PRIVACY POLICY

Elpida Platform Inc.

 

Last updated: [September 2025]

 

• INTRODUCTION

• This privacy policy (“Privacy Policy”) describes how we, Elpida Platform, Inc. and our affiliates (“We”, “Our” or “Us”) process, use, collect and store Personal Information (defined below) that We receive from or about you (“You”) in connection with your use of Our Site and Our service offerings (collectively referred to herein as the “Services“). This Privacy Policy applies to all Our features and functionality offered to you, as well with respect to any electronic communications exchanged with You with respect to the Services or otherwise provided by You to us. Please read this Privacy Policy carefully, so You can fully understand Our practices in relation to your Personal Information. Important note: Nothing in this Privacy Policy is intended to limit in any way your statutory rights, including your rights to a remedy or means of enforcement.

 

1. In situations where We are providing Services to Our customers where the entity customer has entered into an agreement for use of the services with Us, We are the processor/service provider (a provider that processes personal data on behalf of or at the direction of a controller, or other similar designation under the law) and the entity customer is the controller/business (the entity that decides how and why information is processed) of the information provided to Us via use of the Services. In such situations, Our processing of your Personal Information may also be subject to an applicable data processing agreement with Our customer. In the event of a conflict between the data processing agreement and this Privacy Policy, the data processing agreement governs.

 

1. “Personal Information” and/or “Personal Data” mean any information that can be used, alone or together with other data, to uniquely identify any living human being and any information deemed as Personally Identifiable Information by applicable privacy laws.

 

1. Please note that this is a master privacy policy and some of its provisions only apply to individuals in certain jurisdictions. For example, some jurisdictions require that We provide You with the “legal basis” for processing your Personal Information, and We have included this information below.

 

1. We may update this Privacy Policy from time to time and therefore We ask You to check back periodically for the latest version. If We implement any significant changes to the use of your Personal Information in a manner different from that stated at the time of collection, We will notify You by posting a notice on Our Site or by other means in accordance with applicable legal requirements.
   
2. This Privacy Policy forms an integral part with Our Site Terms of Use (“Terms of Use”) (please see at [https://getelpida.com/terms-of-use/). Any capitalized but undefined term in this Privacy Policy shall have the meaning given to it in the Terms of Use.

 

• WHAT PERSONAL INFORMATION WE COLLECT AND HOW WE USE IT

 

Sources	Category of Personal Information	Personal Information Collected	Purposes (How We Process Your Personal Information)	Legal Basis
Browsing or visiting Our Site	Identifiers, Internet or other electronic network activity information; Other Information (Geolocation information)	IP address, pages clicked, search and browser history, device information	To analyze trends and behavior, maintain and improve the Site and Services, and for marketing and promotional efforts	Consent (non-essential cookies), Legitimate interest (essential cookies, marketing)
Requesting a demo or trial	Identifiers; Professional or Employment-Related Information	Full name, business email, job title, company, business address, telephone number,  number of employees in company, Company field of activity,  country, and any other provided information	To provide a demo, send marketing communications	Legitimate interest (for marketing), Consent
Subscribing to Our blog/newsletter	Identifiers	Full name, business email address	To send communications for which You have subscribed and other marketing communications	Consent
Contacting us	Identifiers; Professional or Employment-Related Information	Full name, business email, company, job title, work telephone number, country, message (to the extent it includes personal data), any other provided information	To answer questions, send marketing communications	Consent
Providing personal data for marketing reasons	Personal Information; Professional or Employment-Related Information	Full name, business email, job title, company, address, telephone number, country, any other provided information	To establish a business relationship, contact about services, send marketing communications	Legitimate interest, Consent (for marketing)
Acquiring personal data from third-party sources for marketing	Personal Information; Professional or Employment-Related Information	Full name, business email, job title, company, address, telephone number, country	To contact regarding services, send marketing communications	Legitimate interest, Consent (for marketing)
Social media marketing	Identifiers; Professional or employment-related information Internet or other electronic network activity information; Other Information (Geolocation information)	Full name, business email, job title, company, telephone number, IP address, pages clicked, search and browser history, device information, any other provided information	To contact via social media, establish business relationship, contact about services, create marketing lists for social media	Legitimate interest, Consent (if required)

 

 

1. ‍Tracking technologies – When You visit or access Our Site, We use (and authorize third parties to use) pixels, cookies, events and other technologies. Those allow Us to automatically collect information about you, your device, and your online behavior in order to enhance your navigation in Our Site, improve Our Site’s performance, perform analytics and customize your experience. In addition, We may merge information We have with information collected through these tracking technologies and information We may obtain from other sources and, as a result, such information may become personal information.

 

1. Cookie Policy – Cookies are small text files that are stored on your computer. They are designed to hold a small amount of data specific to a website or server that can be accessed either by the website or your computer. We use cookies to capture information described in this Section 2, such as IP address and electronic activity data. We use this information to remember your site preferences. Additionally, We aggregate this data to analyze site traffic and the effectiveness of Our marketing efforts. You can delete advertising cookies in your browser by using this form: https://optout.aboutads.info/.

 

1. Finally, please note that some of the abovementioned Personal Information may be used for detecting, taking steps to prevent, and prosecution of fraud or other illegal activity, to identify and repair errors, to conduct audits, and for security purposes. Personal Information may also be used to comply with applicable laws, with investigations performed by the relevant authorities, law enforcement purposes, and/or to exercise or defend legal claims.

 

1. In certain cases, We may or will anonymize or de-identify your Personal Information and further use it for internal and external purposes, including, without limitation, to improve Our services and for research and development purposes. “Anonymous Information” means information which does not enable identification of an individual user, such as aggregated information about the use of Our services. We may use Anonymous Information and/or disclose it to third parties without restrictions (for example, in order to improve Our services and enhance your experience with them).

• HOW DO WE SHARE YOUR PERSONAL INFORMATION

 

Depending on the context described above, We may share your Personal Data to the following categories of third parties:

 

• Hosting/ storage providers;
• Email system providers;
• Marketing partners;
• CRM systems; 
• Sales automation tools; 
• Analytics and business intelligence services;
• Document management / automation tools;
• Other service providers to the extent required to fulfil the purposes listed above; and
• We may also share your Personal Data as follows:

 

1. to the extent necessary in Our good faith determination, with regulators, courts or competent authorities, to comply with applicable laws, regulations and rules (including, without limitation, federal, state or local laws), and requests of law enforcement, regulatory and other governmental agencies or if required to do so by court order;
2. with Our business partners with whom We jointly offer products or services;
3. with Our affiliated companies to the extent necessary to fulfil the purposes listed above;
4. if, in the future, We sell or transfer some or all of Our business, shares, or assets to a third party, We may disclose information to a potential or actual third party purchaser of Our business, shares or assets. In the event that We are acquired by or merged with a third party entity, or in the event of bankruptcy or a comparable event, We reserve the right to transfer or assign Personal Information in connection with the foregoing events;
5. with service providers and third parties for Our operational purposes and to guarantee Our Services’ improvement, such as analytics partners; 
6. with social media platforms for the purposes mentioned above; and
7. where You have provided your consent to Us disclosing or transferring the Personal Information.

 

• HOW DO WE PROTECT AND STORE YOUR INFORMATION

 

1. Security. We have implemented appropriate technical, organizational and security measures designed to protect your Personal Information and reduce the risks of damage, loss of information and unauthorized access or use of information. However, please note that We cannot guarantee, and You cannot expect, that the information will not be compromised including as a result of unauthorized penetration to Our servers. As the security of information depends in part on the security of the computer, device or network You use to communicate with Us and the security You use to protect your user IDs and passwords, please make sure to take appropriate measures to protect this information.

 

1. Retention of your Personal Information. We may store your Personal Information for as long as necessary to fulfil the purpose for which We collected it, and as long as necessary to fulfill your requests or inquiries or provide and improve Our services or until We proactively delete it or You send a valid deletion request. In addition, in some circumstances We may store your Personal Information for longer periods of time, for example (i) where We are required to do so in accordance with legal, regulatory, tax or accounting requirements, or (ii) for Us to have an accurate record of your dealings with Us in the event of any complaints or challenges, or (iii) if We reasonably believe there is a prospect of litigation relating to your Personal Information or dealings. We have an internal data retention policy to ensure that We do not retain your Personal Data perpetually (e.g., for demo requests, We retain Personal Information for up to 2 years). Regarding retention of cookies, You can read more in Our Cookies Policy as set forth under Section 2 above.

 

• ADDITIONAL INFORMATION REGARDING TRANSFERS OF GDPR PROTECTED PERSONAL DATA

 

1. Internal transfers: Transfers within Our group will be covered by an internal data processing agreement between entities of Our group which contractually obliges each member to ensure that Personal Data receives an adequate and consistent level of protection wherever it is transferred to.

 

1. Cross-border transfers: When We engage in transfers of GDPR and UK GDPR protected Personal Data outside of the EEA or UK (for example to third party service providers for the purposes listed above), We generally rely on either: (i) Adequacy Decisions adopted by the European Commission under Article 45 of the GDPR (for example, when Our team accesses Personal Data from Israel); (ii) the Standard Contractual Clauses issued by the European Commission or the United Kingdom (as updated from time to time); or (iii) another lawful transfer mechanism provided for under the GDPR e.g. Binding Corporate Rules. We also monitors the circumstances surrounding such transfers to ensure that Personal Data continues to be afforded a level of protection that is essentially equivalent to the one guaranteed by the GDPR and UK GDPR.

 

• YOUR PRIVACY RIGHTS

 

1. Rights: The following rights (which may be subject to certain exemptions or derogations) may apply to certain individuals depending on their jurisdiction of residence. The rights that may be applicable to You are as follows:

 

• Right of access – You may have the right to request a copy of the Personal Information We have about You and to request supporting information explaining how the personal information is used;
• Right of rectification – You may have the right to request that We rectify inaccurate Personal Information about You;
• Right of erasure – You may have the right to request that We erase Personal Information about You;
• Right to restrict processing – in some situations, You may have the right to request that We do not use the Personal Information You have provided (for example, if You believe it to be inaccurate);
• Right to data portability – You may have the right to receive your Personal Information in a structured, commonly used and machine-readable format and to transmit such information to another controller;
• Right to withdraw consent – where We process your personal information based on consent (including direct marketing consents), You have the right to withdraw consent at any time. However, this will not affect the lawfulness of the processing based on consent before its withdrawal. Furthermore, even in case of a withdrawal We may continue to use your personal information as permitted or required by law; and
• Right to object – where We are processing your Personal Information based on a legitimate interest (or those of a third party) You may challenge this. However, We may be entitled to continue processing your personal information based on Our legitimate interests or where this is relevant to legal claims. You also have the right to object where We are processing your personal information for direct marketing purposes.

 

1. To the extent privacy laws applicable to You afford You with the rights referenced above, We will respect your rights and comply with such laws. You can exercise your rights by contacting Us at Info@getelpida.com. Subject to legal and other permissible considerations, We will make every reasonable effort to honor your request promptly in accordance with applicable law or inform You if We require further information in order to fulfil your request.

 

1. To help protect the security of your Personal Data, We will verify your identity in connection with any requests. We also take steps to ensure that only You or your authorized representative can exercise rights with respect to your information. If You are an authorized agent making a request, We may require and request additional information to protect the Personal Data entrusted to Us, including information to verify that You are authorized to make that request. There may be situations where We cannot grant your request, for example, in the event that your request would adversely affect the rights and freedoms of others (for example, would impact the duty of confidentiality We owe to others) or if We are legally entitled to deal with your request in a different way than initially requested, We will address your request to the maximum extent possible, all in accordance with applicable law.

 

1. We will not discriminate against You (e.g., by restricting or denying You access to Our Services) because of choices and requests You make in connection with your Personal Data. Please note, certain choices may affect Our ability to deliver Our Services. For example, if You sign up to receive marketing communications by email, then ask Us to delete all of your information, We will be unable to send You marketing communications. You may exercise any of your rights in relation to your Personal Information by contacting Us using the details provided under the “CONTACT US” section below.

 

• USE BY MINORS

 

We do not offer Our products or Services for use by minors and, therefore, We do not knowingly collect personal information from, and/or about minors under the majority age of eighteen (18). If You are under 18, You may not provide any information to the Site without involvement of a parent or a guardian. In the event that We become aware that You provide Personal Information in violation of applicable privacy laws, We reserve the right to delete it. If You believe that We might have any such information, or if a parent or guardian becomes aware that his or her child has provided Us with personal information, please contact Us at  Info@getelpida.com.

 

• LINKS AND INTERACTION WITH THIRD PARTY PRODUCTS

 

Our Site or Services may enable You to interact with or contain links to your third party accounts and other third party websites mobile software applications and products or services that are not owned or controlled by Us (each a “Third Party Service”). We are not responsible for the privacy practices or the content of such Third Party Services. Please be aware that Third Party Services may collect Personal Information from You. Accordingly, We encourage You to read the terms and conditions and privacy policies of each Third Party Service that You choose to use or interact with.

 

• PRIVACY INFORMATION FOR CALIFORNIA RESIDENTS

 

1. If You are a California resident, the California Consumer Privacy Act (“CCPA”) requires Us to provide You with the following additional information about: (1) the purpose for which We use each category of “personal information” (as defined in the CCPA) We collect; and (2) the categories of third parties to which We (a) disclose such personal information for a business purpose, (b) “share” personal information for “cross-context behavioral advertising,” and/or (c) “sell” such personal information. Under the CCPA, “sharing” is defined as the targeting of advertising to a consumer based on that consumer’s personal information obtained from the consumer’s activity across websites, and “selling” is defined as the disclosure of personal information to third parties in exchange for monetary or other valuable consideration. Please see the “What Personal Information We collect and how We use it” and the “How do We share your Personal Information” sections above in Our Privacy Policy for detailed information about Our data collection and use practices, as well as for more information about Our advertising practices. The following chart details the categories of Personal Information that We sell/share with third parties:

 

Category of Personal Information	Categories of Third Parties to Which We Sell/Share this Category of Personal Information
Identifiers (device information) and Internet or other electronic network activity information (Service usage information)	Ad networks and advertising analytics partners
Personal Information (Email address)	Ad networks and advertising analytics partners

 

1. Your Choices Regarding “Sharing” and “Selling”: You have the right to opt out of Our sale/sharing of your Personal Information for purposes of online advertising by sending a request via email to  Info@getelpida.com. To opt out of the offline disclosure of your Personal Information to third parties for these purposes, please send Us a request via email to  Info@getelpida.com. Please note that there may be circumstances in which We are entitled by law to continue to sell or share your data. Also note that your withdrawal of consent shall not affect Our right to request your consent to such sell or share again after twelve (12) months.

 

1. Other CCPA Rights. If We ever offer any financial incentives in exchange for your Personal Information, We will provide You with appropriate information about such incentives. The CCPA also allows You to limit the use or disclosure of your “sensitive personal information” (as defined in the CCPA) if your sensitive personal information is used for certain purposes. Please note that We do not use or disclose sensitive personal information other than for business purposes for which You cannot opt out under the CCPA. Please see Section 6 of the Privacy Policy, “Your Privacy Rights,” for information about the additional rights You have with respect to your personal information under California law and how to exercise them.

 

1. California “Shine the Light” disclosure. The California “Shine the Light” law gives residents of California the right under certain circumstances to opt out of the disclosure of certain categories of personal information (as defined in the Shine the Light law) with third parties for their direct marketing purposes, or in the alternative, that We provide a cost-free means for consumers to opt out of any such disclosure. For more information about Our compliance under the Shine the Light law please contact Us via Info@getelpida.com.

 

• CHANGES TO THIS PRIVACY POLICY

This Privacy Policy may be amended at any time and from time to time, consistent with the requirements of applicable data protection laws. It is Our policy to publish any changes amendments to Our Privacy Policy at Our Site. Changes to this Privacy Policy shall become binding and effective when they are published at Our Site.

 

• CONTACT US

 

If You have any questions regarding this Privacy Policy, or if You wish to exercise your rights, We encourage You to contact Us at Info@getelpida.com.