Privacy Policy

Introduction

This Privacy Policy (“Policy”) describes how personally identifiable information (“Personal Information”) you may provide through the Connect Persona software applications (“Software Applications” or “Service”) and any of its related products and services (collectively, the “Services”) is collected, protected, and used. It also outlines the choices available to you regarding our use of your Personal Information, and how you can access and update this information.

This Policy is a legally binding agreement between you (“User”, “you” or “your”) and anka EK LLC (“anka EK”, “we”, “us” or “our”), the operator of the Connect Persona platform.

By accessing and using the Software Applications and Services, you acknowledge that you have read, understood, and agree to be bound by the terms of this Policy.

This Policy does not apply to the practices of companies we do not own or control, or to individuals we do not employ or manage.

Automatic collection of information

At Connect Persona, your data security is our top priority. We process only the minimal amount of user data necessary to maintain and operate the Software Applications and Services effectively.

Any information collected automatically is used solely to detect potential misuse, ensure system integrity, and generate statistical insights about how the Services are being used. This helps us improve performance without compromising your privacy.

Collection of personal information

You can access and use the Connect Persona Software Application and Services without identifying yourself or revealing any information that could be used to recognize you as a specific individual. However, to access certain features of the Software Applications, you may be asked to provide specific Personal Information—such as your name, email address, or other contact details.

We collect and store any information you knowingly provide when you create an account, interact with certain features, make purchases, or complete any online forms within the application.

Depending on your use of the Services, the information we collect may include:

• Personal details (e.g., name, country of residence, State and Street Addresses)
• Contact information (e.g., email address, phone number, mailing address, Social Media Credentials)
• Account details (e.g., username, unique user ID, password)
• Payment details (e.g., credit card, bank account information, billing address, Payment Wallet Credentials)
• Geolocation data (e.g., latitude and longitude, if location access is granted)
• Access to mobile features, where explicitly permitted by the user (e.g., contacts, calendar, photo gallery)

In relation to staff, collaborators, and job applicants, we may collect additional information including:

• Work experience, qualifications, skills, and references
• Background screening results (e.g., identity, eligibility to work, criminal record, directorship, or health checks)
• Drug and alcohol test results, where applicable
• Performance, conduct, and usage of workplace resources and IT systems
• Payroll, tax, and benefit-related information
• Emergency contact details

Some of this information may be collected to ensure compliance with applicable laws and regulations, including (but not limited to) U.S. federal and state labor laws, tax laws, occupational health and safety legislation, and anti-discrimination requirements.

Direct and third party collection of data

Some of the Personal Information we collect is provided directly by you through the Connect Persona Software Applications and Services. However, we may also collect information about you from external sources, including public databases, social media platforms, third-party data providers, joint marketing partners, and Partners of Connect Persona.

The types of Personal Information we may collect from such sources include:

• Demographic details (e.g., age, gender)
• Device-related data (e.g., IP address, device type, browser)
• Geolocation information (e.g., city and state)
• Online behavioral data (e.g., page views, search results, social media interactions, referral links)

Providing your Personal Information is optional, but please note that declining to do so may limit your access to certain features of the Software Applications.

If you're unsure which information is required or have questions about our data collection practices, you are encouraged to contact us directly for clarification.

Cookies

Our websites may use cookies to enhance your browsing experience. A cookie is a small file of letters and numbers placed on your device—if you allow it—when you visit our site. These cookies help us recognize your device on future visits, allowing us to distinguish you from other users and improve both the functionality and personalization of your experience.

We use cookies to:

• Remember your preferences and settings
• Analyze site performance and usage patterns
• Provide a smoother and more tailored experience across sessions

If you prefer not to use cookies, you can adjust your browser settings to block or delete cookies. However, please note that doing so may impact your ability to fully access all features of our website, and could affect the performance and usability of the Services.

Website analytics

Our website uses analytics and monitoring tools such as Google Analytics, Segment, Amplitude, and Datadog to help us better understand user behavior, traffic patterns, and performance metrics. This information allows us to continually improve the quality, stability, and usability of our Services.

While the data collected by these tools is primarily anonymous and aggregated, in certain cases it may be linked to identifiable individuals — for example, when combined with other Personal Information you voluntarily provide through your use of Connect Persona.

We use this data strictly to enhance user experience and system reliability, in accordance with our privacy and data protection practices.

Use and processing of collected information

To provide you with access to the Connect Persona Software Applications and Services, or to comply with applicable legal obligations, we may need to collect and process certain Personal Information. If you choose not to provide this information, we may be unable to deliver some or all of the Services you request.

We may use the information we collect from you for the following purposes:

• Create and manage user accounts
• Deliver requested products or services
• Improve our products, services, and features
• Send important administrative updates
• Respond to user inquiries and provide support
• Solicit user feedback for product enhancement
• Enhance overall user experience
• Enforce our Terms of Service and policies
• Detect, prevent, and protect against abuse or malicious activity
• Comply with legal requests and mitigate potential harm
• Operate and maintain the Software Applications and Services

The legal basis for processing your Personal Information depends on how you interact with the Services, your geographic location, and applicable law. Processing may be based on one or more of the following grounds:

• Your explicit consent for one or more specific purposes (Note: This may not apply when the processing falls under the California Consumer Privacy Act or certain European data protection laws.)
• Contractual necessity, where processing is required to perform our agreement with you or pre-contractual obligations
• Legal obligations, where we are required to process data to comply with applicable laws
• Public interest or official authority, where processing is related to tasks carried out under legal authority
• Legitimate interests, pursued by us or by a third party, provided they do not override your fundamental rights and freedoms

In some jurisdictions, we may process your Personal Information without relying on consent, as long as you have not opted out of such processing. We are always happy to clarify the legal basis applicable to your situation — including whether providing your data is legally or contractually required, or necessary to enter into an agreement with us.

Billing and payments

We use third-party payment processors to handle your payment transactions securely. These processors manage your payment information in accordance with their own privacy policies, which may differ from or offer different levels of protection compared to this Policy.

While we take care to partner with trusted providers, we recommend that you review the privacy policies of any third-party payment services you interact with through Connect Persona to understand how your Personal Information is handled.

Managing information

You have the ability to delete certain Personal Information that we hold about you. The specific types of data you can delete may vary depending on the current functionality and features of the Connect Persona Software Applications and Services.

When you choose to delete your Personal Information, please note that we may retain a secure copy of the original (unrevised) data in our records if required to:

• Comply with legal, regulatory, or contractual obligations
• Fulfill commitments to our affiliates, partners, or service providers
• Enforce our Terms of Service or prevent fraud and misuse
• Maintain business continuity or audit trails in accordance with industry practices

If you would like to delete your Personal Information or permanently close your account, you may do so by contacting us directly through our support channels.

Disclosure of information

Depending on the Services you request, or as necessary to complete transactions or provide functionality, we may share your Personal Information — with your consent — with trusted third parties who assist in operating the Connect Persona Software Applications and Services. This may include affiliates, subsidiaries, and authorized service providers.

We do not share your Personal Information with unaffiliated third parties for their own marketing purposes. All service providers we engage are contractually bound to handle your data in accordance with this Privacy Policy or a policy offering comparable protections. They are granted access to Personal Information only to perform designated tasks, and they are not authorized to use or disclose the information for any other purposes.

Additionally:

• Information provided during text message opt-in will not be shared with third parties, excluding aggregators or service providers directly involved in delivering SMS communications.
• We may disclose Personal Information when required or permitted by law, such as to comply with legal proceedings (e.g., a subpoena or court order), or when we believe in good faith that disclosure is necessary to:
  • Protect our legal rights
  • Ensure your safety or the safety of others
  • Prevent fraud or security threats
  • Respond to a lawful government request

In the event of a business transition—such as a merger, acquisition, or sale of all or part of our assets—your account and associated Personal Information may be transferred as part of that transaction. We will ensure that any acquiring party is bound to respect your Personal Information in a manner consistent with this Policy.

Retention of information

We may store your Personal Information in both physical and digital formats. In some cases, we may engage trusted third-party service providers to store or manage this information on our behalf. Regardless of the storage method, we take reasonable technical and organizational measures to ensure that your Personal Information remains confidential and secure.

We retain and use your Personal Information for as long as necessary to:

• Fulfill the purposes outlined in this Privacy Policy
• Comply with applicable legal and regulatory obligations
• Resolve disputes
• Enforce our terms, agreements, and policies

Where required or permitted by law, we may retain your information for longer periods. After the relevant retention period has expired, your Personal Information will be securely deleted or anonymized.

We may continue to use aggregated or de-identified data derived from your Personal Information even after it has been updated or deleted, but never in a way that can be used to identify you personally.

Please note that once the retention period has expired, the following rights may no longer be enforceable:

• Right of access
• Right to erasure
• Right to rectification
• Right to data portability

Transfer of information

Depending on your location, the processing and storage of your Personal Information may involve transferring it to a country other than your own. Some of the trusted third parties with whom we share Personal Information may be located in or operate servers in regions such as North America, Latin America and the Caribbean, Africa, Europe, the Middle East, Asia, Mainland China, and Oceania.

When we transfer Personal Information internationally, we take reasonable steps to ensure that appropriate data protection and privacy safeguards are in place. This includes working only with service providers and partners who adhere to robust privacy and security standards.

Please note:

• These overseas recipients may be subject to their own local privacy obligations, which may not always align with the requirements of your country's data protection laws (e.g., Australian Privacy Act or EU GDPR).
• By agreeing to this Policy, you acknowledge that, in some jurisdictions, your legal rights and remedies in relation to overseas data recipients may be limited or not enforceable against them or us.

If your data is transferred outside the European Union, or to any international organization governed by public international law (e.g., the United Nations), we will ensure that such transfers are based on a valid legal mechanism—such as adequacy decisions, standard contractual clauses, or other approved safeguards.

To learn more about specific data transfer mechanisms and the security measures we use, please refer to other relevant sections of this Policy or contact us directly using the information provided in the Contacting us section.

Limited Use requirements

Connect Persona's use and transfer of information received from Google APIs will comply with the Google API Services User Data Policy, including its Limited Use requirements.

This means that any data accessed through Google integrations (such as calendar, contacts, or authentication) will only be used to provide or improve user-facing features that are clearly described and expected within Connect Persona, and will not be transferred to others except as explicitly allowed under that policy.

The rights of users

As a user of Connect Persona, you have certain rights regarding the Personal Information we process about you. These rights may vary depending on your jurisdiction, but generally include the following:

• Right to Withdraw Consent. You may withdraw your consent at any time if we are processing your Personal Information based on your prior consent.
• Right to Object to Processing. You may object to the processing of your information where we rely on a legal basis other than consent (such as legitimate interest).
• Right to Access. You have the right to know whether your information is being processed by us, request details about the nature of the processing, and obtain a copy of the Personal Information we hold about you.
• Right to Rectification. You have the right to verify the accuracy of your Personal Information and request that it be updated or corrected if necessary.
• Right to Restrict Processing. Under certain circumstances, you can request that we restrict the processing of your Personal Information. If granted, we will retain your information solely for storage and not for any other purposes.
• Right to Erasure (Right to be Forgotten). In specific cases, you have the right to request that we delete your Personal Information from our systems.
• Right to Data Portability. Where technically feasible, you have the right to receive your Personal Information in a structured, commonly used, and machine-readable format. You may also request that we transmit this data directly to another controller, provided that the processing is carried out by automated means, and is based on your consent or on a contract to which you are a party (or pre-contractual obligations thereof).

If you wish to exercise any of the above rights, please contact us using the details provided in the Contacting us section of this Policy.

The right to object to processing

If your Personal Information is being processed based on our legitimate interests, in the public interest, or under the exercise of official authority, you have the right to object to such processing by presenting a reason specific to your personal situation that justifies the objection.

However, if your Personal Information is being processed for direct marketing purposes, you have the right to object at any time without needing to provide a justification.

To determine whether we process Personal Information for direct marketing purposes, please refer to the relevant sections of this Privacy Policy or contact us directly.

Data protection rights under GDPR and UK GDPR

anka EK LLC is committed to full compliance with the General Data Protection Regulation (GDPR) and the UK Data Protection Act 2018 (collectively referred to in this Policy as the “GDPR”) in relation to the collection, use, and retention of personal data from individuals located in the European Union and the United Kingdom.

Legal basis for processing

Under the GDPR, we process personal data based on one or more of the following lawful bases:

• Consent. You have given clear consent for us to process your personal data for a specific purpose.
• Contractual necessity. Processing is necessary for the performance of a contract with you, or to take steps at your request before entering into a contract.
• Legal obligation. Processing is necessary to comply with a legal obligation to which we are subject.
• Vital interests. Processing is necessary to protect your vital interests or those of another individual.
• Public task. Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in us as the controller.
• Legitimate interests. Processing is necessary for the purposes of the legitimate interests pursued by anka EK LLC or a third party, except where such interests are overridden by your fundamental rights and freedoms.

Data transfers

We may transfer personal data collected through Connect Persona to countries outside the European Economic Area (EEA) and the United Kingdom for the purposes described in this Policy.

When such transfers occur, we take appropriate steps to ensure that your privacy and data security are protected in line with applicable data protection laws, including the GDPR. This may include implementing:

• Standard Contractual Clauses (SCCs) approved by the European Commission
• Data Processing Agreements with appropriate safeguards
• Transfers to countries recognized as providing an adequate level of data protection by the European Commission or UK authorities

These safeguards are designed to ensure that your personal data remains secure, confidential, and handled lawfully, regardless of where it is processed.

Data subject rights (EEA & UK residents)

If you are a resident of the European Economic Area (EEA) or the United Kingdom, you are entitled to certain data protection rights under the GDPR and related regulations. anka EK LLC is committed to ensuring that you can access, correct, delete, or restrict the use of your Personal Information as required by law.

If you would like to know what Personal Information we hold about you, or if you want it removed from our systems, you can contact us at any time.

Depending on your location and the specific circumstances, you may have the following rights:

• Right of Access. You can request access to the Personal Information we hold about you and receive a copy of it.
• Right to Rectification. You can request that we correct any inaccurate Personal Information and complete any incomplete data.
• Right to Erasure (“Right to be Forgotten”). You may request that we delete your Personal Information, subject to certain conditions outlined in this Policy.
• Right to Object. You can object to our processing of your Personal Information if we are relying on a legitimate interest or carrying out processing in the public interest.
• Right to Restrict Processing. You can request that we limit how we use your Personal Information. In such cases, we will retain the data but will not process it further.
• Right to Data Portability. You have the right to receive your Personal Information in a structured, commonly used, and machine-readable format, and to have it transmitted to another controller, where technically feasible.
• Right to Withdraw Consent. Where we rely on your consent to process Personal Information, you may withdraw that consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
• Right to Lodge a Complaint. You have the right to file a complaint with your local Data Protection Authority regarding our collection and use of your Personal Information. For more information, please contact the supervisory authority in your country of residence.

Additional disclosures for California residents

If you are a California resident, you are entitled to specific rights under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA). This section supplements the main Privacy Policy and applies exclusively to individuals who reside in California.

Under these laws, you may exercise the following rights (subject to certain limitations):

• Right to Access. Request access to the personal information that anka EK LLC (via Connect Persona) has collected about you.
• Right to Deletion. Request that we delete any personal information we have collected from or about you.
• Right to Correction. Request that we correct any inaccurate personal information.
• Right to Opt-Out of Sale. Opt out of the “sale” of your personal information (Note: Connect Persona does not currently sell personal information as defined under CCPA).
• Right to Opt-Out of Sharing. Opt out of the “sharing” of your personal information for cross-context behavioral advertising.
• Right to Non-Discrimination. You will not receive discriminatory treatment for exercising your privacy rights.
• Right to Limit Use of Sensitive Personal Information. Request limits on how your sensitive personal information is used or disclosed.
• Right to Private Action in Case of Breach. Initiate a private cause of action in case your personal information is subject to certain types of data breaches.

Categories of personal information collected (past 12 months)

For more details about:

• What we collect, see Collection of personal information
• How we use it, see Use and processing of collected information
• Who we may share it with, see Disclosure of information

Sensitive personal information

We do not use or disclose sensitive personal information for any purpose other than those expressly permitted under applicable laws, including the California Privacy Rights Act (CPRA) and other relevant data protection regulations.

Retention

We retain your Personal Information for as long as necessary to fulfill the business purposes outlined in this Policy, or as required by applicable laws and regulations.

The duration of retention may vary depending on several factors, including but not limited to:

• Legal and regulatory recordkeeping obligations
• The need to resolve disputes, inquiries, or complaints
• Enforcement of our terms and policies
• The continuation of an active relationship or account with you

For further details, please refer to the Retention of information section of this Policy.

How to exercise these rights

If you are a California resident or otherwise wish to exercise your privacy rights under applicable law, you may submit a request by contacting us at [email protected].

Any requests to exercise your rights under this Policy can be directed to anka EK LLC through the contact details provided. Please be aware that:

• We may require you to verify your identity before fulfilling your request.
• Your request must include sufficient information to allow us to confirm your identity or authority to act on someone else's behalf.
• You must provide enough detail for us to understand, evaluate, and respond appropriately to the request.

We will not be able to respond to your request or provide access to your Personal Information unless we can verify that the information pertains to you or that you are legally authorized to act on behalf of the individual in question.

Opt out of certain disclosures to third parties

You have the right to opt out of the “sale” of your personal information and the “sharing” of your personal information for purposes of cross-context behavioral advertising.

Authorised agent

You may authorize an agent to exercise your privacy rights on your behalf. To do so, you must provide the authorized agent with written permission to act on your behalf.

When an agent submits a request on your behalf, we may:

• Require a copy of the written authorization granting them permission
• Ask you to verify your identity directly
• Request that you confirm your authorization of the agent

These steps help ensure that your Personal Information is protected and that requests are legitimate.

Privacy of children

We do not knowingly collect any Personal Information from children under the age of 18. If you are under 18, please do not submit any Personal Information through the Connect Persona Software Applications and Services.

We strongly encourage parents and legal guardians to monitor their children's online activity and to help enforce this Policy by instructing their children never to share Personal Information without parental permission.

If you believe that a child under the age of 18 has submitted Personal Information to us, please contact us immediately so we can take appropriate steps to delete the information.

In accordance with applicable laws, you must also be at least 16 years old to consent to the processing of your Personal Information in your country. In jurisdictions such as the European Union, a parent or legal guardian may provide this consent on your behalf if required.

Advertisements

We may display online advertisements as part of the Connect Persona experience. To support this, we may share aggregated and non-identifiable information about our users—collected through your use of the Software Applications and Services—with advertising partners.

Importantly, we do not share personally identifiable information about individual users with advertisers.

In some cases, we may use this aggregated, anonymized data to deliver tailored advertisements that are more relevant to specific user groups or audience segments. These practices help improve the effectiveness of our advertising without compromising your privacy.

Email marketing

We offer electronic newsletters and marketing communications that you may voluntarily subscribe to at any time.

We are committed to protecting your privacy and keeping your email address confidential. We will not share your email address with third parties except as outlined in the Use and processing of collected information section or when using trusted third-party providers to deliver such emails on our behalf.

All communications sent via email are managed in compliance with applicable laws and regulations, including the CAN-SPAM Act. Every email from Connect Persona will:

• Clearly state the sender's identity
• Include a valid contact method
• Provide an easy-to-follow unsubscribe link

You may opt out of receiving newsletters or promotional communications at any time by clicking the unsubscribe link included in the email or by contacting us directly.

However, opting out of marketing communications will not affect your ability to receive important transactional or service-related messages, such as account notifications or updates essential to the operation of the Services.

Links to other resources

The Connect Persona Software Applications and Services may contain links to external websites, services, or resources that are not owned or controlled by anka EK LLC.

Please be aware that we are not responsible for the privacy practices or the content of such third-party sites or services. When you leave our platform, we encourage you to review the privacy policies of every external resource that may collect or process your Personal Information.

Your interactions with third-party platforms are governed solely by their terms and policies.

Notice to end users

If you access Connect Persona through an account provided by an organization you are affiliated with—such as your employer, educational institution, or another affiliated entity—we may collect, use, and disclose your Personal Information to provide Services as instructed by that organization.

Please be aware that your organization may have administrative control over your account and may be able to:

• Access and view your data
• Modify or delete certain information
• Manage your account settings and permissions

We process your Personal Information in accordance with the organization's instructions, which may differ from our standard practices.

We encourage you to review your organization's privacy policy to understand how your data is handled, what rights you may have, and how to exercise them in the context of your affiliation.

Information security

We store the Personal Information you provide on secure computer servers in a controlled environment, protected from unauthorized access, use, or disclosure. We implement and maintain reasonable administrative, technical, and physical safeguards designed to protect your data from unauthorized access, alteration, or misuse while it is under our control.

However, it's important to understand that no method of transmission over the Internet or wireless network is entirely secure. While we strive to use commercially acceptable means to protect your Personal Information, you acknowledge that:

• There are inherent security and privacy limitations of the Internet that are beyond our control.
• The security, integrity, and confidentiality of any data exchanged between you and Connect Persona cannot be fully guaranteed.
• Despite our best efforts, data transmitted over networks may be intercepted, accessed, or modified by unauthorized third parties.

We encourage you to take steps on your end—such as using strong passwords and keeping your device secure—to further protect your information.

Data breach

In the event that we become aware of a security incident affecting the Connect Persona Software Applications and Services—such as the unauthorized access, disclosure, or loss of users' Personal Information—we reserve the right to take all reasonably appropriate actions. These may include:

• Conducting an internal investigation
• Preparing incident reports
• Notifying and cooperating with law enforcement authorities, as required by applicable law

Where required under the GDPR, California law, New York law, or other applicable legal frameworks, we will notify the appropriate government or regulatory bodies without undue delay.

If we determine that the breach presents a reasonable risk of harm to affected individuals, or if notification is otherwise legally required, we will make reasonable efforts to inform affected users. Notification may include:

• Posting a notice within the Software Applications
• Sending a direct email to impacted users

We are committed to transparency and timely communication in the event of any data security compromise.

Changes and amendments

We reserve the right to update or modify this Privacy Policy and its terms relating to the Connect Persona Software Applications and Services at our discretion and from time to time.

If we make material changes to how we handle your Personal Information, we will:

• Notify you by email using the contact information you have provided
• Optionally provide notice through in-app notifications or other appropriate means

Unless otherwise stated, the updated version of this Policy will take effect immediately upon posting. Your continued use of the Software Applications and Services after the effective date of the revised Policy will signify your consent to the updated terms.

However, we will not use your Personal Information in a materially different way than was stated at the time of collection without first obtaining your explicit consent.

Acceptance of this policy

By accessing and using the Connect Persona Software Applications and Services, you acknowledge that you have read, understood, and agreed to the terms of this Privacy Policy.

If you do not agree to be bound by the terms of this Policy, you are not authorized to access or use the Software Applications and Services.

Contacting us

If you have any questions, concerns, or requests regarding this Privacy Policy, your Personal Information, or your individual rights, you may contact us through our support channels:

We are committed to responding to your inquiries in a timely and respectful manner.