Privacy Policy

Last updated: August 1, 2025

Jeen AI Ltd and its related companies (”Jeen,” “company,” “we,” “us,” or “our”) respect the

privacy of our users (“User(s),” “you,” “data subject(s),” or “Visitor(s)”) and our customers

(“Customer(s)”). We are committed to safeguarding your personal data, which you share

with us through our website located at https://jeen.ai/ (the “Site” or “Website”) and our

proprietary enterprise software platform, the Jeen Platform (the “Platform” or the

“Software”), deployed in customer-controlled environments or accessed as a hosted

solution. Together, the Site, the Platform, and any associated services or support we provide

are referred to as the Services.

Our Privacy Policy (the “Policy” or “Privacy Policy”) outlines the data collection and

processing practices used in connection with our Services. This Policy aims to provide

transparency regarding the types of personal information we collect and how we use it. By

accessing our Site, using our Software, or utilizing our Services, you acknowledge and agree

to the data practices described in this Policy.

Jeen develops an enterprise AI platform that enables organizations to deploy and manage AI

capabilities securely, flexibly, and at scale. The Jeen Platform offers no-code interfaces and

integration tools that support a variety of internal use cases, while allowing organizations to

retain full control over AI usage and data flows. This policy outlines Jeen’s alignment with

global privacy and data protection frameworks, including the EU General Data Protection

Regulation, U.S. state privacy laws, Israel’s Protection of Privacy Law (PPL), and other

applicable legal regimes. It reflects Jeen’s commitment to responsible AI deployment and

privacy-by-design principles across all deployment models.

Please note that if you access a third-party website through a link provided in our Services,

we encourage you to review their privacy policies before submitting any personal

information. By visiting our Site or registering for our Services, you consent to our collection

and use of your information in accordance with this Privacy Policy.

Preliminary Notes

Please read this policy and make sure you fully understand our practices in relation to your

personal information before you access or use the Site or our Services. If you have read this

Privacy Policy and remain opposed to our practices, you must immediately leave this Site and

discontinue all use of the Services.

Binding Agreement – This Privacy Policy constitutes an integral part of our Conditions (“Terms”)

Terms and

Content – Our Site and Services do not contain inappropriate content. Nevertheless, we use

appropriate technical and organizational measures to ensure the protection and retention of

data subjects.

1Changes and updates to this Privacy Policy – We reserve the right to modify or update this

Privacy Policy, to reflect changes in our Services or data processing practices or to conform to

a regulatory requirement. Such changes will be effective immediately upon the display of the

revised Privacy Policy. The last revision date will be reflected in the “Last Updated” heading.

If we make material changes to this Privacy Policy, we will do our best to notify you by email

or through a notice on our Site.

About This Privacy Policy

We created this Privacy Policy to emphasize our commitment to protecting your privacy. Using

our Site and Services may require you to provide certain Personal Data (as defined below), but

only if you choose to do so voluntarily. Some features of our Site and Services, such as

accessing our Platform, may require registration and submission of Personal Data, as detailed

in this Policy. We will retain and handle the Personal Data you provide in accordance with this

Privacy Policy.

If you would like to learn more about Jeen’s region-specific processing of personal data, please

refer to the relevant notices below for individuals in different regions.

Please read the Privacy Policy carefully to ensure you understand it and agree with its terms

before using the Services. You have no legal requirement to provide us with your Personal

Data. We collect, process, and retain your Personal Information only if you choose to access

and engage with our Services and in accordance with this privacy policy. You can always avoid

providing us with certain Personal Data; however, you acknowledge that it may prevent us

from providing you with certain Services or from using our Site. If you do not agree with any of

the terms provided in this Privacy Policy, and the choices we provide do not mitigate your

concerns, please do not access or use our Services and avoid accessing and using our Site.

Definitions

Adequate Country means a country or territory recognized by the European Commission or

by the United Kingdom (as applicable) under the Data Protection Laws as providing adequate

protection for Personal Data.

Applicable Privacy Laws means any applicable privacy or other law relevant to our

operations, including the General Data Protection Regulation (EU) 2016/679 (GDPR);

European Union Member State laws, Switzerland, the United Kingdom, rules, and guidelines

implementing or supplementing the GDPR, as amended from time to time and to the extent

applicable to our Company’s operation and our Services; the California Consumer Privacy Act

(CCPA), as amended by the California Privacy Rights Act of 2020 (CPRA), Cal. Civ. Code §§

1798.100 et seq.; and additional US state-specific privacy laws, including but not limited to

the Virginia Consumer Data Protection Act (VCDPA), the Colorado Privacy Act (CPA), the

Connecticut Data Privacy Act (CTDPA), the Utah Consumer Privacy Act (UCPA), the Texas Data

Privacy and Security Act (TDPSA), and other similar state laws enacted or amended in the

future; the Israeli Privacy Protection Law, 5741-1981, including any amendments and

regulations enacted thereunder, such as the Privacy Protection Regulations (Transfer of Data

2to Databases Abroad), 5761-2001, and the Privacy Protection Regulations (Data Security),

5777-2017, as well as any applicable guidelines, standards, and instructions published by the

Israeli Privacy Protection Authority (ILITA), in effect from time to time, relating to data

protection and privacy.

Minor refers to a data subject underage (under 16 years or less depending on the legal

jurisdiction applicable), whose processing of his/her personal data is only lawful if parental or

guardian consent has been obtained.

Data Controller refers to any natural or legal person, public authority, agency, or other body

that, alone or jointly with others, determines the purposes and means of the processing of

Personal Data and establishes the necessary controls for such processing.

Data Processor refers to any natural or legal person, public authority, agency, or other body

(excluding employees of the Data Controller) that processes Personal Data on behalf of the

Data Controller.

Data Subject refers to an identified or identifiable individual to whom the Personal Data

relates.

Data Subject Consent refers to the Data Subject’s approval or agreement for an activity to

take place, having considered the benefits and risks of the activity. For consent to be valid,

the Data Subject needs to be informed, have the capacity and knowledge to decide, and to

have given their consent voluntarily.

Personal Data (or Personal Information) refers to information about a living individual,

which means that they can be identified (a) from that data, or (b) from that data and any

other information capable of being associated with, or reasonably linked to, a particular

person, now or in the future, as provided in this Privacy Policy.

Non-personal data means information that does not personally identify you and does not

reveal your specific identity as an individual, such as anonymized information.

Process or Processing refers to any operation that is performed upon or applied to personal

data, whether undertaken manually or by automated means, including its acquisition,

organization, storage, retrieval, consultation, amendment, availability, disclosure, erasure, or

destruction.

Subprocessor shall mean any entity appointed by us or by one of our sub-processors, to

Process Personal Data on our behalf or on behalf of that sub-processor, excluding any

employee of our sub-processor or of any such appointed person but including any contractor

or affiliate of the foregoing.

The terms “Controller”, “Processor”, “Sub-Processor”, “Data Subject”, “Personal Data”,

“Processing” (and/or “Process”), “Personal Data Breach”, “Union”, “Member State” and

“Special Categories of Personal Data” shall have the meanings given in the GDPR and related

EU data protection laws.

The terms “Business”, “Business Purpose”, “Consumer”, “Service Provider”, “Third Party”

and “Contractor” shall have the same meanings as defined in the CCPA, as amended.

To the extent that CCPA applies, the term “Controller” shall also mean “Business”, and

“Processor” shall also mean “Service Provider”, “Contractor” or “Third Party”, as the context

requires.

This Policy was originally written in English. If you are reading a translation and it conflicts

with the English version, please note that the English language version prevails.

3Roles and Responsibilities

Jeen Technologies AI Ltd. primarily acts as a Data Processor, providing enterprise software

that processes Personal Data on behalf of its customers. In this capacity, Jeen processes data

strictly in accordance with Customer instructions and subject to applicable data processing

agreements. Jeen does not determine the purposes or means of such processing and does

not use the data for its own purposes.

In limited contexts, such as when collecting Personal Data through Jeen’s corporate Site,

handling inbound Customer communications, or managing business subscriptions, Jeen may

act as a Data Controller. In these cases, Jeen determines the purpose and means of

processing and is responsible for compliance with Applicable Privacy Laws.

Our main registered office is:

Derech Menahem Begin 121, Tel-Aviv, Israel 6701203.

To Whom Does This Privacy Policy Apply?

This Privacy Policy applies to Personal Data we collect online and offline and applies in the following

situations:

● Visitors and Users of the Jeen Website:

We collect Personal Data when you browse our Website, contact us, request a demo, submit an

inquiry, apply for open roles, or otherwise engage with Jeen.

● Enterprise Customers and Their Authorized Users:

When enterprise clients deploy the Platform, we may process limited Personal Data of their

personnel (such as names, business contact details, roles, and usage metadata) to support account

management, technical support, and service delivery.

● Suppliers, Partners, and Service Providers:

We collect and process business contact information from vendors, consultants, and other service

providers to manage procurement, contractual relationships, and ongoing collaboration. Where

applicable, such processing is governed by specific contractual obligations.

● Use of the Jeen Platform and Related Services:

In providing access to our Platform and services, Jeen may process Personal Data for user

authentication, support requests, access logs, configuration, and service performance. Jeen

processes such data in accordance with contractual agreements and applicable privacy laws.

4When Does This Privacy Policy Apply?

This Privacy Policy applies to Personal Data about you that we collect, use, or otherwise

process regarding your relationship with us as a Visitor of our Site or a User of our Services.

Data You Share with Us Directly

Submitting information to us is optional in certain cases and required in others, depending on

the Service you choose to use or access. This category includes one or more of the following

data categories:

I. II. III. IV. Admin and service login. To access the Jeen Platform and related services, authorized

users may be required to create or use credentials such as business email addresses,

login IDs, and role identifiers.

Purpose: We use this data to provision and manage access to the Platform,

authenticate users, apply role-based access controls, and maintain system security.

Retention: We retain account-related data for as long as the user is active and as

needed to provide services or meet legal obligations.

Contact details. We may process your contact details, including your name, email

address, phone number, company name, and any other information you choose to

provide. This information is collected when you engage with us, for example, by

applying for support, or seeking information about how our solutions can help you

address emerging challenges.

Purpose: We process this information, based on your consent, for the specific purpose

for which it was provided. This includes responding to your inquiry and providing the

support or information you have requested.

Retention: We retain your contact information for as long as necessary to fulfill your

request or as required under applicable law.

Providing the services. As part of service delivery, enterprise customers may share

limited user data (e.g., name, email, user role, SSO ID) to enable onboarding, access

provisioning, and account setup within their environment.

Purpose: To support secure and efficient use of the Platform and enable functionality

such as user management, access control, and audit trails.

Retention: Processed in accordance with the customer’s instructions and retained as

necessary for service continuity or legal compliance.

Payment information. When utilizing our Services, we may collect and process certain

payment-related information, such as your full name, email address, billing address,

bank account details, and other necessary data. This information is used for issuing

invoices, processing payments, and providing Service-related confirmations or

notifications.

Purposes: Payment information is collected and processed to facilitate the billing and

payment of fees for the Services provided, as outlined in your agreement with us.

Retention: We retain payment information for as long as necessary to fulfill our billing

and payment obligations or as required by applicable law.

5V. VI. Recruitment and job applications. When applying for a position, we may collect and

process your Personal Data to evaluate your application and manage the recruitment

process. This may include information such as your name, email address, phone

number, resume, LinkedIn URL, cover letter, and any additional information you

provide in the application form.

Purpose: Personal Data is used to evaluate your qualifications, communicate regarding

the role, and manage the recruitment process.

Retention: Recruitment data is retained for the duration of the hiring process and,

where applicable, to comply with legal requirements or to consider you for future

opportunities. Unless you request its deletion, this data may be retained for up to two

years.

Aggregated data. We may collect and retain metadata and statistical information

concerning the use of the Services to operate, maintain, manage, and improve the

Services. Some data may be retained on our third-party service providers’ servers in

accordance with their retention policies. This retained metadata or statistical

information does not identify you personally. When data is aggregated and

anonymized using reasonable and practical methods to ensure it cannot identify any

individual, it is no longer considered Personal Data and is therefore not subject to

applicable data protection laws.

Data We Collect When You Use Our Services

This category covers the ways we enhance your experience and improve the performance of our

Services.

When you access our Site and software or use our Services, we may process information related to

your activities, device, and visit. This processing enables us to deliver, maintain, and enhance the

Services, analyze usage patterns, develop new features and updates, provide effective support, and

ensure the security and integrity of our platforms.

I. Online identifiers. We may process various online identifiers, such as IP addresses

assigned to your device by your internet provider, data from cookies and pixel tags

collected when you visit our Site, and information from log files. This data may include

online usage data, login data (when applicable), timestamps, and device-specific details

like your operating system. These identifiers are used to enhance your experience,

maintain system functionality, ensure security, and support our Services.

Purposes: to perform analytics and statistical evaluations to better understand user

behavior and improve our Services (legitimate interests); to monitor, detect, and

prevent fraud or automated activities and ensure compliance with regional regulations

by determining the country from which you access our Services; and to provide proper

access and functionality of the Services you have requested (contractual necessity). In

certain cases, third-party cookies and tags may also be used for advertising, marketing,

and retargeting campaigns, based on your consent or, where applicable, notice where

consent is not legally required.

Retention: We retain online information for as long as necessary to achieve the purpose

for which it is processed, to begin with, or, until we make it Non-Personal Data, in which

6II. III. IV. case, we reserve the right to retain the information without any time limitation, based

on our discretion and commercial necessities.

Device Information. We may collect certain information about the device from which

you access the Services, such as the user-agent (including IP address, operating system

type, and version), device type (e.g., mobile, tablet, desktop), and the system language

settings configured on your device.

Purposes: Based on your consent, or in certain cases, we may process device

information to ensure the software or service is compatible with your device type and

operating system version. This helps optimize the functionality and user experience by

tailoring features to your device’s capabilities and ensuring smooth operation.

Retention: We retain device information for as long as necessary to provide the

Service’s functionality, to maintain a record of your license key and usage of the

product, to associate license terms and renewals.

Online activity. We also may collect certain online activity information from Visitors.

Under this category, we may also document in log files your clicks on actions and

buttons across our Site, Software, or Services, if provided, as described under the

category of “Online Identifiers”.

Purpose: This information is used based on your consent, for advertising, marketing,

and retargeting of our Services, where required by law, and to ensure the security and

integrity of our Services.

Retention: We retain online activity information for as long as necessary to fulfill the

purposes outlined above. If the information is no longer required, it will be deleted or

anonymized unless we are required to retain it for legal, regulatory, or contractual

obligations.

Engagement and Marketing Data. We may collect and process information related to

your interactions with our communications, Services, and marketing activities. This data

may include customer interaction metrics (e.g., email opens, subscription preferences,

and responses to campaigns), as well as CRM data, behavioral segmentation, and

related analytics. Such data is typically collected directly from your interactions with our

Services or, in some cases, through third-party analytics and marketing tools integrated

into our platform.

Purpose: This data is processed based on your consent, where required under

Applicable Privacy Laws, or otherwise based on notice, to provide personalized

communications, advertising, and marketing, including retargeting campaigns.

Retention: Engagement and marketing data is retained only for as long as necessary to

achieve the purposes described above or until you withdraw your consent, if applicable.

If the data is collected via third-party services, retention will comply with the terms of

those services and our agreements with them. Data that is no longer required will be

deleted or anonymized unless we are required to retain it for legal, regulatory, or

contractual purposes.

7Data we collect from third parties

This category refers to data we may receive from third parties concerning the Services we provide to

you.

I. II. Data from companies that offer their products or services in relation to our Services or

whose products or services may be linked from our Service or whose products or

services may be linked to their service.

Information for marketing operations provided by third-party marketing services. We

may also share or receive information about you with/from third parties, including

advertising and remarketing providers or similar partners. These partnerships allow us

to personalize content and ads based on your interests and preferences, as well as to

understand how you engage with our advertising campaigns. The purpose of sharing or

receiving information with/from third-party advertisers/remarketers is to tailor, target,

analyze, report on, and/or manage advertising campaigns or other initiatives. These

third parties may use cookies, pixel tags, or other technologies to collect information in

furtherance of such purposes.

Depending on your region, you may have the option to opt in or opt out of data sharing

and processing activities with third-party advertisers and remarketers. We respect your

preferences and comply with applicable regional laws and regulations. Information

shared or received with/from these third-party providers is retained only as long as

necessary to provide you with the Services or as required by law. By using our Services,

you consent to this processing unless you have opted out where permitted.

III. IV. V. VI. Analytical information. We use one or more third-party analytics services, such as

Google Analytics, to evaluate your use of the Services by compiling reports on activity

(based on their collection of IP addresses, Internet service provider, browser type,

operating system, and language, referring and exit pages and URLs, date and time,

amount of time spent on particular pages, what sections of the Site or Software you

visit, number of links clicked, search terms and other similar usage data) and analyzing

performance metrics. These third parties use cookies and other technologies to help

collect, analyze, and provide us with reports or other data. By accessing and using the

Services, you consent to the processing of data about you by these analytics providers in

the manner and for the purposes set out in this Privacy Policy.

Additional information as required from us to comply with legal obligations.

Any data obtained by any of the above means may be associated with other data you

have previously provided to us.

Third-party advertising companies are sometimes used to help us collect this Personal

Information.

8Cookies

At Jeen, we may use few cookies and other tracking technologies to enhance user

experience and improve our Services through the Site or Software. Cookies are small data

files that are transferred to your device via your web browser, allowing our systems to

recognize your browser and capture certain information.

Cookies may be collected by us or by third-party vendors, to collect cookies to analyze how

you interact with and use our Site and Software. The information collected by these cookies

includes your IP address, time of visit, whether you are a return visitor, any referring Site or

Software, URL, referrer, device and browser characteristics, and timestamp.

The data collected by these cookies is transmitted to and stored by the third-party vendors

and is subject to their respective privacy policies.

We also may utilize other tracking technologies, such as flash cookies, embedded scripts,

eTags, and web beacons, to collect and store information about your visit. This includes

details such as your browser type, operating system, mobile device information, and

clickstream data. Cookies are used to facilitate your site usage without requiring you to re-

enter your login information, customize and enhance your website experience, monitor

website usage, manage the Site, and improve our products and services. These cookies may

be session cookies, which expire once you close your browser, or persistent cookies, which

remain on your device until deleted. The information collected by these cookies may be

used to analyze trends, gather insights into visitor movements, diagnose potential server

problems, investigate actual or potential security incidents, and ensure the Site’s proper

functionality. Additionally, we may utilize third-party analytics tools to assist us in measuring

traffic and usage trends for the service and gaining a better understanding of our users’

demographics.

Managing Your Cookie Preferences

We work with trusted third-party providers, such as Google Analytics, that may place cookies on

your device to collect data when you visit our website. These cookies support essential functionality,

analytics, and marketing performance.

Google Analytics may set cookies on your device to track usage patterns. These cookies do not

identify you personally but may collect information such as your device type, browser, and general

location.

If you wish to opt out of Google Analytics tracking, you can install the Google Analytics Opt-out

Browser Add-on.

You may also manage your cookie preferences at any time by accessing our website’s Cookie Settings

banner.

9How We Use Personal Data (Purposes of Processing)?

Jeen uses Personal Data to provide, operate, and maintain its website, platform, and related

services; to monitor, analyze, and improve performance, usability, and functionality; and to

personalize the user experience and enhance offerings, including surfacing relevant features or

content from partners. Personal Data is also used to provide technical support and customer

assistance, to send service announcements, operational notices, and, where permitted, promotional

communications. We process Personal Data to enforce our Terms, policies, and contractual

commitments; detect, investigate, and prevent misuse, fraud, or security incidents; and comply with

legal obligations, regulatory requirements, court orders, or law enforcement requests. In addition,

we may use Personal Data to manage legal disputes, understand user needs and usage patterns

(whether on an individual or aggregated basis), improve our products and services, and

communicate with users—including to request feedback. Where necessary, we may disclose

Personal Data to authorized third-party service providers who perform functions on our behalf,

subject to appropriate contractual safeguards and in accordance with applicable law.

The Legal Basis for Personal Data Use

Jeen processes Personal Data only where a valid legal basis applies, as required under applicable

privacy laws. The specific legal basis depends on the context in which the data is collected and used.

For example, when you use our website, we may process your data based on your consentת such as

when accepting cookies or submitting a contact formת where consent is required by law. When you

or your organization engage with Jeen to use our Platform or Services, we process Personal Data as

necessary to perform our contractual obligations. In some B2B interactions, we may rely on our

legitimate interests, provided those interests are balanced with your rights and expectations.

When Jeen acts as a Data Processor on behalf of enterprise customers, we process Personal Data

strictly according to their instructions and the terms of the applicable Data Processing Agreement

(DPA), in line with relevant privacy regulations.

Sharing Personal Data with Third Parties:

We do not sell, rent, or lease your Personal Data. We may share your Personal Data with service

providers and other third parties to the extent necessary to fulfill our Services, but not for marketing

purposes. Additionally, to provide, operate, maintain, and improve our Site and Services, and to

offer additional products and features, we utilize third-party services. These services include

payment processors, feedback features, support tools, operational tools, analytics, statistical tools,

and more. The specific categories of these services are as follows:

Hosting and Storage: Our Site and Services are hosted on third-party platforms,

including cloud storage providers. We require them to maintain strong data

protection standards, though their processing is governed by their own privacy

policies.

10Analytics: We may use analytics tools to understand how Users interact with our Site

and Services and improve performance.

Support Services: To provide timely assistance, we may use external support and

help desk providers for handling inquiries and customer care.

Authentication & Security: When you open an account, we may integrate third-party

authentication tools to enhance account security.

Payment Processing: If you engage with our Services or receive payments from us

(e.g., as a vendor), we may work with payment processors to handle transactions

securely.

CRM & Mailing Lists: We may use services to manage customer relationships, store

Personal Information securely, and operate our email notifications or subscription

lists.

Technology Partners: Some of our features may incorporate third-party technologies

or widgets to enhance product functionality.

Advertising & Retargeting: Certain third parties may collect non-identifiable data

about your browsing activity to serve relevant ads on other sites. You can opt-out

directly through those ads.

Legal Compliance: We may share Personal Information if required by law, to enforce

our terms, prevent fraud, or protect Jeen, its users, or the public.

Corporate Transactions: In case of a merger, acquisition, or asset sale, your

information may be transferred to the new entity, subject to applicable privacy

protections.

User-Generated Content & Social Media: If you share personal information in public

areas or via Third-Party Social Media Services, that information may be visible to

others and publicly accessible.

Data Subject Rights

We recognize that the protection of Personal Data is a fundamental right, and we are

committed to respecting the privacy rights of all individuals, regardless of their location.

Certain privacy rights apply universally and are upheld by Jeen as a global standard:

● Right to Transparency: You have the right to clear, accessible, and transparent

information about how your Personal Data is collected, used, and shared.

● Right to Access: You can request details about the Personal Data we hold about you,

including the purposes for which it is processed and the parties with whom it is

shared.

● Right to Correction: You may request corrections to any inaccuracies or incomplete

information in the Personal Data we hold about you.

● Right to Deletion: You may request the deletion of your Personal Data where legally

permitted, subject to certain exceptions, such as compliance with legal obligations or

the establishment of legal claims.

● Right to Object: You have the right to object to the processing of your Personal Data

for certain purposes, including direct marketing or where processing is based on our

legitimate interests.

11To exercise any of these rights, please contact us at: dataprivacy@jeen.ai We are committed

to responding to all valid requests in accordance with Applicable Privacy Laws and our

internal policies. Note that the implementation of these rights may vary based on your

jurisdiction and the nature of your relationship with us.

If you reside in the EEA or the US, please refer below to “Region-Specific Processing of

Personal Data” for additional rights specific to your location

Data Security

Jeen takes the protection of both Personal Data and non-personal data seriously. We

implement a range of industry-standard technologies, security processes, and organizational

safeguards to protect information against loss, theft, unauthorized access, misuse, or

damage.

Jeen maintains compliance with SOC 2 and is certified under ISO/IEC 27001, reflecting our

commitment to recognized international standards for information security management.

Data is encrypted both in transit and at rest, and system access is restricted through strict

role-based access controls.

While we employ robust technical and organizational measures, no system is entirely

immune to vulnerabilities or misuse. We therefore maintain a proactive security posture:

continuously monitoring our infrastructure, conducting regular penetration tests and security

audits, and implementing ongoing improvements to enhance resilience.

In the event of a data breach, Jeen will notify affected individuals and relevant supervisory

authorities without undue delay, as required under applicable law. Notifications will include

details about the nature of the breach, the types of data involved, and recommended steps

to mitigate potential risks. We are committed to managing such incidents with transparency,

urgency, and full regulatory compliance.

Retention Of Your Personal Data

As detailed above, we retain different types of data for varying periods based on legal,

operational, and regulatory requirements. Personal Data is retained only for as long as

necessary and determined to fulfill the purposes for which it was collected, including

supporting our business operations and services. These purposes may include data storage,

documentation, cybersecurity management, legal proceedings, and compliance with tax or

other regulatory requirements.

Aggregated or anonymized Non-Personal Data may be stored indefinitely, as it no longer

identifies any individual and is used for analytical and operational purposes.

As long as you continue using our services, we will retain your information as described in

this Policy unless we specify different retention periods, establish alternative terms in a DPA,

or are required by law to delete it. If you exercise your right to request deletion under

12Applicable Privacy Laws, we will delete your data to the extent required, while retaining only

what is necessary to comply with legal obligations.

If you exercise your right to request deletion under Applicable Privacy Laws, we will delete

your data to the extent required, while retaining only what is necessary to comply with legal

obligations.

Transfer Of Your Personal Data

Your information, including Personal Data, may be processed by Jeen and its authorized

service providers in jurisdictions outside your state, country, or region of residence. This may

include transfers of data to locations where data protection laws differ from those applicable

in your jurisdiction.

By using our Services and submitting Personal Data to us, you acknowledge and agree to such

transfers. Jeen takes appropriate measures to ensure that any cross-border data transfers are

carried out in compliance with applicable privacy laws and with adequate protections in

place. Where required, we rely on recognized legal mechanisms such as the European

Commission’s Standard Contractual Clauses (SCCs) or other appropriate safeguards to ensure

a lawful and secure transfer of Personal Data across borders.

Jeen’s Region-Specific Processing of Personal Data

A Notice for EEA Residents:

Depending on your country of residency, and on the type of your use of our Site (Visitor or a

User), Software (User), or Services, certain rights concerning your Personal Data may apply to

you.

If you are located in the EEA including the UK, you have certain rights with respect to your

Personal Data, including:

● The right to be informed: You have the right to receive clear and transparent

information about how your data is being used.

● The right of access: You can request a copy of your Personal Data and details on how

it is processed.

● The right to rectification: You are entitled to request corrections to any inaccurate or

incomplete data we hold about you.

● The right to erasure: Commonly known as the “right to be forgotten,” you can

request that we delete your data, subject to certain conditions.

● The right to restrict processing: You can ask us to limit how your data is used under

specific circumstances, such as while a dispute is being resolved.

● The right to object to processing: You have the right to object to the processing of

your data, particularly for direct marketing purposes.

● Rights related to automated decision-making and profiling: You can request human

intervention in decisions made solely through automated means, including profiling if

these decisions significantly affect you.

Please contact us at dataprivacy@jeen.ai with your detailed request and sufficient

information to allow us to verify you and your request, and we will process your verifiable

13request within the timeframe indicated in the applicable regulation. Note that when handling

these requests, we may require additional information from you to verify your identity.

When you ask us to exercise any of your rights under this Policy and the Applicable Privacy

Laws, we may need to ask you to provide us with certain credentials to make sure that you

are who you claim you are, to avoid phishing and/or disclosure to you of Personal Data

related to others. We may redact from the data which we will make available to you, any

Personal Data related to others, if applicable.

Transfer of Data Outside of Your Territory

If you are a resident of the EEA (including the UK), your data may be transferred outside the

EEA, to third parties who can assist us in our Services. We may process your Personal Data in

any country in which we do business. If we transfer the Personal Data of an EU resident

outside of the EU, we shall comply with Applicable Privacy Laws in relation to such transfer

and according to our commitment under DPA with our Customers.

We are subject to the provisions of the GDPR that protect your Personal Data. We ensure

that appropriate measures are in place to maintain a comparable level of security for your

Personal Data. Each data transfer outside the EEA will comply with the SCC unless the data is

shared with a country that has been deemed to have an adequate level of data protection. In

the event of data transfer to the US, we verify whether the third party is registered in the

DPF program at: https://www.dataprivacyframework.gov/

In any case, our transfer, storage, and handling of your Personal Data will continue to be

governed by this Privacy Policy and according to our commitment under the DPA with the

Data Controller.

A Notice for US Residents:

We recognize the importance of your privacy and are committed to complying with

Applicable Privacy Laws across the United States. This section informs US residents, including

those in California and other states with privacy laws, of their rights regarding the processing

of their Personal Information and how to exercise those rights.

We comply with the Children’s Online Privacy Protection Act (COPPA) and do not knowingly

collect personal information from children under 13 without verifiable parental consent.

A Notice for California Residents

We hereby inform Visitors and Users that are California residents, of the following rights (by

virtue of the CCPA) with respect to the Processing of your Personal Data:

To learn more about the categories of Personal Data we collect, its sources, purposes, and

the service providers we share it with, refer to the relevant sections above.

We do not sell Personal Data for business or commercial purposes, but we may share

Personal Information or aggregated information with a third party for a business purpose.

When we do so, we enter a contract that describes the purpose and requires the recipient to

keep that personal information confidential and not use it for any purpose other than what is

described in the agreement.

14If you wish to exercise your rights concerning our third party’s disclosure aspects, please refer

to the “Exercising Your Rights” section below.

Consumer Rights:

The CCPA grants California consumers specific rights in connection with the Personal Data

collected by businesses, as described below:

● Right to Know: You have the right to know the categories and specific pieces of

Personal Data we have collected about you in the previous 12 months.

● Right to Deletion: You have the right to request that we delete any Personal Data we

have collected about you.

● Right to Request Information: You have the right to request information about our

collection, sale, and disclosure of your Personal Data from the previous 12 months.

● “Shine the Light” Law: Under California’s “Shine the Light” law (Cal. Civ. Code

§1798.83), you have the right to request information regarding whether and how we

disclose your Personal Data to third parties for their direct marketing purposes,

unless our disclosures under the CCPA fulfill this requirement. This right allows you to

request and receive a list of the third parties, if any, with whom we have shared

Personal Data for such purposes, along with the types of Personal Data disclosed.

● Right to Opt-Out of the Sale and Sharing of Personal Data: California consumers

have the right to opt out of the sale and sharing of their Personal Data, including for

purposes such as cross-context behavioral advertising. While Jeen does not engage in

the sale or sharing of Personal Data, we are committed to honoring your privacy

preferences. If you have any concerns or wish to exercise your rights, please contact

us using the information provided below. Furthermore, Jeen does not sell the

Personal Data of Minors, as our services are not intended for individuals under the

applicable age threshold.

● Sensitive Information: Under laws such as CCPA, you have the right to limit the use

and disclosure of sensitive personal information for purposes other than those

permitted by law (e.g., providing services).

● Right to Non-Discrimination: You have the right not to receive discriminatory

treatment for exercising your CCPA rights. We will not treat you differently for

exercising any of the above rights.

Under the California Online Privacy Protection Act (CalOPPA), our service does not currently

respond to Do Not Track (DNT) signals. However, we recognize and honor Global Privacy

Control (GPC) signals, allowing you to indicate your preference to opt out of the sale or

sharing of Personal Data. Please note that third-party operators integrated with our service

may collect information about your browsing activities. To manage your tracking preferences,

you can enable a GPC signal or adjust the settings on your web browser or mobile device to

notify websites and apps of your preferences. For detailed instructions on configuring these

settings, refer to the help documentation provided by your browser or device.

Exercising Your Rights:

To exercise any of the CCPA rights above, don’t hesitate to contact us via email at

dataprivacy@jeen.ai . We will fulfill your request within 45 days of receiving your request (If

we require an extension, we will notify you within the initial 45 days, explaining the reasons

and providing an estimated completion date). Some of these rights may be subject to

15limitations and qualifications, such as where fulfilling the request would conflict with federal,

state, or local law, regulatory inquiries, subpoenas, or our ability to defend against legal

claims. We will verify your request using your email address and the information associated

with your account if you have one.

Note that we cannot respond to your request if we cannot verify your identity and confirm

the Personal Data related to you. Making a verifiable consumer request does not require you

to create an account with us. If you wish to use an authorized agent to submit a request to

opt-out on your behalf, you must provide the authorized agent with written permission

signed by you. We may deny a request from an authorized agent if the agent cannot provide

us with your signed authorization demonstrating that they have been authorized to act on

your behalf.

If you do not wish for our online third-party partners or us (such as advertising networks) to

sell or share your Personal Information with others, please click on the “Do Not Sell or Share

My Personal Information” link to contact us with questions or to exercise your right to opt-

out.

US State-Specific Residents

If you are a resident of any state with privacy laws, including but not limited to Virginia,

Colorado, Connecticut, Utah, Oregon, Texas, Florida, Montana, Iowa, Indiana, Tennessee, or

Delaware, you are entitled to specific privacy rights regarding your personal information

under your state’s respective data privacy laws. These laws grant you rights to access,

correct, delete, and obtain your personal data, subject to certain exceptions. Please review

the following information to understand your privacy rights and how to exercise them.

Scope of Applicability:

The respective privacy laws apply to natural persons acting in an individual or household

context. These laws generally do not extend to individuals acting in a commercial or

employment context unless explicitly noted otherwise. If you are a resident of one of these

states, you can make requests regarding your Personal Information, and we will honor such

requests as required by the law in your state. In cases where we are unable to comply with

your request, in whole or in part, we will provide you with an explanation of our reasons.

Consumer Rights Across Applicable States

You may exercise the following rights concerning your Personal Information:

● Right to Access Your Personal Information: You have the right to request access to

the Personal Information we have collected about you, including details about the

purposes for which it was collected, the types of Personal Information, and the third

parties with whom we share it.

● Right to Correct Your Personal Information: You may request that we correct any

inaccuracies in the Personal Information we hold about you.

● Right to Delete Your Personal Information: You can request the deletion of your

Personal Information, subject to certain legal exceptions, such as when retaining the

16information necessary for compliance with legal obligations or in connection with

ongoing business operations.

● Right to Obtain a Copy of Your Personal Information (Data Portability): You may

request a copy of your Personal Information in a portable and readily usable format,

subject to technical feasibility.

● Right to Opt-Out of Targeted Advertising: You have the right to opt out of the

processing of your Personal Information for targeted advertising purposes.

● Right to Opt-Out of the Sale of Personal Information: You may request that we do

not sell your Personal Information to third parties. While Jeen does not sell Personal

Information for monetary gain, we respect your right to opt out of any activities

classified as “sale” under Applicable Privacy Laws.

● Right to Opt-Out of Profiling: In states like Colorado and Connecticut, you have the

right to Opt-Out of profiling that produces legal or similarly significant effects.

How to Exercise Your Rights

To exercise any of your privacy rights as a resident of Virginia, Colorado, Connecticut, Utah,

Oregon, Texas, Florida, Montana, Iowa, Indiana, Tennessee, or Delaware, please contact us

at. We will fulfill your request within the timeline prescribed by the Applicable Privacy Laws.

Please note the following:

● Authentication: To ensure the protection of your data, we may require verification of

your identity before fulfilling your request. If you submit a request through an

authorized agent, we may require proof of authorization, such as a signed written

permission or power of attorney.

● Response Timeline: Most states require responses within 45 days, with a possible

extension of another 45 days. However, specific timelines may vary, and we will

inform you if additional time is needed.

A Notice for Individuals Residing in Israel:

This privacy notice applies to individuals residing in Israel and outlines how Jeen processes

personal data in compliance with the Israeli Privacy Laws (as detailed under Applicable

Privacy Laws).

Your Rights Regarding Personal Data

● Right to Access: You have the right to inquire whether we hold any personal data

about you and to review such data, subject to the terms and conditions outlined in

Israeli law.

● Right to Rectification: If you find that any personal data we hold is incorrect,

incomplete, or outdated, you have the right to request corrections.

Exercising Your Rights

17To exercise these rights, please contact us at :dataprivacy@jeen.ai . We will respond to your

request as required under Israeli law. To ensure security and privacy, we may require

verification of your identity.

Data Sharing and Transfers

Jeen may share personal data with trusted third parties to provide services or comply with

legal requirements. If personal data is transferred outside Israel, we ensure that adequate

safeguards are in place to protect your data, in accordance with applicable laws.

Compliance and Protection

Jeen is committed to processing and protecting personal data responsibly and in accordance

with legal obligations. Robust security measures are implemented to safeguard your data

against unauthorized access, misuse, or disclosure

Non-Discrimination Policy

We will not discriminate against you for exercising your privacy rights under Applicable

Privacy Laws. For example, we will not deny you services, charge you a different price, or

provide a different quality of services for exercising your rights.

If you have any concerns relating to this Policy, please contact us and we will make good-faith

efforts to address your concerns. We are usually able to resolve privacy questions or

concerns promptly and effectively. If you are not satisfied with the response you receive from

us, you may escalate concerns to the applicable privacy regulator in your jurisdiction. Upon

request, we will provide you with the contact information for that regulator.

Links To Other Websites

Our Service may contain links to other websites that are not operated by Us. If you click on a

third-party link, you will be directed to that third-party’s site. We strongly advise you to

review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies, or

practices of any third-party sites or services.

Contact Us

For further information about this Policy or if you have any concerns relating to the handling

of your personal data, please contact us at: dataprivacy@jeen.ai

We commit to making good-faith efforts to address your inquiries. If you are not satisfied

with the response you receive, you have the option to escalate your concerns to the

applicable privacy regulator in your jurisdiction. Upon request, we will provide you with

contact information for that regulator.

©2025 Jeen AI Ltd. All rights reserved.

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