Privacy Policy

Introduction

This Privacy Notice details how Visual Layer Inc. ("us", "we", or "Company") process
information of users of our website and of our customers' employees who are
registered users of our services (each, "you" or "User") collected through our website
(the "Website") or our platform (the "Services"), as applicable.

We may revise this notice from time to time, in our sole discretion, and the most
current version will always be posted on our website. We encourage you to visit this page regularly for any changes.

What information we collect

When you use our Website or Services, we may collect personal information about you
as follows ("Personal Information"):

Voluntary Information: We may collect information that you provide us
voluntarily such as your name, email address and company. For instance, when
you sign up to receive updates or further information from us, when you
communicate with us via the 'contact us' option or 'Get a demo' option on the
Website or Service. In those cases, we will collect your name, email address,
and the name of your organization, and retain them in our systems. If we
combine Personal Data with non-identifiable information, the combined
information will be treated by us as Personal Data for as long as it remains
combined.
Device Information: We may collect specific types of connection details and
information with regard to your device, software or hardware that may identify
you. Such information may include: browser type, device identifiers, and IP
address.
User Activity: Information regarding User's activity on the Website such as the
time and frequency of access, the referrer page domain, pages viewed, and
interactions between the User and the Website.
User Content: We also collect the content you create, upload, or receive from
others when using our Services or Website.

It should be made clear that you have no legal obligation to provide us with Personal
Information and the submission of such information is subject to your sole discretion
and consent.

Legal basis

The Company processes Personal Information collected through the Website based on
the following legal basis: (i) 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 – with regard to voluntary information; and (ii)
The data subject has given consent to the processing of his or her personal data for
one or more specific purposes – with regard to device information. To withdraw
consent, see our cookie notice below or contact us at [email protected].

The Company processes Personal Information collected through the Services based on
the following legal basis: 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.

Cookies

We may use cookies and other technologies or methods of web and mobile analysis
(e.g., Pixels, Beacons etc.) to gather, store, and track certain information related with
your access to and activity through the Website. A "cookie" is a small piece of
information that a website assign to your device while you are viewing a website.
Cookies are very helpful and may be used for various different purposes. These
purposes include, among other things, allowing you to navigate between pages
efficiently, enabling automatic activation of certain features, remembering your
preferences and making the interaction between you and the Website quicker, easier
and smoother.
We use the following types of cookies:

Session Cookies: which are stored only temporarily during a browsing session
in order to allow normal use of the system and are deleted from your device
when the browser is closed.
Persistent Cookies: which are saved on your device for a fixed period and are
not deleted when the browser is closed. Such cookies are used where we need
to identify who you are for repeated visits (for instance, to allow us to store your
preferences for the next visit to our page).

You may remove the cookies by following the instructions of your device preferences.
However, if you choose to disable cookies, some features of the Website may not
operate properly and your online experience may be limited.

Third Party Tracking Technologies

We also use google ads to collect information about your use of the Website. This third
party service collects and shares information about your use of the Website in accordance with the following terms: https://www.google.com/analytics/terms/default.html.

How we use the information

We use the information in the manners described in this Privacy Policy. In addition to
the purposes listed herein, the information we collect, which may include your
Personal Information, is used for the following purposes:

To provide our customers with the Website and Services, as well as to improve
our Website and Services;
To investigate and resolve disputes in connection with your use of the Website
and/or Services;
To detect and prevent fraudulent and illegal activity or any other type of activity
that may jeopardize or negatively affect the integrity of the Website and/or
Services; and
To investigate violations and enforce our policies, and as required by law,
regulation or other governmental authority, or to comply with a subpoena or
similar legal process or respond to a government request.

With whom we share the information and for what purpose

We do not rent or sell any Personal Information. We may share Personal Information
with the following recipients:

our third party vendors engaged in providing services in connection with the
Website and/or Services;
our subsidiaries and affiliated companies;
auditors or advisers of our business processes; and
any potential purchasers or investors in the Company.

We may share Personal Information with our recipients for any of the following
purposes: (i) storing or processing Personal Information on our behalf (e.g., cloud
computing service providers); (ii) assisting us with our business operations (e.g.,
issuing credit cards and processing transactions); and (iii) performing research,
technical diagnostics, personalization and analytics that will enable us to improve the
Website and/or Services.

We may also disclose Personal Information, or any information you submitted via the
Website and/or Services if we have a good faith belief that disclosure of such
information is helpful or reasonably necessary to: (i) comply with any applicable law,
regulation, legal process or governmental request; (ii) enforce our policies (including
our agreements), including investigations of potential violations thereof; (iii)
investigate, detect, prevent, or take action regarding illegal activities or other
wrongdoing, suspected fraud or security issues; (iv) establish or exercise our rights to
defend against legal claims; (v) prevent harm to the rights, property or safety of us,
our affiliates, our users, yourself or any third-party; (vi) for the purpose of

collaborating with law enforcement agencies; and (vii) in case we find it necessary in
order to enforce intellectual property or other legal rights.

International transfer

Since we operate globally, it may be necessary to transfer data, including Personal
Information, to other countries than the country in which the information was
collected. In these instances, we will transfer your data only based on standard data
protection clauses adopted by the European Commission.

For how long we retain the information

We retain the information that we collect from our Users for as long as we are
providing the Services to the applicable customer. Retention periods will be
determined taking into account the type of information that is collected and the
purpose for which it is collected, bearing in mind the requirements applicable to the
situation and the need to destroy outdated, unused information at the earliest
reasonable time. Under applicable regulations, we may keep records containing Users'
Personal Information, account opening documents, communications and anything else
as required by applicable laws and regulations.

We may rectify, replenish or remove incomplete or inaccurate information, at any time
and at our own discretion.

Your privacy rights

Certain jurisdictions provide Users with certain statutory rights to their Personal
Information. Subject to exemptions provided by law, and with proper identification,
you may have the right to certain actions to your Personal Information such as:

Right to verify your Personal Information (to access, delete, 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 or deleted);
Right to see what Personal Information about you we have;
Right to request that we erase Personal Information about you (subject to any
other legal obligation that may require us to keep that information);
Right to restrict us from processing Personal Information pertaining to you (for
example, you may request that we will stop using or sharing your Personal
Information with third-parties); and
Right to export Personal Information in a portable format.

If you wish to exercise any of these rights, contact us at: [email protected].
When handling your request, we will ask for additional information to confirm your
identity (which may include Personal Information). However, please note that if you
choose not to allow us to process your Personal Information, we may be prevented
from providing our Services or accessing our Website.

Please note that these rights are not absolute and may be subject to our own
legitimate interests and regulatory requirements.
If you wish to raise a complaint on how we have handled your Personal Information,
please contact us directly at: [email protected]
If you are not satisfied with our response or believe we are collecting or processing
your Personal Information not in accordance with the laws, you can file a complaint to
the applicable data protection authority.