Privacy Policy

Privacy Policy

Last updated: September 2025

PROJECT MAP LTD. PRIVACY POLICY

1. Applicability.

1.1.   This privacy policy (“PP“) explains how ProjectMap‚Ñ¢ Ltd. (together with its affiliated companies, the
Company” or ‚ÄúProggio‚Äù) collects, stores, uses, and shares, etc. Personal Data of you and your employees who are using the Service
Offerings on your behalf (collectively, or as applicable, “Customer“) as a data controller in connection with the Service Offerings. This PP
does not apply to any personal data that Proggio collects, processes and manages on behalf of Customers, submitted
and/or uploaded to the Service Offerings (‚ÄúCustomer Data“). Proggio processes such Customer Data, in its position as a processor under the GDPR or as a
service provider under the CCPA on behalf and under the instruction of the Customer subject to Proggio’s Data Processing Agreement provided upon request
(“DPA”).

1.2.   For the purpose of this PP “Personal Data” shall mean personal data or personal information, as applicable
in the Applicable Data Protection Law (as defined below), or any other applicable data protection laws.

1.3.   The PP is an integral part of the Company’s Customer Agreement which is available at
https://app.proggio.com/terms (“TOU“, together with the PP and the DPA, the “Terms“).

1.4.   By attempting to use or access, or by using or accessing the Service Offerings, Customer agrees to be bound by the
Terms. If Customer does not agree with the Terms Customer must not use or access the Service Offerings.

1.5.   The Company may amend this PP from time to time. If Company makes any changes to this PP that materially
affect Company’s practices with regard to the personal data Company previously collected from Customer, Company will endeavor to provide Customer
with notice in advance of such change by highlighting the change on the Service Offerings. Company will seek Customer’s prior consent to any material changes,
if and where this is required by Applicable Data Protection Laws.

1.6.   For the purposes of (i) the General Data Protection Regulation (2016/679) (“GDPR“), including any subordinate or implementing legislation, and (ii) the California Consumer
Privacy Act of 2018, Cal. Civ. Code 1798.100 et seq. (“CCPA“), as applicable (collectively, the ‚”Applicable Data Protection Laws”).

1.7.   All capitalized terms used but not defined herein shall have the meaning ascribed to them in the Customer Agreement.

2. Collection of Personal Data.

2.1.   Information provided by Customer.

Company collects any data Customer provides Company with via the Service Offerings, including but not limited to:

2.1.1.     Customer’s contact details (e.g., name, email address, phone number);

2.1.2.     Customer’s payment information, only when payment is done through the app (e.g. credit card or bank account
information); alternate payment options available, please contact 
[email protected]

2.1.3.     Customer password and other authentication and security credential information;

2.1.4.     Any communication between Customer and the Company, e.g. emails, phone conversations, chat sessions.

2.1.5.   It shall hereby be clarified that Customer is not under any legal obligation to submit personal data to Company.
However, in case Customer chooses not to submit personal data to Company, Customer may not be able to become a Customer and/or use (all) the
Service Offerings.

2.1.6 The Company shall process personal data solely for the purpose lawfully established herein and/or in the DPA. Should the Company
seek to introduce additional purposes and/or to collect additional personal data, it shall obtain the Customer’s prior consent. However, if such consent is not
granted, the Company may be unable to provide certain or all Service Offerings to that Customer.

2.2.   Information collected automatically.

Company automatically collects data when Customer visits, interacts with, or uses the Service Offerings, including but not limited to:

2.2.1.   identifiers and information contained in cookies;

2.2.2.   Customer’s settings preferences, backup information; 

2.2.3.   Uniform Resource Locators (URL) clickstream to, through, and from the Service Offerings;

2.2.4.   content Customer viewed or searched for, page response times, and page interaction information (such as scrolling,
clicks, and mouse-overs);

2.2.5.   network and connection information, such as the Internet protocol (IP) address and information about Customer’s
Internet service provider; 

2.2.6.   computer and device information, such as browser type and version, operating system, or time zone setting; the
location of device.

2.3.   Information collected by Third parties.

2.3.1.   This PP does not apply to any content created, used, processed and/or stored by Customer when using the
Service Offerings. Also, the PP does not apply to any products, services, websites, links or any other content that are offered by third
parties. Customer is advised to check the applicable third party policies. Company has no control over such third parties’ privacy
practices, or the technology used by such third parties. Each Customer is advised to thoroughly review such third parties’ privacy policies before making
any use of such third party’s products and services.

2.3.2.   Without derogating from the generality of the above, when clicking on certain social media links provided on the Site
(e.g. Twitter) Customer will be transferred to Company’s site on such social media (“Social Media Site“). It shall hereby be
clarified that such Social Media Site is governed by the terms of use and privacy policy of the respective social media and not by the Company.

3. Cookies  

3.1.   To facilitate and customize the Customer’s experience of the Service Offerings and to track Customer’s use of
the Service Offerings Company may utilize cookies and other industry standard technologies. A cookie is a small text file that is stored on a Customer‚ computer
for record-keeping purposes which contains information about that Customer. Most browsers automatically accept cookies, but Customer may be able to modify
its browser settings to decline cookies. Please note that if Customer declines or deletes these cookies, some parts of the Service Offerings may not work properly.

3.2.   By clicking on a link to a third-party website or service, a third party may transmit cookies to Customer. This PP does not cover the use of cookies by any third parties, and the Company is not responsible for such third parties’ privacy policies and practices.

4. The Company’s Use of Collected Information.

4.1.   The Company processes Customer’s personal data to operate, provide, and improve the Service Offerings, including
but not limited to:

4.1.1.     creating and managing Customer profiles;

4.1.2.     contacting Customer by the Company and communicating with Customer with respect to the Service Offerings, e.g. by phone call, sms, email, chat; responding to inquiries from Customer;

4.1.3.     informing Customer about updates
or offers;

4.1.4.     personalizing the Service Offerings, i.e. identifying Customer’s interests and recommending offers that might be of interest to Customer;

4.1.5.     marketing and promoting Company’s Service Offerings;

4.1.6.     providing assistance and support;

4.1.7.     fulfilling Customer requests; meeting contractual or legal obligations;

4.1.8.   protecting Customers security, e.g. preventing and detecting fraud;

4.1.9.   internal purposes, e.g. trouble shooting, data analysis, testing and statistical purposes.

4.2.   The Company does not use any personal data other than as necessary to provide the Service Offerings.

4.3.   The Company may ask for Customer’s consent to use Customer’s Personal Data for a specific purpose which will be provided to Customer.

4.4.   In case Customer’s Personal Data contains third party personal data, Customer represents and warrants that it has obtained any consent required under the PP to the Company’s privacy
practices set forth in the PP from such third party.

5. Sharing Customer’s Information

5.1.   In the following cases Company discloses, without notification, personal data, any communications sent or received by each Customer, and any other information that Company
has collected and/or was provided with:

5.1.1.   Service Providers: The Company engages selected third-party companies and individuals as ‚ÄúService Providers‚Äù, to
perform services on the Company‚Äôs behalf or complementary to its own. These may include amongst others providers of: hosting and server location
services, data and cyber security services, text analyzing services, billing and payment processing services, fraud detection, analytics, data optimization
and marketing services, social and advertising networks, content, lead generating and data enrichment providers, email, and support and customer relation
management systems. The Company’s Service Providers may have access to personal data, depending on each of their specific roles and purposes in the provision
of the Service Offerings or other activities, and may only use the data as determined in the Company’s agreements with them.

5.1.2.   Third-Party Integrations: The Customer may choose to integrate its account on the Service Offerings with certain third
party services offered via the Service Offerings (“Third Party Services“). The Company may disclose to the Third Party Services personal data and relevant connectivity, technical and usage data of the
third party integration added to Customer‚account. The provider of such integrated Third Party Services may disclose certain relevant data from the account on the third-party provider‚Äôs services. The
Company does not receive or store Customer‚ passwords for any of the Third Party Services (but does generally require an API key in order to integrate with them).

5.1.2.   Legal Compliance: The Company may disclose personal data in exectional cases, if required to do so by law according to its understanding of such law (including, but not limited to, in cases of court orders or subpoenas); to verify the information obtained by Company; to prevent or investigate suspected fraud, or any activity that Company believes may be illegal or may expose Company to legal liability; in
case of potential threats to the physical safety of any person or property if Company believes that Customer’s information in any way relates to that threat;
if Company believes that Customer’s conduct on or in connection with the Service Offerings is inappropriate and inconsistent with generally accepted norms of behavior; in additio, Company may be
required to disclose Personal Data to relevant national, state and local law enforcement authorities, who may further disclose the Personal Data.

5.1.3.   Merger: In the event that Company, or any of its businesses, are sold or disposed of, whether by merger, sale of assets or otherwise, Personal Data collected hereunder may
be one of the assets sold or merged in connection with such transaction. Personal Data collected hereunder may also be disclosed in connection with a
commercial transaction where Company or any of its businesses are seeking financing, investment, and support or funding.

5.2.   The Company may share personal data in additional manners, pursuant to Customer‚ explicit approval, or if the Company is legally obligated to do so, or if the Company has successfully rendered such
data non-personal and anonymous.

5.3.   When Company shares Customer’s Personal Data with third parties as specified above, Company requires such recipients to agree to only use the Personal Data Company shares with them in
accordance with this PP and Company’s contractual specifications and for no other purpose than those determined by Company in line with this PP.

5.4.   It is clarified that Company is under no obligation to exercise its rights hereunder and shall not incur any liability with such exercise or lack of exercise of its rights.

6. Advertisement

6.1.   Company may also send Customer advertisements, as such term is defined in the Media Law (Bezeq and Broadcasting), 1982.

6.2.   Customer can opt out of receiving such advertisement emails and sms from the Company at any time by
unsubscribing using the unsubscribe link within each email or sms, or emailing Company to have Customer’s contact information removed from
Company’s email list or registration database.

7. Data Subjects Rights under Israeli Law.

7.1. Subject to the Israeli Privacy Protection Law, 1981 (“PPL“) and its implementing regulations, Customer have the following rights with respect to Customer Personal Data (as defined in the PPL)
processed by the Company, and Company will act in accordance with the PPL, to comply with your requests to exercise such rights:

Right to Review: the right to review Personal Data about Customer processed by the Company;

Right to Rectification: the right to request the Company to correct any inaccurate or incomplete Personal Data processed by the Company;

Right to Deletion: the right to request the deletion of Personal Data about Customer;

Right to restrict Company from processing Personal Data pertaining to Customer (for example, Customer may request that Company shall stop using or sharing its Personal
Data with third parties); and

Right to export Personal Data in a portable format, or to transfer it to a third party, subject to applicable legal requirements.

To exercise any of these rights, Customer may contact the Company as follows:

Name: Proggio Inc

Email: [email protected]

7. Security 

Company has taken appropriate technical and organizational measures to protect any Customer Personal Data from loss, misuse, unauthorized
access, disclosure, alteration, destruction, and any other form of unauthorized processing. Customer should be aware, however, that no data security measures
can guarantee 100% security.

8. Customers in the European Economic Area (EEA)

8.1.   Legal Basis for Processing of Personal Data

Company will only process Customer’s personal data if it has one or more of the following legal bases for doing so:

8.1.1.   Contractual Necessity: processing of personal data is necessary to enter into a contract with Customer, to perform
Company’s contractual obligations to Customer under the TOU, to provide the Service Offerings, to respond to requests from Customer, or to provide Customer
with customer support;

8.1.2.   Legitimate Interest: Company has a legitimate interest to process Customer’s personal data;

8.1.3.   Legal Obligation: processing of Customer’s personal data is necessary to comply with relevant law and legal
obligations, including to respond to lawful requests and orders; or

8.1.4.   Consent: processing of Customer’s personal data with Customer’s consent.

8.2.   Customer’s Rights regarding Personal
Data

8.2.1.   Subject to Applicable Data Protection Laws, Customer has certain rights with respect to Customer’s Personal Data,
including the following:

8.2.2.   Customer may ask whether Company holds personal data about Customer and request copies of such personal data and
information about how it is processed;

8.2.3.   Customer may request that inaccurate personal data is corrected;

8.2.4.   Customer may request the deletion of certain personal data;

8.2.5.   Customer may request Company to cease
or restrict the processing of personal data where the processing
is inappropriate;

8.2.6.    When Customer consents to processing Customer’s personal data for a specified purpose by Company,
Customer may withdraw Customer’s consent at any time, and Company will stop any
further processing of Customer’s data for that purpose.

8.2.7.   In certain circumstances, Company may not be able to fully comply with Customer’s request, such as if it is frivolous
or extremely impractical, if it jeopardizes the rights of others, or if it is
not required by law, however, in those circumstances, Company will still
respond to notify Customer of such a decision. 

8.2.8.   Customer can exercise Customer’s rights of access, rectification, erasure, restriction, objection, and data
portability by contacting Company at [email protected]. In some cases, Company
may need Customer to provide Company with additional information, which may
include personal data, if necessary to verify Customer’s identity and the
nature of Customer’s request.

8.3.   Transfer of Customer’s Personal Data outside of the EEA

8.3.1.   Company currently stores Customer data in Company’s data centers located in Western Europe and the US.

9. Customers in California, USA.

9.1.   Company will at all
times comply with all Applicable Data Protection Laws (including the CCPA) and only process Personal Data on Customer’s behalf.

9.2.   Company will (i) not collect, retain, use, or disclose Personal Data for any purpose other than for the specific
purposes set out in the Company terms of use and the Data Processing Agreement between Company and Customer; (ii) not sell Personal Data (as defined under the
CCPA); and (iii) put in place appropriate technical and organizational measures to protect Personal Data against unauthorized or unlawful processing or
accidental destruction, loss or damage.

10. International Storage. 

Each Customer is advised to be aware that Personal Data that the Company collects might be transferred to, processed and stored outside of Customer’s jurisdiction, and that data protection laws in
such jurisdiction where the information is collected stored and/or processed may differ from Customer’s jurisdiction. Each Customer hereby gives Customer’s consent to such transfer, processing and storage of Customer’s
Personal Data outside its jurisdiction.

11. Personal Data of Children

11.1.   The Company’s Service Offerings are not intended for children. Children under the age of 18, may use the Service Offerings only with the involvement of a parent or guardian.

12. Questions Regarding Customer’s Personal Data? 

12.1.   If Customer has any questions about this PP or Company’s data practices in general, Customer may contact Company using the following information: [email protected]

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