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Privacy Policy

Last Updated: 22/2/2026

We care about your privacy and want you to clearly understand how we handle personal data. We have the utmost respect for your privacy and understand that your personal information is important to you.

Tupaia Ltd. and its subsidiaries and affiliates ("Tupaia", "Company", "we", "us", or "our") are committed to protecting and respecting your rights to privacy. This Privacy Policy explains what personal data we collect, why we collect it, how we use it, who we share it with, and the choices available to you. It applies to our website(s) (the "Sites"), our products and technology (the "Products"), and our support, portal, and cloud-based services (the "Services").

This Privacy Policy is an integral part of our Terms of Use and should be read together with them. If you do not agree to the terms of this Privacy Policy, we ask that you do not provide personal information or discontinue use of the Sites; however, in such case you may not be able to enjoy all the features and services offered on the Sites.

IMPORTANT: BY USING OUR SITES, PRODUCTS, OR SERVICES, YOU ACKNOWLEDGE THAT ANY PERSONAL DATA YOU SUBMIT OR THAT IS COLLECTED MAY BE PROCESSED BY US IN THE MANNER AND FOR THE PURPOSES DESCRIBED IN THIS PRIVACY POLICY. YOU ARE NOT LEGALLY REQUIRED TO PROVIDE US WITH PERSONAL DATA; HOWEVER, SOME OF OUR SERVICES REQUIRE IT. IF YOU CHOOSE TO WITHHOLD REQUIRED PERSONAL DATA, IT MAY NOT BE POSSIBLE FOR YOU TO USE THOSE SERVICES. IF YOU DO NOT AGREE TO THE TERMS AND CONDITIONS SET FORTH HEREIN, PLEASE DO NOT USE OUR SITES, PRODUCTS, OR SERVICES.

1. Information We Collect

Information You Provide to Us

For certain services on our Sites, Products, or Services, you may be asked to provide personal details as set forth below. Generally, you are not required by law to provide this information and doing so depends on your wish and consent; however, without providing the details marked as mandatory fields, we will not be able to provide you with the requested services.

If you provide personal information on behalf of a third party, you represent and warrant that you are duly authorized to provide such information and that the provision of such information was made with the consent of that third party in accordance with this Privacy Policy.

This includes:

  • Contact Information: Name, email address, telephone number, company name, job title, and business address when you contact us through our Sites to request information about our Products or Services. You represent that the details you have entered are your own details and that they are true, current, accurate, and complete. Providing partial or incorrect details may prevent us from responding to your inquiries or contacting you if necessary.
  • Communications: Inquiries, feedback, requests for information, and any other correspondence you send to us. This information may be recorded in our systems to enable us to respond to your inquiries and improve our Services.

Information Collected Automatically

Subject to your device settings and applicable legal requirements (including consent where required), we may automatically collect:

  • Device and Technical Data: IP address, browser type and version, operating system, device identifiers, language settings, time zone, and mobile carrier information.
  • Usage Data: Pages viewed, time spent on pages, referral and exit pages, click data, session information, and other interaction data.
  • Cookies and Similar Technologies: We use cookies, pixels, tags, and similar technologies for various purposes as described in Section 3 below.

Information from Third Parties

We may receive information from partners, vendors, and publicly available sources to supplement the data we collect directly from you, including for verification, analytics, and service improvement purposes.

How We Collect Information

We collect information in the following ways: (a) automatically when you use our Sites, through logs, cookies, and similar technologies; (b) voluntarily, when you provide details through contact forms, inquiries, or other communications; and (c) from third parties, as described above, all in accordance with applicable law.

2. How We Use Personal Data

We will not collect or use personal data for purposes other than those described in this Privacy Policy. If we intend to use your personal data for any purposes other than those described herein, we will ask for your explicit consent prior to such use.

We process personal data only for specific and limited purposes, including:

  • Service Delivery: To provide, operate, maintain, and improve our Sites, Products, and Services.
  • Responding to Inquiries: To respond to your requests for information and inquiries about our Products and Services.
  • Communications: To send you service-related notices, updates, and, with your consent, marketing communications.
  • Analytics and Improvement: To understand usage trends, analyze user behavior, and enhance user experience. We may use aggregated, non-identifying statistical information for business analysis and marketing purposes.
  • Security: To detect, prevent, and address fraud, security issues, and technical problems.
  • Legal Compliance: To comply with applicable laws, regulations, and legal processes.
  • Dispute Resolution: For settling disputes, preparing for and defending against legal claims, and other legal purposes.

3. Legal Bases for Processing

We will only collect and process personal data about you where we have a lawful basis. We rely on the following legal grounds to process your personal data:

  • Contractual Necessity: To provide the Services you have requested and fulfill our contractual obligations to you, and to respond to information or support requests.
  • Legitimate Interests: To pursue our legitimate business interests, such as improving our Services, ensuring security and integrity of our systems, conducting analytics, and internal record keeping, while balancing these interests against your rights. We also rely on legitimate interests to protect the rights, property, or safety of Tupaia, our users, or the public.
  • Consent: Where required by law, we rely on your consent for certain processing activities, such as marketing communications and non-essential cookies. You may withdraw consent at any time, and where we rely on legitimate interests, you have the right to object.
  • Legal Obligation: To comply with applicable laws and respond to lawful requests from competent authorities.

If you have any questions about the lawful basis upon which we collect and use your personal data, please contact us using the details provided in Section 14.

4. Cookies and Similar Technologies

Our Sites and Services use "cookies" and other data collection technologies for their regular and proper operation, including to collect statistical data about use of our Sites, to verify details, to customize the Sites to your personal preferences, and for information security purposes.

"Cookies" are small text files that are created by the browser at the Company's command and stored on your device. Cookies contain a variety of information, such as the pages you visited, the time you spent on the Sites, where you came to the Sites from, and more. They also help eliminate the need to re-enter details each time you revisit certain parts of the Sites.

We may use the following types of cookies:

  • Essential Cookies: Necessary for the operation of our Sites and Services, including to keep you logged in and maintain session security.
  • Analytics Cookies: To understand how visitors interact with our Sites, analyze usage patterns, measure traffic sources, track page views, and improve performance. We may use third-party analytics services (such as Google Analytics and similar tools) that use cookies to help us analyze how users use the Sites.
  • Functional Cookies: To remember your preferences, settings, language choices, and other customizations to enhance your user experience.
  • Advertising Cookies: Where applicable and with your consent, to deliver relevant advertisements and measure their effectiveness.

The information generated by cookies about your use of the Sites (including your IP address) may be transmitted to and stored by third-party service providers on servers around the world.

Your Choices: You can refuse the use of cookies by selecting the appropriate settings in your browser. Most browsers allow you to delete cookies, block cookies, or receive a warning before a cookie is stored. Please note, however, that if you do so, you may not be able to use the full functionality of the Sites. For more information on how to manage cookies, please refer to your browser's help documentation or visit www.allaboutcookies.org.

5. How We Share Information

We will not transfer your personal data to third parties for their use without your consent, nor will we sell or rent information about you, except as described below:

  • Affiliated Companies: With Tupaia group companies, subsidiaries, parent companies, and companies under their control, on a need-to-know basis to provide and improve our Services.
  • Service Providers: With third-party vendors who assist us in operating our business, such as hosting and cloud services providers, analytics services, email and communication services, and customer support tools. Transfer of information to these providers shall be made only to the extent necessary for the provision of the service. These providers are bound by contractual obligations to protect your data and process it only for specified purposes.
  • Business Partners: Where necessary to deliver, measure, and optimize our Services, subject to appropriate privacy and confidentiality terms.
  • Legal and Safety Purposes: When we have a good faith belief that disclosure is necessary to: (a) comply with applicable law, regulation, legal process, or enforceable governmental request; (b) enforce our agreements and investigate potential violations; (c) detect, prevent, or address fraud, security, or technical issues; or (d) protect the rights, property, or safety of Tupaia, our users, or the public as required or permitted by law.
  • Violations: If you breach our Terms of Use or if you perform, or attempt to perform, actions through or in connection with the Sites that are contrary to law or that may harm any person or their property.
  • Disputes and Legal Proceedings: In any case of dispute, claim, demand, or legal proceedings between you and Tupaia, or arising from your use of the Sites.
  • Corporate Transactions: In connection with a merger, acquisition, sale of assets, bankruptcy, reorganization, or other corporate transaction, your personal data may be transferred to the successor entity, subject to continued privacy protections. In such circumstances, you will be notified on a best-efforts basis via email and/or a prominent notice on our Sites, of any change in ownership, uses of your personal data, and choices you may have regarding your personal data.

We do not sell personal data in the ordinary sense. Where local law defines "sale" more broadly, we honor applicable opt-out rights.

We may share aggregated, non-identifying statistical information, with or without consideration, with third parties with whom we have business or other relationships, including companies engaged in analyzing such anonymous statistical information for the purpose of improving services, user experience, or for other purposes, at our sole discretion.

6. International Data Transfers

We operate globally and may transfer personal data to countries outside your country of residence. For transfers from the European Economic Area (EEA) or the United Kingdom, we rely on:

  • Adequacy decisions by the European Commission.
  • Standard Contractual Clauses (SCCs) approved by the European Commission, with supplementary measures where appropriate.
  • Other lawful transfer mechanisms as applicable.

We assess relevant risks and implement appropriate technical and organizational measures to protect your data during international transfers.

7. Data Retention

We retain personal data for no longer than is necessary for the purposes for which it was collected. To determine the appropriate retention period, we consider the nature and sensitivity of the data, the purposes of processing, applicable legal requirements, and whether those purposes can be achieved through other means.

Information required for legal and accounting documentation purposes will be retained for up to seven (7) years from the date of the last engagement, or as required by applicable law. Anonymous or statistical information may be retained indefinitely.

When personal data is no longer required, we securely delete or anonymize it in accordance with our internal procedures.

8. Data Security

We make efforts to secure our Sites, Products, Services, and the personal data of our users. We follow generally accepted industry standards to protect against unauthorized access to or unauthorized alteration, disclosure, or destruction of personal data. We implement reasonable and industry-standard technical and organizational security measures, including access controls, encryption (in transit), identity and access management, network segmentation, monitoring, logging, and staff training. Access to personal data is restricted to employees, contractors, and service providers who we believe reasonably need to come into contact with that information. These individuals are bound by confidentiality obligations.

While these measures reduce the risks of unauthorized intrusion into our computer systems and servers, we cannot guarantee that they will provide absolute protection against breaches or unauthorized access. No method of transmission over the Internet or electronic storage is completely secure, and we cannot guarantee absolute security. We work continuously to reduce risks and improve our security measures.

Although we cannot guarantee against any loss, misuse, unauthorized disclosure, alteration, or destruction of data, we try to prevent such occurrences, including by implementing corporate procedures in this regard. If you have reason to believe that your use of the Sites is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us by contacting us in accordance with Section 14.

9. Children's Privacy

We care about the safety of children. Our Sites, Products, and Services are not directed toward children under the age of 16 (or the applicable age of majority in your jurisdiction). We do not knowingly collect personal data from children. If you are a parent or guardian and you have reason to believe that a child under the relevant age has provided us with their personal data without your consent, please contact us so we can take appropriate action to delete such information. Upon receiving such notification, we will make reasonable efforts to promptly delete that information from our records. If we become aware that we have unknowingly collected personal data from a child, we will take commercially reasonable steps to delete such information.

By using our Sites, you represent that you are of legal age (above 18) or that you have obtained the consent of a parent or legal guardian.

10. Your Rights

Depending on your location and applicable data protection laws, you may have the following rights regarding your personal data:

  • Right to Access: Request information on personal data that we hold about you.
  • Right to Rectification: Request correction of inaccurate or incomplete personal data.
  • Right to Erasure: Request deletion of your personal data in certain circumstances, if Tupaia is not permitted or legally obligated to retain the data.
  • Right to Restrict Processing: Request that we limit the processing of your personal data.
  • Right to Data Portability: Request that your data be transferred in a generally usable, machine-readable, and standardized format.
  • Right to Object: Object to processing based on legitimate interests or for direct marketing purposes at any time.
  • Right to Withdraw Consent: Where processing is based on consent, withdraw your consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
  • Right to Lodge a Complaint: File a complaint with a competent data protection authority about our collection and use of your personal data.

To exercise any of these rights, please contact us at the details provided in Section 14. We may request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to an unauthorized recipient. We will respond within the timeframes required by applicable law.

We do not charge for complying with a correction request; however, for other requests, we may charge a small fee to cover our costs. We may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others, or would be extremely impractical.

Nothing in this Privacy Policy is interpreted as an obligation to store information, and we may, at our own discretion, delete or avoid recording and storing any and all information.

11. Automated Decision-Making and Profiling

We may use profiling for purposes such as analytics and service personalization. We do not make decisions based solely on automated processing that produce legal effects or similarly significantly affect you without human involvement, unless required or permitted by law with appropriate safeguards.

12. Third-Party Links and Content

Our Sites and Services may contain links to third-party websites, applications, or services. We are not responsible for the privacy practices, security, or content of these third parties. Your interactions with these third-party features are governed by the privacy policy of the provider. We encourage you to carefully read the terms of use and privacy policies of such third-party sites and applications before using their services. This Privacy Policy applies solely to personal data collected by us.

We work with our service providers according to accepted standards and under appropriate contractual frameworks, but we cannot vouch for their activities beyond that.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time without prior notification. Nevertheless, we will notify you about significant changes in the way we treat personal data by placing a prominent notice on our Sites. The updated Privacy Policy will be posted on our Sites under "Privacy Policy" and will take effect from the date of its publication.

We encourage you to periodically review this Privacy Policy for the latest information about our privacy practices. Please look at the "Last Updated" date at the top of this page to see when this Privacy Policy was last revised. Your continued use of our Sites, Products, or Services after any changes constitutes your acceptance of the revised Privacy Policy.

14. Enforcement

We regularly review our compliance with this Privacy Policy. Please feel free to direct any questions or concerns regarding this Privacy Policy or our treatment of personal data by contacting us using the details below. When we receive formal written complaints, it is our policy to contact the complaining user regarding his or her concerns. We will cooperate with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the processing of personal data that cannot be resolved between us and an individual.

15. Governing Law and Jurisdiction

This Privacy Policy and the use of our Sites shall be governed exclusively by the laws of the State of Israel. Exclusive jurisdiction for any matter arising from this Privacy Policy or the use of our Sites is granted to the competent courts in Tel Aviv, Israel.

16. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please feel free to contact us at:

Tupaia Ltd.

Address: 24 Raoul Wallenberg St., Tel-Aviv, Israel

Email: privacy@tupaia-pos.com

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