Privacy policy

8. DATA RETENTION

We retain Personal Data we collect as long as it remains necessary for the purposes set forth above, all in accordance with applicable laws, or until an individual expresses a preference to opt-out.

In certain circumstances, we will retain your Personal Data for longer periods of time and mainly:

• Where we are required to retain Personal Data in accordance with legal, regulatory, tax, or accounting requirements;

• Where we deem retention is necessary to obtain an accurate record of your dealings with us in the event of any complaints or challenges (e.g., Product adverse event); or

• 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 may at our sole discretion, delete data from our systems, without notice to you, once we deem it is no longer necessary for such purposes.

9. DATA SECURITY

Securing your Personal Data is of high priority. We design our systems with your security and privacy in mind. We have implemented physical, technical, and administrative security measures that comply with applicable laws and industry standards, such as encryption, access restrictions and permissions, etc.

Note that we cannot be held responsible for unauthorized or unintended access beyond our control, and we make no warranty, express, implied, or otherwise, that we will always be able to prevent such access.

Please contact us at: privacy@annoory.com, if you feel that your privacy was not dealt with properly, 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. We will make a reasonable effort to notify you and the appropriate authorities (if required by applicable law) if we discover a security incident related to your Personal Data.

10. INTERNATIONAL DATA TRANSFER

Our data servers in which we host and store the information are located in the US, UK and Israel. The Company's HQ are based in Israel in which we may access the information stored on such servers or other systems such as the Company’s ERP, CRM and other systems. In the event that we need to transfer your ‎Personal Data out of your jurisdiction, we will take appropriate measures to ensure that your Personal Data ‎receives an adequate level of protection as required under applicable law. Furthermore, when Personal ‎Data that is collected within the European Economic Area ("EEA") is transferred outside of the EEA to a ‎country that has not received an adequacy decision from the European Commission, we will take necessary ‎steps in order to ensure that sufficient safeguards are provided during the transferring of such Personal ‎Data, in accordance with the provision of the standard contractual clauses approved by the European Union. ‎Thus, we will obtain contractual commitments or assurances from the data importer to protect your Personal ‎Information, using contractual protections that EEA and UK regulators have pre-approved to ensure your ‎data is protected (known as standard contract clauses), or rely on adequacy decisions issued by the ‎European Commission. Some of these assurances are well-recognized certification schemes.‎

11. PROTECTING CHILDREN

The Services are not intended for use by children (the phrase "child" shall mean an individual that is under ‎the age defined by applicable law, which concerning the EEA is under the age of 16, and with respect to the ‎US, under the age of 13), and we do not knowingly process children's information. We will discard any ‎information we receive from a user that is considered a "child" immediately upon discovering that such a ‎user shared information with us. Please contact us at privacy@annoory.com, if you have reason to ‎believe that a child has shared any information with us. ‎

12. ADDITIONAL NOTICE FOR US RESIDENTS

Residents of certain U.S. states (depending on the applicable state law, acting in an individual or household context and not in a commercial or employment context or as a representative of business), including California, Colorado, Connecticut, Virginia, and Utah, may have additional rights under applicable privacy laws and be entitled to additional disclosures. 

"Personal Data" under applicable US privacy laws, generally means any information that is linked or reasonably linkable to an identified or identifiable individual (and usually does not include publicly available information that is lawfully made available from government records, or that a consumer has otherwise made available to the public; de-identified or aggregated consumer information; or information excluded from the states laws scope, such as: HIPAA, GBPA, non-profit entities, etc.)

“Sensitive Data” means data revealing racial or ethnic origin, religious beliefs, mental or physical health condition or diagnosis, sex life, sexual orientation, citizenship, or immigration status; The processing of genetic or biometric data for the purpose of uniquely identifying an individual; Personal Data collected from a known child; Precise geolocation data. 

We are required to provide you with a clear and accessible privacy notice that includes the categories of Personal Data processed, purpose of processing, instructions for exercising consumer rights and appealing decisions, categories of Personal Data shared with third parties, categories of third parties with whom data is shared, and any sale of data or targeted advertising.

Categories of Personal Data & Categories of third parties with whom Personal Data is shared: 

Under the paragraph “‎THE DATA WE COLLECT & PURPOSE OF COLLECTION AND USE ” of this Privacy Policy, we describe our collection and processing of Personal Data, the categories of Personal Data that are collecting and processing, and the purposes for which Personal Data is processed, stored or used. 

Additionally, under the paragraph “SHARING DATA WITH THIRD PARTIES” of this Privacy Policy, we detail and disclose the categories of third parties we share Personal Data with for business purposes. We will not collect additional categories of Personal Data or use the Personal Data we collected for a materially different, unrelated, or incompatible purpose without obtaining your consent. 

“Sale” of Personal Data: 

Under US privacy laws, in principle, the term “sale” is referring to disclosing or making available Personal Data to a third-party in exchange for monetary or other valuable consideration, including for targeted advertising purposes. We do not “sell” information as most people would commonly understand that term, we do not, and will not, disclose your Personal Data in direct exchange for money or some other form of payment.

Consumer Rights: 

Residents of certain U.S. states, including Colorado, Connecticut, Virginia, and Utah, may have additional rights under applicable privacy laws, subject to certain limitations, which may include:

• Access - the right to confirm whether we are processing their Personal Data and to obtain a copy of their Personal Data in a portable and, to the extent technically feasible, readily usable format.

• Delete - the right to delete their Personal Data provided to or obtained by us.

• Correct - the right to correct inaccuracies in their Personal Data, taking into account the nature and purposes of the processing of the Personal Data.

The paragraph “YOUR RIGHTS UNDER PRIVACY PROTECTION LAWS” provides additional information regarding your principal rights. 

Exercising Your Privacy Rights: 

You may submit a request to exercise most of your privacy rights under U.S. state privacy laws by contacting us at: privacy@annoory.com

When you submit a request, we will take steps to verify your identity and your request by matching the information provided by you with the information we have in our records. In some cases, we may request additional information to verify your identity, or where necessary to process your request. If we are unable to verify your identity after a good faith attempt, we may deny the request and, if so, will explain the basis for denial and how to remedy any deficiencies, where applicable.

Authorized agents may initiate a request on behalf of another individual by contacting us at privacy@annoory.com;authorized agents will be required to provide proof of their authorization and we may also require that the relevant consumer directly verify their identity and the authority of the authorized agent.   

If we decline to take action on your request, we shall so inform you without undue delay, within the timeframe set out under applicable law. Our notification will include a justification for declining to take action and instructions on how you may appeal. Within the timeframe set out under applicable law of our receipt of your appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied, you may submit a complaint to the applicable authority or Attorney General of your jurisdiction.

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Veridian Flow CCPA PRIVACY NOTICE

[Last Amended: July 30,2025]

This CCPA Privacy Notice (“CCPA Notice”) applies to California residents (“Consumers” or “you”). It describes how Anoory  (together with our subsidiaries and affiliates “Company”, “us” or “we”), collect, use, disclose and share “Personal Information” (as defined below) of Consumers in operating our business. Any terms defined in the California Consumer Privacy Act of 2018 as amended by the California Privacy Rights Act of 2020 effective January 1, 2023 (collectively “CCPA”), have the same meaning when used in this CCPA Notice.

This CCPA Notice is an integral part of our Privacy Policy, and thus, definitions used herein shall have the same meaning as defined in the Privacy Policy. When we refer to “Personal Data” under our Privacy Policy, it shall also mean “Personal Information” as defined under the CCPA. 

This CCPA Notice applies to Personal Information, which is collected directly or indirectly while using our Services or in order to provide our Services. 

If you wish to learn more about your California privacy rights, you may visit https://oag.ca.gov/privacy/consumer-privacy-resources.

PART I: A COMPREHENSIVE DESCRIPTION OF THE INFORMATION PRACTICES

1. Categories of Personal Information We Collect & Disclosure of Personal Information for Business Purpose

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 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 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.

We may disclose your Personal Information to a contractor or service provider for a business purpose (as such term is defined under the CCPA). 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 for performing the contract. We further restrict the contractor and service provider from selling or sharing your personal information. 

Below we detail the categories of Personal Information that we collect, share for a business purpose and the categories of recipients to whom we disclose (within the last 12 months) 

1. Categories of Sources of Personal Information 

• Information you provide us directly – for example, when you register and create an account or correspond with us. 

• Information we receive from third parties – for example, if you access the Services through a third-party connection or log-in, if applicable, such third party may pass certain information about your use of their service to us. 

• Information we receive automatically – for example, we will collect your online identifiers and usage data including analytics data (or use third-party measurement and marketing tools) automatically. 

1. Use of Personal Information

We may use the Personal Information collected as identified above, for the following purposes: to fulfill or meet the reason you provided the Personal Information (support, respond to a query, open an account etc.); monitor and improve our Services; provide our Services; marketing our Services; analyzing your use of our Services; respond to law enforcement; or otherwise as detailed in our 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 notice. 

1. Sale or Share 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 payment.  

For retargeting and analytic purposes, when we promote our Services, we use third-party providers and tracking tools, advertising networks and social media. They provide these services by placing cookies, pixel or other tracking technology on our website, and sharing with these vendors the online identifiers and online behavior information. The CCPA defines these actions as “sharing” or “selling”.    

Below we detail the categories of Personal Information that we “sell” or “share” in the preceding 12 months for a business purpose (as defined under the CCPA).

1. Children Under Age 16

Our Services are not intended for use by children and we do not collect or maintain information about anyone under the age of 16. 

Please contact us at: Privacyannoory.com if you have reason to believe that a child has shared any information with us.

1. Data Retention

The retention periods are determined according to the following criteria:

1. For as long as it remains necessary in order to achieve the purpose for which the Personal Information was initially processed;

2. To comply with our regulatory obligations;

3. To resolve a claim, we might have or a dispute with you, including any legal proceeding between us, until such dispute will be 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 Personal Information for any particular period, and we may delete it for any reason and at any time, without providing you with prior notice if our intention to do so. 

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

1. Your Rights Under the CCPA 

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, by contact us at:Privacyannoory.com.

We may limit our response to your exercise of these privacy rights as permitted under applicable law, all as detailed herein.

To learn more about your California privacy rights, please visit https://oag.ca.gov/privacy/privacy-laws.

1. How Can You Exercise The Rights?

You may exercise your rights by contacting our privacy team at:Privacyannoory.com.

Note, certain rights can be exercised by you independently without contacting us, for example, depending on your interaction with us: 

• You can opt-out from receiving emails from us by clicking the “unsubscribe” link or other opt-out alternatives we make available, as detailed in the marketing communication we sent you or otherwise through the communication preferences settings we make available within your account.

• You can delete, access and correct any information available in your account, through your account settings. 

• Opt-out from selling or sharing can be executed at any time, by using the cookie settings tool or the "Do Not Sell or Share my Personal Information" button all available through our website. Also, you do not want to receive interest-based advertisements, you can limit the collection of certain information through your device and browser settings or use the Global Privacy Control (“GPC”) signals. 

1. Notice of Financial Incentive

We do not offer financial incentives to consumers for providing personal information.

1. Authorized Agents 

You can designate an authorized agent to submit requests on your behalf via the methods above. However, we will require written proof of the agent’s permission to do so and verify your identity directly. We will not verify your identity if the agent provides a power of attorney documentation.

1. Response Timing and Format

We endeavor to respond to a verifiable Consumer request within forty-five (45) days of its receipt. If we require more time (up to an additional forty-five (45) days), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

1. Contact Us

By email: Privacyannoory.com

By mail: NY, New York City - 140 Broadway st, 10005, USA

1. Updates

This notice was last updated on July 30, 2025. As required under the CCPA, we will update the CCPA Notice every 12 months, if needed. The last revision date will be reflected in the “Last Amended” heading at the top of this CCPA Notice.

PART III: OTHER RIGHTS APPLICABLE TO CALIFORNIA RESIDENTS 

California 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 contact us at: Privacyannoory.com

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 so not respond to the 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.