Privacy policy

This privacy policy (the “Policy”) explains how LIGHTNEUP AI SERVICES LTD (the “Company”), collects, uses, shares, and protects the personal data of the customers (the “Customers”) who access and use the Company’s software-as-a-service (SaaS) application programming interface (API) offering (the “Service”). The Service leverages various cloud services provided by third party Cloud providers, such as , Azure, and Amazon AWS, Google GCP and Nebius (the “Cloud Providers”).

1. WHAT PERSONAL DATA DO WE COLLECT AND WHY?

We collect the following types of personal data from the Customers or through the Service:

● Account data: We collect the Customers’ name, email address, password, and other information that the Customers provide when they create an account or log in to the Service. We use this data to identify, authenticate, and communicate with the Customers, and to provide and manage the Service.

● Service data: We collect the data, content, and information that the Customers submit, upload, or transmit to the Service or the AI Providers, or that the Service or the AI Providers collect, process, or store on behalf of the Customers (the “Service Data”). The Service Data may include text, images, audio, video, or other types of data that the Customers use or generate through the Service or the AI services. We use this data to provide and improve the Service and the AI services, and to comply with the Customers’ instructions and requests. The Customers are solely responsible for the Service Data, and they should ensure that they have the necessary rights and permissions to use and share the Service Data, and that the Service Data does not infringe or violate the rights or interests of the Company, the AI Providers, or any third parties, or any applicable laws or regulations.

● Usage data: We collect the data about how the Customers access and use the Service or the AI services, such as the IP address, device type, browser type, operating system, language preference, time zone, location, referral source, pages visited, actions taken, errors encountered, and other technical and behavioral data. We use this data to monitor and analyze the performance, functionality, and usage of the Service and the AI services, and to improve and personalize the Customer experience.

2. HOW DO WE SHARE THE PERSONAL DATA?

We may share the personal data with the following parties and for the following purposes:

● Cloud Providers: We share the Service Data with the Cloud Providers, as necessary to provide the Service and the AI services to the Customers, and in accordance with the Customers’ instructions and requests. The AI Providers may use the Service Data to improve, enhance, or modify the AI services, or to develop new products or services, and they may retain, aggregate, or anonymize the Service Data for these purposes. The AI Providers may also disclose the Service Data to comply with any legal obligations, requests, or orders, or to protect the rights or interests of the AI Providers or any third parties. The Customers should review the privacy policies of the AI Providers before accessing or using the AI services. Our AI providers privacy policies are attached for reference below. o AWS Bedrock o Azure o OpenAI o Google gemini

● Service Providers: We share the personal data with our service providers, such as hosting providers, payment processors, analytics providers, marketing providers, or other third parties that help us to provide and improve the Service. We only share the personal data that is necessary for the service providers to perform their services, and we require them to protect the personal data and use it only for the purposes that we authorize.

● Affiliates: We share the personal data with our affiliates, such as our parent company, subsidiaries, or other related entities, for the purposes of providing and improving the Service, and for marketing and advertising purposes, subject to the Customers’ consent and preferences.

● Business Partners: We share the personal data with our business partners, such as our resellers, distributors, or other third parties that offer or promote the Service, subject to the Customers’ consent and preferences. The Customers should review the privacy policies of these business partners before accessing or using their products or services. ● Business Transfers: We may share the personal data with a successor entity in the event of a merger, acquisition, reorganization, sale of assets, or bankruptcy, or with a potential buyer or investor in the course of a due diligence process. We will notify the Customers of any change of ownership or control of the personal data, and we will ensure that the personal data is transferred and used in accordance with this Policy and the applicable laws and regulations.

● Legal and Regulatory Compliance: We may share the personal data with the competent authorities, such as courts, regulators, or law enforcement agencies, if we are required or permitted to do so by law, regulation, court order, or governmental request, or if we believe that such disclosure is necessary or appropriate to protect the rights or interests of the Company, the AI Providers, or any third parties, or to prevent or investigate any illegal, fraudulent, or harmful activities. 3. HOW DO WE PROTECT THE PERSONAL DATA? We take reasonable and appropriate measures to protect the personal data from unauthorized access, use, or disclosure, such as encryption, firewalls, access controls, and security audits. However, we cannot guarantee that the personal data is completely secure or immune from any cyberattacks, breaches, or errors, and we disclaim any liability for any loss, damage, or corruption of the personal data, unless caused by our gross negligence or willful misconduct. The Customers are responsible for maintaining the security and confidentiality of their account credentials, manage access to these accounts and devices, and for notifying us promptly of any unauthorized or suspicious activities on their account or the Service.

4. HOW LONG DO WE KEEP THE PERSONAL DATA?

We retain the personal data for as long as necessary to provide and improve the Service and the AI services, and to comply with our legal obligations, contractual agreements, and business policies. We may delete or anonymize the personal data when it is no longer needed for these purposes, or when the Customers request us to do so, subject to our retention rights and obligations uner the applicable laws and regulations.

5. WHAT RIGHTS DO THE CUSTOMERS HAVE?

The Customers have the following rights with respect to their personal data, subject to the applicable laws and regulations, and our legitimate interests and obligations: ● Access: The Customers have the right to access and obtain a copy of their personal data that we hold and process, and to verify the accuracy and completeness of their personal data.

● Correction: The Customers have the right to correct or update their personal data that is inaccurate, incomplete, or outdated, or to request us to do so.

● Deletion: The Customers have the right to delete or request us to delete their personal data that is no longer necessary for the purposes that we collected or processed it, or that we processed unlawfully or without their consent, or that they withdraw their consent to.

● Restriction: The Customers have the right to restrict or request us to restrict the processing of their personal data, if they contest the accuracy or lawfulness of their personal data, or if they object to the processing of their personal data for our legitimate interests or direct marketing purposes.

● Objection: The Customers have the right to object or request us to stop the processing of their personal data for our legitimate interests or direct marketing purposes, unless we demonstrate compelling and overriding grounds for the processing, or for the establishment, exercise, or defense of legal claims.

● Portability: The Customers have the right to receive or request us to transmit their personal data that they provided to us, in a structured, commonly used, and machine-readable format, and to transfer their personal data to another data controller, without hindrance from us, where technically feasible, and where the processing is based on their consent or a contract, and is carried out by automated means.

● Withdrawal of consent: The Customers have the right to withdraw their consent to the processing of their personal data at any time, without affecting the lawfulness of the processing based on their consent before the withdrawal, and without prejudice to the processing based on other lawful grounds.

● Complaint: The Customers have the right to lodge a complaint with the relevant data protection authority, if they believe that we have violated their rights or interests, or any applicable laws or regulations.

6. CHANGES TO THIS PRIVACY POLICY

We retain the right to modify this policy to align with new regulations, legal precedents, and evolving industrial or commercial practices. If any changes are made to our Privacy Policy, they will be published on this page. The last modification to this Privacy Policy occurred on 02/04/2024. 2 7. CONTACT US If you have any questions about this Privacy Policy, please contact us at legal@lightenup.ai.