Privacy Policy

1. Introduction

CivicLabs Ltd. (“CivicLabs,” “we,” “us,” or “our”), registered in Israel and operating internationally, is committed to protecting the privacy of individuals who visit our website at civic-labs.com (“the Website”) and interact with our services.

This Privacy Policy explains what personal data we collect, how we use it, the legal basis for processing it, and your rights in relation to it. It applies to all visitors to the Website regardless of location. CivicLabs operates under Israeli privacy law — the Protection of Privacy Law, 5741-1981, as amended, including by Amendment No. 13, 5784-2024 (“Amendment 13”), which entered into force on August 14, 2025 — and, where applicable, the European Union General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679). If you are located in the European Economic Area (EEA), the GDPR applies to the processing of your personal data.

2. Who We Are

Data Controller: CivicLabs Ltd. HQ Yokneam, Israel contact@civic-labs.com

CivicLabs has assessed its data processing activities against the criteria under Amendment 13 and has determined that the appointment of a Data Protection Officer is not currently required, as CivicLabs is not a public body, does not act as a data broker, does not conduct systematic monitoring of data subjects, and does not process especially sensitive data as a primary activity. This assessment is reviewed periodically as our operations evolve. All privacy-related enquiries should be directed to contact@civic-labs.com.

3. What Data We Collect

We collect personal data in the following ways:

a) Data you provide directly When you submit an enquiry through our contact form, we collect:

• Full name
• Email address
• Company name (if provided)
• The content of your message

b) Data collected automatically When you visit the Website, we automatically collect certain technical data, which constitutes personal data under applicable law, including:

• IP address
• Browser type and version
• Device type and operating system
• Pages visited and time spent on each page
• Referring URL
• Date and time of visit

This data is collected via Google Analytics and Meta Pixel (see Section 7).

We do not collect or process any special categories of data (including biometric, genetic, health, criminal record, or similarly sensitive data) through the Website.

4. How We Use Your Data

We use the personal data we collect for the following purposes:

• To respond to enquiries submitted through our contact form
• To assess potential engagements and follow up on expressed interest in our services
• To analyse Website traffic and user behaviour in order to improve the Website’s performance and content
• To measure the effectiveness of our marketing activities
• To comply with applicable legal obligations

5. Legal Basis for Processing (GDPR)

If you are located in the EEA, we rely on the following legal bases for processing your personal data:

Where we rely on consent, you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out before withdrawal.

Where you are located in Israel, our collection and use of your personal data is based on your consent (for analytics and marketing cookies) and on our legitimate business interest in responding to enquiries you have initiated. Consent for analytics and marketing cookies is collected on an explicit, granular, opt-in basis through our cookie consent banner, and you may withdraw it at any time.

6. If Your Data Originates in the EEA

Where personal data we hold originates from or relates to individuals in the EEA, that data may be subject to additional obligations under the Israeli Privacy Protection Regulations concerning data transferred from the EEA to Israel, in addition to the GDPR itself. We apply the same standard of protection to this data as we do to all personal data we process, and you retain the rights described in Section 11 regardless of where your data originates.

7. Third-Party Services and Data Processors

We use the following third-party tools that may process your personal data on our behalf:

Google Analytics Operated by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Google Analytics collects anonymised data about Website usage to help us understand how visitors interact with the Website. Data may be transferred to and processed in the United States. Google LLC participates in the EU–US Data Privacy Framework. For more information, see Google’s Privacy Policy at policies.google.com/privacy. You may opt out of Google Analytics tracking by installing the Google Analytics Opt-out Browser Add-on at tools.google.com/dlpage/gaoptout.

Meta Pixel Operated by Meta Platforms, Inc., 1 Hacker Way, Menlo Park, CA 94025, USA. Meta Pixel collects data about your interactions with the Website to enable us to measure the effectiveness of our advertising and to reach relevant audiences. Data may be transferred to and processed in the United States. Meta Platforms participates in the EU–US Data Privacy Framework. For more information, see Meta’s Privacy Policy at facebook.com/privacy/policy. You may manage your Meta ad preferences at facebook.com/ads/preferences.

We do not sell your personal data to third parties. We do not share your personal data with any third party except as described in this policy or as required by law.

8. Cookies

The Website uses cookies and similar tracking technologies. Cookies are small text files placed on your device when you visit a website.

We use the following categories of cookies:

• Strictly necessary cookies — required for the Website to function. These do not require consent.
• Analytics cookies — used by Google Analytics to collect information about how visitors use the Website. These are only placed with your prior, explicit, and granular consent.
• Marketing cookies — used by Meta Pixel to track conversions and enable targeted advertising. These are only placed with your prior, explicit, and granular consent.

No analytics or marketing cookies are placed until you have made an active choice via our cookie consent banner. You can review or change your cookie preferences at any time via the banner. You may also configure your browser to refuse cookies, though this may affect the functionality of the Website.

9. Data Retention

We retain personal data only for as long as necessary for the purposes described in this policy:

• Contact form enquiries are retained for up to 24 months from the date of submission, or until the business relationship concludes, whichever is later.
• Analytics data collected via Google Analytics is retained in accordance with Google’s standard retention settings, which we have configured to 26 months.
• Data collected via Meta Pixel is retained in accordance with Meta’s data retention policies.

10. International Data Transfers

CivicLabs is headquartered in Israel. The European Commission has recognised Israel as providing an adequate level of data protection for transfers of personal data from the EEA.

Where we transfer data to third-party processors located outside Israel or the EEA (including Google LLC and Meta Platforms, Inc. in the United States), we ensure that appropriate safeguards are in place, including reliance on the EU–US Data Privacy Framework where applicable.

11. Your Rights

If you are located in the EEA, you have the following rights under the GDPR:

• Right of access — to request a copy of the personal data we hold about you
• Right to rectification — to request correction of inaccurate or incomplete data
• Right to erasure — to request deletion of your personal data, subject to applicable legal obligations
• Right to restriction of processing — to request that we limit how we use your data
• Right to data portability — to receive your data in a structured, machine-readable format
• Right to object — to object to processing based on legitimate interests
• Right to withdraw consent — where processing is based on consent, to withdraw that consent at any time

If you are located in Israel, you have rights under the Protection of Privacy Law, 5741-1981, as amended, including:

• The right to access personal data we hold about you in a database, which we will provide in Hebrew, English, or Arabic, at your election, either directly or via an authorised representative
• The right to request correction of personal data that is incorrect, incomplete, unclear, or outdated
• The right to request deletion of your personal data where it is no longer necessary for the purpose for which it was collected, or where there is no longer a lawful basis for its continued processing
• The right to object to the use of your personal data for direct marketing purposes

To exercise any of these rights, please contact us at contact@civic-labs.com. We will respond within 30 days. We may need to verify your identity before processing your request.

If you are located in the EEA and believe we have not handled your data in accordance with the GDPR, you have the right to lodge a complaint with your local supervisory authority. A list of EEA supervisory authorities is available at edpb.europa.eu. If you are located in Israel, you have the right to lodge a complaint with the Israeli Privacy Protection Authority (PPA).

12. Data Security and Breach Notification

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, destruction, or alteration, in accordance with the Protection of Privacy Regulations (Data Security), 5777-2017. However, no method of transmission over the internet is completely secure, and we cannot guarantee absolute security.

In the event of a data breach that is reasonably likely to adversely affect your privacy, we will assess the incident, take appropriate remedial measures, and notify affected individuals and, where legally required, the Israeli Privacy Protection Authority, without undue delay and in accordance with applicable law.

13. Children

The Website is not directed at individuals under the age of 18. We do not knowingly collect personal data from minors. If you believe we have inadvertently collected such data, please contact us at contact@civic-labs.com and we will delete it promptly.

14. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable law. The date at the top of this page indicates when the policy was last revised. We encourage you to review this page periodically.

15. Contact

For any questions, requests, or concerns regarding this Privacy Policy or the handling of your personal data, please contact: CivicLabs Ltd. contact@civic-labs.com