Last Updated: April 2026 This privacy policy (this “Privacy Policy”) in intended to inform you about how Fluent Trade Technologies Ltd., an Israeli corporation with an address at Jaffa Street 224, Jerusalem, 9438311, Israel (“Fluent”, “we”, “our”, or “us”) collects and uses personally identifiable information ("PII"), which is uploaded, submitted to us or otherwise provided by you (“you”, “your” or “yours”) through our website located at www.fluenttech.net (the “Website”). This Privacy Policy governs your browsing and use of the Website. For clarity, this Privacy Policy does not apply to your use of components of Fluent’s software or services operated or controlled by third party vendors and/or other service providers who fulfill tasks requested by us on your behalf or otherwise who assist us in connection with Fluent’s software, if applicable. If you have any questions regarding the use of your PII regarding the use of Fluent’s software, please contact Fluent for further information. Important note: Nothing in this Privacy Policy is intended to limit in any way your statutory rights, including your rights to a remedy or other means of enforcement.

How can the terms of this Privacy Policy be modified?

We reserve the right to modify this Privacy Policy at any time. You agree to review this Privacy Policy periodically to be aware of all such modifications. You further agree that your continued use of the Website after any such modifications have been made shall be deemed to be your conclusive acceptance of any modified version of this Privacy Policy. We will indicate that changes to this Privacy Policy have been made by updating the date indicated after “Last Updated” at the beginning of this Privacy Policy. We will be happy to provide you with prior versions of this Privacy Policy upon your written request to us. If you do not agree to abide by the initial version or any modified version of this Privacy Policy, then you are not authorized to continue using the Website.

What other type of PII does Fluent collect from you through the Website and how do we use it?

When you visit the Website, Fluent will collect PII that you choose to provide to us via the Website, including through online forms, such as your name, email address, phone number, company name, and the content of any message or other information you submit. We also collect information provided by you through our third party career vendor (for example, when you submit a CV or otherwise engage in the application process for one of our open positions). In addition, we collect information automatically via online technologies, such as cookies and similar technologies, and other usage and device information generated when you interact with the Website. Fluent uses the PII for the following purposes: (i) to allow you to make use of the Website, including to process and respond to your requests; to answer your questions and enable you to communicate with us; to analyze your use of the Website and to improve the Website; and to customize your experience; (ii) for administrative purposes, including to respond to your questions, comments, and other requests for customer support or information (including information about potential or future services); (iii) for internal quality control purposes; and to establish a business relationship; (iv) to market the Website, including to notify you about offers and services that may be of interest to you; and (v) for security purposes, including detecting, preventing and investigating fraud or other illegal activity; identifying and repairing errors; conducting audits; complying with applicable laws; responding to investigations by relevant authorities; for law enforcement purposes; and/or to exercise or defend legal claims. We also may collect PII about you from other sources, including (i) publicly available or commercially available information (including from third-party data platforms, partners and service providers); (ii) information you provide to us in person; and (iii) information we collect from online interactions, for example if you attend a webinar, contact us via social media, or otherwise interact with our business (including as a representative of a current or prospective customer, supplier or partner). We may track and keep a record of these interactions, which include your contact details (such as full name, email address and phone number), correspondence content (such as messages), and any other PII that you choose to provide. Fluent may use PII in our possession to (i) respond to your requests (including demo requests) and communicate with you, (ii) market our services, and (iii) establish a business relationship with you.

Which lawful bases do we rely on for processing PII (if and when applicable)?

a. The data subject has given consent to the processing of his or her PII; b. Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract; c. processing is necessary for compliance with a legal obligation to which the controller is subject; and/or d. Processing is necessary for the purposes of a legitimate interest.

Under what other circumstances may we disclose your PII to third parties?

Other than as described above, we may also release certain of the PII to third parties if we believe that such release is necessary (i) to comply with the law (e.g., a legal process or a statutory authorization or requirement) or a court order; (ii) to apply or enforce any of our agreements with you or otherwise to protect our interests; (iii) to protect against the fraudulent, abusive, or unlawful use of the Website and/or any of Fluent’s services; or (iv) if we reasonably believe that a danger to any person or property requires disclosure of such PII. We may disclose PII with our affiliated companies, lawyers, accountants, auditors and other professional advisors where necessary to obtain legal or other advice or otherwise protect and manage our business interests. Our rights under this Privacy Policy may be automatically assigned by Fluent, in our sole discretion, to a third party or parties, and such an assignment will inure to the benefit of our successors, assigns and/or licensees. Without limitation of the foregoing, we may sell, transfer or otherwise share some or all of our assets (which may include PII and) with any parent company, subsidiary, joint venture, and/or a company under our common control, as well as with a potential acquirer or an acquirer, including without limitation in connection with a merger, reorganization, or sale of assets, or in the event of bankruptcy. We use third party service providers to process your PII for the purposes outlined above, including, without limitation: • With cloud service providers for hosting purposes; • With websites and web content creation platforms in order to help us manage the Website; • With email providers, marketing, CRM, other similar tool providers; • With career and candidate tools; • With artificial intelligence tools and features; and • With analytic companies, in order to help us understand and analyze information we collect in accordance with this policy.

What are the measures in place to transfer you PII cross-border?

In order to run our business and provide the Website to you, we may transfer PII to certain countries around the world, including to our affiliates and service providers, many of whom are located outside of your jurisdiction. Therefore, your PII may be processed in countries with privacy laws that are different from privacy laws in your country. Whenever PII is transferred internationally, we ensure it is protected by executing data onward transfer instruments such as data processing and protection agreements. According to the Israeli law, by providing your consent to this Privacy Policy, you acknowledge and agree that PII relating to you may be transferred to and stored outside the borders of Israel, in accordance with applicable law and for the purposes described herein.

How do we store and safeguard your PII?

Fluent takes steps consistent with commercially reasonable industry standards to secure PII collected from you from loss, misuse, unauthorized access and accidental destruction while such PII is under our control. However, please note that despite our efforts to protect all PII provided to us, we cannot guarantee that such information will not be lost, disclosed or accessed by accidental circumstances or unauthorized acts. Further, while we will use reasonable commercial efforts to promptly notify you of a breach of your PII about which we become aware, there may be ways that a breach could occur from a your or a third party system in a manner so that we may not learn of such breach in a timely fashion, and in such an event we would not be able to alert you of such a breach.

Does Fluent provide links to other websites?

Fluent may provide links to other websites of possible interest to you. The collection and use of your PII and other information by such websites shall be subject to the policies and procedures of such websites and not those contained in this Privacy Policy. Further, the information collected by our service providers in executing transactions you have requested through the Website is subject to the privacy policies of such third parties and is not subject to this Privacy Policy.

What are our policies regarding minors?

The Website is intended for general use by persons who are above the age of eighteen (18) and not a minor in their state of residence. The Website is not targeted to anyone under eighteen (18) years of age. Fluent does not knowingly collect PII from anyone under eighteen (18) years of age. If we learn that we have unwittingly collected PII from anyone under eighteen (18) years of age, we will promptly delete such information. Please contact us in writing if you have any concerns or questions about this section.

What are Your Privacy Rights?

The following rights (which may be subject to certain exemptions or derogations) shall apply to certain individuals (some of which only apply to individuals protected by specific laws): • You have the right to withdraw consent to the processing, where consent is the basis of processing; • You have the right to request access to your PII held by us, along with details on how it is processed, subject to certain conditions; • You have the right to demand rectification of inaccurate PII about you, and we will promptly correct any information found to be incorrect; • You have the right to object to unlawful data processing under certain conditions; • You have the right to the erasure of past PII about you (your “right to be forgotten”) under certain conditions; • You have the right to demand that we restrict the processing of your PII, under certain conditions, if you believe we have exceeded the legitimate basis for processing, the processing is no longer necessary, or if you believe your PII is inaccurate; and • You have the right to data portability of PII concerning you that you provided us in a structured, commonly used, and machine-readable format, subject to certain conditions. You can exercise your rights by contacting us at info@fluenttech.net. You may use an authorized agent to submit a request on your behalf if you provide the authorized agent written permission signed by you. To protect your privacy, we may take steps to verify your identity before fulfilling your request. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly in accordance with applicable law or inform you if we require further information in order to fulfil your request. When processing your request, we may ask you for additional information to confirm or verify your identity and for security purposes, before processing and/or honoring your request. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive. In the event that your request would adversely affect the rights and freedoms of others (for example, would impact the duty of confidentiality we owe to others) or if we are legally entitled to deal with your request in a different way than initial requested, we will address your request to the maximum extent possible, all in accordance with applicable law. Please express your preference to us by contacting us at: info@fluenttech.net or write to us at Fluent Trade Technologies Ltd., Jaffa Street 224, Jerusalem, 9438311, Israel, Attn: Privacy Officer.

Do we have a mechanism to address the removal of PII and complaints about the handling of PII that we collect?

If you wish to remove PII that you have submitted to Fluent, please send us an email requesting such removal (with the word “Removal” in the email subject line) to info@fluenttech.net.

How to contact us?

If you have questions or concerns about any of our information collection or handling practices, please contact us at info@fluenttech.net or write to us at Fluent Trade Technologies Ltd., Jaffa Street 224, Jerusalem, 9438311, Israel, Attn: Privacy Officer.