This privacy notice for ConvertifAI LTD (conducting business as Revenue Flare) (‘we’, ‘us’, or ‘our’), describes how and why we might collect, store, use, and/or share

(‘process’) your information when you use our services (‘Services’), such as when you

or any website of ours that links to this privacy notice

• Visit our website at https://app.revenueflare.com
• Engage with us in other related ways, including any sales, marketing, or events

Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please

do not use our Services. If you still have any questions or concerns, please contact us at support@revenueflare.com.

SUMMARY OF KEY POINTS

This summary provides key points from our privacy notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for.

What personal information do we process?

When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use.

Do we process any sensitive personal information? 

We do not process sensitive personal information

Do we receive any information from third parties? 

When you connect third-party services to our platform (such as Google Analytics), we receive analytics and reporting data from those services via their APIs, as authorised by you. See Section 5 (Google API Services and User Data) for full details.

How do we process your information?

We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so.

In what situations and with which types of parties do we share personal information?

We may share information in specific situations and with specific categories of

third parties.

How do we keep your information safe? 

We have organisational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information.

What are your rights?

Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information.

How do you exercise your rights? 

The easiest way to exercise your rights is by contacting us at support@revenueflare.com. We will consider and act upon any request in accordance with applicable data protection laws.

TABLE OF CONTENTS

1. WHAT INFORMATION DO WE COLLECT?
2. HOW DO WE PROCESS YOUR INFORMATION?
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
5. GOOGLE API SERVICES AND USER DATA
6. SHOPIFY API SERVICES AND MERCHANT DATA
7. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
8. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
9. HOW LONG DO WE KEEP YOUR INFORMATION?
10. HOW DO WE KEEP YOUR INFORMATION SAFE?
11. DO WE COLLECT INFORMATION FROM MINORS?
12. WHAT ARE YOUR PRIVACY RIGHTS?
13. CONTROLS FOR DO-NOT-TRACK FEATURES
14. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
15. DO OTHER REGIONS HAVE SPECIFIC PRIVACY RIGHTS?
16. DO WE MAKE UPDATES TO THIS NOTICE?
17. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
18. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you

make, and the products and features you use. The personal information we collect may include the following:

• Names
• email addresses
• billing addresses

Sensitive information. We do not process sensitive information.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our

Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (ike your name or contact

information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences,

referring URLS, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily

needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies.

The information we collect includes:

• Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date time stamps associated with your usage. pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called ‘crash dumps’), and hardware settings).

• Device Data. We collect device data such as information about your computer, phone, table, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.

• Location Data. We collect location data such as information about your device's location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. However, if you choose to opt out, you may not be able to use certain aspects of the Services.

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

• To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service.

• To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.

• To send administrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information.

• To fulfil and manage your orders. We may process your information to fulfil and manage your orders, payments, returns, and exchanges made through the Services.

• To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services.

• To send you marketing and promotional communications. We may process the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt out of our marketing emails at any time.

• To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.

• To identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them.

• To determine the effectiveness of our marketing and promotional campaigns. We may process your information to better understand how to provide marketing and promotional campaigns that are most relevant to you.

• To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual's vital interest, such as to prevent harm.

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?

In Short: We only process your personal information when we believe itis necessary and we have a valid legal reason (i.e. legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfil our contractual obligations, to protect your rights, or to fulfil our legitimate business interests.

If you are located in the EU or UK, this section applies to you.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As

such, we may rely on the following legal bases to process your personal information

• Consent. We may process your information if you have given us permission (i.e. consent) to use your personal information for a specific purpose. You can withdraw your consent at any time.

• Performance of a Contract. We may process your personal information when we believe it is necessary to fulfil our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.

• Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described in order to:

• Send users information about special offers and discounts on our products and services

• Analyse how our Services are used so we can improve them to engage and retain users

• Support our marketing activities

• Diagnose problems and or prevent fraudulent activities

• Understand how our users use our products and services so we can improve user experience

• Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.

• Vital Interests. We may process your information where we believe itis necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

If you are located in Canada, this section applies to you.

We may process your information if you have given us specific permission (i.e. express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e. implied consent). You can withdraw your consent at any time.

In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:

• If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way

• For investigations and fraud detection and prevention

• For business transactions provided certain conditions are met

• If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim

• For identifying injured, il or deceased persons and communicating with next of kin

• If we have reasonable grounds to believe an individual has been, or may be victim of financial abuse

• If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province

• If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records

• If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced

• If the collection is solely for journalistic, artistic, or literary purposes

• If the information is publicly available and is specified by the regulations

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION

In Short: We may share information in specific situations described in this section and/or with the following categories of third parties.

Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents (third parties’) who perform services for us or on our behalf and require access to such information to do that work. We have contracts in place with our third parties, which are designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will also not share your personal information with any organisation apart from us. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct. The categories of third parties we may share personal information with are as follows:

• Cloud Computing Services
• Communication & Collaboration Tools
• Data Storage Service Providers
• Payment Processors
• User Account Registration & Authentication Services
• Website Hosting Service Providers

We also may need to share your personal information in the following situations:

• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

• When we use Google Analytics. We may share your information with Google Analytics to track and analyze the use of the Services. The Google Analytics Advertising Features that we may use include:Google Analytics Demographics and Interests Reporting, Google Display Network Impressions Reporting and Remarketing with Google Analytics. To opt out of being tracked by Google Analytics across the Services, visit https://tools.google.com/dlpage/gaoptout. You can opt out of Google Analytics Advertising Features through Ads Settings and Ad Settings for mobile apps. For more information on the privacy practices of Google, please visit the ‘Google Privacy & Terms’ page.

• Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honour this privacy notice. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.

• Business Partners. We may share your information with our business partners to offer you certain products, services, or promotions.

5. GOOGLE API SERVICES AND USER DATA

In Short: When you connect Google services to our platform, we access specific Google user data via Google APIs to deliver analytics and optimisation features. Our use of this data adheres to the Google API Services User Data Policy, including the Limited Use requirements.

What Google user data do we access?

When you authorise a connection to your Google account, we may access:

• Google Analytics (GA4) reporting data: Sessions, page views, conversions, revenue, traffic sources, audience demographics, and engagement metrics from your GA4 property.
• GA4 property configuration: Account and property identifiers, and the ability to create custom dimensions for A/B test tracking.

How do we access this data?

We use Google's OAuth 2.0 authorisation protocol. You are redirected to Google's consent screen where you review the specific permissions before granting access. You may revoke access at any time.

How do we use this data?

• Dashboard reporting: Displaying analytics reports, performance dashboards, and trend analyses within your account.
• A/B test measurement: Measuring test performance by comparing sessions, conversions, and revenue across test variations.
• Custom dimension creation: Creating custom user-scoped dimensions on your GA4 property for A/B test variation tracking (one-time setup).
• Audience analysis: Generating Ideal Customer Profile insights from aggregated demographic and interest data.
• Data interpretation: We use AI-based processing to analyse and interpret your Google Analytics data — for example, to generate audience profiles, identify performance trends, and surface actionable insights within your dashboard.

How do we store this data?

OAuth tokens are stored securely in Google Cloud Firestore with encryption at rest. We do not store raw GA4 reporting data long-term; data is queried in real-time from the GA4 Data API when you view reports. Aggregated insights (such as Ideal Customer Profile summaries) may be stored within your account.

Do we share Google user data?

We do not sell your Google user data or use it for advertising, retargeting, or profiling.

To deliver certain analytics features — such as Ideal Customer Profile generation and performance analysis — aggregated Google Analytics data (e.g. session counts, traffic sources, conversion metrics, and demographic summaries) may be processed by third-party AI service providers acting as data sub-processors. These providers operate under API data-use agreements that prohibit using inputs for model training or any purpose other than generating the requested output. We do not permit any sub-processor to retain, share, or repurpose your Google user data.

Beyond the analytics processing described above, we do not transfer or share your Google user data with any other third parties.

Google API Services Limited Use Disclosure

Revenue Flare's use and transfer to any other app of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements.

Your controls

You may revoke Revenue Flare's access to your Google data at any time by:

• Disconnecting the integration from your Revenue Flare dashboard (Settings → Integrations).
• Removing access via your Google Account permissions page.

Upon disconnection, we will delete your stored OAuth tokens. Previously generated insights may be retained but will no longer refresh with new data.

6. SHOPIFY API SERVICES AND MERCHANT DATA

In Short: When you connect your Shopify store to our platform, we access store and order data via Shopify's APIs to power analytics, A/B testing, and optimisation features. Our use of Shopify data complies with the Shopify Partner Program Agreement and the Shopify API License and Terms of Use.

What Shopify data do we access?

When you install our Shopify app or connect your store, we may access the following data via Shopify's Admin API:

• Order data: Order details including totals, line items, dates, fulfilment status, returns, and refunds. We use the read_orders and read_all_orders scopes to analyse historical and ongoing order performance.
• Product data: Product titles, descriptions, variants, pricing, inventory levels, and collections. Used for reporting, A/B test configuration, and product-level analytics.
• Customer data: Aggregated customer metrics and event data (e.g. purchase frequency, customer segments). We access read_customers and read_customer_events to generate Ideal Customer Profile (ICP) insights. We do not store individual customer personal information (names, emails, addresses) beyond what is needed for aggregate analysis.
• Store configuration: Theme files, navigation structure, metaobjects, and store metadata. Used to deploy A/B test variations, sections, and tracking scripts.
• Discounts and promotions: Discount codes and automatic discounts. Used for price and offer testing features.
• Shipping and fulfilment: Shipping rates, locations, and fulfilment data for order-level analytics.

How do we access this data?

We use Shopify's OAuth 2.0 authorisation flow. When you install our app, you are presented with Shopify's permission screen listing the exact data scopes being requested. Your Shopify access token is encrypted and stored securely (see 'How do we store this data?' below).

How do we use this data?

• Performance dashboards: Displaying revenue, order, and product analytics within your Revenue Flare account.
• A/B test deployment: Writing theme modifications, script tags, and web pixels to your store to run A/B tests and measure their impact on conversions and revenue.
• Web pixel tracking: We deploy a Shopify web pixel to capture anonymised conversion events (e.g. page views, add-to-cart, purchases) tied to A/B test variations. This pixel does not collect personally identifiable information.
• Ideal Customer Profile (ICP) generation: Querying aggregated order and customer data via ShopifyQL to generate audience insights for your brand.
• AI-powered analytics: Our AI assistant uses your store data to answer questions about products, orders, revenue trends, and performance.

How do we store this data?

Your Shopify access token is encrypted using AES-256-GCM and stored in Google Cloud Firestore. We do not store bulk copies of your Shopify data; analytics queries are run in real-time against Shopify's APIs. Aggregated insights and report snapshots may be cached within your account. Web pixel configuration is stored as a Firestore document and served via a secure, token-authenticated endpoint.

Do we share Shopify merchant or customer data?

We do not sell, transfer, or share your Shopify store data or customer data with any third parties. We do not use customer data for advertising, retargeting, profiling, or any purpose other than delivering the analytics and optimisation features described above.

Data retention

We retain your encrypted Shopify access token and store metadata for as long as your integration remains connected. If you disconnect Shopify from Revenue Flare or uninstall our app, we delete your stored access token and associated configuration. Aggregated analytics snapshots previously generated may be retained within your account but will no longer refresh.

Shopify compliance

Our use of Shopify's APIs complies with the Shopify Partner Program Agreement, the Shopify API License and Terms of Use, and Shopify's Protected Customer Data requirements. We process only the minimum data required to deliver our app's functionality.

Your controls

You may revoke Revenue Flare's access to your Shopify store at any time by:

• Disconnecting the integration from your Revenue Flare dashboard (Settings → Integrations).
• Uninstalling the Revenue Flare app from your Shopify Admin (Settings → Apps and sales channels).

Upon disconnection or uninstallation, we will delete your encrypted access token and cease all API access to your store.

7. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information.

8. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?

In Short: We may transfer, store, and process your information in countries other than your own.

Our servers are located in the United States. If you are accessing our Services from outside the United States, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information (see "WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION? above), in the United States, and other countries.

If you are a resident in the European Economic Area (EEA), United Kingdom (UK), or Switzerland, then these countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. However, we will take all necessary measures to protect your personal information in accordance with this privacy notice and applicable law.

European Commission's Standard Contractual Clauses:

We have implemented measures to protect your personal information, including by using the European Commission's Standard Contractual Clauses for transfers of personal information between our group companies and between us and our third-party providers. These clauses require all recipients to protect all personal information that they process originating from the EEA or UK in accordance with European data protection laws and regulations. Our Standard Contractual Clauses can be provided upon request We have implemented similar appropriate safeguards with our third-party service providers and partners and further details can be provided upon request.

9. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfil the purposes outlined in  this privacy notice unless otherwise required by law.

We will only keep your personal information for as long as itis necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

10. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organisational and technical security measures.

We have implemented appropriate and reasonable technical and organisational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

11. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent's use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at support@revenueflare.com.

12. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: In some regions, such as the European Economic Area (EEA), United Kingdom (UK), Switzerland, and Canada, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.

In some regions (like the EEA, UK, Switzerland, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request ‘access and obtain a copy of your personal information, ii) to request rectification or erasure; (ii) to restrict the processing of your personal information; (iv) if applicable, to data portability: and (v) not to be subject to automated decision-making. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?”.

We will consider and act upon any request in accordance with applicable data protection laws.

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority.

If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

Withdrawing your consent:

If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section ‘HOW CAN YOU CONTACT US ABOUT THIS NOTICE?’ below.

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Opting out of marketing and promotional communications:

You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, or by contacting us using the details provided in the section’ HOW CAN YOU CONTACT US ABOUT THIS NOTICE? below.

You will then be removed from the marketing lists. However, we may still communicate with you — for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.

Cookies and similar technologies

Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services.

If you have questions or comments about your privacy rights, you may email us at support@revenueflare.com.

13. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (DNT) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognising and implementing DNT signals has been finalised. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

14. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: If you are a resident of Colorado, Connecticut, Utah, Virginia or California, you are granted specific rights regarding access to your personal information.

What categories of personal information do we collect?

We have collected the following categories of personal information in the past twelve (12) months:

Category A: Identifiers

Example: Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, internet protocol address, email address, and account name

Collected: Yes

Category B: Personal information as defined in the California Customer Records statute

Example: Name, contact information, education, employment, employment history, and financial information

Collected: Yes

Category C: Protected classification characteristics under state or federal law

Example: Gender and date of birth

Collected: No

Category D: Commercial information

Example: Transaction information, purchase history, financial details, and payment information

Collected: No

Category E: Biometric information

Example: Fingerprints and voiceprints

Collected: No

Category F: Internet or other similar network activity

Example: Browsing history, search history, online behaviour, interest data, and interactions with our and other websites, applications, systems, and advertisements

Collected: No

Category G: Geolocation information

Example: Device location

Collected: No

Category H: Audio, electronic, visual, thermal, olfactory, or similar information

Example: Images and audio, video or call recordings created in connection with our business activities

Collected: No

Category I: Professional or employment-related information

Example: Business contact details in order to provide you our Services at a business level or job title, work history, and professional qualifications if you apply for a job with us

Collected: Yes

Category J: Education information

Example: Student records and directory information

Collected: No

Category K: Inferences drawn from collected personal information

Example: Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics

Collected: No

Category L: Sensitive personal information

Collected: No

We will use and retain the collected personal information as needed to provide the Services of for:

• Category A - As long as the user has an account with us
• Category B - As long as the user has an account with us
• Category I - As long as the user has an account with us

We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:

• Receiving help through our customer support channels;
• Participation in customer surveys of contests; and
• Facilitation in the delivery of our Services and to respond to your inquiries

How do we use and share your personal information?

You can learn about how we use your personal information in the section, ‘HOW DO WE PROCESS YOUR INFORMATION?’.

We collect and share your personal information through:

• Targeting cookies Marketing cookies
• Social media cookies
• Beacons/Pixels/Tags

Will your information be shared with anyone else?

We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider.

We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This

is not considered to be ‘selling' your personal information.

We have not sold or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. We have disclosed the following categories of personal information to third parties for a business or commercial purpose in the preceding twelve (12) months:

• Category A. Identifiers
• Category B. Personal Information as defined in the California Customer Records aw.

The categories of third parties to whom we disclosed personal information for a business or commercial purpose can be found under the ‘WHEN AND WITH WHOM DO WE

‘SHARE YOUR PERSONAL INFORMATION?’ section.

California Residents

Califomia Civil Code Section 1798.83, also known as the ‘Shine The Light lau permits our users who are California residents {0 request and obtain from us, once a year and free of charge, information about categories of personal information ( any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing 1o us using the contact information provided below.

If You are under 18 years of age, reside in California, and have a registered account with the Services, you have the right 10 request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the contact information provided below and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g. backups, etc).

CCPA Privacy Notice

This section applies only to California residents. Under the California Consumer Privacy Act (CCPA}, you have the right listed below.

‘The California Code of Regulations defines 3 residents’ as:

1. Every individual who is in the State of California for other than a temporary or transitory purpose and
2. Every individual who is domiciled in the State of California who is outside the State of California for temporary or transitory purpose.

All other individuals are defined as ‘non-residents’.

If this definition of resident applies to you, we must adhere to certain rights and obligations regarding your personal information.

Your rights with respect to your personal data

Right to request deletion of the data — Request fo delete

You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject fo certain exceptions provided by lav, such as (but not limited to) the exercise by another consumer of is of her fight 0 free speech, our compliance requirements resulting from a legal obligation, or any processing that may be required to protect against legal activities.

Right to be informed - Request to know

Depending on the circumstances, you have a right to know:

• Whether we collect and use your personal information;
• The categories of personal information that we collect;
• The purposes for which he collected personal information is used;
• Whether we sell or share personal informaion to third parties;
• The categories of personal information that we sold, shared, or disclosed for a business purpose;
• The categories of third parties to whom the personal information was sold, shared, or disclosed for a business purpose;
• The business or commercial purpose for collecting, selling, or sharing personal information; and
• The specific pieces of personal information we collected about you.

In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.

Right to Non-Discrimination for the Exercise of a Consumer's Privacy Rights

We will not discriminate against you if you exercise your privacy rights.

Right to Limit Use and Disclosure of Sensitive Personal Information

We do not process consumer's sensitive personal information.

Verification process

Upon receiving your request we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match with information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g. phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.

We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting

additional information from you for the purposes of verification. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.

Other privacy rights

• You may object to the processing of your personal information.

• You may request correction of your personal data if it is incorrect or no longer relevant, or ask to restrict the processing of the information.

• You can designate an authorised agent to make a request under the CCPA on your behalf. We may deny a request from an authorised agent that does not submit proof that they have been validly authorised to act on your behalf in accordance with the CCPA.

• You may request to opt out from future selling or sharing of your personal information to third parties. Upon receiving an opt-out request, we will act upon the request as soon as feasibly possible, but no later than fifteen (15) days from the date of the request submission.

To exercise these rights, you can contact us by email at support@revenueflare.com, or by referring to the contact details at the bottom of this document. If you have a complaint about how we handle your data, we would like to hear from you.

Colorado Residents

This section applies only to Colorado residents. Under the Colorado Privacy Act (CPA), you have the rights listed below. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law.

• Right to be informed whether or not we are processing your personal data

• Right to access your personal data

• Right to correct inaccuracies in your personal data

• Right to request deletion of your personal data

• Right to obtain a copy of the personal data you previously shared with us

• Right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiting in furtherance of decisions that produce legal or similarly significant effects (‘profiling’).

To submit a request to exercise these rights described above, please email support@revenueflare.com.

If we decline to take action regarding your request and you wish to appeal our decision, please email us at support@revenueflare.com. Within forty-five (45) days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal including a written explanation of the reasons for the decisions.

Connecticut Residents

This section applies only to Connecticut residents. Under the Connecticut Data Privacy Act (CTDPA) you have the rights listed below. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law.

• Right to be informed whether or not we are processing your personal data

• Right to access your personal data

• Right to correct inaccuracies in your personal data

• Right to request deletion of your personal data

• Right to obtain a copy of the personal data you previously shared with us

• Right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiting in furtherance of decisions that produce legal or similarly significant effects (‘profiling’)

To submit a request to exercise these rights described above, please email support@revenueflare.com.

If we decline to take action regarding your request and you wish to appeal our decision, please email us at support@revenueflare.com. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal including a written explanation of the reasons for the decisions.

Utah Residents

This section applies only to Utah residents. Under the Utah Consumer Privacy Act (UGPA), you have the rights listed below: However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law.

• Right to be informed whether or not we are processing your personal data

• Right to access your personal data

• Right to request deletion of your personal data

• Right to obtain a copy of the personal data you previously shared with us

• Right to opt out of the processing of your person data if it is used for targeted advertising or the sale of personal data

To submit a request to exercise these rights described above, please email support@revenueflare.com.

Virginia Residents

Under the Virginia Consumer Data Protection Act (VCDPA):

"Consumer’ means a natural person who is a resident of the Commonwealth acting only in an individual or household context. It does not include a natural person acting in a commercial or employment context.

"Personal data’ means any information that is linked or reasonably linkable to an identified or identifiable natural person. ‘Personal data’ does not include de-identified data or publicly available information.

‘Sale of personal data’ means the exchange of personal data for monetary consideration.

If this definition of ‘consumer’ applies to you, we must adhere to certain rights and obligations regarding your personal data.

Your rights with respect to your personal data

• Right to be informed whether or not we are processing your personal data

• Right to access your personal data

• Right to correct inaccuracies in your personal data

• Right to request deletion of your personal data

• Right to obtain a copy of the personal data you previously shared with us

• Right to opt out of the processing of your personal data if its used for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects (‘profiling’)

Exercise your rights provided under the Virginia VCDPA

You may contact us by email at support@revenueflare.com.

If you are using an authorised agent to exercise your rights, we may deny a request if the authorised agent does not submit proof that they have been validly authorised to act on your behalf.

Verification process

We may request that you provide additional information reasonably necessary to verify you and your consumer's request. If you submit the request through an authorised agent, we may need to collect additional information to verify your identity before processing your request.

Upon receiving your request, we will respond without undue delay, but in all cases, within forty-five (45) days of receipt. The response period may be extended once by forty-five (45) additional days when reasonably necessary. We will inform you of any such extension within the initial 45-day response period, together with the reason for the extension.

Right to appeal

If we decline to take action regarding your request, we will inform you of our decision and reasoning behind it. If you wish to appeal our decision, please email us at support@revenueflare.com. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may contact the Attorney General to submit a complaint.

15. DO OTHER REGIONS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: You may have additional rights based on the country you reside in.

Australia and New Zealand

We collect and process your personal information under the obligations and conditions set by Australia's Privacy Act 1988 and New Zealand's Privacy Act 2020 (Privacy Act).

This privacy notice satisfies the notice requirements defined in both Privacy Acts, in particular: what personal information we collect from you, from which sources, for which purposes, and other recipients of your personal information.

If you do not wish to provide the personal information necessary to fulfil their applicable purpose, it may affect our ability to provide our services, in particular:

• Offer you the products or services that you want
• Respond to or help with your requests

At any time, you have the right to request access to or correction of your personal information. You can make such a request by contacting us by using the contact details

provided in the section 'HOW CAN YOU REVIEW, UPDATE. OR DELETE THE DATA WE COLLECT FROM YOU?'.

If you believe we are unlawfully processing your personal information, you have the right to submit a complaint about a breach of the Australian Privacy Principles to the

Office of the Australian Information Commissioner and a breach of New Zealand's Privacy Principles to the Office of New Zealand Privacy Commissioner.

16. DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this privacy notice from time to time. The updated version will be indicated by an updated ‘Revised’ date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

17. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may email us at support@revenueflare.com or contact us by post at

ConvertifAI LTD (trading as Revenue Flare)

Company Number: 14919489

8 Brinkburn Gardens,

Northumberland,

NE42 5GA

United Kingdom

18. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete

it. To request to review, update, or delete your personal information, please email us at: support@revenueflare.com.