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Privacy Policy

Last Modified: September 9, 2026

This Privacy Policy (“Privacy Policy”) governs the processing and transfer of personal data collected or processed by Mindstk Ltd., collectively with its subsidiaries and affiliated companies (“Company”, “we”, “us” or “our”) when we provide our services to our customers through our platform, when we provide to our customers’ users our mobile application (“platform” and “application”), or when any of our users access or use our website available www.mindstk.com (“website”), collectively the “services”. This Privacy Policy is an integral part of any other agreement between us. Any capitalized terms not defined herein shall have the meanings ascribed to them in the applicable terms between us (“Terms”), or under the applicable privacy laws.

For the purpose of this Privacy Policy, “you”, “your” or “user”, refers to any of our users, including connection with the platform, application, or website.
This Privacy Policy also applies to the Gal mobile application,
published by MINDSTK LTD.

This Privacy Policy explains what data we may collect from you, how such data may be used or shared with others, how we safeguard it and how you may exercise your rights related to your Personal Data (as defined below), as required under relevant privacy regulation, including without limitation and where applicable: the EU General Data Protection Regulation (“GDPR”) and the Israeli Privacy Protection Law, 1981. In addition, any reference to the GDPR shall also include the UK GDPR as incorporated into the Data Protection Act 2018.

This Privacy Policy does not pertain to Personal Data relating to our employees, contractors and other staff as part of their employment or engagement with us.

If you have any questions regarding this Privacy Policy or our data practices, you are welcome to contact us at: privacy@mindstk.com.

You are not required by law to provide us with any Personal Data. However, please note that some of our services require the processing of certain Personal Data and without such data we may not be able to provide you with all or part of such services (e.g., without completing the registration process required to create an account within the platform, we will not be able to provide you with our services).

Policy Amendments

We reserve the right to amend this Policy from time to time. The most recent version of the Policy will always be posted on the website. The updated date of the Policy will be reflected in the “Last Modified” heading. Subject to applicable law, any amendments to the Policy will become effective immediately, unless we notify you otherwise. If we materially change the way in which we process your previously collected Personal Data, we will provide you with prior notice, or where legally required, request your consent prior to implementing such changes. We strongly encourage you to review this Policy periodically to ensure that you understand our most updated privacy practices.

Contact Information and Data Controller Information

Mindstk Ltd. is the Data Controller of Personal Data that it processes for its own purposes, including Personal Data relating to website visitors, Customer representatives and business contacts, as well as information processed for security, legal compliance and business administration purposes.

When Mindstk processes Personal Data relating to an end user solely to provide the Services on behalf of any of its customers (“customer” and “end-user”), the Customer acts as the Data Controller and Mindstk acts as its Data Processor or service provider. Such processing is performed in accordance with the Customer’s instructions and is also subject to the Customer’s applicable privacy notice. End users should generally direct requests concerning such Personal Data to the relevant Customer. Mindstk will assist the Customer in responding to such requests as required by applicable law. References in this Privacy Policy to the processing of End User Personal Data are provided for transparency purposes and do not alter the respective responsibilities of Mindstk and the relevant Customer.

Nothing in this Privacy Policy changes the respective roles of Mindstk and its Customers as determined under applicable law.

You may contact us as follows:

Representative for data subjects in the EU

Our representative in the European Union under Article 27 of the GDPR (“DPR”) may be contacted here.

Data Sets We Collect and for What Purpose

Below you can find information regarding the purposes for which we process your personal data as well as our lawful basis for processing, the definition of “personal” and “non-personal” data, and how it is technically processed.


Non-Personal Data

Non-Personal Data means data that does not identify an individual and cannot reasonably be used to identify an individual, including aggregated or irreversibly anonymized data. Non-Personal Data may include, for example: Aggregated usage statistics (e.g., number of users accessing certain features, average session duration, feature adoption rates), provided that such data does not enable identification of any individual; Technical and device-related information (e.g., device type, operating system, browser type, general system configurations), where such data is not linked to an identifiable individual; De-identified or anonymized analytics data (e.g., traffic patterns, performance metrics, latency and system logs), processed in a manner that prevents re-identification; High-level geographic or demographic insights (e.g., country-level usage distribution), where no individual can be identified; Aggregated business or performance data derived from user activity (e.g., trends, benchmarks, or statistical models), provided such data does not relate to an identifiable person.

Where we process Personal Data to create anonymized or aggregated datasets, we will implement measures designed to prevent re-identification. To the extent such data does not constitute Personal Data under applicable law, we may use it for legitimate business purposes, subject to applicable law.


Personal Data

We may also collect from you, directly or indirectly, during your access or interaction with the services, individually identifiable information, namely information that identifies an individual or may, with reasonable effort, be used to identify an individual (“Personal Data”). The types of Personal Data that we collect as well as the purpose for processing and the lawfulness are specified below. If we combine Personal Data with Non-Personal Data, we will treat the combined data as Personal Data.

As part of our services, we do not systematically collect or process any Personal Data constituting or revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data, data concerning a person’s health or data concerning a person’s sex life or sexual orientation (“Special Categories of Personal Data”). If you provide us with any such information (e.g., when contacting our support center) you do so under your sole responsibility.

We will not use Customer data or End User Personal Data to train any AI or machine-learning model without Customer’s or End User prior express written consent.

The following details the processing of Personal Data, the purpose, lawful basis, and processing operations:


Contact and Customer Support Information

If you voluntarily contact us in order to receive our support, e.g., through a “contact us” form in our website, you may be required to provide us with certain Personal Data such as your name, email address and any additional information you decide to share with us.


Purpose and operations: We will use this data to respond to your inquiry or information request. The correspondence with you may be processed and stored by us to improve our internal operations, as well as in the event we reasonably determine it is needed for future assistance or to handle any dispute you might have with us. We may retain and manage such information using external services and platforms such as CRM systems.

Lawful basis per GDPR: We process such Contact Information subject to our legitimate interest. If you are a customer of our services approaching us with respect to your usage of the services, the data will be processed per the contract between us. Support to an end-user is provided in our capacity of a processor, acting upon relevant customer’s behalf.


Business Engagement Information

If you engage with us as a customer, including in the course of initiating, negotiating, or managing such relationship, you may be required to provide us with certain Personal Data such as your name, business email address, phone number, professional role, and any additional information you decide to share with us.

Further, we will record and retain the content of our communications and interactions, including in connection with contractual arrangements.

Purpose and operations: We will use this data to communicate with you, and to evaluate, establish and manage the business relationship between us.


Lawful basis per GDPR: We process such information subject to our legitimate interest, and per the contract between us.


Online Identifiers and Advertising and Targeting Data

When you interact with the services, we may collect online identifiers such as your Internet Protocol address (IP), Cookie-ID, etc., and other information that relates to your activity through the services, such as pages viewed, click stream data, login time and date stamp, etc. This data might be collected directly by us or through our use of third parties’ cookies and advertisement platforms.

Similarly, we may collect Ad calls, which is a code shared with advertisers, include zip code, advertiser ID, the webpage that you came from, the IP address, and approximate location which assists the advertiser to determine which ads to place. The ad-call will also include your preference regarding interest-based advertising as further explained herein.

Please see more in the Cookies section below.


Purpose and operations: Collection of device identifiers is needed for the following purposes: (i) Internal statistics and analysis, for which device identifiers might be combined with usage data, for example, to analyze how many visitors have accessed certain content and from which country (where the country is extracted from the IP address) in order to enhance and improve our services. (iii) Marketing and advertising purposes. Our partners will process this data to manage and deliver advertisements and content more effectively and personally, including contextual, behavioral, and interests-based advertising based on your activity, preferences or other data available to us or to our business partners and advertisers, including for re-targeting purposes.


Lawful basis per GDPR: Our lawful basis for processing this data for technical and security purposes is based upon our legitimate interest. If we process your Personal Data for analytics and advertising purposes and to the extent required under applicable laws (e.g., if we use third party cookies), we will obtain your consent for such processing. In any such case, you may withdraw consent or change your preferences at any time by using the cookie settings tool available on our website.


User Account Basic Information

Any user of our services must have an account. The information provided during the registration process (whether by user or the customer) for both the application and the platform may include your name, email, phone number, username, and the designated travel dates and destinations.

Purpose and operations: We process this information on behalf of the Customer to create and administer the End User’s account, authenticate access, provide the Services and deliver operational communications enabled by the Customer.

Lawful basis per GDPR: The applicable Lawful Basis is determined by the Customer as Data Controller. We process this information as a Data Processor in accordance with the Customer’s instructions. To the limited extent that Mindstk independently processes Account or authentication data to protect the Services or its own systems, we act as Data Controller and relies on its Legitimate Interests in maintaining the security and integrity of the Services.


Platform and Application Use Data

We may process information relating to the end-user’s use of the Platform or Application, including applicable settings, Alerts and Recommended Actions received, and interactions with the Services.

Purpose and operations: We process this information on behalf of the Customer to operate, configure and support the Services and provide the applicable features to End Users. We may use specific third-party tools for the collection, analysis and management of such information.

Lawful basis per GDPR: The applicable Lawful Basis is determined by the customer as Data Controller. We process this information as a Data Processor in accordance with the customer’s instructions.


Technical Usage and Log Data

The Services may generate technical records concerning access and use, including device and network information, login records, system activity, errors and security events  including crash and diagnostic logs.

Purpose and operations: We process this information on behalf of the customer to operate, secure, troubleshoot and support the Services. We may use information that has been properly aggregated or anonymized for analytics and improvement of the Services.

Lawful basis per GDPR: Personal Data is processed on the basis determined by the customer. Properly anonymized information is not Personal Data and may be used by us subject to applicable law.


Location and Travel Data

Where location permissions are enabled, we may process the end-user’s precise or approximate device location. We may also process travel destinations or dates provided by the customer or end-user.

Purpose and operations: We process location and travel information on behalf of the customer to determine whether an event or Alert is relevant to the End User. The Application periodically accesses the End User’s device location, including in the background, and retains selected time-stamped location points when changes in location or movement are detected. Not every sampled location is retained. If the End User activates SOS, location may be collected and reported more frequently, including while the End User is stationary. The retained location points may form a limited history of the End User’s movements during the applicable monitoring period. Location permission may be withdrawn through the device settings, but this may limit the Services.

Lawful basis per GDPR: The applicable Lawful Basis is determined by the customer as Data Controller. We process this information as a Data Processor in accordance with the customer’s instructions. Note that per your device’s configurations, granting us such access will be done through explicit consent and acknowledgment.

Emergency Incident Information

If an end-user contacts the emergency support center, we may process information provided during the interaction, including incident details and related communications.

Please note that calls and other communications with our support center may be recorded, and all information provided to the support center in connection with an incident, including call recordings and related correspondence, may be retained by us.

If you provide us with Personal Data relating to another individual, you represent that you are authorized to provide such information and that such individual has been informed, to the extent required under applicable law, that their information may be collected and processed by us.

Purpose and operations: We process this information on behalf of the customer to respond to the request, support the management of the incident and maintain the records required by the customer.

Lawful basis per GDPR: The applicable Lawful Basis is determined by the customer as Data Controller. We process this information as a Data Processor in accordance with the customer’s instructions.

Promotional Marketing

We may send our direct users and customers materials and marketing content through the email information you provided during your registration.

Purpose and operations: We will use this information to keep you updated with offers and content such as updates, new capabilities and features, and to send supporting documentation.

Lawful basis per GDPR: We process such data subject to our legitimate interest. You can opt-out at any time through the “unsubscribe” link within the email or by contacting us directly. However certain operational content will still be sent.

Recruitment Data

In the event you wish to apply for a job, you may voluntarily provide us with your CV through our means of communication.

Purpose and operations: We will use the CV and information you provide to process your job application for recruitment purposes and check your suitability.

Lawful basis per GDPR: We will process basic recruitment data subject to our legitimate interests to consider your application and respond. If we move forward with you in the recruitment process, or where you have initiated the recruitment application, at an advanced stage of the negotiations we will process your data as part of our contractual relationship with you. If we choose to retain your data for any other future positions that may apply to you, we will ask for your explicit consent to the extent required by applicable law.

Please note that the actual processing operation for each purpose of use and lawful basis detailed above may differ. Such processing operation usually includes a set of operations made by automated means, such as collection, storage, use, disclosure by transmission, erasure, or destruction. The transfer of Personal Data to third-party countries, as further detailed in the Data Transfer Section below, is based on the same lawful basis as stipulated above.

In addition, we may use certain Personal Data to prevent potentially prohibited or illegal activities, fraud, misappropriation, infringements, identity thefts, and any other misuse of the services and to enforce the Terms, as well as to protect the security or integrity of our databases, services, and the website, and to take precautions against legal liability. Such processing is based on our legitimate interests.

How We Collect Your Information

Depending on the nature of your interaction with us, we may collect the above detailed information from you, as follows:

  • Automatically – we may use cookies and SDKs (as elaborated in the section below) or similar tracking technologies (such as pixels, tags, agent, etc.), or use your phone’s interfaces, for automatically collecting certain information (e.g., location).

  • Provided by you or about you voluntarily – we will collect information if and when you choose to provide us with the information, through the contact form, when you register to our services, or when you contact our emergency support center, etc.

  • Provided from third parties – certain data may be provided by the customer. In addition, where permitted under applicable law and provided with your consent for cookie usage, we may enrich the Personal Data collected about you with data provided by third parties.

Cookies & SDKs

When you access or use our services, we may use “cookies” or similar tracking technologies, which store certain information on your device (i.e., locally stored). The use of cookies is standard industry-wide practice. A “cookie” is a small piece of information that a website assigns and stores on your computer while you are viewing a website. Cookies are used by us for various purposes, including allowing you to navigate between pages efficiently, as well as for statistical purposes, analytic purposes and advertising. You can find more information about our use of cookies here: www.allaboutcookies.org.

There are several types of cookies, including without limitation:

  • Essential, Functionality, Operation & Security Cookies. These cookies are essential for enabling visitor movement around the website, for the website to function properly, and for security purposes (i.e., used to authenticate visitors, prevent fraudulent use, and protect visitor data from unauthorized parties). This category of cookies either cannot be disabled, or if disabled, certain features of the website may not work.

  • Analytic, Measurement & Performance Cookies. These cookies are used to collect information about how visitors use our website, in order to improve our website, content, and the way we offer them, as well as assess the performance of the content and marketing campaigns. These cookies enable us, for example, to assess the number of visitors who have viewed a certain page as well as their country of origin. It enables our website to remember information that changes the way it behaves or looks, such as your preferred language.

  • Preference, Targeting & Advertising Cookies. These cookies are used to advertise across the internet and to display relevant ads tailored to visitors based on the parts of the website they have visited (e.g., the cookie will indicate you have visited a certain webpage and will show you ads relating to that webpage).

You may find more information about the cookies we use as well as opt-out from cookies or change your preferences at any time by using the cookies setting tool available on the footer of our website.

Where we use third-party advertising cookies, such third-party may independently collect, through the use of such tracking technologies, some or all types of Personal Data detailed above, as well as additional data sets, including to combine such information with other information they have independently collected relating to your online activities across their network of websites, for the purpose of enhanced targeting functionality and delivering personalized ads, as well as providing aggregated analytics related to the performance of our advertising campaign you interacted with. These third parties collect and use this information under their own privacy policies, and we are not responsible for their privacy practices.

Although we do not sell your Personal Information for profit, we may engage in targeted advertising on the website. Please note that even if you opt-out you may still see personalized ads based on information other companies and ad networks have collected about you, if you have not opted out of sharing with them.

For IBA opt out options on desktop and mobile websites, please visit:

Moreover, we use the following SDK (a Software development kit) which is a set of tools that provide us with the ability to build a custom app which can be based on, or connected to, another program. SDKs are used only in our application. SDK creates the opportunity to enhance our application with more functionality, as well as include advertisement and push notifications, if applicable.

The specific SDK we currently use, purpose of use, their privacy policy and opt-out controls are set forth below:

Expo Location

Purpose: Enables access to the device’s location for the provision of location-based features, Alerts, and Recommended Actions.

Privacy Policy: https://expo.dev/privacy

Expo Notifications

Purpose: Enables the registration of devices for, and delivery of, push notifications, including Alerts, Recommended Actions, and operational communications.

Privacy Policy: https://expo.dev/privacy

Data Sharing

We share your data with third parties, including our partners or service providers that help us operate and make the most of the website. You can find here information about the categories of such third-party recipients.

Our Affiliated Companies

We may share Personal Data with our affiliated companies and subsidiaries in order to provide joint services, for example, marketing, improving our services, etc.

Our Service Providers

We share your Personal Data with our trusted service providers and business partners that perform business operations for us on our behalf (as data processors) and pursuant to our instructions. This includes the following categories of service providers:

  • AI/ML systems, who help us to provide and improve our services;

  • Advertising and marketing service providers, who help us with advertising measurements, email marketing, etc.;

  • Data storage providers, with whom we entrust the hosting and storage of our data;

  • Consent Manager (CMP), an external service that provides us with the ability to allow website visitors to control and manage their cookies preferences and consent;

  • General IT and SaaS providers – providing us with IT systems for the management of our daily conduct;

  • Data analytics and data management providers, who help us improve, personalize and enhance our operation.

  • Data security partners, who help us detect and prevent potentially illegal acts, violations of our policies, fraud and/or data security breaches and ensure compliance with legal obligations.

Legal and Law Enforcement

We may disclose certain Personal Data to law enforcement, governmental agencies, or authorized third parties, in response to a verified request relating to criminal investigations or alleged illegal activity or any other activity that may expose us, you, or any other visitor to legal liability, and solely to the extent necessary to comply with such purpose.

Corporate Transactions

In the event of a corporate transaction (e.g., sale of a substantial part of our business, merger, consolidation, or asset sale) we will share the Personal Data we store with our acquiring company. In any such case, we will oblige the acquiring company to assume the rights and obligations as described in our Privacy Policy.

When we share Personal Data with service providers acting on our behalf, we limit their access to the information reasonably necessary to perform the applicable services. Such service providers are required to protect the information and process it only for the agreed purposes and in accordance with applicable data protection laws. Where a service provider has a separate and independent relationship with you, its processing for its own purposes is governed by its own terms and privacy notice, and it is independently responsible for such processing.

End User Personal Data may also be made available to the relevant customer, which acts as the Data Controller of such information.

Data Retention

In general, we retain the Personal Data we collect for as long as it remains necessary for the purposes set forth above, all under the applicable regulation, or until you express your preference to opt-out, where applicable.

The circumstances in which we will retain your Personal Data include: (i) where we are required to do so in accordance with legal requirements, or (ii) for us to have an accurate record of your interaction with us in the event of any inquiries or contact requests, or (iii) if we reasonably believe there is a prospect of litigation relating to your Personal Data. Please note that except as required by applicable law, we will not be obliged to retain your data for a particular period, and we may delete it for any reason and at any time, without providing you with prior notice of our intention to do so.

When we process Personal Data in our capacity of a data processor on behalf of a customer, the applicable customer is responsible for setting the proper retention periods.

Security Measures

We take great care in implementing physical, technical, and administrative security measures for the website and services, that we believe comply with applicable regulation and industry standards to prevent your information from being accessed without the proper authorization, improperly used or disclosed, unlawfully destructed, or accidentally lost.

If you feel that your privacy was not dealt with properly or was dealt with in a way that was in breach of our Privacy Policy or if you become aware of a third party’s attempt to gain unauthorized access to any of your Personal Data, please contact us at our email.

International Data Transfer

Due to the international nature of our operations, we and our service providers may store or process Personal Data in Israel, the EEA, the United Kingdom, the United States and other jurisdictions. Accordingly, Personal Data may be transferred to a country that provides a different level of data protection than the country in which you are located. Where we process end-user Personal Data as a Data Processor, such transfers are also subject to the relevant customer’s instructions and the applicable agreement with that customer.

Where Personal Data subject to the GDPR or UK GDPR is transferred to a country that is not covered by an applicable adequacy decision or adequacy regulation, we will rely on an appropriate transfer mechanism and implement any additional safeguards required by applicable law. Such mechanisms may include the EU–US Data Privacy Framework, the European Commission’s Standard Contractual Clauses, the UK International Data Transfer Agreement or UK Addendum, or another lawful transfer mechanism, as applicable.

Certain analytics, cookie and similar service providers may process Personal Data in multiple jurisdictions. Their use will be subject to applicable consent requirements and their respective privacy policies. Any related international transfer for which we are responsible will be made in accordance with the safeguards described above.

Your Rights

Data protection and privacy laws may grant you certain rights with regards to your Personal Data, all according to your jurisdiction. The rights may include one or all of the following: (i) request to amend your Personal Data we store; (ii) review and access your Personal Data that we hold; (iii) request to delete your Personal Data that we hold (as long as we do not have a legitimate reason for retaining the data); (iv) restrict or object to the process of your Personal Data; (v) exercise your right of data portability (vi) contact to a supervisory authority in your jurisdiction and file a complaint; and (vii) withdraw your consent (to the extent applicable).

To exercise your rights set out above, you may fill out the Data Subject Request Form (“DSR”) available here and send it to our email at: privacy@mindstk.com. You may also complete the DSR form if you do not want us to share your Personal Data with unaffiliated or non-agent third parties for promotional purposes.

When you contact us and request to exercise your rights regarding your Personal Data, we will require certain information from you in order to verify your identity and locate your data and that the process of locating and deleting the data may take reasonable time and effort, as required or permitted under applicable law. Data privacy and related laws in your jurisdiction may provide you with different or additional rights related to the data we collect from you, which may also apply.

You always have the right to make a data protection complaint directly to us if you believe that we have infringed applicable data protection law in connection with your Personal Data. You may submit such complaint by contacting us at privacy@mindstk.com or through our Data Subject Request form. We will always take appropriate steps to review and respond to your complaint without undue delay, including by making appropriate enquiries and keeping you informed of the progress and outcome of the complaint within the timeframes set by applicable law.

If you are an EU resident you have the right to lodge a complaint with the EU Member State supervisory authority if you are not satisfied with the way in which we handled the complaint. If you are a UK resident you can always approach the Information Commissioner’s Office (ICO).

Third Party Websites

Our Privacy Policy only addresses the use and disclosure of Personal Data we collect from you. To the extent that you disclose your Personal Data to other parties via the website (e.g., by clicking on a link to any other website or location), different rules may apply to their use or disclosure of the Personal Data you disclose to them, and this Privacy Policy does not apply to any such third-party products and services. You agree that we shall have no liability whatsoever with respect to such third-party sites and your usage of them.

Eligibility and Children Privacy

Our services are not directed nor intended for use by children, and we do not knowingly process, sell or share children’s information, unless provided by an end-user under our EULA and per applicable law.

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