DATA SUBJECT RIGHTS REQUEST FORM

Phenome Networks Ltd., and its affiliated companies and subsidiaries (collectively “Company”) values privacy rights. As required under applicable law, and specifically the EU General Data Protection Regulations (“GDPR”), the California Consumer Privacy Act of 2018 (“CCPA“), the California Privacy Rights Act of 2020 effective January 1, 2023 (“CPRA”), the Virginia Consumer Data Protection Act of 2021 (“CDPA”), the Colorado Consumer Protection Act (“CPA”) and other applicable federal, state laws, the Israeli Protection of Privacy Law (“IPPL”), etc. (all collectively shall be defined as “Data Protection Laws”), individuals are permitted to make certain requests and exercise certain rights regarding their Personal Data or Personal Information (as such term is defined under Data Protection Regulations) and depending on their jurisdiction.

In order to submit a request to exercise individual rights pursuant to the Data Protection Laws, please complete this form and send it to our privacy team at: info@phenome-networks.com.

Upon receipt of your completed request, we will process it and respond within the timelines required under applicable Data Protection Laws. If additional information is necessary, we will contact you using the contact information you provided in this form. Information provided in connection with this request will be processed only for the purpose of processing and responding to your request and will be deleted immediately thereafter. For more information, please review our Privacy Policy.

• CONTACT INFORMATION: 

Full Name: ___________________

Email Address: ___________________

If applicable, US State: _______________

• WHAT IS YOUR RELATIONSHIP WITH US? 

• User of our App
• Customer of any of our other Products or Services
• Employee 
• Vendor
• Website Visitor 

• Other (specify): ____________

• YOUR REQUEST: 

Detailed below are various rights and requests you may submit depending on your residence. Please check the applicable right you are requesting to execute. 

• CALIFORNIA: 

Note: Under the CCPA your rights only apply to the Personal Information collected 12 months prior to the request (unless in certain cases) and you are not entitled to submit more than 2 requests in a 12 months period.

Please check the applicable right you are requesting to execute:

• Right to Know or Access;
• Right to Deletion;
• Right to Data Portability;
• Right to Non-Discrimination;
• Right to Rectification;
• Right to Limit the Use and Disclosure of Sensitive Personal Information; 
• Opt-Out of the Use of Automated Decision Making; or
• Other (specify): ____________ 

Opt-Out Rights: 

The Right to Opt-out of Sale; Opt-Out of Sharing for Cross-Contextual Behavioral Advertising; can be executed without filling the form by, but rather through the “Do Not Sell or Share My Personal Information” link presented in the footer of our website. 

Authorized Agency: you may submit the request by an authorized agency as detailed in the US Privacy Notice. 

• VIRGINIA: 

• Right to Confirm if the Data is Being Processed and to Access That Personal Data;
• Right to Deletion; 
• Right to Data Portability;
• Right to Correct Inaccuracies; or
• Other (specify): _____________

The right to Opt-Out of “The Processing of the Personal Data for Purposes of Targeted Advertising, the Sale of Personal Data, or Profiling in Furtherance of Decisions that Produce Legal or Similarly Significant Effects Concerning the Consumer” can be done without filling this form, please see above the options under CCPA Opt-Out Section.

• COLORADO: 

• Right of Access;
• Right to Correction;
• Right to Deletion of Personal Data;
• Right to Data Portability – to obtain a portable copy of the data; or 
• Other (specify): _____________ 

Right to Opt-out of the Processing of Personal Data for the Purposes of: Targeted advertising; Sale for personal data; or Profiling used for decisions that produce legal or similarly significant effects on a consumer, can be done without filling this form, please see above the options under CCPA Opt-Out Section. 

If you are a Colorado, Virginia, or Connecticut consumer, and we refuse to take action on your request, you may appeal our refusal within a reasonable period after you have received notice of the refusal.  

• EU, UK, EEA AND OTHER APPLICABLE JURISDICTIONS: 

• Right to be Informed to the Processing of Personal Data; 
• Right to Access to Your Personal Data;
• Right to Rectification and Amendment;
• Right to Deletion / Erasure; 
• Right to Restrict Processing;
• Right to Data Portability;
• Right to Object to the Processing of Personal Data; 
• Rights Related to Automated Decision-Making and Profiling; or
• Other (specify): _____________

• VALIDATION 

The verifiable request must provide enough information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.

We cannot respond to your request if we cannot verify your identity or authority to make the request and confirm the Personal Information or Personal Data is relates to you. 

Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

Substantiate the request – please provide additional information about your request: __________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________

Thank you for filling in the form, please send it to the email mentioned above. We will process the request within the time frame under the applicable Data Protection Laws, we reserve the right to extend the aforementioned period by the time specified in the Data Protection Laws if the request is complex or numerous or we require additional information. 

The processing of the request is free of charge; however, we may want to reserve the right to charge a reasonable fee to cover certain administrative costs (such as providing additional copies of the data) or for handling manifestly unfounded or excessive requests.

Note that, you might not be eligible to exercise all or part of the rights detailed above – this depends on your jurisdiction and the applicable Data Protection Laws, our relationship, and our rights to refuse or retain data under applicable Data Protection Laws. Where we are not able to provide you with the information for which you have asked or otherwise fulfil your request, we will endeavor to explain the reasoning for this and inform you of your rights.