Privacy Policy

Last updated: May 19th, 2026

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(1)  INTRODUCTIONAND SCOPE OF THIS PRIVACY POLICY

Thisprivacy policy (“Privacy Policy”) describes how VYBS ENTERTAINMENTTECHNOLOGIES LTD and its affiliates company and subsidiaries (collectively,“Company”, “we” or “our”) collect, use and processPersonal Data (as defined below), including the needed disclosure andinformation about the types of Personal Data collected, why we collect yourPersonal Data and the purposes for which we will use it, how long we willretain it, with whom we share it, what are your applicable right regarding yourPersonal Data, and how you can exercise them.

ThisPrivacy Policy applies to our data collection and privacy practice inconnection with any individuals, including representatives of prospects andpotential business partners, who access and use our website, available at: https://partners.vybs.co/, andrelated interactions with us (respectively “website” and “user”or “you”). Please note that this Privacy Policy applies only to youruse of the website and does not govern our data collection or privacy practicesrelated to your use of our apps, products and services.

YOU ACKNOWLEDGE THAT YOU ARE NOT UNDER ANY STATUTORYOBLIGATION TO PROVIDE US WITH PERSONAL DATA, AND PERSONAL DATA YOU PROVIDE ISMADE AT YOUR FREE WILL (AND CONSENT, WHERE REQUIRED UNDER APPLICABLE DATAPROTECTION LAWS). HOWEVER, IF YOU WILL NOT PROVIDE US WITH CERTAIN PERSONALDATA, WE WILL NOT BE ABLE TO FULFILL CERTAIN PURPOSES, FOR EXAMPLE, COMMUNICATEWITH YOU REGARDING ANY INQUIRIES YOU SUBMIT - ALL AS DESCRIBED UNDER SECTION 4OF THIS PRIVACY POLICY “THE DATA SETS COLLECTED, PURPOSES OF USE ANDLAWFUL BASIS” WHICHDETAILS THE PURPOSES FOR WHICH EACH PERSONAL DATA SET IS PROCESSED.

This Privacy Policy further includes orincorporates specific information required under applicable data protectionlaws for residents of certain jurisdictions, including but not limited to:

If you are located in the EEA or UK, thisPrivacy Policy further details our lawful basis for processing Personal Data,information regarding cross-border data transfers, your rights related to thePersonal Data we process, as well as additional information we are required todisclose to you under the EU and UK General Data Protection Regulations(collectively, “GDPR”).

If you are a California resident, please also review Section 14of this Privacy Policy – CCPA Privacy Notice – which serves as a Notice atCollection as required under the California Consumer Privacy Act (“CCPA”) andfurther details the categories of information collected and additionalinformation regarding our privacy practices, including your rights under theCCPA and other California privacy laws.

 

(2)  PRIVACYPOLICY AMENDMENTS

The Company reserves the right to amend this Privacy Policyfrom time to time, at the Company’s sole discretion. The most recent version ofthis Privacy Policy will always be posted on our website, and the “Last Update”heading reflects the last date of amendments. We will provide notice to you ifthese changes are material, and, where required by applicable law, we willobtain your consent. Any amendments to the Privacy Policy will become effectiveimmediately, unless we notify otherwise. We recommend our users to review thisPrivacy Policy periodically.

 

(3)  CONTACTINFORMATION AND DATA CONTROLLER INFORMATION

VYBS ENTERTAINMENTTECHNOLOGIES LTD is the “data controller(as such term is defined under applicable privacy and data protectionlegislation) of the Personal Data collected subject to this Privacy Policy. This means that the Company is responsible fordeciding how, and the purposes for which, your Personal Data is processed aswell as to enable you to exercise your rights related to your Personal Dataprocessed by the Company.

For any questions you may have related to our processing ofyour Personal Data and this Privacy Policy, please contact as follows:

ByEmail: Support@vybs.co  

 

(4)  THE DATA SETSCOLLECTED, PURPOSES OF USEAND LAWFUL BASIS

Depending on your interaction withus and our website, we may collect certain information that may be classifiedas Non-Personal Data, or Personal Data, as follows:

Non-Personal Data” meaning informationwhich is non-identifiable and anonymous. We are not awareofthe identity of the individual from whom such Non-Personal Data was collected,and we are not able to link between this information and the individual byusing reasonable means. Non-Personal Data may include technical informationsuch as type of operating system and type of browser, type of device, youractions on the website – all when collected on anaggregate basis, or otherwise not combined with any identifiers. Wemay further process and anonymize data in a manner that the data will beNon-Personal Data.

Personal Data” meaning informationthat identifies an individual or may with reasonable effort identify anindividual.

Below you will find details regardingthe types of Personal Data we collect, how and for which purposes we use yourPersonal Data, and our lawful basis for processing Personal Data (subject tothe GDPR, if applicable). 

Pleasenote that the actual processing operation per each purpose of use and lawfulbasis, as we detail below, may differ. Such processing operation usuallyincludes a set of operations made by automated means, such as collection,storage, use, disclosure by transmission, erasure, or destruction, and is basedon the same lawful basis as stipulated below. In addition, we may processcertain Personal Data, based on our legitimate interests, to preventpotentially prohibited or illegal activities, fraud, misappropriation,infringements, identity thefts, and any other misuse of our website, to enforceour other policies, and to take precautions against legal liability.

 

(I)            Online Identifiers and Usage Data:

Types of Personal Data:

When you access and otherwise interact with our website, we may collect your onlineidentifiers, such as Internet Protocol (IP) address, Cookie ID, user agent, and similar onlineidentifiers (collectively “Online Identifiers”).

Online Identifiers are further usedto generate certain information, for example, IP address can be used to extractyour approximate location (e.g., country).

Further, when you access andotherwise interact with our website, we may further collectinformation related to such actions or interactions, for example the time anddate of the access or interaction, the duration, the URL of the website’s pageyou have viewed, click stream,crash and error data, browser or settings of languagepreferences, and similar information. We may further use tools on our websitewhich provide us with information and insights, such as the advertisingcampaign from which you have reachedour website (collectively “Usage Data”). Where such Usage Data isassociated with an Online Identifier it is processed by us as Personal Data.

Purposes of Processing:

We collect and use OnlineIdentifiers and Usage Data for the following purposes:

· To operate and enable the properfunctionality of our website, including to secure our website and prevent fraudor other malicious conducts, to detect errors, for debugging and to resolvesuch technical issues.

· For internal analyticpurposes and to enhance and improve our website and its content, as well as the way we offer it. For example, we use OnlineIdentifiers and Usage Data to understand how users use our website or the mostviewed content and pages.

· Toadvertise and promote our website and services. This includes to serve ads onthird party’s platforms across the web, as well as targeted ads (furtherdepending on your browser and cookies setting and preferences) andto measure effectiveness of, and improve, our ads and marketing campaigns, forexample, to track conversions (how many users reached our website or contactedus), build targeted audience and remarket our website and services.

Lawful Basis under the GDPR

Online Identifiers and Usage Data collected through cookies that are strictlynecessary for the proper and basic operation of our website, including for strict security purposes, will be processed by us based on our legitimate interest.

Online Identifiers and Usage Data collected for analytics and marketing purposes through our use of third-party cookies, will be processed by us based on yourconsent which we will obtain through our cookies preference management toolavailable on our website.

You may withdraw consent at any timeby using the cookies preference management tool, or bymanaging opt-out through your browser or device.  

Foradditional information regarding our use of cookies and the choices you canmake, please see Section 6 of this Privacy Policy Our Use of Cookies andTracking Technologies”.

 

(II)           Contact Information and ContactCommunications:

Types of Personal Data

If you contact us, either throughan online form available on the website or through other means wemake available through our website (such as sending us an email or calling us),or if you sign up to receive marketingcommunications from us, you will be requested to provide us with your contactinformation, which depending on the interaction with us may include your name,telephone number, email address or business email address, your organization,etc. (“Contact Information”).

Whenwe communicate with you, by means of communication such as emailcorrespondence, phone call etc., we will further process and store the communications with you,and may also process data related to these communications, such as,interactions with email correspondence (including access time and date), etc.(collectively “Contact Communications Data”).

Purposes of Processing:

We collect and use ContactInformation and Contact Communications Data for the following purposes:

· Torespond to your inquiry or request, for example, send you with information youhave requested, etc.

·  For business prospects or partners, we mayuse your Contact Information to send you marketing material related to ourservices in which you have shown your interest, such as new products, specialopportunities etc., or otherwise, subject to applicable laws, to contact youand explore potential business opportunities and offer you informationregarding our services that we think will be of interest to you or yourorganization.

·  To enhance and improve our marketingefforts.  

· To keep internal records of our communications, where webelieve it is required, for example, to comply with our obligations underapplicable laws or have internal records demonstrating our compliance, in orderto provide you with any further assistance, or in the event of any potential,threatened or actual claim or dispute.

Lawful Basis under the GDPR

Contact Information and Contact Communications Data processed byus to respond to your inquiry or requests,as well as, where processed to send you information and materials you havevoluntarily signed up to receive, are processedbased on your consent.

Contact Information and Contact Communications Data processed byus for direct marketing practices, are processed based on our legitimateinterests.

Contact Information and Contact Communications Data processed byus to improve our marketing efforts and for internal records keeping, areprocessed based on our legitimate interests.

Youhave the right to withdraw your consent at any time. You may further opt-outfrom our marketing communications by using the “unsubscribe” within the body ofthe message or other option we may make available.

 

(5)  HOWPERSONAL DATA IS COLLECTED

Depending on the nature of your interactionwith the website and with us, we may collect Personal Data:

·    By using automated means –we may use cookies or similar technologies to gather some informationautomatically when you interact with our website. For additional informationregarding our use of cookies and the choices you can make, please see Section 6of this Privacy Policy “Our Use of Cookies and Tracking Technologies

·    When provided by you voluntarily –we will collect Personal Data if and when you provide us with such information,for example when you submit a “contact us” form.

 

(6)  OURUSE COOKIES AND TRACKING TECHNOLOGIES

Weuse “cookies” (or similar tracking technologies such as tags and pixels) on ourwebsite. The use of cookies is a standard industry-wide practice. Cookies andsimilar technologies are a small piece of information, text or code that awebsite assigns and stores on your browser while you access a website. Cookiescan be used for various purposes, including for operation and securitypurposes, to improve website functionality and remember preferences, forstatistical purposes, as well as for advertising purposes.

Theinformation generally collected and stored by cookies includes OnlineIdentifiers and Usage Data (as defined in Section 4 of thisPrivacy Policy “The Data Sets Collected,Purposes of Use and Lawful Basis”).  

Thecookies and tracking technologies can be either placed by us (known as “firstparty cookies”), or by third parties whose services we use, such as ourmarketing partners, social media, analytic providers, etc. (known as “thirdparty cookies”). The duration of cookies and tracking technologies – meaningthe period until such are deleted – can be either when you close your browser(known as “session cookies”) or longer periods according to their purpose andsettings (known as “persistent cookies”).

Third-partyadvertising providers whose cookies we may use, may independently collect additionaldata sets, including to combine Online Identifiers and Usage Data with otherinformation they have independently collected relating to your online interactionsacross their network of websites, for the purpose of enhanced targeting campaignsand personalized ads, as well as providing aggregated analytics related to theperformance of advertising campaign you interacted with. These third partiescollect and use this information under their own privacy policies and areresponsible for their practices.

Thecookies preference management tool available on our website lists and detailsthe cookies we use on our website. You may change your cookies preference atany time, including, as applicable, withdraw consent or opt-out from theprocessing of Personal Data through cookies for certain purposes, by using thecookies preference management tool available on our website Note that, certain cookies used for strictoperation and security purposes are considered as “strictly necessary” andcannot be disabled.

Inaddition, most browsers will allow you to block acceptance of cookies or erasecookies by adjusting the privacy and security settings of your web browser.Please refer to the support page of your browser to learn more.

Pleasenote that once you choose to opt out or disable cookies, some features of ourwebsite may not operate properly.

 

(7)   DISCLOSUREOF PERSONAL DATA

We may disclose your Personal Data to thirdparties, including our affiliated companies, partners or service providers thathelp us manage our website, business operationsand marketing campaigns. The categories ofsuch third-party recipients or otherwise events in which we may share PersonalData are as follows:

·       Our Service Providers - we share Personal Data withour service providers to perform the requested functions and services on ourbehalf, for example, cloud providers, analytic tools, security tools,communication management providers, professional advisors, etc. These providersare prohibited from using the Personal Data we share with them for any purposeother than providing us with the requested services and we only share with themthe types of Personal Data that are needed for the provision of the applicableservices they provide us with.

·       MarketingPartners – we mayshare Personal Data with marketing partners we engage with or use their toolsand services to market and promote our website, including for targetedadvertising campaigns, for example, social media operators. The Personal Datashared may include Online Identifiers and Usage Data, (as defined in Section 4 ofthis Privacy Policy “The Data Sets Collected, Purposes ofUse and Lawful Basis”). These marketing partners maycombine your Personal Data with other data they collect independently from yourvisits and interactions on other websites where their tools are used or thatthey otherwise operate.

·       Our Affiliated Companies and Sharingin the Event of Corporate Transactions - we share Personal Data, internallywithin our company group to fulfil certain purposes for which Personal Data iscollected and retained, and may further share Personal Data in the event of acorporate transaction (for example, sale of our assets or substantial part ofour business, merger, consolidation, etc.). The types of Personal Data thatwill be shared can be any data processed by us, asneeded. Ouraffiliated companies or acquiring company will assume the rights andobligations as described herein.

·       Sharing with LawEnforcement or Governmental Authorities & to Enforce our Rights or forSecurity and Fraud Prevention - we may disclosecertain Personal Data to law enforcement,governmental agencies, or authorized third parties, to comply with applicablelaws or in response to a verified request or order. We may further sharePersonal Data to defend our rights, enforce our agreements or policies, toinvestigate or prevent potential violations thereof or any alleged illegalactivity or any other activity that may expose us, you, or other users to legalliability, however Personal Data will be shared solely to the extent required.

Forthe avoidance of doubt, we may transfer, disclose, or otherwise useNon-Personal Data, including information linked to anonymous random identifiersor aggregated in a non-identifiable way, at our sole discretion.

 

(8)   YOURRIGHTS RELATED TO YOUR PERSONAL DATA

Depending on your relationship withus, your jurisdiction and the data protection laws that apply to you, you havethe right to control and request certain limitations or rights to be executed.

The principal rights that may apply toyour Personal Data (subject to your jurisdiction and additional conditions) mayinclude:  

·       Right to Be Informed – you havethe right to be provided with information regarding our privacy practices,including the Personal Data we collect and how we use it – as we detailed underthis Privacy Policy. If you have any additional questions, you can contactus as set forth under this Privacy Policy.

·       Right to Access/Inspect Your PersonalData –you have the right to ask us to confirm whether or not we collect and use yourPersonal Data and which Personal Data we specifically hold about you, and toask for a copy of your Personal Data or otherwise access it.

·       Right to Correction/Rectification – you have the right toask us to correct inaccuracies or update yourPersonal Data we hold or request deletion for inaccurate Personal Data,considering and subject to the nature and purposes ofthe processing.  

·       Right to Deletion/“To Be Forgotten” – you have the rightto request the deletion of certain Personal Data we process, if specificconditions are satisfied, for example, if you think  we no longer need itfor the purpose we collected it; where we have used it unlawfully; where thecollection was based on your consent; or where we are subject to a legalobligation to delete  it. Deletion request will be subject to ourrights and obligations under applicable law (for example, our legitimateinterests to maintain record keeping, providing a service you requested, takingactions reasonably anticipated within the context of our ongoing businessrelationship with you, debugging and detecting security incidents, protectingagainst deceptive, fraudulent, or illegal activity; exercising rights underlaw, etc.). 

·       Right to Withdraw Consent – when we collect and processyour Personal Data based on your consent, you have the right to withdraw suchconsent at any time.

·       Right to Opt-Out/Opt-Out of “Sale” – you have the rightto opt-out from receiving our marketing communications, if applicable, byunsubscribing through the message received. You further have the right to opt out of the “sale” of Personal Data (i.e., to optout of targeted advertising by us) as further explained under Section 9 of thisPrivacy Policy “Sale” of Personal Data. Wedo not profile you in a manner that has a significant effect on youor other individuals, therefore we do not provide an opt-out option from suchuse of Personal Data.

·       Right to Object – you have the right toobject to any use of your Personal Data which is based on our legitimateinterest if you believe your fundamental rights and freedoms to data protectionoutweigh our legitimate interest.

·       Right to Restrict Processing – you have the right toask us to restrict or limit the purpose for which we process your PersonalData, where certain conditions are satisfied.  

·       Data Portability Right – you have the right torequest to be provided with a copy of your Personal Data in a portableformat and, to the extent technically feasible, readily usable format thatallows you to transmit the Personal Data. 

·       Right to Appeal or Lodge a Complaint – If we decline totake action on your request to exercise your rights, we will inform you within the timeframe set out underapplicable law, and we will explain the justification for declining yourrequest as well as how you may appeal, if applicable. Where applicable, we will inform you of action taken ornot taken in response to your appeal, including the reasons for the decision.If the appeal is denied, you may submit a complaint to the applicable authorityor Attorney General of your state.

Where theGDPR applies, you have the right to lodge a complaint with theapplicable Data Protection Authority in the EU orthe Information Commissioner in the UK. 

You may submit a requestto exercise most of your privacy rights under applicable privacy laws by contacting us at Support@vybs.co . We will respond and fulfill your request within the timeframerequired under applicable laws. 

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

Certain rights can be easily executed independently by you withoutthe need to contact us, and for example, you can use the cookies preferencemanagement tool on our website to change your preferences and opt-out ofcookies including opt-out of “sale” of Personal Data and you can opt-outfrom receiving our marketing messages by clicking “unsubscribe” link or followother opt-out instructions.

 

(9)  “SALE”OF PERSONAL DATA 

Under USprivacy laws, the term “sale” refers to disclosing or making available PersonalData to a third party in exchange for monetary or other valuable consideration,including for targeted advertising purposes. We do not “sell” Personal Data asmost people would commonly understand that term, i.e., we do not disclose yourPersonal Data in direct exchange for money or some other form of payment.  However, subject to the definition of theterm “sale” under such US privacy laws, our practice of sharing the categoriesof Personal Data detailed above, when we use cookies or other third-partyadvertising services, is considered as “selling” Personal Data. The categoriesof Personal Data shared for this purpose include: Online Identifiers such as IPand Cookie ID; Internet and electronic network activity information (UsageData); Geolocation data (such as country level extracted from IP) (all terms asdefined under Section 4 of this Privacy Policy – The Data Sets Collected,Purposes of Use and Lawful Basis). You have the right to opt out of such “sale” at any time by changingyour preference using the cookies preferences management tool available on our website.

 

(10)                 PERSONALDATA RETENTION

Weretain the Personal Data for as long as it is needed for the purposes for whichit was collected, in accordance with applicable laws, or, where applicable,until we receive an expresses preference to opt-out or delete Personal Data byan individual. There are other circumstances in which we willretain your Personal Data for longer periods, as follows: we are required toretain the Personal Data in accordance with legal, regulatory, tax, oraccounting requirements;  where we determine we need to retain records of your dealings with us in the event of anycomplaints or in the event we reasonably believe there is a prospect of litigation relating toyour Personal Data.

Without derogating from the above, exceptwhere we are required to retain Personal Data under applicablelaw, we may at our sole discretion, delete oramend any data, without notice, once we deem it is no longer needed.

 

(11)                 SECURITY

Wehave implemented physical, technical, and organizational security measures thatcomply with applicable laws and industry standards intended to protect PersonalData from unauthorized access, alteration, disclosure or destruction.

Notehowever that security incidents cannot always be prevented, and we will not beheld responsible for unauthorized or unintended access beyond our control, andwe make no warranty, express, implied, or otherwise, that we will always beable to prevent such unauthorized access or use.

Please contact us at if you become aware of any attempt to gainunauthorized access to your Personal Data.

 

(12)                 CROSS-BORDERDATA TRANSFER

Wemay transfer, store or process your Personal Data in countries outside thecountry from which you accessed our website. We will take appropriate measuresin accordance with applicable laws to ensure that your Personal Data receivesan adequate level of data protection upon its transfer.

 

(13)                 CHILDREN

Ourwebsite and services are not intended for use by children, and we do notknowingly collect or maintain information about children. Please contact usat Support@vybs.co ,if you have reason to believe that a child has shared any information with us.