We at Auroca Association, incorporated as a Verin underthe laws of Switzerland ("Auroca", "us", "we", or"our"), recognize and respect the importance of maintaining theprivacy of visitors of our website. This Privacy Notice describes the types ofinformation we collect from you when you visit our website ("Site")and/or use the features available thereon (together with the Site, the"Services"). This Privacy Notice also explains how we process,transfer, store and disclose the information collected, as well as your abilityto control certain uses of the collected information. If not otherwise definedherein, capitalized terms have the meaning given to them in the Terms of Service, available at https://auroca.webflow.io/terms-conditions ("Terms"). "You" means any visitor and/or user of the Siteand/or Services.

If you are an individual located in the EuropeanEconomic Area ("EEA" and "EEA Individual", respectively) orin Switzerland, some additional terms and rights may apply to you, as detailedherein. Our registered office is c/o Confidaris Ag Hertizentrum 15 6300 Zug Zug,Switzerland. You can contact us at contact@auroca.io .

"PersonalData" means any information that refers to, is related to, or isassociated with an identified or identifiable individual or as otherwise may bedefined by applicable law. This Privacy Notice details which Personal Data iscollected or processed by us in connection with provision of the Services.

2. Personal Data We Collect, Uses and Legal Basis.‍

Depending on your usage, we collect different types ofdata and we and any of our third-party subcontractors and service providers usethe data we collect for different purposes, as specified below. You have nolegal obligation to provide us with certain Personal Data, but if you refuse toprovide such Personal Data we may not be able to register you to the Siteand/or provide you with the Services or part thereof.

2.1. Contact Information - When you request information from us, orcontact us for any other reason, we will collect any data you provide, such asyour name, email address and the content of your inquiry. When you sign up fornewsletters or email lists, we collect your email address.

How we use this data: To respond to your request orinquiry and to provide you with newsletters and updates and for marketingpurposes.

Legal Basis: We process this Personal Data based onperformance of a contract when we respond to your inquiry and provide you withnewsletters and updates. Processing your Personal Data for remarketing purposesis based on our legitimate interests.

2.2. Job Applicant Data -If you apply for a job with us, whether through our Site and/or any third partyplatform ("Recruitment Platform"), we collect your Personal Data whenwe process your job application. This may include your name, contact details,resume, recommendations, any other information we may request or that youchoose to share with us, and any information posted on or provided by theRecruitment Platform, subject to such Recruitment Platform’s terms andconditions and privacy notice.

How we use this data: We use thisdata to process your job application, including to contact you for schedulingpurposes and to provide you with updates.

Legal Basis: We process this PersonalData based on our legitimate interests to attract and assess candidates foremployment.

2.3. Automatically Collected Data - When you visit the Site, weautomatically collect information about your computer or mobile device,including non-Personal Data such as your operating system, and Personal Datasuch as your IP address, device ID. For more information about the cookies andsimilar technologies we use and how to adjust your preferences, please see thesection "Cookies and Similar Technologies" below.

How we use this data: (1) to provide you with the Siteand Services; (2) to review usage and operations, including in an aggregatednon-specific analytical manner, develop new products or services and improvecurrent content, products, and Services; (3) to prevent fraud, protect thesecurity of our Site and Services, and address any problems with the Siteand/or Services.

Legal Basis: When we process Personal Data to provideyou with the Site and Services by means of necessary cookies and/orfunctionality session cookies (each as defined in Section 8 below), we do sobased on performance of a contract with you or based on our legitimateinterest. When we process this Personal Data for developing and improving ourproducts and Services, review usage, and perform analytics, we do so based onyour consent or based on our legitimate interest. When we process Personal Datato prevent fraud and/or to protect the security of our Site and Services, we doso based on our legitimate interest.

3. Additional Uses.

3.1. Statistical Information and Analytics. We and/or our serviceproviders use analytics tools, including "Google Analytics" tocollect and analyze information about the use of the Site and/or Services, suchas how often users visit the Site, what pages they visit when they do so, andwhat other sites and mobile applications they used prior to visiting the Site.By analyzing the information we receive, we may compile statistical informationacross a variety of platforms and users, which helps us improve our Site andServices, understand trends and customer needs and consider new products andservices, and tailor existing products and services to customer desires. Theinformation we collect is anonymous and aggregated and we will not link it toany Personal Data. We may share such anonymous information with our partners,without restriction, on commercial terms that we can determine in our solediscretion. You can find more information about how Google collects informationand how you can control such use athttps://policies.google.com/technologies/partner-sites.

3.2. Direct Marketing. As described above, we may use Personal Data tolet you know about our products and Services that we believe will be ofinterest to you. We may contact you by email. In all cases, we will respectyour preferences for how you would like us to manage marketing activity withrespect to you. To protect privacy rights and to ensure you have control overhow we manage marketing with you:

3.2.1. We will take steps to limit direct marketing to a reasonable andproportionate level and only send you communications which we believe may be ofinterest or relevance to you.

3.2.2. You can ask us to stop sending email marketing by following the"unsubscribe" link you will find on all the email marketing messageswe send you. Alternatively, you can contact us at contact@auroca.io .

3.2.3. You can change the way your browser manages cookies, which may beused to deliver online advertising, by following the settings on your browseras explained below. If our marketing activities are based upon your consent,you may withdraw this consent at any time.

4. Sharing the Personal Data We Collect.

We share your information, including Personal Data, asfollows:

4.1. Affiliates. We may share information, including your Personal Data,with our affiliated companies, where this is necessary to provide you with ourproducts and Services, and for the purpose of management of our business. Wemay collect, share and process your contact details as a processor on behalf ofour affiliated companies.

4.2. Service Providers, and Subcontractors. We disclose information,including Personal Data we collect from and/or about you, to our trustedservice providers and subcontractors, who have agreed to confidentialityrestrictions and who use such information solely on our behalf in order to: (1)help us provide you with the Site and/or Services; (2) aid in theirunderstanding of how users are using our Site and/or Services; (3) for thepurpose of direct marketing (see above for more details).

Such service providers and subcontractors provide uswith IT and system administration services, security, storage services, dataanalysis.

4.3. Business Transfers. Your Personal Data may be disclosed as part of,or during negotiations of, any merger, sale of company assets or acquisition(including in cases of liquidation). In such case, your Personal Data shallcontinue being subject to the provisions of this Privacy Notice.

4.4. Law EnforcementRelated Disclosure. We may share your Personal Data with third parties: (i) ifwe believe in good faith that disclosure is appropriate to protect our or athird party's rights, property or safety (including the enforcement of theTerms and this Privacy Notice); (ii) when required by law, regulation subpoena,court order or other law enforcement related issues, agencies and/orauthorities; or (iii) as is necessary to comply with any legal and/orregulatory obligation.

4.5. Legal Uses. We may use your Personal Data as required or permittedby any applicable law, for example, to comply with audit and other legalrequirements.

5. International Transfer

5.1. We use subcontractors and service providers and have affiliates whoare located in countries other than your own, such as Switzerland and the Stateof Israel and send them information we receive (including Personal Data). Weconduct such international transfers for the purposes described above. We willensure that these third parties will be subject to written agreements ensuringthe same level of privacy and data protection as set forth in this PrivacyNotice, including appropriate remedies in the event of the violation of yourdata protection rights in such third country.

5.2. Whenever we transfer your Personal Data to third parties basedoutside of the European Economic Area ("EEA") and when required underapplicable law, we ensure a similar degree of protection is afforded to it byensuring at least one of the following safeguards is implemented:

5.2.1. We will only transfer your Personal Data to countries that have beendeemed to provide an adequate level of protection for Personal Data by theEuropean Commission.

5.2.2. Where we use certain service providers not located in countries withan adequate level of protection as determined by the European Commission, wewill enter into contracts with our service providers that include the StandardContractual Clauses approved by the European Commission which give PersonalData the same protection it has in the EEA.

5.3. Please contact us at contact@auroca.io if you would like furtherinformation on the specific mechanism used by us when transferring yourPersonal Data out of the EEA.

6. Security.

We have implemented and we maintain appropriatetechnical and organization security measures, policies and procedures designedto reduce the risk of accidental destruction or loss, or the unauthorizeddisclosure or access to Personal Data appropriate to the nature of such data.The measures we take include:

6.1. Safeguards – The physical, electronic, and procedural safeguards weemploy to protect your Personal Data include secure servers and SSL encryptionof data.

6.2. Access Control – We dedicate efforts for a proper management ofsystem entries and limit access only to authorized personnel, who havecommitted themselves to confidentiality, on a need to know basis of leastprivilege rules, review permissions periodically, and revoke access immediatelyafter employee termination.

6.3. Internal Policies – We maintain and regularly review and update ourprivacy related and information security policies.

6.4. Encryption – Weencrypt the data in transit using secure SSL encryption protocols.

6.5 However, no method of transmission over the Internet or method ofelectronic storage is 100% secure. Therefore, while we strive to usecommercially acceptable means to protect your Personal Data, we cannotguarantee its absolute security.

6.6. As the security of information depends in part on the security ofthe computer you use to communicate with us and the security you use to protectuser IDs and passwords, please take appropriate measures to protect thisinformation.

7. Your Rights - How to Access and Limit Our Use of Certain PersonalData.

Subject to applicable law and certain exemptions, andin some cases dependent upon the processing activity we are undertaking, youhave certain rights in relation to the Personal Data that we hold about you, asdetailed below. You can exercise your rights by contacting us by email contact@auroca.io.We will investigate and attempt to resolve complaints and disputes and makeevery reasonable effort to honor your wish to exercise your rights as quicklyas possible and, in any event, within the timescales provided by applicabledata protection laws. We reserve the right to ask for reasonable evidence toverify your identity before we provide you with any information and/or complywith any of your requests, as detailed below:

7.1. Right of Access. You have a right to know what Personal Data wecollect about you and, in some cases, to have such Personal Data communicatedto you. Subject to applicable law, we may charge you with a fee. Please notethat we may not be able to provide you with all the information you request,and, in such case, we will endeavor to explain to you why.

7.2. Right to Data Portability. If the processing is based on yourconsent or performance of a contract with you and processing is being carriedout by automated means, you may be entitled to (request that we) provide you oranother party with a copy of the Personal Data you provided to us in astructured, commonly-used, and machine-readable format.

7.3. Right to Correct Personal Data. Subject to the limitations inapplicable law, you may request that we update, complete, correct or deleteinaccurate, incomplete, or outdated Personal Data.

7.4. Deletion of Personal Data ("Right to Be Forgotten"). Ifyou are an EEA or Swiss Individual or otherwise entitled under applicable law,you have a right to request that we delete your Personal Data if either: (i) itis no longer needed for the purpose for which it was collected, (ii) ourprocessing was based on your consent and you have withdrawn your consent, (iii)you have successfully exercised your Right to Object (see below), (iv)processing was unlawful, or (v) we are required to erase it for compliance witha legal obligation. We cannot restore information once it has been deleted. Wemay retain certain Personal Data (including following your request to delete)for audit and record-keeping purposes, or as otherwise permitted and/orrequired under applicable law.

7.5. Right to Restrict Processing. If you are an EEA or Swiss Individualor otherwise entitled under applicable law, you can ask us to limit theprocessing of your Personal Data if either: (i) you have contested its accuracyand wish us to limit processing until this is verified; (ii) the processing isunlawful, but you do not wish us to erase the Personal Data; (iii) it is nolonger needed for the purposes for which it was collected, but we still need itto establish, exercise, or defend of a legal claim; (iv) you have exercisedyour Right to Object (below) and we are in the process of verifying ourlegitimate grounds for processing. We may continue to use your Personal Dataafter a restriction request under certain circumstances.

7.6. Direct Marketing Opt-Out. You can change your mind at any time aboutyour election to receive marketing communications from us and/or having yourPersonal Data processed for direct marketing purposes. If you do, please notifyus by contacting us at contact@auroca.io. We will process your request as soonas reasonably possible, however it may take a few days for us to update ourrecords before any opt out is effective.

7.7. Right to Object. If you are an EEA or Swiss Individual or otherwiseentitled under applicable law, you can object to any processing of yourPersonal Data which has our legitimate interests as its legal basis, if youbelieve your fundamental rights and freedoms outweigh our legitimate interests.If you raise an objection, we have an opportunity to demonstrate that we havecompelling legitimate interests which override your rights and freedoms.

7.8. Withdrawal of Consent. When we process your personal data on thebasis of your consent, you may withdraw your consent at any time. This will notaffect the lawfulness of any processing prior to such withdrawal. In order towithdraw consent to cookies, you will need to make changes to your browsersettings; see section 9.4 below.

7.9. Right to Lodge a Complaint with Your Local Supervisory Authority. Ifyou are an EEA or Swiss Individual or otherwise entitled under applicable law,you may have the right to submit a complaint to the relevant supervisory dataprotection authority if you have any concerns about how we are processing yourPersonal Data, though we ask that as a courtesy you please attempt to resolveany issues with us first.

For a list of all national supervisory authorities ofthe EEA states, please refer to:https://edpb.europa.eu/about-edpb/about-edpb/members_en

For the Swiss supervisory authority, please refer to:https://www.edoeb.admin.ch/edoeb/en/home.html

8. Data Retention

8.1. Subject to applicable law, we retain Personal Data only as long asnecessary for the purposes set forth above. We may delete information from oursystems without notice to you once we deem it is no longer necessary for thesepurposes. We require that our processors delete Personal Data when they nolonger require it.

8.2. In some circumstances, we may store your Personal Data for longerperiods of time, for instance where we are required to do so in accordance withlegal, regulatory, tax, audit, accounting requirements and so that we have anaccurate record of your dealings with us in the event of any complaints orchallenges, or if we reasonably believe there is a prospect of litigationrelating to your Personal Data or dealings. To determine the appropriateretention period, we consider the amount, nature, and sensitivity of thePersonal Data, the potential risk of harm from unauthorized use or disclosureof your Personal Data, the purposes for which we process your Personal Data,and whether those purposes can be achieved through other means, as well asapplicable legal requirements.

8.3. Please contact us at contact@auroca.io if you would like detailsregarding the retention periods for different types of your Personal Data.

9. Cookies and Similar Technologies.

We use cookies and similar technologies for a number ofreasons, including to help personalize your experience. When visiting thisSite, you shall be notified of the use of and placement of cookies and othersimilar technologies on your device as specified herein.

9.1. What are Cookies? A cookie is a small piece of text that is sent toa user's browser or device. The browser provides this piece of text to thedevice of the originating user when this user returns.

9.1.1. A "session cookie" is temporary and will remain on yourdevice until you leave the Site.

9.1.2. A "persistent cookie” may be used to help save your settingsand customizations across visits. It will remain on your device until youdelete it.

9.1.3. First-party cookies are placed by us, while third-party cookies maybe placed by a third party. We use both first- and third-party cookies.

9.1.4. We may use the terms "cookies" to refer to alltechnologies that we may use to store data in your browser or device or thatcollect information or help us identify you in the manner described above, suchas web beacons or "pixel tags".

9.2. How We Use Cookies.

We use cookies and similar technologies for a number ofreasons, as specified below. We will not place any cookies on your browser thatare not strictly necessary unless you have first consented to the cookie pop up.

The specific names and types of the cookies, webbeacons, and other similar technologies we use may change from time to time.However, the cookies we use generally fall into one of the following categories:

Type of Cookie

Why We Use These Cookies

Necessary

These cookies are necessary in order to allow the Siteto work correctly. They enable you to access the Site, move around, and accessdifferent services, features, and tools. Examples include remembering previousactions (e.g. entered text) when navigating back to a page in the same session.These cookies cannot be disabled.

Functionality

These cookies remember your settings and preferencesand the choices you make (such as language or regional preferences) in order tohelp us personalize your experience and offer you enhanced functionality andcontent.

Security

These cookies can help us identify and prevent securityrisks. They may be used to store your session information to prevent othersfrom changing your password without your login information.

Performance

These cookies can help us collect information to helpus understand how you use our Site, for example whether you have viewedmessages or specific pages and how long you spent on each page. This helps usimprove the performance of our Site.

Analytics

These cookies collect information regarding youractivity on our Site to help us learn more about which features are popularwith our users and how our Site can be improved.

9.3. Third Party Cookies. We use cookies from Google Analytics andWebflow. Additionally, cookies may be placed in messages we send in order totrack your interaction with such emails.

9.4. How to Adjust Your Preferences. Most Web browsers are initiallyconfigured to accept cookies, but you can change this setting so your browsereither refuses all cookies or informs you when a cookie is being sent. Inaddition, you are free to delete any existing cookies at any time. Please notethat some features of the Services may not function properly when cookies aredisabled or removed. For example, if you delete cookies that store your accountinformation or preferences, you will be required to input these each time youvisit, and if you block cookies, certain legal notices may re-appear on eachpage of the Site that you visit.

10. Children.

We do not knowingly collect Personal Data from childrenunder the age of sixteen (16). In the event that you become aware that anindividual under the age of sixteen (16) has used our Services without parentalpermission, please advise us immediately.

11. Profiling and Automated Individual Decision-Making.

We may automatically evaluate personal aspects relatingto you («profiling») based on your Personal Data for the purposes set out insections 2 and 3, where we wish to determine preference data, but also in orderto detect misuse and security risks, to perform statistical analysis or foroperational planning. We may also create profiles for these purposes, i.e. wemay combine behavioral and preference data, but also master data, contract dataand technical data relating to you in order to better understand you as aperson with your various interests and other characteristics.

In both cases, we pay attention to the proportionalityand reliability of the results and take measures against misuse of these profilesor profiling. Where these can produce legal effects concerning you or similarlysignificantly affect you, we generally ensure human review.

In certain situations, it may be necessary for theefficiency and consistency of decision-making processes that we automatediscretionary decisions that produce legal effects concerning you or similarlysignificantly affect you («automated individual decisions»). In these cases, wewill inform you accordingly and take the measures required by applicable law.

12. Changes to the Privacy Notice.

We may update this Privacy Notice from time to time tokeep it up to date with legal requirements and the way we operate our business,and we will place any updates on this webpage. Please come back to this pageevery now and then to make sure you are familiar with the latest version. If wemake material changes to this Privacy Notice, we will seek to inform you bynotice on our Site or via email.

13. Comments and Questions.

If you have any comments or questions about thisPrivacy Notice or if you wish to exercise any of your legal rights as set outherein, please contact us at contact@auroca.io.