceptance of this Privacy Policy; to maintain and improve our
Services; to develop new services and features for our Users; and to personalize the Services in order for
you to get a better user experience.

* Legitimate interests: We process your information for our legitimate interests while applying appropriate
safeguards that protect your privacy. This means that we process your information for things like detecting,
preventing, or otherwise addressing fraud, abuse, security, usability, functionality or technical issues with
our services, protecting against harm to the rights, property or safety of our properties, or our users, or the
public as required or permitted by law; Enforcing legal claims, including investigation of potential
violations of this Privacy Policy; in order to comply and/or fulfil our obligation under applicable laws,
regulation, guidelines, industry standards and contractual requirements, legal process, subpoena or
governmental request, as well as our Terms of Service.

Purpose of Use
We may use information that we collect about you for the following purposes:

* To provide and improve our Services and manage our business;

* To send you updates, notices, notifications, announcements, and additional information related to the Services;

* To be able to manage your account and provide you with customer support;

* To display or send to you marketing and advertising material and general and personalized content and
advertisement via the Services, email, postal mail, telephone and/or mobile devices;

* To develop, display, and track content and advertising tailored to your interests on our Service and other
sites, including providing our advertisements to you when you visit other sites;

* To create cumulative statistical data and other cumulative information and/or other conclusive information
that is non-personal, in which we and/or our business partners might make use of in order to operate and
improve our Website and provide related services;

* To perform functions or services as otherwise described to you at the time of collection;

* To prevent, detect, mitigate, and investigate fraud, security breaches or other potentially prohibited or
illegal activities;

* To comply with any applicable rule or regulation and/or response or defend against legal proceedings
versus us or our affiliates.

To whom we share personal information

We may share your Personal Information with third parties (or otherwise allow them access to it) only in the
following manners and instances:
Third Party Services: We are partnering with a number of selected service providers, whose services and solutions
complement, facilitate and enhance our own. These include hosting, database and server co-location services (e.g.,AWS),
data analytics services (e.g. Google Analytics), payment processors (e.g. Bluesnap) call routing services (e.g. Voximplant)
Communications operator (e.g. Bandwidth), and our business, legal and financial advisors (collectively, “Third Party Service
 Providers”
).

Such Third Party Service Providers may receive or otherwise have access to your Personal Information,
depending on each of their particular roles and purposes in facilitating and enhancing the Services, and may only use your
 Personal Information for such purposes. Such disclosure or access is strictly subject to the recipient’s or use0r’s
undertaking of confidentiality obligations, and the prevention of any independent right to use this data except as
required to help us provide the Services. We are remained responsible and liable for any Personal Information
processing done by Third Party Service Provider on its behalf, except for events outside of its reasonable control.

Third Party’s offering our Services: We may share your personal information with our business partners or
Customers who offer a service to you jointly with us or offer our Services to you as integrated into their website or
mobile application.

Law enforcement, legal proceedings, and as authorized by law: We may disclose or otherwise allow access to
Personal Information pursuant to a legal requirement or request, such as a subpoena, search warrant or court order,
 or in compliance with applicable laws and regulations. Such disclosure or access may occur with or without notice to you,
if we have a good faith belief that we are legally required to do so, or that disclosure is appropriate in connection with efforts
 to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing.

Protecting Rights and Safety: We may share your Personal Information with others, with or without notice to you,
if we believe in good faith that this will help protect the rights, property or personal safety of our Company, any of
our Users, or any members of the general public.

Our Affiliated Companies: We may share Personal Information internally within our family of companies, for the
purposes described in this Privacy Policy. In addition, should we or any of our affiliates undergo any change in
control, including by means of merger, acquisition or purchase of substantially all of its assets, your Personal
Information may be shared with the parties involved in such event. If we believe that such change in control
might materially affect  your Personal Information then stored with us, we will notify you of this event and the choices
you may have via e-mail and/or prominent notice on our website or Services.

For the removal of doubt, we may share your Personal Information in additional manners, pursuant to your
explicit approval, or if we are legally obligated to do so. Additionally, we may transfer, share or otherwise use
non-personal information in our sole discretion and without the need for further approval.

3. WHERE DO WE STORE USER’S PERSONAL INFORMATION?

Information regarding the Users will be maintained, processed and stored by us and our authorized affiliates and
service providers in the United States, Ireland and in Israel, and as necessary, in secured cloud storage, provided
by our third party service provider.
While the data protection laws in the above jurisdictions may be different than the laws of your residence or
location, please know that we, our affiliates and our service providers that store or process your Personal
Information on the our behalf are each committed to keep it protected and secured, pursuant to this Privacy Policy
and industry standards, regardless of any lesser legal requirements that may apply in their jurisdiction.
You hereby accept the place of storage and the transfer of information as described above.

4. USING COOKIES AND OTHER TRACKING TECHNOLOGIES
We use certain monitoring and tracking technologies, including ones offered by third party service providers.
These technologies are used in order to maintain, provide and improve our website on an ongoing basis,
 and in order to provide a better experience to our Users. For example, these technologies enable
 us to: (i) keep track of our Users’ preferences and authenticated sessions, (ii) secure our website by detecting
abnormal behaviors, (iii) identify technical issues and improve the overall performance of our website, (iv) create and
monitor analytics, and (v) deliver you targeted advertisements that are more tailored to you based on your browsing
activities and inferred interests and track ad performance (For more information about this practice, click here:
http://www.aboutads.info/choices/).

* Cookies: A cookie is a small data file that is downloaded and stored on your computer or mobile device
when you visit our Website. Learn more about cookies here: www.allaboutcookies.org

* Pixel Tags: Pixel tags (also commonly known as web beacons) are transparent images, iFrames, or
JavaScript placed on a website that our third party service providers use to understand how our Users
interact with them online.

We use the following third party service providers, which may use one or more of the above tracking technologies:
* Google: We use Google analytics, a web analytics service provided by Google, Inc. Non-personal
Information is transmitted to and stored by Google on their servers. Please visit Google Analytics find out
how Google uses such information or how you can opt out of being tracked.

Learn more about your choices and how to opt-out of tracking technologies:
In order to delete or block any tracking technologies, please refer to the “Help” area on your internet browser for
further instructions, or You may also opt out of third party tracking technologies by following the instructions
provided by each third party service provider in its privacy policy listed above or visiting
www.youronlinechoices.eu. Please note however that deleting any of our tracking technologies or disabling
future tracking technologies may prevent you from accessing certain areas or features of our Website, or may
otherwise adversely affect your user experience. Please note however that we do not respond to
the ‘Do Not Track’ setting on your browser.

TO THE EXTENT YOU USE ANY COOKIES, TRACKING TECHNOLOGIES, OR OTHERWISE
DELIVER ADVERTISEMENTS TO END USERS IN CONNECTION WITH THE SERVICES
INCLUDING THE TOOL, YOU ARE SOLELY RESPONSIBLE TO RECEIVE AND HEREBY
REPRESENT AND UNDERTAKE TOWARDS OVERTOK THAT YOU HAVE RECEIVED THE
CONSENT, AUTHORITY, PERMISSION AND APPROVAL OF SUCH PERSON, PROVIDED THEM
WITH SUFFICIENT DISCLOSURES, AND PROPER OPT-OUT PROVISIONS, TO ALLOW THE USE
OF SUCH TRACKING TECHNOLOGY AND TO ALLOW OVERTOK TO PROVIDE THE SERVICES IN
ACCORDANCE WITH THE TERMS. ADDITIONALLY YOU SHALL NOTIFY OVERTOK IN WRITING
OF ALL TRACKING TECHNOLOGIES USED BY YOU IN CONNECTION WITH THE SERVICES
INCLUDING THE TOOL.

5. DIRECT MARKETING
You hereby agree that we may use your contact details provided during the filling of a contact form,
for the purpose of informing you regarding our products and services which may interest you, and to
send to you other marketing material. You may withdraw your consent via sending us written notice
 by email to the following address:
info@overtok.com or by pressing the “Unsubscribe” button in the mail.
Please note that the Company may also contact you with important information regarding our Website.
For example, we may notify you (through any of the means available to us) of changes or updates to our
Website, payment issues, service maintenance, etc. You will not be able to opt-out of receive such service messages.

6. MINORS
To use our Services, you must be over the age of sixteen (16). Therefore, we do not knowingly collect Personal
Information from minors under the age of sixteen (16) and do not wish to do so. We reserve the right to request
proof of age at any stage so that we can verify that minors under the age of sixteen (16) are not using the Website.

7. INFORMATION SECURITY
We employ industry standard procedures and policies to ensure the safety of Users’ Personal Information,
reduce the risks stemming from loss of information and prevent unauthorized use of any such information.
However, no measure can provide absolute information security.

8. DATA RETENTION
We retain the Personal Information we collect only for as long as needed in order to provide you with our
services and to comply with applicable laws and regulations. We then either delete from our systems or
anonymize it without further notice to you.
If you withdraw your consent to us processing your Personal Information, we will delete your Personal Information
from our systems (except to the extent such data in whole or in part to comply with any applicable rule or regulation
and/or response or defend against legal proceedings versus us or our affiliates).

9. UPDATING, OBTAINING A COPY OF, OR DELETING YOUR PERSONAL INFORMATION
If the law applicable to you grants you such rights, you may ask to access, correct, or delete your Personal
Information that is stored in our systems. You may also ask for our confirmation as to whether or not we process
your Personal Information.
Subject to the limitations in law, you may request that we update, correct, or delete inaccurate or outdated
information. You may also request that we suspend the use of any Personal Information whose accuracy you contest
while we verify the status of that data.
Subject the limitations in law, you may also be entitled to obtain the Personal Information you directly provided us
(excluding data we obtained from other sources) in a structured, commonly used, and machine-readable format and
may have the right to transmit such data to another party.
If you wish to exercise any of these rights, contact us at: info@overtok.com. When handling these requests, we may
ask for additional information to confirm your identity and your request. Please note, upon request to delete your
personal Information, we may retain such data in whole or in part to comply with any applicable rule or regulation
and/or response or defend against legal proceedings versus us or our affiliates
To find out whether these rights apply to you and on any other privacy related matter, you can contact your local
data protection authority if you have concerns regarding your rights under local law.

10. UPDATES TO THIS PRIVACY POLICY
We reserve the right to change this policy at any time, so please re-visit this page frequently. We will notify you
regarding substantial changes of this Privacy Policy by changing the link to the Privacy Policy in the Service and/or
by sending you an e-mail regarding such changes to the e-mail address that you provided during registration.
Such substantial changes will take effect seven (7) days after such notice was provided on our Website or sent by email.
Otherwise, all other changes to this Privacy Policy are effective as of the stated “Last Revised” date and your
continued use of the Website after the Last Revised date will constitute acceptance of,
and agreement to be bound by,  those changes.

11. GENERAL INFORMATION
This Privacy Policy, its interpretation, and any claims and disputes related hereto, shall be governed by the laws
 of the State of Israel, without respect to its criminal law principles. Any and all such claims and disputes shall be
brought in, and you hereby consent to them being litigated in and decided exclusively by a court of competent
jurisdiction located in Tel Aviv, Israel.

This Privacy Policy was written in English, and may be translated into other languages for your convenience. If a
translated (non-English) version of this Privacy Policy conflicts in any way with the English version, the provisions
of the English version shall prevail.

12. HAVE ANY QUESTIONS?
If you have any questions (or comments) concerning this Privacy Policy, you are welcome to send us an email at:
info@overtok.com and we will make an effort to reply within a reasonable timeframe.