Privacy Notice

Last Revised: 21/08/2026

Introduction

This Privacy Notice details how ActiveLens LTD ("us", "we" or "Company") process information of users of our website (each, "you" or "User") collected through our website at www.activelens.ai, or through any other online services or platforms operated by us (collectively, the "Services").

Company Details

ActiveLens LTD is the data controller responsible for the Personal Information described in this notice.

11 Bublik Street, Jerusalem, Israel, POB 9722193

ActiveLens LTD is a subsidiary of ActiveLens Inc., New Burton Road, Suite 201, City of Dover, County of Kent, Delaware, US 19904.

Email: contact@activelens.ai

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

What Information We Collect

We may collect personal information about you as follows ("Personal Information"):

• Voluntary Information: We may collect information that you provide us voluntarily such as your full name, email address, phone number, company and job title. For instance, when you sign up to receive updates or further information from us, or when you communicate with us via the 'contact us' option on the Services, or when you submit an application for a position on our "Careers" page.
• Device Information: We may collect specific types of connection details and information with regard to your device, software or hardware that may identify you. Such information may include your IP address, browser type, and OS version.
• User Activity: Information regarding User's activity on the Services such as your clicks, pages viewed, actions and browsing on the Services.

Legal Basis

The Company processes Personal Information based on the following legal basis: consent, performance of a contract or processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, being those purposes specified below.

How We Use the Information

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

• To provide our customers with the Services;
• To authenticate your login to the Services;
• To investigate and resolve disputes in connection with your use of the Services;
• To respond to inquiries and requests from our Users, to improve our Services and to provide you with further information about our products and services;
• To detect and prevent fraudulent and illegal activity or any other type of activity that may jeopardize or negatively affect the integrity of the Services; and
• To investigate violations and enforce our policies, and as required by law, regulation or other governmental authority, or to comply with a subpoena or similar legal process or respond to a government request.

Cookies and Related Technologies

Cookies are small data files that are placed on users' devices to monitor how users interact with websites and other online services. Cookies can be used to identify your IP address, browser type, domain name, and specific web pages through which you click.

We and our service providers may use cookies because they:

• help us optimize, personalize and/or otherwise improve your experience and/or the performance of the Services and our service and marketing-related communications with you; and
• enable advertising delivered to you to be more relevant.

Most web browsers allow you to erase cookies on your computer, block cookies from your computer, or notify you when a cookie is stored on your computer. If you choose to disable or otherwise block certain cookies, you may be unable to use, or experience decreased functionality with, parts of the Services.

We use Google Analytics to collect information about your use of the Services. This third party service collects and shares information about your use of the Services in accordance with the following terms: https://policies.google.com/technologies/partner-sites. You can opt-out of this tracking technology here: https://support.google.com/analytics/answer/181881.

We also use Facebook/Instagram/LinkedIn pixel tags when Users access the Services. You may opt out of the pixel tags and other advertising tracking technologies by following the instructions at: www.networkadvertising.org/choices or www.aboutads.info/choices.

With Whom We Share Information and for What Purpose

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

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

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

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

Google User Data

Where you choose to connect a Google account, ActiveLens requests only the permissions needed for the features you enable:

• Calendar events (read and write) — to read your upcoming meetings, and to create the meeting drafts that follow a call.
• Calendar free/busy (read only) — to find an available slot when proposing a time.
• Calendar list (read only) — so you can choose which calendar to use.
• Contacts and other contacts (read only) — to suggest attendees when you create a meeting.

You can disconnect a Google account at any time from within ActiveLens, or revoke access directly from your Google Account permissions page. Revoking access ends any further use, and we delete the associated tokens.

Limited Use of Google User Data

ActiveLens’s use and transfer of raw or derived information received from Google APIs adheres to the Google API Services User Data Policy, including the Limited Use requirements. Specifically:

• We use Google user data only to provide and improve the features you have enabled.
• We do not use Google user data to develop, improve or train generalized artificial intelligence or machine learning models.
• Our AI features operate on the call recording and transcript. Where a matched calendar event supplies the participant list for a call, those participant names and email addresses are included as context so that the summary attributes statements to the right people. No other Google Calendar or Google Contacts data is placed in a model prompt.
• Where a call produces a draft meeting invitation, that draft is generated from the call transcript and is written to your Google Calendar only after you review and confirm it.
• We do not transfer Google user data to others except as necessary to provide these features, to comply with applicable law, or in connection with a merger or acquisition. We do not sell Google user data and we do not use it for advertising.
• We do not allow humans to read Google user data unless we have your explicit consent, it is necessary for security purposes such as investigating abuse, it is required to comply with applicable law, or the data has been aggregated and anonymized.

How We Protect Information

We apply the following safeguards to Personal Information, including sensitive information such as call recordings, transcripts and data received from connected accounts:

• Encryption in transit. All traffic between your device, our services and every third-party API we call is encrypted using TLS.
• Encryption at rest. Databases, search indexes and file storage are encrypted at rest. Credentials and access tokens for connected third-party accounts are additionally encrypted at the application layer before storage.
• Authentication. Access requires an authenticated session issued by our identity provider, with optional multi-factor authentication.
• Authorization and least privilege. Every request is checked server-side against role-based access controls and per-user data-visibility permissions. Users can reach only the data they are entitled to see.
• Tenant isolation. Every record is scoped to a single customer organization and enforced server-side, so one customer cannot access another’s data.
• Infrastructure. Our services run on Amazon Web Services in the European Union, using managed services with vendor-maintained security patching.
• Monitoring and audit logging. Access to production systems and material actions on customer data are logged and retained for review.
• Deletion. A scheduled retention process removes expired data from our database, search index and file storage. Disconnecting a connected account deletes the associated access tokens.

ActiveLens Ltd has completed a SOC 2 Type 2 examination covering the security, availability, confidentiality and privacy trust services criteria. The same examination assessed the design and operating effectiveness of controls against certain applicable administrative, physical and technical safeguards of the HIPAA Security Rule (45 CFR Part 164, Subpart C). The report was issued by an independent auditor.

No method of transmission or storage is completely secure, so while we work to protect your information we cannot guarantee absolute security.

International Transfer

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

For How Long We Retain Information

We retain the information that we collect from our Users for as long as it is relevant based on the purpose it was collected for. Retention periods will be determined taking into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time.

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

Your Privacy Rights

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

• Right to verify your Personal Information (to access, delete, change or update any Personal Information relating to you);
• Right to see what Personal Information about you we have;
• Right to request that we erase Personal Information about you (subject to any other legal obligation that may require us to keep that information);
• Right to restrict us from processing Personal Information pertaining to you; and
• Right to export Personal Information in a portable format.

If you wish to exercise any of these rights, contact us at: privacy@activelens.ai. When handling your request, we will ask for additional information to confirm your identity. However, please note that if you choose not to allow us to process your Personal Information, we may be prevented from providing our Services.

Please note that these rights are not absolute and may be subject to our own legitimate interests and regulatory requirements.

If you wish to raise a complaint on how we have handled your Personal Information, please contact us directly at: privacy@activelens.ai