Vilo End User Privacy Policy

Last update: January 10, 2026

This End User Privacy Policy (“Privacy Policy”) explains how Vilo HR Technologies Ltd. and its affiliates (“Vilo”, “Company”, “we”, “us”, “our”) collect, use, and store end-user’s (collectively “you”, “your”, “User”) Personal Data (as defined below) when using Vilo’s web application at https://hr.vilohub.com/auth or software application (collectively, the “Platform”).

Please note that our Platform may be used as part of a business account. In such cases, certain Personal Data we process for the Platform’s functionalities is processed by us as a data processor on behalf of our business customers (“Business Customers”). The processing of Personal Data in these circumstances is governed by the agreements we have with those Business Customers, and not by this Privacy Policy. Personal Data we process on behalf of our Business Customers may include, among other things, your contact details (such as your workplace email address and organizational role), passwords and other authentication or security credentials, interests, and specialties. If you have any questions or concerns regarding the processing of this information, please contact your employer.

This Policy is an integral part of our End User Terms of Use (“Terms”). Any capitalized terms not defined herein shall have the meaning ascribed to them in the Terms.

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 legal obligation to provide us with Personal Data. However, we must collect or receive some Personal Data to perform our obligations according to the Terms, and in case you choose not to provide us with Personal Data, we will not be able to fulfill certain purposes, and you may not be able to use the Platform.

1. Policy Amendments

Vilo reserves the right to amend this Privacy Policy from time to time, at our sole discretion. The most recent version of this Policy will always be posted on the Platform and will reflect the publication date. 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. Data Controller Details

Vilo HR Technologies Ltd. incorporated under the laws of the State of Israel, is the “Data Controller” (as such term is defined under Israeli Privacy Protection Law) of the Personal Data collected from you as detailed herein below.

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

By email: support@vilohub.com

3. Personal Data collected by Vilo

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

3.1. 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 whom we have collected the Non-Personal Data. Non-Personal Data consists of technical information, and may contain, among other things, the type of operating system and type of browser, type of device, device serial number, session duration, etc.

3.2. 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” as defined under the applicable 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. However, this Privacy Policy does not apply to any data insofar as it is held, processed, disclosed or published in a form which cannot be linked to an individual (such as anonymized or aggregated data which cannot directly or indirectly be used to identify you or to obtain information about you (“Anonymized and Aggregated Data”). We may generate or extract Anonymized and Aggregated Data out of any databases containing your Personal Data and we may make use of any such Anonymized and Aggregated Data for our purposes as we see fit.

The table below details the types of Personal Data we may collect depending on your interaction with us, as well as how and for which purposes we process and use your Personal Data:

Type of Data	Purposes and Operation
Online Identifiers and Usage Data: When you interact with the Platform, we may collect online identifiers associated with your browser or device such as your Internet Protocol address (“IP”) and generate and assign to your device additional identifiers allowing us to individually identify you, such as a Cookie ID (“Online Identifiers”). Further, additional information is automatically collected regarding your “Platform online behavior”. Such information includes the pages you viewed, click stream data, access time stamp, etc. (collectively “Usage Data”). Online Identifiers and Usage Data are collected through our use of our or third party’s tools such as cookies and similar technologies.	Online Identifiers and certain Usage Data are used: To operate the Platform and enable its proper functionality (for example, in order to automatically recognize you by the next time you enter the Platform), For security and fraud prevention purposes (for example, to confirm you are a real person), For debugging and to resolve technical problems. To understand how individuals use the Platform.
Account Details: During the registration process you will be requested to provide us with your Contact Information (as defined below) and additional information, such as your interests, specialties, and Goals etc. (“Account Details”).	We will use this information to provide the support needed, the Platform and our services, authentication. We will retain such correspondence for as long as needed.
Contact Information: If you voluntarily contact us for support or other inquiries either through an online form available on the Platform, by sending us an email or by any other means of communications we may make available to you, provide your feedback, respond to a survey, or otherwise, or interact with us in connection with the Platform, you will be required to provide us with certain information such as your email address, etc. In addition, you can choose to provide us with additional information as part of your correspondence with us (support@vilohub.com).	Contact Information is used for: Provide you with the support you requested or to respond to your inquiry. The correspondence with you may be processed and stored by us in order to improve our service and in the event, when we believe it is required to continue to store it, for example, in the event of any claims or in order to provide you with any further assistance (if applicable). We may use your email address in order to send you service communications and marketing promotions, such as new features, additional offerings, special opportunities or any other information we think you will find valuable (“Direct Marketing”) subject to applicable law. We will further use your email address, if applicable, under our suppression list, when you request to opt-out to ensure we comply with such preference and choice.
Telemetry Data and Device Data: We keep track of certain information about you when you visit and interact with our Platform. This information includes the features you use; the links you click on; pages you have viewed; and additional information on how you interact with our services (“Telemetry Data”). We also collect information about your computer, phone, tablet, or other devices you use to access the Platform, such as your connection type and settings when you access, update, or use our Platform. We also collect information through your device about your operating system, browser type, IP address, URLs of referring/exit pages, device identifiers, and crash data (“Device Data”).	We use this information: To provide and improve functionality; to recognize you across different services and devices; operate, maintain, and improve the Platform. To troubleshoot, to identify trends, usage, activity patterns, and areas for integration and to improve our Platform and to develop new products, features and technologies that benefit our clients and the public. To resolve technical issues you encounter, to respond to your requests for assistance, to analyze crash information, and to repair the Platform. We will disclose the information to third party analytic providers for tracking purposes, analytics and operational purposes, correcting errors and bugs, enhance the Platform such as to adjust language preference, if applicable, to enable you to use the Platform and to provide you with its functionalities.
Step Count (Health Data): If you choose to participate in a Step Challenge and grant permission, we read your step count from Apple Health (iOS) or Android Health Connect. Providing this access is entirely optional.	We use this information solely to enable your participation in Step Challenges and to display step counts and rankings. We read only your step count; we do not access any other health data, and we do not write or synchronize any data back to Apple Health or Android Health Connect. If you do not grant this permission, the rest of the Platform continues to work normally, but Step Challenges will not be available.

Please note that the actual processing operation per each purpose of use detailed in the table above may differ. Such processing operation usually includes a set of operations, made by automated means, such as collection, storage, use, disclosure by transmission, erasure or destruction.

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 Platform 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.

As mentioned above, we may also aggregate all personally identifying characteristics from any data we collect and may share that aggregated, anonymized data with third parties or publish it. This data does not personally identify you and helps us to measure the success of the services and its features and to improve your experience. We reserve the right to make use of any such aggregated data as we see fit.

4. How We Collect Personal Data:

Depending on the nature of your interaction with us, we may collect information as follows:

Automatically – certain Personal Data such as Online Identifiers and Telemetry Data is generated automatically and collected through the use of cookies and similar tracking technologies (such as pixels, tags, agent, etc.). For more information on the cookies we use and how to opt out of third-party collection of this information, please see our Section 5 below “Cookies”.
Provided by you voluntarily – we will collect Personal Data if and when you choose to provide us with the information, such as when you decide to contact us.
Provided by the Business Customer – certain Personal Data may be shared by the Business Customer in their capacity as an employer, in accordance with the notice provided by the Business Customer within the scope of their employment.

5. Cookies

5.1. Vilo uses tracking mechanisms such as cookies and web beacons in order to provide and improve the Platform. The use of cookies is a standard industry-wide practice. Cookies are used by us for various purposes, including allowing you to navigate between pages efficiently, as well as for statistical purposes, analytic purposes and advertising.

5.2. A cookie is a small text sent and saved on your device for record-keeping purposes, which contains information about you. The cookies will not harm your device or files.

5.3. Most browsers automatically accept cookies, but you may be able to modify browser settings to decline cookies. Please refer to the support page of your browser to learn more about how you can adjust your privacy and security settings. Please note that if you decline or delete these cookies, some parts of the Platform may not work properly. You can find more information about our use of cookies here: www.allaboutcookies.org.

6. Sharing Personal Data with third parties

We share your Personal Data with third parties, including with trusted partners or service providers that help us to manage our business operation, Platform, etc. You can find information about the categories of such third-party recipients in the table below:

Category of Recipient	Data that will be shared	Purpose of Sharing
Service providers and business partners	All types of Personal Data depending on the applicable service provider or business partner, and your interaction with us	We may share Personal Data about you with third party business partners and service providers that perform services on our behalf in connection with our Platform, such as cloud service provider, analytics and service providers, our CRM provider, etc. Where your Personal Data is shared with such third parties, we ensure that the third party will deal with your information only on our behalf and on our instructions and solely for the benefit of our business (and not for its own benefit).
Affiliated companies	All types of Personal Data, as strictly necessary and on a case-by-case basis.	We may share certain information with our affiliated companies, which will provide us with certain required services and, for internal compliance and measurement. In addition, certain information may also be shared with potential affiliated companies in the event of a potential business re-organization while we undergo certain due diligence processes. In such event, those potential affiliated companies are bound by robust confidentiality obligations.
Legal authorities, regulators, etc.	All types of Personal Data as strictly necessary and on a case-by-case basis.	To the extent permitted or required by applicable law, we may disclose information about you to third parties to: (i) enforce or apply our terms of use or any applicable service agreement; (ii) comply with laws, subpoenas, warrants, court orders, legal processes or requests of government or law enforcement officials; (iii) protect our rights, reputation, safety or property, or that of our users or others; (iv) protect against legal liability; (v) establish or exercise our rights to defend against legal claims; or (vi) investigate, prevent or take action regarding known or suspected illegal activities; fraud; our rights, reputation, safety or property, or those of our clients or others; violation of our applicable policies and agreements; or as otherwise required by law.

7. Security

Vilo has taken appropriate technical and organisational measures to keep your data safe and secure in order to prevent loss, misuse, unauthorized access, disclosure, alteration, destruction, and any other form of unauthorized processing. Although we take reasonable steps to safeguard information, and we cannot be responsible for the acts of those who gain unauthorized access or abuse our Platform and we make no warranty, express, implied or otherwise, that we will always be able to prevent such access.

Please contact us at: support@vilohub.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.

8. International Storage

You should be aware that Personal Data Vilo collects may be processed and stored outside your jurisdiction, and that data protection laws in the jurisdiction where the information is collected stored and/or processed may differ from your jurisdiction. However, in all cases, we will take appropriate measures to ensure that your Personal Data receives an adequate level of data protection upon its transfer. You hereby give consent to this transfer, processing and storage of your information outside its jurisdiction.

9. Privacy rights

Subject to the provisions of the Israeli Protection of Privacy Law, 1981 and related regulations, you have the right to review, correct, or delete Personal Data held about you in our databases. You may request to review your Personal Data by submitting a written request at: support@vilohub.com. If you find that the information is incorrect, incomplete, unclear, or outdated, you may request that it be amended or deleted. We will respond to your request in accordance with the timelines and procedures set out in applicable law. Please note that in certain circumstances, we may retain information as required by law or for legitimate business purposes, even after a request for deletion.

10. 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.

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; (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 may at our sole discretion, delete or amend information from our systems, without notice to you, once we deem it is no longer necessary for such purposes.

11. Children’s Data

Our Platform is not intended for children under the age of 18. We do not, knowingly or intentionally, collect information about children who are under 18 years of age.

IF YOU ARE UNDER THE AGE OF 18 YOU MAY NOT USE THE PLATFORM.