CRUNCH SOLUTIONS FZCO (“WAGS”) offer employee analysis software, including WAGS AI HR service which can help prevent burnout, engagement shifts, and team dynamics (“WAGS Product”). WAGS understands the importance of protecting Personal Information (as defined below). For this reason, WAGS strives to have business procedures and security safeguards in place to protect Personal Information under its control.

1. Scope of this policy
This privacy policy (the “Policy”) describes WAGS ’s practices with respect to the collection,use and disclosure of Personal Information.
This Policy is intended to establish responsible and transparent practices for the management of Personal Information, and to satisfy applicable legal requirements. This Policy sets out the standards, responsibilities and obligations of WAGS in respect of any Personal Information collected, accessed or processed by WAGS in the course of its business operations, and specifies WAGS ’s obligations arising from the WAGS Product-Specific Terms (available at https://wags-ai.com/terms) (collectively the “Terms”) entered into between WAGS and its corporate customers (each, a “Customer”), which establish how WAGS might process or have access to Personal Information.  
This Policy also governs Personal Information collected about WAGS ’s website users or users of the WAGS Products (the “Users”) and explains how WAGS processes Personal Information collected from people who visit its website and otherwise interact with WAGS through https://wags-ai.com/ (the “Website”) or through the WAGS Products. It also explains how WAGS uses cookies and similar technologies. Users who do not agree with this Policy shall not access or use the WAGS Products and any related services (collectively, the “Services”) or the Website.
To the extent WAGS provides the Services to an organization (e.g. to a User’s employer), WAGS, as a data processor, processes such User’s Personal Information under such organization’s instructions as a data controller.

2. Definition of Personal Information
“Personal Information” is defined as any information about an identifiable individual. This may include, for example, email addresses and contact details and any similar information provided to WAGS in the course of its business operations, or which WAGS may receive from business inquiries. Personal Information that cannot be associated with an identifiable individual, for instance through aggregation or anonymization, is no longer considered Personal Information.

‍3. International Compliance
WAGS complies with: (i) data protection laws applicable to WAGS; (ii) anti-spam legislation applicable to WAGS; and (iii) applicable industry standards concerning data protection, confidentiality or information security.
WAGS has global operations and therefore, in some cases, Personal Information managed by WAGS may be transferred to, processed and stored in jurisdictions outside the country in which it was collected. In such cases, WAGS ensures that Personal Information is protected in accordance with applicable Privacy Laws, including through the implementation of appropriate safeguards such as Standard Contractual Clauses, the UK International Data Transfer Addendum, or other legally recognized transfer mechanisms.
WAGS complies with applicable data protection laws in the United Arab Emirates, including Federal Decree-Law No. 45 of 2021 Regarding the Protection of Personal Data (PDPL) and, where applicable, the Data Protection Regulations of the International Free Zone Authority (IFZA).
WAGS also complies with the General Data Protection Regulation (Regulation (EU) 2016/679), the UK GDPR and other applicable international data protection laws.
Where required, WAGS shall cooperate with and be subject to the oversight of competent supervisory authorities, including, where applicable, the UAE Data Office or relevant IFZA regulatory authority.
WAGS also complies with the General Data Protection Regulation (Regulation (EU) 2016/679) and the Data Protection Act 2018 and the GDPR as saved into United Kingdom law by virtue of Section 3 of the United Kingdom’s European Union (Withdrawal) Act 2018. Where applicable, WAGS ’s commitment to such regulation may be found in the WAGS Products’ respective Data Processing Addendums (available at https://wags-ai.com/dpa). WAGS (or third parties acting on WAGS ’s behalf) may transfer Personal Information that WAGS collects to countries outside of the European Economic Area. Where such transfer occurs, WAGSwill take steps to ensure that Personal Information is protected. WAGS will make such transfers only if at least one of the following conditions is present:
a. WAGShas entered into a contract based on the “Standard Contractual Clauses” (including the United Kingdom’s International Data Transfer Addendum), provided that such contract, combined with technical and organizational measures, offers appropriate safeguards for the rights of the individuals whose personal data is being transferred;
b. Such transfer is governed by “Binding Corporate Rules”, which have been approved by data protection authorities; or
c. Such transfer is covered by a European Union Commission “adequacy decision”.

4. Collection of Personal Information through the Services
WAGS collects information about its Users either directly from them, through their use of the Services or of the Website, or when they are provided by another source, as detailed below.
a. Information provided by Users
Users may provide WAGS with Personal Information by inputting it directly into the Services or via another direct channel such as WAGS ’s customer support system. Such information may include:

• Account and profile information: When Users register for an account, WAGSmay collect Personal Information such as contact information, information allowing WAGS to better know who Users are, and information regarding User preferences, such as preferred language. Some Services may also allow Users to input a profile picture, a display name, job title, location and similar information.
• Content provided in a support context: By using the Services, Users may interact with WAGS ’s Customer Success team if they encounter a problem with the Services, or simply if they wish to learn more about WAGS products. In doing so, Users may submit contact information and other Personal Information to WAGS ’s Customer Success in order for them to identify and better assist the Users.
• Payment information: WAGS asks Customers to designate a representative for billing purposes. WAGS thus collects that person’s name and contact information, together with the relevant payment details, which are collected through a trusted payment processing service.

b. Information collected when Users use the Services
In order to provide the Services, WAGScollects information about how Users interact with the Services under certain circumstances.

• Technical information about a User’s device: WAGS collects information about the devices used to connect to, or interact with, the Services. This information may include the type of device used, the type of connection used to access the Services, a User’s IP address, browser type and device identifier. This information may be used to guess the User’s approximate location (i.e. country from where Services are accessed) so as to offer a better experience.
• Use of the Services: WAGS collects information about its Users when they use the Services. Depending on the Services used, this information may include the features used, the links clicked on, information about other Users interacted with, and other similar information.
• Cookies: WAGS uses cookies and other tracking technologies to provide certain security and product functionalities, and to recognize Users and their preferences across various platforms and devices.

c. Information collected by Customers and through other third parties
WAGS may collect information about its Users through trusted partners, other Users, related companies and more importantly, from WAGS ’s Customers.

• Information provided by Customers: WAGS ’s Customers may provide WAGS with information about Users when they set up an account in their name in their capacity as the Users’ employer or service provider. Such information may include a User’s name, contact information and other personal characteristics, such as compensation information, kept in a Customer’s human resources information system or applicant tracking system. Personal Information may be collected directly from third parties via data integrations in accordance with a Customer’s instructions.
• Information provided by other Users: When Users submit content through the Services, they may submit Personal Information about other Users, such as their name, contact information, job title or similar information relating to their employment, including information relating to employee performance and employee compensation.
• Information provided by third-party services: WAGS collects information about Users when they connect a third-party service to their account, for instance to facilitate login or to integrate the Services within an external platform. WAGSmay also collect information when Users authorize the Services to synchronize with their calendar or with a contact list.
• Information provided by WAGS’s affiliated companies: WAGS collects information from its affiliated companies in accordance with their own privacy policy.
• Information collected by partners and service providers: WAGS may collect information about Users from its business and research partners who provide WAGS with information on Users’ interests and engagement with WAGS Services. WAGS may also collect profiling information disclosed by its marketing and advertising partners, or by partners with whom WAGS organizes and promotes events, insofar as this collection and disclosure are permitted by such partners’ privacy policies.

5. Collection and Use of Personal Information through the Website
WAGS generally collects and uses Personal Information from or about its Website Users as follows:
a. Information Provided by Users
In many cases, WAGS collects Personal Information directly from Users when they visit or use the Website. For instance, WAGS may collect the following types of information:  

• Inquiries and Requests for a Trial or Service. WAGS may collect a User’s name, contact information, email address and any other information provided when they make an inquiry or contact WAGS through the Website, when they sign up to receive WAGS ’s newsletter or when they submit a request or an order for a WAGS trial or service.  
• Personalization of Website. When Users visit the Website, they may, from time to time, be invited to provide information, such as their job title, to help WAGS personalize or customize the User’s experience when using the Website.

b. Technical Information.
When Users visit the Website, WAGS may collect technical information using electronic means such as cookies. This information may include information about visits to the Website, including the IP address of the User’s computer and which browser was used to view the Website, the User’s operating system, screen resolution, approximate location, browser language settings, the site the User came from, keywords searched (if arriving from a search engine), the number of page views, information entered, advertisements seen, etc. This data is used to measure and improve the effectiveness of the Website or to enhance the experience for Users. While most of the time this information is depersonalized, if this information relates to an identifiable individual, WAGS will treat this information as Personal Information. WAGS may also, without limitations, collect and use the following types of information when Users visit and/or interact with WAGS on the Website:  

• Google Analytics. WAGS uses Google Analytics which allows it to see information on User website activities including, but not limited to, page views, source and time spent on the Website. This information is depersonalized and is displayed as numbers, meaning that it cannot be tracked back to individuals. Users may opt-out of WAGS ’s use of Google Analytics by visiting https://tools.google.com/dlpage/gaoptout.

c. Choice with Cookies
Users can block the use of cookies via the Website’s cookie banner, or via their browser’s settings. The “Help” feature on most browsers will tell Users how to prevent their browser from accepting new cookies, how to have the browser notify the Users when they receive a new cookie, or how to disable cookies altogether. If Users choose to withhold consent, or subsequently block cookies, they may not be able to access all or part of the content of the website. Additionally, Users can disable or delete similar data used by browser add-ons, by changing the add-on’s settings or visiting the website of its manufacturer.

d. Privacy Policies of other Websites
This Policy only addresses the use and disclosure of information by WAGS. Other websites that may be accessible through the Website have their own privacy policies and data collection, use and disclosure practices.  

6. Use of Personal Information
When providing the Services, WAGS only processes Personal Information in accordance with the Terms and applicable laws. WAGS generally uses Personal Information from or about its Customers and Users for the following purposes:
a. to create, establish and administer Customer’s account, to process payments, to respond to Customer’s inquiries related to its account and to contact Customer about WAGS ’s Services or account-related matters;
b. to provide Services, including to provide Customer and its Users with access and use of the WAGS Products and customer support;
c. to send transactional communications, such as purchase confirmation, renewal notifications, and information related to User activity on the WAGS Products, such as technical notices, release notes, security alerts and other messages related to the administration of the WAGS Products;
d. to measure and analyze User behavior;  
e. to monitor, maintain and improve WAGS’s Services or features;
f. to understand how Users interact with WAGS and ensure its services, products or features work correctly;
g. to develop new services, products, features, programs and promotions;
h. to understand Customers’ and Users’ needs and preferences and customize how WAGS tailors and markets products, programs and Services to its Customers and Users based on their interest;
i. to meet legal and regulatory requirements and to allow WAGS to meet contractual requirements relating to the Services provided to Customer;  
j. to conduct surveys on the quality of WAGS ’s Services or to collect feedback on the Services;
k. to provide Users with offers for additional services, features and products that WAGS believes may be of interest to Users (Users can opt-out of such communications by using the “unsubscribe” link provided in such communications); and
l. to measure the effectiveness of WAGS ’s marketing.
Whenever possible, WAGS will use Personal Information in a depersonalized, aggregated and/or anonymized format.
Unless required or authorized by law, WAGS will not use Personal Information for any other or new purpose without obtaining prior consent.  
WAGS may use automated systems, analytics tools or artificial intelligence technologies in connection with the Services. Such Processing is carried out in accordance with applicable Privacy Laws, including the UAE PDPL, and WAGS implements appropriate safeguards to protect the rights and freedoms of individuals, including measures designed to prevent unlawful or discriminatory impacts.

7. Legal bases for processing Personal Information
Pursuant to privacy laws applicable in the European Economic Area and in the United Kingdom, WAGS collects and processes Personal Information about individuals under a variety of legal bases, depending on the reason for such collection or processing. WAGS shall only collect, process or use Personal Information where:

• Personal Information is required to provide the WAGS Products and all services ancillary to the proper functioning of the WAGS Products, such as support services, to provide a personalized experience, and to ensure the security of the WAGS Products;
• The Customer or User gave WAGS consent to use Personal Information for a specific purpose (including for a purpose listed under section 6 hereof);
• Processing of Personal Information is necessary to comply with a legal obligation;
• Processing of Personal Information is warranted by a legitimate interest of WAGS (which is not overridden by your data protection interests), such as the purposes listed in paragraphs (d), (e), (f), (g), and (h) of section 6 hereof, or to protect WAGS ’s legal rights and interests.

If a User has consented to WAGS ’s use of their Personal Information, the User can withdraw their consent at any time, although this will not affect processing which took place prior to withdrawal. Where WAGS processes a User’s Personal Information because it relies on WAGS ’s legitimate interests, objecting to the processing may mean the User will no longer be able to use or access the Services or the Website.
Where the Processing of Personal Information is subject to applicable laws of the United Arab Emirates, WAGS shall ensure that such Processing is based on lawful grounds recognized under the PDPL, including consent, contractual necessity, compliance with legal obligations or other lawful bases as provided under applicable law.

8. Disclosure of Personal Information
WAGS will not sell, rent or trade Personal Information to any third party. WAGS does not share Personal Information with third-party tools, including AI models, except with permission from Customers or Users. However, WAGS may disclose Personal Information when authorized and/or required by law or as follows:
8.1. In the context of the Services. The content shared by Users on the Services and account or profile information linked to Users’ accounts may be accessed by other Users from within their organization, and sometimes from outside their organization provided they were granted permission by their organization to access this information. Customer administrators may use this information in accordance with their organization's policies. WAGS may also use the collected information for marketing or statistical purposes insofar as they are directly related to the training they provide.
8.2 Service Providers. WAGS may grant access to Personal Information to third-party service providers who process it on behalf of WAGS to help provide and improve the Website and Services. Before disclosing any Personal Information with any of its third-party service providers, WAGS will ensure that the third party maintains data management practices for maintaining the confidentiality and security of Personal Information and preventing unauthorized access which comply with applicable industry standards and privacy laws.
8.3 As Permitted or Required by Law. WAGS may disclose Personal Information as required by applicable law or by proper legal or governmental authority. WAGS may also disclose information to its accountants, auditors, agents and lawyers in connection with the enforcement or protection of its legal rights. WAGS may also release certain Personal Information when it has reasonable grounds to believe that such release is reasonably necessary to protect the rights, property or safety of others and itself, in accordance with or as authorized by law. In the event WAGS receives a governmental or other regulatory request for any Personal Information, WAGS will promptly notify Customer and/or Users, unless it is prohibited to do so, in order that Customer and/or Users shall have the option to defend such action. WAGS shall reasonably cooperate with Customer and/or Users in such defense.
8.4 Business Transaction. WAGS may disclose Personal Information to a third party in connection with a sale or transfer of business or assets, an amalgamation, re-organization or financing of parts of its business. However, in the event the transaction is completed, Personal Information will remain protected by applicable data protection laws. In the event the transaction is not completed, WAGS will require the other party not to use or disclose the Personal Information received in any manner whatsoever and to delete such Personal Information.

9. Security of Personal Information
WAGS will store and process the Personal Information in a manner consistent with industry security standards. WAGS has implemented technical, organizational and administrative systems, policies, and procedures to help ensure the security, integrity and confidentiality of Personal Information and to mitigate the risk of unauthorized access to, or use of, Personal Information, including: (i) appropriate administrative, technical and physical safeguards and other security measures designed to ensure the security and confidentiality of the Personal Information it manages; (ii) a security design intended to prevent any compromise of its own information systems, computer networks or data files by unauthorized users, viruses or malicious computer programs; (iii) appropriate internal practices including, but not limited to, encryption of data in transit; using appropriate firewall and antivirus software; maintaining these countermeasures, operating systems and other applications with appropriate reasonable up-to-date virus definitions and security patches so as to avoid any adverse impact to the Personal Information that it manages; (iv) appropriate logging and alerts to monitor access controls and to assure data integrity and confidentiality; and (v) permitting only authorized users access to systems and applications, and all persons with authorized access to Personal Information must have a genuine business need-to-know prior to access.  

10. Data Retention
WAGS will retain the Personal Information as necessary for the purposes described in this Policy, unless a longer retention is required by law or justified by a legitimate business interest of WAGS, subject to applicable laws. Personal Information related to a User’s WAGS Product account is retained so long as the account is active, in accordance with Customer’s instructions. Some Personal Information about a User’s account may be retained after the account is deactivated in order for other Users to make full use of the Services. Notwithstanding the foregoing, upon termination of the Terms, WAGS shall retain the Personal Information stored in the WAGS Products until Customer instructs WAGS to delete the Personal Information or until Customer’s access to the Services is terminated in accordance with the Terms, whichever occurs first.
Upon expiry of the retention period, Personal Information is either deleted or permanently de-identified. Notwithstanding the applicable retention period, where Personal Information is kept in a backup, it will be stored in accordance with this Policy until it can be deleted, and it will not be used for any purpose other than as a backup copy.

11. Training and Supervision
WAGS maintains adequate training programs to ensure that its employees and any third parties acting on its behalf are aware of and adhere to its Security Program. WAGS shall exercise necessary and appropriate supervision over its relevant employees to maintain the appropriate confidentiality and security of the Personal Information it manages.

12. Data Incidents Involving Personal Information
WAGS shall promptly notify Customer of a data breach, of a loss of data or of a failure of WAGS’s Security Program:
(a) which has resulted or is suspected to have resulted in the loss, unauthorised access, disclosure, use or acquisition of Personal Information (including hard copy records); and
(b) which presents a real risk of significant harm to individuals whose Personal Information is impacted (“Data Incident”).
While the initial notice may be in a summary form, a comprehensive written notice shall be given to Customer within the legally required timeframe, where applicable. The notice shall summarize in reasonable detail the nature and scope of the Data Incident (including each data element type) and the corrective action taken or to be taken by WAGS. WAGS shall promptly take all necessary and advisable corrective actions, and shall cooperate with Customer in all reasonable efforts to mitigate the adverse effects of Data Incidents and to prevent their recurrence.

13. Users Legal Rights Regarding Personal Information
To the extent that WAGS ’s processing of Personal Information is subject to the General Data Protection Regulation (Regulation (EU) 2016/679) or to the Data Protection Act 2018 and the GDPR as saved into United Kingdom law by virtue of Section 3 of the United Kingdom’s European Union (Withdrawal) Act 2018, WAGS relies on the legal bases described under section 7 hereof to process Personal Information. Subject to applicable laws, all Users have the right to: (i) access and rectification or erasure of Personal Information, including erasure and deletion of their profile on the WAGS Products, except to the extent that WAGS may need to retain certain Personal Information, including for record keeping purposes or to comply with legal obligations; (ii) restrict or object to WAGS’s use of Personal Information (though, in some cases, this may mean no longer using the Services or the Website) where WAGS is relying on a legitimate interest (or those of a third party) and there is something about User’s particular situation which impacts on User’s fundamental rights and freedoms; (iii) lodge a complaint with their local data protection authority; and (iv) data portability. Users will not have to pay a fee to exercise such rights, however, WAGS may charge a reasonable fee or refuse to comply if the request is unfounded, repetitive or excessive.
To the extent that WAGS’s Processing of Personal Information is subject to applicable laws of the United Arab Emirates, Users may also have rights under the PDPL, including the right to access Personal Information, request correction or erasure, restrict Processing and object to certain Processing activities, in accordance with applicable law.

14. How to Contact Us
Any questions, complaints or requests regarding this Policy or WAGS’s handling of Personal Information can be addressed to WAGS’s customer service at:
https://wags-ai.com
Аttention: Data Protection Officer
IFZA Business Park, DDP, 25851 - 001, Dubai, United Arab Emirates
email: b.frischter@wags-ai.com

A User who seeks to exercise their data protection rights referred to in Section 13, in respect of Personal Information stored or processed by WAGS on behalf of a Customer (typically the User’s employer), should direct their request to such Customer, as the data controller. If WAGS receives such a request, WAGS shall redirect the User to the relevant Customer and, upon request from the Customer, shall assist the Customer in responding to such request, where applicable.
WAGS’s Data Protection Officer will respond to User requests within the timeframe required under applicable Privacy Laws and, in any event, without undue delay. WAGS will advise a User in writing of its response. Where WAGS refuses to act on a request, it will inform the User of the reasons for such refusal, as well as the remedies available to them and the applicable time limits.
Should a User be unsatisfied with the outcome of their request, they may lodge a complaint with a competent supervisory authority in their jurisdiction, including, where applicable, the UAE Data Office or relevant IFZA regulatory authority, or another applicable data protection authority.

15. Change to Privacy Policy
WAGS will review and update its policies and procedures as required to keep current with rules and regulations, new technologies, standards and customer concerns. This Policy may therefore change from time to time. If WAGS makes changes that materially alter Users privacy rights, WAGS may provide additional notice, such as via email or through the Services or the website. If Users disagree with the terms of this Policy, their only remedy is to discontinue use of the websites and the Services.

This Policy Published on March 23^th, 2026.