PRIVACY POLICY 

1. INTRODUCTION 

Columbus is a B2B app, together with the websites www.columbusapp.ai and www.columbusapps.com  
(collectively referred to as the "Platform"), are managed and operated by Diplomat Distributors (1968) 
Ltd. (“Diplomat”, “we”, “us”, “our”). The Platform is provided as a Software-as-a-service (SaaS) for 
distributors and their affiliated retailers and agents. 

This Privacy Policy details how we collect and use personal data via the Platform, the types of personal 
data we collect, how we use your personal data, who we share it with and more.  

This Privacy Policy applies to the main personal data processing activities the Platform performs, in 
relation to the following Platform users’ : (1) Distributors including their agents that use the Platform to 
process and fulfil retailers orders (the “Business”); (2) retailers (end-users) who purchase products from 
Businesses using the Platform (the “End User”); together the Business and the End User, the “User” or 
"Users").  

The information you provide us is subject to your consent and is not legally required. Personal data will 
be stored in Diplomat's databases in accordance with the purposes set out in this Privacy Policy. Your use 
of the Platform constitutes your consent to this Privacy Policy. For the avoidance of doubt, if you do not 
agree to the terms of this Policy — including providing your personal data to Diplomat — you must cease 
all use of the Platform. In such a case, the Company will be unable to provide you and/or anyone on your 
behalf with the services provided by the Platform. 

2. WHAT PERSONAL DATA DO WE COLLECT ABOUT YOU?  

Depending on the nature of your relationship with the Platform (i.e. whether you are a Business, an End 
User, or other type of Users), we collect, use and process the following categories of personal data: The 
Platform collects and processes personal data provided by Users, including name, company number, 
contact details (phone, mobile phone, email), address and login password for the Platform.  

2.1. We also collect details about purchases made in the Platform, including order history, the contents of 
the User’s order basket, payment methods and credit card token.  

2.2. If you are a Business agent, we may collect your geo-location and timestamp when you press 
"Start/End Visit" or "Start/End Day" (if your Business uses this feature). 

2.3. Any other information submitted by the User or received by the Platform in connection with their 
use of the Platform may also be collected.  

2.4. Usage Data that may be collected also, automatically either generated by the use of the Platform or 
from the Platform infrastructure itself,  including information such as your device’s internet protocol 
(IP) address, device type, operating system and version, browser type and version, the time and date 
of your use, the time spent on the Platform, unique device identifiers, and other diagnostic data to 
improve functionality and user experience.  

2.5. Non-Identifying Information – Please see our separate dedicated section about it (Section 10). 

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3. WHAT ARE THE PURPOSES OF THE COLLECTION AND/OR OF THE PROCESSING OF 
YOUR PERSONAL DATA (the “Purposes”)? 

When we process personal data, we collect and use your personal data for the following purposes:  

3.1. For and in connection with the provision of the services provided by the Platform or anyone on 
its behalf; 

3.2. Activating and managing the Platform including marketing, advertising, sales promotion and 
encouragement of purchases; 

3.3. In order to enable the actions to be performed through the Platform by the User; 

3.4. For the development and operation of the Platform; 

3.5. For the maintenance of the Platform and monitoring the activity of the User therein; 

3.6. For improving the quality of the services provided by the Platform; 

3.7. For making contact with the User; 

3.8. For the purpose of compiling statistical data and transferring information, including statistics or 
other, to third parties; 

3.9. For analysis, and research and compilation of statistics; 

3.10. For conducting surveys among the Users; 

3.11. Analysis of profiles of Users of the Platform for marketing products, including but not limited to 
on the internet; 

3.12. For the purpose of sending by electronic means advertisements, information about products and 
services, benefits, promotions, discounts and marketing information; 

3.13. For internal needs of the Platform; 

3.14. For defending against lawsuits, demands and claims against the Platform and anyone on its behalf, 
and against third parties; 

3.15. For enforcing the provisions of this Privacy Policy; 

3.16. For complying with the provisions of any law. 

4. WE MAY COLLECT THE ABOVEMENTIONED PERSONAL DATA IN THESE WAYS:  

Information you provide directly, such as when placing orders or interacting with the Platform; data related 
to services provided through the Platform, including purchase history and order details; and data 
automatically collected during your use of the Platform. 

5. WHAT IS THE LEGAL BASIS FOR THE PROCESSING OF YOUR PERSONAL DATA?  

We collect and use your personal under the following legal basis: 

• As a result of your consent: By using the Platform you have agreed to the Platform and to this Privacy 
Policy.  

• To comply with contractual obligations: Following a contractual agreement between us, to provide 
you with our Platform or services, processing of Personal Data is necessary in order to fulfil our 
commitments in accordance with the contractual agreement; 

• Within the scope of a legitimate interest: On occasion, taking into account the minimum privacy 
impact for you, the processing of your Personal Data might be necessary: 

▪ For the administration, management and performance of our business relationship, if any, 
including accounting, auditing, performance of contracts; 

▪ For the analysis and optimisation of our Platform or services; 

▪ For ensuring IT security (to detect security threats, frauds or other malicious or criminal 
activities) and the IT operation of The Platform; 

▪ For prevention and investigation of criminal acts; 

▪ For communication purposes to keep you up-to-date on the latest information about our 
services, solution and/or business activities, events, marketing campaigns, market analysis or 
other promotional activities and for analysis and improving the quality of our Platform and 
services and communication with you (subject to the law and to receiving your specific 
consent to receive such information, if such consent is required by law); 

▪ For monitoring the compliance with our policies and standards; 

• On the basis of our legal obligations or in the public interest: The Platform, as any other company, 
is subject to legal obligations and regulations. In some cases, the processing of your Personal Data will 
be necessary in order to fulfil these legal obligations.  

6. WHO WILL RECEIVE YOUR PERSONAL DATA?  
As part of providing the services and/or fulfilling the Purposes, we may disclose Personal Data to 
third parties, as detailed below: 

6.1. We may share your personal data with third-party service providers who assist us with various 
operations, including IT services, security systems, storage (including cloud storage), payment 
processing, website development and operation, survey and research services, marketing, legal and 
professional consulting, logistics, and other services that support our activities.  

6.2. Your personal data may be disclosed to courts, law enforcement, regulatory authorities, or other 
government entities if required by law, such as responding to a legal order, court directive, or other 
binding legal processes. 

6.3. In the event of a merger, acquisition, reorganization, sale, or transfer of Diplomat or its assets 
including the Platform (in whole or part), your data may be shared with relevant third parties involved 
in the transaction. This includes evaluating the feasibility of such activities. 

6.4. If necessary, we may share your personal data in cases of disputes, claims, lawsuits, or if we suspect 
fraud, illegal activities, or potential harm to the Platform, our users, or others. This includes situations 
where we believe sharing the personal data is essential to protect our rights or prevent harm. 

6.5. We may share your personal data with affiliates and business units within Diplomat Group, including 
any entity that controls Diplomat, is controlled by Diplomat, and/or is under common control with 
Diplomat, whether directly or indirectly ; 

6.6. Your personal data may be transferred to third parties outside your country, including to countries 
with different privacy laws that may offer less protection than local laws. In such cases, Diplomat 
will take appropriate steps to ensure adequate protection of your Personal Data.  

6.7. We do not store credit card information. Payment details are entered into a secure third-party payment 
provider's system, and we do not have access to this information. You are encouraged to review the 
privacy policy of the payment provider before making a purchase. 

6.8. Please note that when we share your Personal Data with a third party pursuant to this Policy, and/or 
with your consent or at your request, and/or in order to provide services you requested, such data 
will be subject to the privacy policies and practices of the relevant third party, and Diplomat shall 
not be held responsible for any use made by such parties . 

7. DATA RETENTION  
We will retain your Personal Data for the period necessary to fulfil the purposes outlined in this Privacy 
Policy, unless a longer retention period is required or permitted by law. 

8. YOUR DATA PROTECTION RIGHTS  

Depending on your location and applicable law, you may have certain rights regarding your personal data. 
These rights may vary based on which User you are with respect to your location and the applicable law, 
you may exercise your rights directly with us by contacting us at support@columbusapp.ai.  

In case of doubt of your identity, we may ask you to justify it by enclosing a copy of any identity document, 
subject to the applicable law. 

9. SECURITY 
We implement appropriate technical and organizational measures to ensure an appropriate level of security 
to personal data, considering the risks that are presented by processing, in particular from accidental or 
unlawful destruction, loss, alteration, unauthorized disclosure of, or access to personal data transmitted, 
stored, or otherwise processed.  We do not guarantee however, that it will not be subject to a security event. 
We may be required, due to legal or other obligations outside our control, to transfer the personal data 
about you to third parties, such as public authorities. In such circumstances, we have limited control over 
the level of protection provided to the personal data by such third parties. Any transfer of personal data via 
the internet cannot be fully secured.  

10.  NON-IDENTIFYING INFORMATION. 

10.1. The Platform uses Cache and other technologies (hereinafter: “Technologies for Collecting Non-
Identifying Information”) through which the Platform collects non-identifying information in 
connection with Users of the Platform. Without derogating from the aforesaid, if a User chooses to 
provide identifying information, this information will be linked to the non-identifying information 
collected in the Platform. 

10.2. The Platform collects non-identifying information that includes the type of the device, the operating 
system, the version of the Platform, the pages the User visited in the Platform, actions performed by a 
User in the Platform, the time spent using the Platform, information the User viewed in the Platform, 
approximate geographical location (when applicable), the number of times the Platform was entered 
into, the number of clicks, screen resolution, language preference and more. 

10.3. The Platform will use the non-identifying information for one or more of the following purposes: to 
manage and operate the Platform; to facilitate the use of the Platform; to analyze, research and perform 
controls in connection with the Platform; to monitor activity patterns in the Platform; to compile 
statistics including calculating Platform User numbers; to analyze, research and perform controls in 
connection with the Platform and to send product rating requests after purchase. In addition, and 
without derogating from the provisions of this policy, the Platform uses tools that record the browsing 
of the Users in the Platform for the purpose of analyzing and improving the User experience in the 
Platform.  

10.4. The Platform uses analytics, statistical analysis and research services of third parties such as but not 
limited to, Google Analytics. Use of Google Analytics services is subject to the Google Analytics 
Terms of Service and Privacy Policy. You can learn about the information collected in the framework 
of these services, the uses of the information, how cookies are canceled and more in Google’s Privacy 
Policy. 

11. PERSONAL DATA OF THIRD PARTIES 

If you provide the Platform with personal data of third parties, you warrant and represent that you will 
provide such personal data in accordance with the applicable law, inter alia, provide all appropriate notices 
required under the applicable law, if required; And/or obtain all required informed consents and/or 
establish any and all ongoing legal bases, if required by applicable law, for allowing the Platform and/or 
its affiliates, third-party vendors and other entities to use and process personal data in accordance with this 
Privacy Policy, for the purposes detailed in this Privacy Policy. 

12. LINKS AND HYPERLINKS 

The Platform may offer links, hyperlinks, or banners to other websites or third-party applications that the 
Platform does not monitor or verify for reliability or legality, including anything related to their security 
and privacy protection policies. Diplomat shall not be responsible for the use made by you of the links 
appearing in the Platform, directing to pages or platforms not managed by the Platform, or displayed 
through other websites or applications. You are responsible for complying with the provisions and 
conditions of those websites or applications and must contact their providers directly in connection with 
any issues that may arise regarding privacy, access, browsing, use, or related matters. Therefore, the 
Platform will not bear any responsibility, of any kind, in connection with third-party websites or 

applications, including matters related to the collection, use, or transfer of information on such platforms, 
the content published on their pages, and more. 

13. CHANGES TO THE PRIVACY POLICY 

We may modify or amend this Privacy Policy from time to time at our discretion. When we make changes 
to this Privacy Policy, we will amend the revision date at the bottom of this page and such modified or 
amended Privacy Policy shall be effective as to you and your information as of that revision date. We 
encourage you to review this Privacy Policy regularly to stay informed about our information practices 
and the choices available to you. 

Last updated: September 2025