CCPA Notice - Binah

Applicability

This CCPA Notice pertains to Binah.ai 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 visitors of our website, users of our user portal, and others who are California residents (“consumers” or “you”) visiting and using our website (“website”) or using any of our services 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 Data relating to our employees, contractors and other staff as part of their employment or engagement with us.

Please note that where the application is provided to you by a “Third Party” (e.g., a company that utilize our SDK as part of its independent app), such Third Party is an independent Business and legal controller of the Personal Information collected within its application, and the Company is not responsible for the privacy practices of such Third Party. In such cases, this CCPA Notice does not apply to such activities and information.

PART I: A COMPREHENSIVE DESCRIPTION OF THE INFORMATION PRACTICES:

Categories Of Personal Information

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, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, or other similar identifiers. We may further retain users’ identifiers for managing their user account within the platform or application, granting them with access to the platform or application, etc. We do not collect 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.
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	Yes, we may collect name, address, telephone number, and employment information (i.e. your company name, title, and contact information). Some details may overlap and already included under category A above. Additionally, when you use our application, we may collect physical characteristics and medical information (e.g., your height, weight and certain vital signs). We do not collect bank account number, credit card number, or any other financial information, your signature, Social Security number, driver’s license number, passport number, state identification card number, insurance notice number, or health insurance information.
C. Protected classification characteristics under California or federal law.	Yes, we may collect information in this category, including age, sex and medical condition e.g., your height, weight and certain vital signs). We do not collect race, color, ancestry, national origin, citizenship, religion or creed, marital status, physical or mental disability, sexual orientation, veteran or military status, genetic information (including familial genetic information).
D. Commercial information.	No, we do not collect records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies, and related 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. Please note., that in order to extract vital signs the application uses a video of a small patch of skin from the user’s face or finger, without any identifiable feature such as eyes. That video footage is processed locally (on the user’s device) in real-time and is not retained once the measurement ends.
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. We may also collect precise geolocation information, subject to your consent.
H. Sensory data.	No, we do not collect any audio, electronic, visual, thermal, olfactory, or similar sensory information.
I. Professional or employment-related information.	No, we do not collect any such information from any California resident.
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 sensitive information such as health data (e.g., certain vital signs). We do not collect government-issued identifying numbers or financial account details, genetic data, precise geolocation, race or ethnicity, religious or philosophical beliefs, union membership, mail, email, text messages, biometric data, and sexual orientation or sex life.

Disclosures Of Personal Information for a Business Purpose

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 F Category G Category L	Cloud computing and storage vendors.	Storage, hosting.
2	Category A Category B Category C Category F Category G Category L	Operating systems.	Operating the website.
3	Category A Category B Category C Category F Category G Category L	Government entities/Law enforcement.	Subject to a law requirement, such as tax authorities.
4	Category A Category B Category F	External AI/ML Models.	We use external AI/ML models to provide you with our services. We do not permit those third parties to use your information for model training purposes.
5	Category A Category B Category F	Data analysis providers.	Providing analytic data on the use of our website.
6	Category A Category B (excluding any sensitive information) Category F	Marketing & promotions providers, CRM providers, social networks, advertising networks.	Marketing, ad delivery, etc.
7	Category A Category B Category F	Security service providers.	Debugging, security, fraud prevention.

How We Collect Personal Information

We collect the categories of Personal Information detailed above, in the following ways:

Directly from you: For example, when you register to our services, or when you enabling integrations such as Apple Health (HealthKit) and Google Health Connect, etc.
Indirectly from activity on the website and services: For example, we collect your usage data automatically from measurement tools.
Indirectly from you: We track your activities across the internet related to engagement with our website, for example, when you view or interact with certain content, web page or ad.

Use Of Personal Information

We may use, or disclose the Personal Information we collect for one or more of the following business purposes:

To fulfill or meet the reason you provided Personal Information. For example, if you contact us with an inquiry and share your name and contact information, we will use that Personal Information to respond to your inquiry, as well as for support, etc.;
For security and fraud detection purposes, monitoring and maintaining the safety, security, and integrity of our website;
To improve our services, which includes but not limited to, analyze which types of ads should be provided as part of the website; analyzing your use of the website;
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations;
As described to you when collecting your Personal Information or as otherwise set forth in the Privacy Policy.

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.

Sale Of Personal Information

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.

Data Retention

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:

For as long as it remains necessary in order to achieve the purpose for which the Personal Information was initially processed. For example, if you contacted us, we would retain your contact information at least until we address your inquiry as part of our internal record keeping.
To comply with our regulatory obligations. For example, transactional data will usually be retained for seven years as of termination of engagement (or even more under certain circumstances) for compliance with our bookkeeping obligations purposes.
To resolve a claim, we might have a dispute with you, including any legal proceeding between us, until such dispute is resolved, and following, if we find it necessary, in accordance with applicable statutory limitation periods.

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, with respect to Personal Data processed directly by Third Parties, Apple Health (HealthKit) or Google Health Connect, in their capacity as independent Data Controllers, retention periods are determined solely by them.

Amendments

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.

Children Under Age 16

We do not knowingly collect information from children under the age of 16.

PART II: EXPLANATION OF YOUR RIGHTS UNDER THE CCPA AND HOW TO EXERCISE THEM

Users’ Rights

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.

How Can You Exercise the Rights?

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.

To opt out from cross contextual ads you can further use these links:
Network Advertising Initiative’s (“NAI”) HERE;
Digital Advertising Alliance’s (“DAA”) HERE Or the European Interactive Digital
Advertising Alliance (“EDAA”) HERE;
California and Colorado residents that wish to opt-out from having your data used for interest-based advertising, you may exercise your right here: https://optout.privacyrights.info/.
We also honor the Global Privacy Control preferences through the CMP tool on our website.

Other rights may be exercised by using the Data Subject Request Form HERE and sending it to us by email at: info@binah.ai. 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 Third Parties, Apple Health (HealthKit) or Google Health Connect, in their capacity as independent Data Controllers, any inquiries regarding the exercise of your rights should be directed to them.

Authorized Agents

“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:

When a consumer uses an authorized agent to submit a request to know or a request to delete, a business may require that the consumer does the following:
Provide the authorized agent signed permission to do so or power of attorney.
Verify their own identity directly with the business.
Directly confirm with the business that they provided the authorized agent permission to submit the request.
A business may deny a request from an authorized agent that does not submit proof that they have been authorized by the consumer to act on their behalf.

Notice Of Financial Incentive

We do not offer financial incentives to consumers for providing Personal Information.

PART III: OTHER CALIFORNIA OBLIGATIONS

Direct Marketing Requests:

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.

Do Not Track Settings:

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.

California’s “Shine the Light” law (Civil Code Section § 1798.83):

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:

By email: info@binah.ai
Our DPO: dpo@binah.ai
By mail: Midtown Buildings, Tel Aviv, Israel.

Last Modified: July 20, 2026

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