Effective date: June 1, 2025

This privacy policy (this “Policy”) applies to our website (www.dbtwin.com) and any other websites operated by Kharabela Venture Incorporated (“dbTwin”, “we,” “us” or “our”) (together, “Websites”), and our data collection practices when you acquire, download, install, access or use certain [online] services (through our Websites, products and services) offered by us (collectively, our “Platform”). Specifically, this policy describes the information, including personal information, we may collect from you, about you, or that you may provide to us when you interact with us through our Platform and how we use, protect, and share such information.

1. Personal Information: What dbTwin collects.

a. Personal information you voluntarily provide to us.

i. Registration Information. We require some basic personal information at the time of account creation, such as your email address and company/employment information. This may also include a real name, photograph, biography, alias, address, or phone number should you decide to populate a user profile. Profiles may be public to other users.

ii. Payment Information. This may include your credit or debit card information, banking information, information about your payment transaction, or other financial information you provide us. dbTwin does not process or store your credit card information, but our third-party payment processor does.

iii. Other Information You Submit to Us. This may include requests or communications you submit to us, including emails, ratings, or customer service and sales call recording.

iv. Research or survey information. This may include survey results, social media data, and other information about your participation in consumer research.

b. Personal information we automatically collect from your use of the Platform.

i. Usage Information. Information regarding your use of our Platform, such as the pageviews, referring sites, your IP address and session information, and dates and times related thereto. This information is collected from every visitor to our website, whether they have an account or not.

ii. Transactional Information. If you have a paid account with us, we automatically collect certain information about your transactions on the Platform, such as the date, time, and amount charged.

iii. ‍Internet and Network Information. This may include cookies, information about your interaction with a website, application, service or advertisement, such as browsing history and how you use your account. Additional information regarding our use of cookies may be found below in Section 6.

iv. Device Information. This may include the operating system of your device, device model and identifier, IP address, language preferences, the type of device you are using, or your geolocation information.

c. Personal information we collect from third parties.

i. Social Media Platforms. Our Platform may contain social media buttons or links, such GitHub, X, LinkedIn, YouTube. These features may collect personal information such as your IP address and which page you are visiting on our Platform, and may set a cookie to enable the feature to function properly. Your interactions with these platforms are governed by the privacy policy of the company providing it.

ii. Third Party Data Brokers. We do not purchase personal information from data brokers.

2. Personal information: What dbTwin does not collect.

a. Sensitive Personal Information. We do not collect “Sensitive Personal Information”, such as personal information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs.

b. Persons Under 18. If you are a person under the age of 18, you may not have an account with dbTwin. Our Platform is not directed to persons under 18 (or other ages as required by local law), and dbTwin does not knowingly collect personal information from or direct any of our content specifically to persons under 18. If we learn or have reason to suspect that you are a user who is under the age of 18, we will have to delete any personal information we have collected from you, unless we have a legal obligation to keep it, and to close your account.

3. How dbTwin uses your personal information.

a. We use your registration information to create your account, and to provide you the Platform, including without limitation, to interact with you, including through email, customer support, and contact requests, or to resolve problems and disputes.

b. We use your payment information to provide you with the paid Platform, or any other dbTwin paid service you request.

c. We use your personal information to send you marketing communications about our products, events, and promotions, including through newsletters, social media, and other channels.

d. We use your personal information, specifically your username, to identify you on dbTwin.

e. We may use your personal information to invite you to take part in surveys, beta programs, or other research projects, subject, where required by law, to your consent.

f. We use your usage information and device information to better understand how our users use dbTwin and to improve our Platform and our users’ experiences.

g. We may use your personal information to ensure the security and availability of our Platform, and to enforce our terms.

h. We use your personal information o comply with or enforce our legal obligations or rights, including to comply with court orders, subpoenas, or other legal process or lawful requests.

i. We limit our use of your personal information to the purposes listed in this Privacy Policy and in any other way that we provide notice of or where you have provided your consent.

4. Processing personal information outside of USA.

a. Legal Basis. If our processing of your personal information is subject to certain international laws (including, but not limited to, GDPR), dbTwin provides the following legal bases for such processing:

i. We rely on your consent to use your personal information under the following circumstances: filling out the information in your user profile; participating in a dbTwin training, trial services, research project, beta program, or survey; and for marketing purposes, where applicable. All of this personal information provided for these purposes is optional, and you have the ability to access, modify, and delete it at any time. You may withdraw your consent at any time.

ii. You must provide your registration information when you create a dbTwin account. This information is required for you to enter a Subscription (as defined in the dbTwin Services Agreement found here) with us, and we process that information on the basis of performing that contract. If you have a paid account with us, we collect and process payment information on the basis of performing under that Subscription.

iii. The remainder of the processing of personal information we perform is necessary for the purposes of our legitimate interest, including without limitation, for legal compliance purposes, security purposes, or to maintain ongoing confidentiality, integrity, availability, and resilience of dbTwin’s systems and Platform.

b. Additional Rights. If you are a resident of a European Union member state or the United Kingdom, GDPR and its UK equivalent provides you with specific rights regarding your personal information, including: (i) the right to request access to your personal information; (ii) the right to correct your personal information; (iii) the right to restrict or delete your personal information; and (iv) the right to object to our processing of your personal information. If you are a resident of a European Union member state or the United Kingdom and would like to exercise any of these rights under the GDPR, please send us an email at [x] with a description of the nature of your request and the personal information at issue, if any. We will respond within the timeframe permitted under applicable law. We will verify your identity prior to fulfilling your request, which may require government identification.

5. Sharing information we collect. We may share your personal information with third parties in the following circumstances

a. Service Providers. We share personal information with our service providers and subcontractors, who perform services on our behalf to operate our business and the Platform, including service providers that help us to run our Websites and Platform, process payments, communicate or market to or with you, and secure the Platform.

b. Security Purposes. If you are an Permitted User (as defined in the dbTwin Services Agreement) of an organization that has purchased dbTwin’s Platform, dbTwin may share your username, usage information, and device information associated with an owner and/or administrator of such organization who has agreed to the dbTwin Services Agreement or applicable customer agreements, to the extent necessary to investigate or respond to a security matter that affects or compromises the security of that particular organization.

c. Retention. We will retain your personal information for as long as your account is active or as long as needed to provide you the Platform after which time it shall be deleted, subject to our right to retain and use such personal information necessary to comply with our legal obligations, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, and to enforce our agreements.

d. Legal Disclosure. dbTwin may disclose personal information or other information we collect about you to law enforcement if required by law (i.e., in response to a valid subpoena, court order, search warrant, a similar government order), or when we believe in good faith that disclosure is necessary to comply with our legal obligations, to protect our property or rights, or those of third parties.

e. Change in Control or Sale. We may disclose or transfer your personal information with a buyer, successor in interest, or any other party involved in a merger, acquisition or other sale or transfer of all or some of the dbTwin’s assets, equity or business or any similar transaction, or as part of a bankruptcy, liquidation, dissolution or similar proceeding, as well as advisors, lawyers, accountants and other third parties that may assist in the negotiation, review, and consummation of any such transaction or proceeding.

f. Aggregate, non-personally identifying information. We share certain information with others when the information has been aggregated, anonymized, or de-identified. For example, we may compile statistics on the Online Service activity across dbTwin. In these situations, we do not disclose any information that could be used to personally identify you.

g. Consent. We may share your personal information, if you consent.

6. Other Information to Understand.

a. Cooking and tracking technologies. Like most technology companies, we (and our service providers and certain third parties) collect information about you automatically, including when you interact with Platform. We collect this information through a variety of technologies (collectively, the “Technologies”), which we explain below:

i. Cookies. A cookie is a small text file that is sent to your browser when you access a website. There are two types of cookies, session cookies and persistent cookies. A session cookie is available and exists only during the course of the browser session. Closing the browser or logging off will invalidate the session cookie. Persistent cookies, similar to their name, last for a longer period of time, from hours, days, or weeks, and remain on your hard drive (or other storage medium) and record or disclose information about you and your interactions with websites and services. For example, cookies are used to retrieve information that you have previously entered (to allow you not to have to re-enter it), analyze the usage of a website, or track users across websites or services. You can often decide whether and what types of cookies you are willing to accept through your browser’s settings or through third party products that may manage, disclose, or block cookies, like browser plugin-ins or other software.

ii. Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in our Platform that collects information about engagement on our Platform. The use of a pixel tag allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.

iii. Embedded Scripts. These are also bits of code on a website or service that measure how a user interacts with a website, application, or service; the scripts are often in JavaScript, a common programming language.

b. dbTwin’s Use of Cookies and Tracking Technologies. Our Platform uses third-party Technologies for several purposes. The third-party Technologies used on our Platform are mainly for understanding how the Platform performs, how you interact with our Platform, keeping our Platform secure, providing advertisements that are relevant to you, and all in all providing you with a better and improved user experience and help speed up your future interactions with our Platform.

c. Third-Party Technologies list

i. Google Analytics used to analyze the Website. For additional information about Google’s privacy practices, please visit Google Analytics’ Privacy Policy. To learn more about how to opt-out of Google Analytics’ use of your information, please click here.

ii. Google Ads used to track advertisements and measure Website activity. For additional information about opting out of the ads, see https://adssettings.google.com/u/0/authenticated

iii. LinkedIn used to track conversions and Website visits from LinkedIn advertisements. For additional information about LinkedIn’s privacy practices, please see https://www.linkedin.com/legal/privacy-policy

iv. Twitter used to track conversions and Website visits from Twitter advertisements. For Additional information about Twitter’s privacy practices, please see: https://twitter.com/en/privacy

d. Browser Settings. Note that different browsers have settings to block and delete the placement of Technologies used by websites on your device. You may be able to modify the settings as your browser or device permits to block/delete cookies and tracking technologies. Our Platform may not work properly if you modify the settings.

e. Additional Information. To learn more about or opt out of third party data collection on the Internet, generally, dbTwin recommends you visit the following websites.

‍Digital Advertising Alliance Consumer Choice Tool. Visit https://optout.aboutads.info/ to opt-out of ads from companies that participate in the DAA.

‍Network Advertising Initiative. Visit https://optout.networkadvertising.org to opt-out of certain interest based advertising from participating NAI members.

Please note that when you opt-out at the websites above, and in general, the opt-out is effective only for the device that you use to opt-out. It will not prevent data collection or targeted ads for other devices that you use – you will need to opt-out on each device. Additionally, certain opt-outs require that a cookie be placed on your device to record your preference.

7. Your privacy Rights and Choices.

a. Additional Privacy Rights and Choices. Depending on your location and applicable law, you may have certain rights regarding your personal information. These rights may include the right to access personal information that dbTwin has about you, the right to request that dbTwin delete personal information about you, the right to correct any errors in any personal information dbTwin maintains about you, the right to request restrictions or object to the processing of your personal information, the right to withdraw your Consent to our processing of your personal information, and the right to lodge complaints (in applicable jurisdictions) . If you wish to exercise these rights, please contact us using the methods described below. If you do not wish to receive further non-transactional, marketing emails from us, you may opt-out by clicking the “unsubscribe” link in any such emails or contacting us using the methods described below.

You may correct or update information that we collect about you by contacting us.

If you make a request as described above (except with respect to e-mail opt-outs), we will verify your identity before honoring any such request, which may involve asking you to provide or confirm certain information about you. We engage in verification where required by law, or where we believe it is necessary to protect your privacy and prevent fraud or impersonation. In certain circumstances, you may also be able to make a request through your agent; any such request may also involve a verification process.

You can opt-out of or control certain data collection through the Platform, including automated data collection, as described above in section 6. You can also control what data is collected about you by limiting the information that you provide to us, taking advantage of settings within your web browser or device that relate to privacy, or using software or other services or websites that help to protect your privacy or inform you about data collection practices “Do Not Track.” At this time, we do not support “Do Not Track” preferences that may be available in your browser.

Please note you must separately opt out in each browser and on each device.

If you would like to exercise any of these rights, please contact us at support@dbtwin.com. We will process such requests in accordance with applicable laws.

b. Additional Information for California residents. If you are a California resident, the California Consumer Privacy Act (“CCPA”) provides you with specific rights regarding your personal information, including: (i) the right to know what information we collect, disclose, and sell; (ii) the right to request deletion of your personal information, subject to certain exceptions; and (iii) the right to opt out of the sale of your personal information.

If you are a California resident and would like to exercise any of these rights under the CCPA, please contact us at support@dbtwin.com. We will respond within the timeframe permitted under applicable law. We will verify your identity prior to fulfilling your request, which may require government identification. Authorized agents may be utilized by consumers to submit such requests, in which we will take certain measures to verify the consumer’s identity and that the agent has the authority to act on the consumer’s behalf. Please note, we are only required to respond to two such requests per consumer each year. You also have the right not to be discriminated against if you exercise any of your rights under the CCPA.

c. Additional information for Nevada residents. If you are a Nevada resident, you have the right to opt-out of the sale of certain personal information to third parties who intend to license or sell that personal information. You can exercise this right by contacting us at support@dbtwin.com and providing us with your name and the email address associated with your account. Please note that we do not currently sell your personal information as sales are defined in Nevada Revised Statutes Chapter 603A. If you have any questions, please contact us as set forth in “Contacting dbTwin” below.

8. Concerns and Complaints. If you have concerns about the way dbTwin is handling your personal information, please contact us immediately. You may contact us at support@dbtwin.com.

9. Changes to our Privacy Policy. dbTwin reserves it right to change our Privacy Policy from time to time. If there are any material changes to this Privacy Policy, we will notify you as required by applicable law. For changes to this Privacy Policy that are not material changes or that do not affect your rights, we encourage users to check our Platform and this Privacy Policy frequently. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you continue to use our Platform after the new Privacy Policy takes effect.

10. Our Contact Information.

Questions regarding dbTwin’s Privacy Policy or information practices should be directed to:
Kharabela Ventures Incorporated (dba dbTwin)
Legal/Privacy Department
support@dbtwin.com