DRUPE PRIVACY NOTICE
Last Revised: June 30, 2022


Sync.Me Ltd. ("Drupe", "Company", "we", "our" or "us") respects the privacy of the users of our mobile application ("App") and of our website available at: https://www.getdrupe.com/ (the "Site" and collectively with the App, the "Services"), and we are committed to protect the Personal Information that our users share in connection with the use of our Services.

This Privacy Notice (the "Privacy Notice") is intended to describe our privacy practices regarding the Personal Information we collect, use and store from you (the "User" or "you") when you use our Services and the options and rights available to you.

Capitalized terms which are not defined herein, shall have the meaning ascribed to them in our Terms of Use (the "Terms of Use"), available at https://www.getdrupe.com/terms-of-use to which this Privacy Notice is incorporated by reference.

We greatly respect your privacy, which is why we make every effort to provide a platform that upholds 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 mentioned below are only relevant for GDPR-protected individuals. Our CCPA policy is available here: https://www.getdrupe.com/privacy-ccpa .

Please note: you are not obligated by law to provide us with any Personal Information and nothing in this Privacy Notice is intended to limit in any way your statutory rights, including your rights to a remedy or means of enforcement.



TABLE OF CONTENTS

1. WHAT INFORMATION DO WE COLLECT ABOUT YOU?

2. WITH WHOM DO WE SHARE PERSONAL INFORMATION?

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

4. COMMUNICATIONS FROM DRUPE

5. TARGETED ADS, COOKIES AND OTHER TRACKING TECHNOLOGIES

6. SECURITY

7. YOUR RIGHTS REGARDING YOUR PERSONAL INFORMATION

8. MINORS

9. THIRD PARTY SERVICES

10. CHANGES TO THE PRIVACY NOTICE

11. DO YOU HAVE ANY QUESTIONS?



1. WHAT INFORMATION DO WE COLLECT ABOUT YOU?

We collect Personal Information from you when you use or interact with our Services. We collect Personal Information from you and from any of the devices (including, mobile devices) you use when you install or have the App installed on your device, browse our Site, use or access our Services, provide us with information on a web form, or through any correspondence we conduct with each other.

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

a. Personal information that we collect when you download the App, create an account, log in and make use of the App

In order to use certain features of the App, you will be able to register and log-in with your Google account. In addition, you may also choose to use certain features that may be offered to you via the App and allow the collection and use of Personal Information, as detailed below:

i. When you make use of the App

Data collected and for which purposes: We collect your full name, phone number and email address, payment information, log-in details (e.g primary account, internal account), information stored on your device phonebook directory, call logs, and SMS messages (e.g. phone number, email address and name of your contacts), your approximate geolocation (via Wi-Fi or cellular technology in your device, including, country), internet protocol (IP) address and other unique device identifiers and descriptions, and any other information that you will decide to provide/supply us with, to be able to: (i) provide you with the Services, (ii) contact the Users of the App for the purpose of providing them with technical assistance, support, handle requests and complaints and collect feedback in connection with performance of the Services, (iii) provide you with and to operate the Service, including for statistical and research purposes and creation of aggregated anonymous data, (iv) personalize the Service and content provided to you, (v) customize your experience with the Services, to suggest recommendations based on your preferences and to enable you to retrieve your Personal Information, (vi) develop, improve and customize the Service, the experience of other Users and the offering available through the Service, and (vii) customize and improve our Service's accuracy and interface.

Legal basis (GDPR only, if applicable): Depending on the context, 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, consent and/or legitimate interest (e.g. to allow you to create an account).

Retention period: Your Personal Information 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, as necessary to comply with our legal obligations, to resolve disputes, to prevent fraud and abuse, and/or to enforce our agreements. Where we no longer need to process your Personal Information for the purposes set out in this Privacy Notice, or following your request to delete your Personal Information, we will delete your Personal Information from our systems.

ii. The Caller Identification Functionality

Data collected and for which purposes: If made available by Drupe in your territory and by your operating system, you can choose to share with us the names, numbers and e-mail addresses contained in your device's address book, call logs, and SMS messages ("Contact Information"), for the purpose of providing the Caller Identification Functionality. Please note that we do not collect, save, nor display any information about the identity of the sources or network connection relating to your contacts (i.e., this means that once you provided your Contact Information to Drupe, we will not save the fact that any of these contacts have been originally provided by you). The Caller Identification Functionality, which includes, associating a name with a phone number through the name tagging functionality, allows a User who receives a call from a phone number, which is not associated with a name in the App database, to indicate a name to be associated with that number. Drupe uses algorithmic methodologies to improve the reliability of the Caller ID feature, taking into account the number of sources, to support caller identification

Please note that at any time during your use of the App you may change your mind and decide whether or not you want to share the Contact Information. As part of this feature, Users can also help us improve our Caller Identification Functionality by suggesting more accurate names for a given number, or mark it as spam, and by doing so helping other Users. If you would like to remove your Personal Information from the App, you may do so by visiting this link: https://getdrupe.com/unsubscribe

Legal basis (GDPR only, if applicable): To the maximum extent permitted by law, if as part of your Contact Information (or otherwise) you provide us with Personal Information about someone else, you confirm that they are aware that you have provided their Personal Information and that they consent (and continue to consent as long as you share with us the Contact Information and use the Caller Identification Functionality) to our collection, processing and use of their data for the purpose of providing the Caller Identification Functionality and according to this Privacy Notice. Depending on the context, 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, consent and/or legitimate interest (e.g. to allow you to use the caller identification functionality).

Retention period: Your Personal Information 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, as necessary to comply with our legal obligations, to resolve disputes, to prevent fraud and abuse, and/or to enforce our agreements. Where we no longer need to process your Personal Information for the purposes set out in this Privacy Notice, or following your request to delete your Personal Information, we will delete your Personal Information from our systems.


iii. The Images Feature

Data collected and for which purposes: If made available by Drupe in your territory and by your operating system, you can choose to send images to your contacts while conducting audio communication. In the event that a contact is not a Drupe User, he/she will receive an SMS message with a link allowing them to access the media files sent to them. In order to respond to such media files, such contact will need to download the Drupe App. When using this image sharing feature, Drupe servers collect and store the image media files which may contain Personal Information of You or of third parties you mention in your communication, in order to send to the recipient.

Legal basis (GDPR only, if applicable): Depending on the context, 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, consent and/or legitimate interest (e.g. to allow the User to make use of the Image Feature).

Retention period: Please note we will retain such media files, which may contain Personal Information of you or of third parties you mention in your communication, for the minimal period of time required in order to provide you with this feature, or if 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, as necessary to comply with our legal obligations, to resolve disputes, to prevent fraud and abuse, to enforce our agreements. Where we no longer need to process your Personal Information for the purposes set out in this Privacy Notice, or following your request to delete your Personal Information, we will delete your Personal Information from our systems.

iv. The Recording Feature

Data collected and for which purposes: If made available by Drupe in your territory and by your operating system, you can choose to use the Recording Feature, as such feature is defined and detailed in the Terms of Use [please add hyperlink to the TOU]. When using this feature, you will cause certain recordings of calls and other telephone communications that you participate in with specific contacts, for which you choose to use the Recording Feature, to be saved on your device (or any third party backup Service which you choose to use).

Legal basis (GDPR only, if applicable): Depending on the context, 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, consent and/or legitimate interest (e.g. to allow the User to make use of the Recording Feature).

You warrant and represent that prior to the use of the Recording Feature all disclosures necessary or advisable under applicable law have been made to all participants of such recorded calls or other telephone communications participants with respect to the use of the Recording Feature, and all consents and approvals for the recording as necessary or advisable under applicable law, have been obtained. You agree to inform all specific contacts participating in your use of the Recording Feature that they are obligated to comply with all applicable laws relating to their use of the recording feature.

PLEASE NOTE THAT THE AFOREMENTIONED NOTIFICATION AND CONSENT REQUIREMENTS MAY VARY FROM STATE TO STATE, AND COUNTRY TO COUNTRY. TO THE MAXIMUM EXTENT PERMITTED BY LAW, YOU REPRESENT, COVENANT, AND WARRANT THAT (I) YOU WILL REVIEW ALL APPLICABLE LAWS, AND TO THE EXTENT REQUIRED, OBTAIN SUCH NEEDED LEGAL COUNSEL BEFORE YOU USE OR ALLOW OTHERS TO USE THE RECORDING FEATURE; AND (II) YOUR USE OF THE RECORDING FEATURE DOES NOT BREACH OR INFRINGE ON THE RIGHTS OF ANY THIRD PARTY, INCLUDING THE RIGHT FOR PRIVACY. YOU ARE SOLELY RESPONSIBLE FOR COMPLYING WITH ANY AND ALL APPLICABLE LAWS IN CONNECTION WITH YOUR USE OF THE RECORDING FEATURE.

Retention period: Your Personal Information 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, as necessary to comply with our legal obligations, to resolve disputes, to prevent fraud and abuse, and/or to enforce our agreements. Where we no longer need to process your Personal Information for the purposes set out in this Privacy Notice, or following your request to delete your Personal Information, we will delete your Personal Information from our systems.

b. Personal information you give us when you contact us through the Site

Data collected and for which purposes: When voluntarily filling out the 'contact us' form in our Site, you may be asked to provide your name and email address, and you may voluntarily provide any other information you deem relevant.

Legal basis (GDPR only, if applicable): 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 and/or legitimate interest (e.g. to answer your queries).

Retention period: Your Personal Information 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, as necessary to comply with our legal obligations, to resolve disputes, to prevent fraud and abuse, and/or to enforce our agreements. Where we no longer need to process your Personal Information for the purposes set out in this Privacy Notice, or following your request to delete your Personal Information, we will delete your Personal Information from our systems.

c. Personal Information we collect automatically when you use our Services

i. Device Information

Data collected and for which purposes: After installation of the App, we will collect and use certain information about your device, such as: device ID or other unique identifier, advertising ID, unique device token, device type, operating system (including version and settings), as well as your device screen resolution and keyboard language.

Legal basis (GDPR only, if applicable): Depending on the context, 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, and/or legitimate interest (e.g. to collect certain information necessary to customize the Services to you).

Retention period: Your Personal Information 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. Where we no longer need to process your Personal Information for the purposes set out in this Privacy Notice, or following your request to delete your Personal Information, we will delete your Personal Information from our systems.

ii. Usage Information

Data collected and for which purposes: We collect information about your interaction with our Services, in certain cases about your impressions of and reactions to our advertisements, and 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: information regarding your clicks, views and engagement with our advertisement and Services, information concerning your traffic to and from the Services, and your referral URL. Please note that this information does not contain any Personal Data, nor is related to a specific data subject. We will process only aggregated information under this use case.

iii. When you make use of the Third Party Platforms offered in the App: When you make use of the App and the offered integrations with third parties applications and platforms that integrate with our Services and that you have authorized to connect with Drupe ("Third Party Platforms"). This may include email, calendar, messaging, file storage, phone services, note taking, reminders, social networking, and other cloud services and other similar platforms from which you authorize us to import, search, and access content to be displayed to you and also to make the connection between your requested action and the Third Party Platforms. Please note that we do not have access to any information (including, without limitation, Personal Information) from the Third Party Platforms. We only generate a short-cut between Drupe, the Contract Information and the Integration Platforms to facilitate your use of the App as part of our Services.

d. Finally, please note that some of the above mentioned Personal Information will be used for detecting, taking steps to prevent, and the prosecution of fraud or other illegal activity, to identify and repair errors, to conduct audits, and for security purposes. Personal Information 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 Information and further use it for internal and external purposes, including, without limitation, to improve the Services and for research purposes. We may share your Personal Information with third parties (including ad networks, advertising companies and service providers) in any of the above circumstances, as well as for the purpose of developing or delivering tailored or targeted advertising (whether via our App or Site), for the purpose of improving our Service, conducting business analysis or other business purposes. This information may be combined with information we collect from other sources, to the extent that the information remains anonymous. "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. WITH WHOM DO WE SHARE PERSONAL INFORMATION?

We will not share any Personal Information we collect with any third party, except in the following cases:

i. Third Party Services

Drupe has partnered 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 (such as AWS), data analytics services (such as Google Analytics and Facebook Analytics), and our business, legal and financial advisors (collectively, "Third Party Services"). Such Third Party Services receive or otherwise have access to our Users' Personal Information, depending on each of their particular roles and purposes in facilitating and enhancing our Services and business, and will only use it for such purposes.

ii. Governmental/Law Enforcement Agencies and Legal Requests or Duties

We disclose or otherwise allow access to your Personal Information pursuant to a legal request, such as a subpoena, search warrant or court order, or in compliance with applicable laws, 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, counter terrorist financing verification requirements, fraud, or other wrongdoing.

iii. Protecting Rights and Safety

We 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 Drupe, any of our Users, or any member of the general public.

iv. Drupe Subsidiaries and Affiliated Companies

We share Personal Information internally within our family of companies, for the purposes described in this Privacy Notice. In addition, should Drupe or any of its 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.

v. Other parties with whom we may share your Personal Information

We may also disclose (or permit their access to) your Personal Information to third party partners via API, mobile carrier, for the purpose of ensuring that the partners' current data is up to date, enriching it and allowing our partners to obtain relevant information for commercial and business opportunities, including, without limitation, to detect spam calls. If you prefer that we do not share your Personal Data publicly on our App, with vendors or business partners, you may opt-out by filling in your relevant details [*].

For the avoidance of doubt, Drupe may share your Personal Information in additional manners, pursuant to your explicit approval. Additionally, we may transfer, share or otherwise use anonymized, aggregated and/or non-personal information in our sole discretion and without the need for further approval.

3. WHERE DO WE STORE PERSONAL INFORMATION?

The Personal Information of Drupe's Users will be maintained, processed and stored by Drupe and our authorized affiliates and service providers in Israel, and as necessary, in secured cloud storage provided by our Third Party Services.

While the data protection laws in the above jurisdictions may be different than the laws of your residence or location, please know that Drupe, its affiliates and service providers that store or process your Personal Information on Drupe's behalf are each committed to keep it protected and secured, in accordance with this Privacy Notice and industry standards, regardless of any lesser legal requirements that may apply in their jurisdiction.

4. COMMUNICATIONS FROM DRUPE

i. Service Messages

Drupe will contact you with information regarding our Services, or your use thereof. For example, we may notify you (through any of the means available to us) of changes or updates to our Services, transactions performed, payment issues, service maintenance, or other Service related communications.

ii. Promotional Messages:

In addition to communications that are an inherently part of our Services, occasionally we will use your contact information to contact and notify you about new services and special opportunities or promotions we think you will find valuable. We will contact you through the Services, or any other contact methods available to us, including with the help of our Third Party Services.

In accordance with your consent, we may be entitled to send you promotional emails and similar forms of communication.

If you do wish not to receive such promotional messages or calls, you may notify Drupe at any time by e-mailing us at privacy@getdrupe.com, or by following the "unsubscribe" or "stop" instructions contained in the promotional communications you receive.

5. SECURITY

We take a great care in implementing and maintaining the security of the Services, and our Users' Personal Information. Drupe employs industry standard procedures and policies to ensure the safety of its Users' Personal Information, and prevent unauthorized use of any such information. However, we do not and cannot guarantee that unauthorized access will never occur. As the security of information depends in part 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.

6. YOUR RIGHTS REGARDING YOUR PERSONAL INFORMATION

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 the right to change or update any Personal Information relating to you (for example, if you believe that your Personal Information is incorrect, you may ask to have it corrected;

o You have the right to remove your name and/or phone number, you must deactivate your account by your User settings. To remove or change your profile information you must change them by your User settings. For the deletion of your Personal Information, you may do so in an easy manner through our opt-out page, available here: [*]. Please note that there may be circumstances in which we are required to retain your Personal Information, for example for the establishment, exercise or defense of legal claims;

o You have the right to access your Personal Information held about you and receive supplementary information regarding your Personal Information. 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 that we will restrict, object or cease any further use of your Personal Information;

o You have the right to data portability. This means that we will provide the Personal Information you volunteered us 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 Information 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; and

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.

You can exercise your rights by contacting us at privacy@getdrupe.com. You may use an authorized agent to submit a request on your behalf if you provide the authorized agent written permission signed by you. To protect your privacy, we may take steps to verify your identity before fulfilling your request. 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.


Notwithstanding anything to the contrary, you acknowledge that the same information, including without limitation, the Personal Data provided to Drupe by you may have already been provided, or will be provided, by other users, or may have already been collected, or will be collected by Drupe independently, or from other sources, or may be available on public sources or publicly available data sources. For the avoidance of doubt, processing of information in such cases (e.g., when it was provided the same Personal Data also by other sources,), including without limitation, the Personal Data shall not be considered a breach of our Terms of Use and/or your rights (even when you request to delete the contact details that you had uploaded to the App). You can opt-out so in an easy manner through our opt-out page, available here: [*].



Deleting your account: Should you ever decide to delete your account, you may do so by emailing privacy@getdrupe.com. If you terminate your account, any association between your account and Personal Information we store will no longer be accessible through your account. However, given the nature of sharing on certain services, any public activity on your account prior to deletion will remain stored on our servers and will remain accessible to the public.

7. MINORS

Our Service is not intended for minors below the age of sixteen (16). Drupe does not knowingly collect Personal Information from children under the age of sixteen (16) and does 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 Services . In the event that it comes to our knowledge that a person under the age of sixteen (16) is using the App, we may prohibit and block such User from using the Services and will make all efforts to promptly delete any Personal Information with respect to such User. If you believe that we might have any such information, please contact us at privacy@getdrupe.com.

8. THIRD PARTY SERVICES

The Services may offer you links to certain Third Party Services' applications installed on your device, through which you may further interact with your mobile contacts. Please be advised that such Third Party Services are independent from Drupe, and may collect non-personal and/or Personal Information about you. We assume no responsibility or liability whatsoever with regard to privacy matters or any other legal matter with respect to such Third Party Services. We encourage you to carefully read the privacy policies and the terms of use of such Third Party Services, as their terms, not ours, will apply to any of your interactions with or through such Third Party Services. Accordingly, we encourage you to read the terms and conditions and privacy policies of each Third Party Services.

9. ADVERTISING PARTNERS.

Through our services, we allow third party advertising partners to set technologies and other tracking tools to collect information regarding your activities and your device (e.g., your IP address, mobile identifiers). We also combine and share such information and other information (such as demographic information and past purchase history) with third party advertising partners. These advertising partners will use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit third party websites within their networks. This practice is commonly referred to as "interest-based advertising" or "online behavioral advertising. We allow access to other data collected by the services to share information that may be useful, relevant, valuable or otherwise of interest to you. If you prefer not to share your Personal Information with third party advertising partners, you may let us know.

We reserve the right to remove or add new analytic tools.

10. CHANGES TO THE PRIVACY NOTICE

Drupe reserves the right to change this Privacy Notice at any time, so please re-visit this page frequently. If we implement significant changes to the use of your Personal Information in a manner different from that stated at the time of collection, we will provide notice of such changes of this Privacy Notice on the Services and/or we will send you an e-mail regarding such changes to the e-mail address that you volunteered, or by other means. To the maximum extent permitted by law, such substantial changes will take effect seven (7) days after such notice was provided on any of the above mentioned methods. Otherwise, all other changes to this Privacy Notice are effective as of the stated "Last Revised" date, and your continued use of the Services after the Last Revised date will constitute acceptance of, and agreement to be bound by, those changes.

11. DO YOU HAVE ANY QUESTIONS?

If you have any questions (or comments) concerning this Privacy Notice, you are welcome to send us an e-mail at privacy@getdrupe.com.