PRIVACY POLICY

[Last Modified: December 4, 2025]

This privacy policy (“Privacy Policy” or “Policy”) describes how CodeFuel Ltd. D/B/A CodeFuel, (“CodeFuel”, “we”, “us”, or “our”), collect and process certain information received when we provide our services, through our product delivered to you through ours and our Partner’s web-apps, mobile apps, desktop-apps, web-pages, platform, software, extensions and other properties (“Properties” and collectively with the services shall be referred herein as “Services“) to our direct or indirect users, customers, all as detailed below. A “Partner” is a business that embeds our search feed within its app, in which we collect certain information on the Partner and also on the users interacting with the Services through such Partner (i.e., indirect customer).

ANY PERSONAL DATA YOU PROVIDE IS MADE AT YOUR FREE WILL AND CONSENT (WHERE REQUIRED UNDER APPLICABLE DATA PROTECTION LAWS), AND YOU ACKNOWLEDGE THAT YOU ARE NOT UNDER ANY STATUTORY OBLIGATION TO PROVIDE PERSONAL DATA TO DUVE. HOWEVER, IF YOU WILL NOT PROVIDE US WITH CERTAIN PERSONAL DATA, WE WILL NOT BE ABLE TO FULFILL CERTAIN SERVICES.

This Privacy Policy further includes or incorporates specific information required under applicable data protection laws for residents of certain jurisdictions, among others:

If you are a located in the EEA or UK – this Privacy Policy further details our lawful basis for processing Personal Data, information regarding cross border data transfer and your rights, as well as additional information we are required to disclose to you under the EU and the UK General Data Protection Regulations (collectively “GDPR”).

If you are a California resident– please also review our CCPA Privacy Notice which serves as a Notice at Collection as required under the California Privacy Rights Act and further details the categories of information collected and additional information regarding our privacy practices, including your rights.

Additional Information to certain United States Residents- please also review Section 12 of this Privacy Policy “Additional Notice for US Residents” to learn more about our privacy practices and your rights under these territories.

1)     POLICY AMENDMENTS:

We evaluate this Privacy Policy and procedures to implement improvements and refinements from time to time. We will review and update this Privacy Policy as necessary at least every 12 months. The most recent version of this Privacy Policy will always be posted on the website. The updated date of the Policy will be reflected in the “Last Modified” heading. We will provide notice if these changes are material and, where required by applicable law; we will obtain your consent. Any amendments to the Privacy Policy will become effective immediately, unless we notify otherwise. We recommend you review this Privacy Policy periodically to ensure that you understand our most updated privacy practices.

2)     CONTACT INFORMATION AND DATA CONTROLLER INFORMATION:

CodeFuel Ltd. D/B/A CodeFuel, incorporated under the laws of the State of Israel, is the controller of the Personal Data listed below, unless otherwise stated.

For any question, inquiry or concern related to this Privacy Policy or the processing of your Personal Data, you may contact our privacy team as follows:

Data Protection Officer: privacy@codefuel.com.

CodeFuel Ltd.
2 Leonardo Da Vinci St., 24th Floor
Tel Aviv, 6473309, Israel

Data Protection Representative for Data Subjects in the EU, UK and Swiss:

Rickert Rechtsanwaltsgesellschaft mbH

CodeFuel Ltd.

Colmantstraße 15

53115 Bonn

Germany

art-27-rep-248@rickert.law

UK-GDPR Representative is:

Rickert Services Ltd UK

CodeFuel Ltd.

PO Box 1487

Peterborough

PE1 9XX

United Kingdom

art-27-rep-248@rickert-services.uk

3)     DATA SETS WE COLLECT AND FOR WHAT PURPOSE:

We may collect two types of information from you, depending on your interaction with us.

The first type of information is non-identifiable and anonymous information (“Non-Personal Data”). We are not aware of the identity of the individual from who we have collected the Non-Personal Data. Non-Personal Data which is being gathered consists of technical information, and may contain, among other things, the type of operating system and type of browser, type of device, your action in the website or Services (such as session duration).

The second type of information is individually identifiable information, namely information that identifies an individual or may with reasonable effort identify an individual (“Personal Data” or “Personal Information” as term may be applicable each data protection law).

For the avoidance of doubt, any Non-Personal Data connected or linked to Personal Data shall be deemed as Personal Data as long as such connection or linkage exists.

The table below details the types of Personal Data we process, the purpose, lawful basis, and our processing operations:

Please note that the actual processing operation per each purpose of use and lawful basis detailed in the table above, may differ. Such processing operation usually includes set of operations, made by automated means, such as collection, storage, use, disclosure by transmission, erasure or destruction. The transfer of Personal Data to third party countries as further detailed in Section 10 “INTENATIONAL DATA TRANSFER” below, is based on the same lawful basis as stipulated in the table above.

In addition, we may use certain Personal Data to prevent potentially prohibited or illegal activities, fraud, misappropriation, infringements, identity thefts and any other misuse of the Services and to enforce our policies and agreements, as well as to protect the security or integrity of our databases and the Services, and to take precautions against legal liability. Such processing is based on our legitimate interests.

4)     HOW WE COLLECT YOUR INFORMATION:

Depending on the nature of your interaction with the Services, or any service provided by us or our Partners, we may collect information either automatically or voluntarily provided by you. Automatic collection of information is usually made through the use of cookies, pixel tags, local storage, databases, and server logs, and voluntarily information is provided when you contact us, type in a search term, etc.

5)     COOKIES AND SIMILAR TRACKING TECHNOLOGIES:

When you interact and use our Services, we, or our Partners, place “cookies” and similar tracking technologies such as Software Developer Kits (‘SDKs’), pixels or web beacons, that collect certain information about your use and interaction with the Properties and Services and use this information for the operation and functionality of the Services as well as for analytics and marketing purposes, all as detailed in the table above. You can find more information about cookies at www.allaboutcookies.org. Currently, we use the following Cookies and SDKs:

6)     DATA SHARING – CATEGORIES OF RECIPIENTS WE SHARE PERSONAL DATA WITH:

We share your Personal Data with third parties, including with business partners or service providers that help us provide our Services. You can find here information about the categories of such third-party recipients.

Where we share information with services provider and agents, we ensure they only have access to such information that is strictly necessary in order for us to provide the Services. These parties are required to secure the data they receive and to use the data for pre-agreed purposes only, while ensuring compliance with all applicable data protection regulations (such service providers may use other non-personal data for their own benefit).

7)     DATA RETENTION:

In general, we retain the Personal Data we collect for as long as it remains necessary for the purposes set forth above, all under the applicable regulation, or until you will express your preference to opt-out, 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 Data was initially processed.
• Where we are required to retain Personal Data in accordance with legal, regulatory, tax, or accounting requirement.
• Where we deem retention is necessary to obtain an accurate record of your dealings with us in the event of any complaints or challenges.
• If we reasonably believe there is a prospect of litigation relating to your Personal Information.

Other circumstances in which we will retain your Personal Data for longer periods of time include: (i) where we are required to do so in accordance with legal, regulatory, tax or accounting requirements, or (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, or (iii) 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 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 if our intention to do so.

8)     SECURITY MEASURES:

We work hard to protect Personal Data we process from unauthorized access or unauthorized alteration, disclosure or destruction. We have implemented physical, technical and administrative security measures for the Services that comply with applicable laws and industry such as: encryption using SSL, we minimize amount of data that we store on our servers, restrict access to Personal Data to CodeFuel employees, contractors and agents, etc. Note that, we cannot be held responsible for unauthorized or unintended access that is 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@codefuel.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) in the event that we discover a security incident related to your Personal Data.

9)     INTERNATIONAL DATA TRANSFER:

Our data servers in which we host and store the information are located in the US. The Company’s HQ are based in Israel, and therefore your Personal Data may be accessed from territories which are not your country of residence. 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 receive an adequate level of protection as required under applicable law. Furthermore, when Personal Data that are collected within the European Economic Area (“EEA“), the UK or Swiss are transferred outside of the EEA, the UK or Swiss (respectively) to a country that has not received an adequacy decision from the European Commission or an equivalent competent authorities, 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 (SCCs) or the UK standard contractual clauses (UK SCCs) as approved by the UK Information Commissioner Office (ICO), as applicable.

10)  ELIGIBILITY AND CHILDREN PRIVACY:

The Services and Properties are not intended for use by children under the age of 16 and we do not knowingly process children’s information. We will discard any information that we receive from a user that is considered a “child” immediately upon our discovery that such a user shared information with us. Please contact us at: privacy@codefuel.com if you have reason to believe that a child has shared any information with us.

11)  USER RIGHTS:

We acknowledge that different people have different privacy concerns and preferences. Our goal is to be clear about what information we collect so that you can make meaningful choices about how it is used. We allow you to exercise certain choices, rights, and controls in connection with your information. Depending on your relationship with us, your jurisdiction and the applicable data protection laws that apply to you, you have the right to control and request certain limitations or rights to be executed.

In the table below you can review your rights, how you can exercise them, and appeal a decision we take in this regard, any specification per geo-location or territory are available below the table:

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,  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 “Personal Data” of this Privacy Policy, we describe our collection and processing of Personal Data, the categories of Personal Data that we are collecting and processing, and the purposes for which Personal Data is processed, stored or used. Under the paragraph “Data Sharing” 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, 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.
• Opt-Out – to opt out of certain types of processing, including: (i) to opt out of the “sale” of their Personal Data; (ii) to opt out of targeted advertising by us; and (iii) to opt out of any processing of Personal Data for purposes of making decisions that produce legal or similarly significant effects.

The paragraph “User rights” 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@codefuel.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@codefuel.com; authorized agents will be required to provide proof of their authorization and we may also require that the relevant User 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.