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[Last Modified: August 31, 2026]
This CCPA Notice pertains to Kemtai Ltd. Privacy practices, collectively with its subsidiaries and affiliated companies (“Company”, “we”, “us” or “our”). This Notice supplements our Privacy Policy, and applies to California residents’ Personal Information, which we collect directly or indirectly while in our role as a Business. The California Consumer Privacy Act of 2018 together with any other applicable California privacy-related laws (“CCPA”), may apply to California residents (“consumers” or “you”) visiting and using our website (“website”) where and to the extent the CCPA applies. Any terms defined in the CCPA shall have the same meaning when used in this CCPA Privacy Notice, and any terms not defined herein shall have the meanings ascribed to them in the Privacy Policy.
This CCPA notice does not pertain to Personal Information relating to our employees, contractors and other staff as part of their employment or engagement with us.
Please note that end-users’ personal data processed on behalf of our enterprise customer within the services is legally owned by such enterprise customers (Businesses), while we merely act as a Service Provider on their behalf (“Enterprise Customers” and “End Users”, respectively). Therefore, any remainder of such End-Users’ data mentioned herein is for informational purposes only and subjected to the instructions and privacy practices of Enterprise Customers, as independent Businesses.
We collect Personal Information which is defined under the CCPA as any information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household or device, all as detailed in the table below. Personal Information further includes Sensitive Personal Information (“SPI”).
Personal Information does not include: publicly available information that is lawfully made available from government records, that a consumer has otherwise made available to the public; De-identified or aggregated consumer information; Information excluded from the CCPA’s or CPRA’s scope, such as: Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPPA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA) and the Driver’s Privacy Protection Act of 1994.
Please see below a table detailing the categories of Personal Information that we collect as a Business from visitors and users of our website:
| Category | Personal Information Collected and Used |
| A. Identifiers. | Yes. We may collect a real name, unique personal identifier, online identifier, Internet Protocol address, email address, or other similar identifiers.
We may further retain users’ identifiers for managing their customer account, etc.
We do not collect alias, postal address, Social Security numbers, Driver’s License number, or passport number.
We may use your contact info, subject to applicable law, to send you promotional emails and marketing content via email or SMS. You may withdraw consent at any time through the “unsubscribe” link within any email sent to you or by contacting us directly.
Please note that Enterprise Customers End-Users’ data may be processed by us on behalf of Enterprise Customers in their capacity as the legal owners (Business) of such data. |
| B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). | Yes, we may collect name, telephone number, bank account number, credit card number, employment information (i.e., your organization and contact information), physical characteristics or description, medical information or health insurance information. Some details may overlap and already included under category A above.
We do not collect address, your signature, Social Security number, Driver’s License number, passport number, state identification card number, insurance notice number.
Please note that Enterprise Customers End-Users’ data may be processed by us on behalf of Enterprise Customers in their capacity as the legal owners (Business) of such data. |
| C. Protected classification characteristics under California or federal law. | Yes, we may collect health-related data in our capacity as a Service Provider, on behalf of and as instructed by the relevant Enterprise Customer. |
| D. Commercial information. | Yes, we may collect payment data which is processed through our third-party providers. |
| E. Biometric information. | No, we do not collect any genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. |
| F. Internet or other similar network activity. | Yes, on our websites and services we may collect browsing history, search history, information on a consumer’s interaction with a website, or advertisement. |
| G. Geolocation data. | Yes, we may collect approximate location derived from IP, if you have enabled and consented to location information collection. |
| H. Sensory data. | Yes. As part of providing you with the services, we may record and capture your photographs and training related videos for analysis purposes. The initial analysis of the captured content is done locally on your device. This includes generation of your skeleton “stick figure”. Basically, the row data, including any of your images or videos, are not uploaded to our servers, and only the locations of your joints and body parts are uploaded during the exercise and information derived from that. However, provided your choice and consent, and with no guarantees regarding such content availability and backup, we may retain the captured images and videos for you. You may opt-out and control those options through the settings Additionally, please note that Enterprise Customers End-Users’ data may be processed by us on behalf of Enterprise Customers in their capacity as the legal owners (Business) of such data |
| I. Professional or employment-related information. | Yes. If you choose to submit an application for positions through the website, we may collect information regarding your educational records. |
| J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). | No, we do not collect this information, for example, education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. |
| K. Inferences drawn from other personal information. | No, we do not collect this information, for example, profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
However, note that our website may be affiliated with third-parties that collect this information. |
| L. Sensitive personal information. | Yes. We may collect health-related data in our capacity as a Service Provider on behalf of Enterprise Customers in their capacity as the legal owners (Business) of such data. |
We may disclose your Personal Information to a contractor or service provider for our business purposes. When we disclose Personal Information for a business purpose, we enter into a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except fulfilling the contract. In the preceding twelve (12) months, we disclosed the following categories of Personal Information for a business purpose:
| Category (corresponding with the table above) | Category of Recipient | Business Purpose | |
1
| Category A Category B Category C Category D Category F Category G Category H Category L | Cloud computing and storage vendors.
| Storage, hosting. |
| Operating systems. | Operating the website. | ||
| Government entities/Law enforcement. | Subject to a law requirement, such as tax authorities. | ||
| 2 | Category A Category B (excluding any sensitive information) Category D | Clerance and Payment processors. | Paying for our services. |
| 3 | Category A Category B (excluding any sensitive information)
Category F | Data analysis providers.
| Providing analytic data on the use of our website. |
| 4 | Category A Category B (excluding any sensitive information) Category F | Marketing & promotions providers, CRM providers, social networks, advertising networks. | Marketing, ad delivery, etc. |
| 5 | Category A Category B (excluding any sensitive information) Category F | Security service providers. | Debugging, security, fraud prevention. |
We collect the categories of Personal Information detailed above, in the following ways:
We may use, or disclose the Personal Information we collect for one or more of the following business purposes:
We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you with a notice.
We do not sell information as most people would commonly understand that term, we do not, and will not, disclose your Personal Information in direct exchange for money or some other form of actual payment. We may “share” Personal Information for “interest-based advertising” or “cross-context behavioral advertising”. The CCPA defines “sharing” as “communicating orally, in writing, or by electronic or other means, a consumer’s Personal Information” to “a third party for cross-context behavioral advertising, whether or not for money or other valuable consideration”. In other words, we may share your Personal Information with a third party to help serve personalized content or ads that may be more relevant to your interests, and to perform other advertising-related services such as enabling our partners to serve such personalized content.
In the preceding twelve (12) months, we “sell” or “share” the following categories of Personal Information for a business purpose:
| Category (corresponding with the table above) | Category Recipient | Purpose of Sale or Share |
Category A Category F Category G | Ad-network and advertising partners. | Sale/Share for cross-context behavioral advertising. |
We will never share any sensitive or health-related data with advertisers for advertising purposes.
In general, we retain the Personal Information 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 optout, where applicable.
The retention periods are determined according to the following criteria:
Please note that except as required by applicable law, we will not be obligated to retain your data for any 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.
Further, retention periods of Enterprise Customers’ End-Users’ data are set by the relevant Enterprise Customer as the independent Business of such data upon its sole discretion.
As required under the CCPA, we will update this Privacy Notice every 12 months. The last revision date will be reflected in the “Last Modified” heading located at the header of the Privacy Notice.
We do not knowingly collect information from children under the age of 16.
If you are a California resident, you may exercise certain privacy rights related to your Personal Information. You may exercise these rights free of charge except as otherwise permitted under applicable law. We may limit our response to your exercise of these privacy rights as permitted under applicable law, all as detailed herein and in the Data Subject Request Form available HERE.
| California Privacy Right | Details |
| The right to know what Personal Information the business has collected. | The right to know what Personal Information the business has collected about the consumer, including the categories of Personal Information, the categories of sources from which the Personal Information is collected, the business or commercial purpose for collecting, selling, or sharing Personal Information, the categories of third parties to whom the business discloses Personal Information, and the specific pieces of Personal Information the business has collected about the consumer. |
| Deletion rights. | The right to delete Personal Information that the business has collected from the consumer, subject to certain exceptions. |
| Correct inaccurate information | The right to correct inaccurate Personal Information that a business maintains about a consumer. |
| Opt-Out of sharing for cross-contextual behavioral advertising | You have the right to opt-out of the “sharing” of your Personal Information for “cross-contextual behavioral advertising”, often referred to as “interest-based advertising” or “targeted advertising”. |
| Opt-out from selling | the right to opt-out of the sale or sharing of Personal Information by the business. |
| Limit the Use or Disclosure of SPI | Under certain circumstances, If the business uses or discloses SPI, the right to limit the use or disclosure of SPI by the business. |
| Opt-out of the use of automated decision making | In certain circumstances, you may have the right to opt-out of the use of automated decision making in relation to your Personal Information. However note that we do not engage in any such an activity. |
| Non-discrimination | The right not to receive discriminatory treatment by the business for the exercise of privacy rights conferred by the CCPA, denying a consumer goods or services, charging different prices or rates for goods or services, providing you a different level or quality of goods or services, etc. We may, however, charge different prices or rates, or provide a different level or quality of goods or services, if that difference is reasonably related to the value provided to us by your Personal Information. |
| Data portability | You may request to receive a copy of your Personal Information, including specific pieces of Personal Information, including, where applicable, to obtain a copy of the Personal Information you provided to us in a portable format. |
To learn more about your California privacy rights, please visit https://oag.ca.gov/privacy/privacy-laws.
We provide option to opt out of Sharing for Cross-Contextual Behavioral Advertising or Selling Personal Information by using the following opt-out options:
Use the “Do Not Sell or Share My Information” or “Reject All” option through the cookie setting tool available on our Site.
Other rights may be exercised by using the Data Subject Request Form HERE and sending it to us by email at: privacy@kemtai.com. The instructions for submission, the general description of the process, verification requirements, when applicable, including any information the consumer or employee must provide are all detailed therein.
Further, with respect to Personal Data processed by Enterprise Customer in its capacity as an independent Business, any inquiries regarding the exercise of your rights should be directed to the relevant Enterprise Customer.
“Authorized Agents” may submit opt out requests on a consumer’s behalf. If you have elected to use an authorized agent, or if you were an authorized agent who would like to submit requests on behalf of a consumer, the following procedures will be required prior to acceptance of any requests by an authorized agent on behalf of a California consumer. Usually, we will accept requests from qualified third parties on behalf of other consumers, regardless of either the consumer or the authorized agent’s state of residence, provided that the third party successfully completes the following qualification procedures:
We do not offer financial incentives to consumers for providing Personal Information.
California Civil Code Section 1798.83 permits you, if you are a California resident, to request certain information regarding disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please use the Data Subject Request Form available HERE.
Cal. Bus. And Prof. Code Section 22575 also requires us to notify you how we deal with the “Do Not Track” settings in your browser. As of the effective date listed above, there is no commonly accepted response for Do Not Track signals initiated by browsers. Therefore, we do not respond to Do Not Track settings. Do Not Track is a privacy preference you can set in your web browser to indicate that you do not want certain information about your web page visits tracked and collected across websites. For more details, including how to turn on Do Not Track, visit: www.donottrack.us. Please note that, though we do not respond to DNT signals, we do honor Global Privacy Control (GPC) signals as detailed above.
Permits California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send us the Data Subject Request Form available HERE.
CONTACT US:
If you wish to contact Company’s DPO, please address your message to Adv. Itamar Cohen, on behalf of Amit, Pollak, Matalon, and state in the subject line that the message is intended for the DPO.
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