Last updated: April 6, 2026

Vimi Adaptive Learning Ltd. (“Vimi”, “we”, “us” or “our”) is deeply committed to protecting the privacy and security of our customers’ data. This Privacy Policy is intended to describe our practices regarding the personal data we may collect from you when you use or access our personalized math teaching program through our mobile App (“App”) and our website at https://heyvimi.com/ (collectively, the “Services”), the ways in which we may use such information to provide the Services, and the choices and rights available to you.
For the purposes of the General Data Protection Regulation (“GDPR”) and any applicable local legislation (“Data Protection Laws”) we are the Data Controller of your personal data.
This Privacy Policy supplements and shall be read in conjunction with our https://heyvimi.com/terms, and may be supplemented by additional privacy statements, terms or notices provided to you. Capitalized terms which are not defined herein, shall have the meaning ascribed to them in our https://heyvimi.com/terms.

1. YOUR CONSENT
PLEASE READ THIS PRIVACY POLICY BEFORE ACCESSING AND USING THE SERVICES. BY ACCESSING THE SERVICES, YOU AGREE TO THIS PRIVACY POLICY, INCLUDING TO THE COLLECTION AND PROCESSING OF YOUR PERSONAL INFORMATION (AS DEFINED BELOW). IF YOU DISAGREE TO ANY TERM PROVIDED HEREIN, WE WILL NOT BE ABLE TO SUPPLY THE SERVICES, AND YOU MAY NOT ACCESS OR USE THE SERVICES.

2. WHAT TYPES OF INFORMATION DO WE COLLECT?
o Parent contact details. E-mail address to set up and manage an educational account on the app;
o Initial Educational details regarding the educational app user to generate adequate learning content and experience that include grade and school district (and approximate age).
o Usage information. to support the internal operations of the Services which may include:
● learner’s name or nickname that will be used as the App username and other information needed for the delivery of the service. This information is not needed for any kind of account creation, nor does it need to be accurate.
● Unique Service internal identifier to track User progress
● information about user activity such as uploading text inputs or math-related images and correct/wrong answers.
o Technical information. Needed to ensure safe and secure delivery of the Service, such as: IP address, UDID (Unique Device Identifier) or other persistent user and/or mobile device token, advertising ID, device type, browser and keyboard language, the User’s ‘click-stream’ and activities on the Services, the period of time the User used the App, and/or related time stamps
o Voice to text – Users can also choose to interact with the Services by speaking to the App through the device microphone. Speech data is processed on your device using phone native capabilities to convert your voice into text. No speech data is shared with third parties. You can also disable microphone and speech recognition permissions from Settings at any time. Please consult your device user manual for additional guidance.

o Payment Information. Your payment information used for payment of the subscription Fees are collected and processed via our third-party payment processors. We have no access to such payment information We do not collect any personal information from you or related to you without your approval, which is obtained, inter alia, through your acceptance of this Privacy Policy. We take reasonable efforts to ensure that we do not collect identifiable information, except for billing purposes. We process and store billing information separately from User information.

3. WHY DO WE COLLECT AND PROCESS YOUR INFORMATION?
● To provide, operate and improve our Services and related offers and to manage our business.
● Usage Data is used for the sole purpose of rendering the service as described, as well as limited debugging and quality assurance purposes, when such circumstances arise.
● To contact users to provide them with technical assistance, and support, handling requests and complaints, and collect feedback in connection with the Services;
● To send you updates, notices, notifications, and additional information related to the Services, including related offers.
● To create cumulative statistical data and other non-personal information, which we and/or our business partners might make use of to operate and improve our services and internal research and development of Vimi services.
● To monitor against, prevent, and handle fraud, illegal behavior on the Services, or other misuse of our Services, including inter-alia detecting, preventing, or otherwise addressing fraud or abuse.
● To comply with any applicable rule or regulation and/or response or defend against legal proceedings versus us or our affiliates.
● To contact you about legal requests.

4. WHAT ARE OUR LEGAL GROUNDS FOR COLLECTING YOUR PERSONAL INFORMATION?
● With your informed consent: We ask for your consent to collect and process your information for the specific purposes, stated in this Privacy Policy; you have the right to withdraw your consent at any time. For instance, By manually uploading Usage Data, you consent to its collection and sharing with us for the purpose of delivering and improving the Services.
● Performance of the contract with you: We collect and process your Personal Information in order to develop and provide you with the Services, following your acceptance of the Terms of Use and this Privacy Policy.
● Legitimate interests: We process your information to deliver our core Services and to protect our legitimate interests while applying appropriate safeguards that protect your privacy. This means that we process your information for purposes of delivering the Service in a secure and safe manner, including for purposes like detecting, preventing or otherwise addressing fraud, abuse, security, usability, functionality or technical issues with our Service; protecting against harm to the our rightsour users or the public as required or permitted by law; enforcing legal claims, including investigation of potential violations of this Privacy Policy; and in order to comply and/or fulfill our obligations under applicable laws, legal process, subpoena or governmental request.

5. WHO DO WE SHARE YOUR INFORMATION WITH AND WHY?
We share your information with our processors, after ensuring that their use is limited to the supply of the services.
● Third Parties & Business Partners – We may share your information with several trusted service providers, whose services and solutions are required or otherwise facilitate achievement of the purposes of processing set forth under Section 4 above. These third parties serve in facilitating and enhancing our Services and related services, including such third-party services required to allow platform analytics (e.g. BigQuery ), payments processing (e.g. Apple store and google store), storing data (e.g Google Cloud), and other third party providers essential for enhancing the Services, such as LLM service providers (e.g, Braintrust). Our third party services providers act as our processors and may only process your information according to our instructions (which are given in accordance with this Privacy Policy).
● Aggregate or de-identified information. We may share information in aggregated and/or anonymous form that cannot reasonably be used to identify any individual.
● Potential transfer of ownership – Should Vimi undergo any change in control, including by means of merger, acquisition or purchase of substantially all of its assets, your information may be shared with the parties involved in such event under strict security conditions, for the purpose of evaluating such event and in accordance with the terms of this Privacy Policy. If we believe that such change in control might materially affect your Personal Information then stored with us, we will notify you of this event and the choices you may have, through prominent notice on our Services.
● Other. We may disclose personal information if we have a good faith belief that such disclosure is reasonably necessary to (a) satisfy any applicable law, regulation, legal process, or enforceable governmental request; (b) enforce applicable Terms of Service, including investigation of potential violations thereof; (c) detect, prevent or otherwise address fraud, security or technical issues; (d) protect the rights, property, or personal safety of Vimi, our users or the public; or (e) as required or permitted by law.

Please note that the App may link to and may be linked by websites operated by other entities or individuals. Some of these websites may be co-branded with our name or logo. This Privacy Policy does not apply to, and we cannot always control the activities of, such other third-party websites. You should consult the respective privacy policies of those third-party websites. It is clarified that such third parties unless explicitly mentioned otherwise, are neither controlled nor owned by Vimi. For avoidance of doubt, we will NOT sell (as “sell” is traditionally defined) your personal data. That is, we will not provide your nick name and email or other personally identifiable information to third parties in exchange for money. We may share anonymized or de-identified information with any other third party, at our sole discretion. However, under California law, certain cases of sharing information, such as for advertising purposes, may be considered a “sale” of personal information. However, to the extent applicable, including if a supervisory authority determines that our practices include the selling and/or sharing of your personal information (as such terms are defined under applicable US State Privacy Laws including the CCPA), and you would like to opt out of the “sale” or “sharing” of your personal information, please contact us at support@heyvimi.com.

6. HOW DO WE PROTECT CHILDREN’S PRIVACY?
Vimi provides features and services intended for use by children. An adult with a verified email address must download the App and register to the Services before permitting a child to use the App. Please contact us at support@heyvimi.com if you believe we have inadvertently collected information from a child under 13 without consent from a parent or guardian so that we may delete the information as soon as possible.

The following applies when a child uses the App with a parent’s consent and oversight:
● We collect the nick name and class grade of the user. We collect Usage Data when a child or parent uses the App, which we associate with the parent’s information. We do not collect other personal information from the child.
● We use it to operate, personalize, maintain, enhance, and provide all of the features of our App. We do not use this information for marketing or advertising purposes. We do not contain user generated content or social features of any kind.
● We share the information only with our service providers and otherwise as described in Section 5 above. We do not share the child’s information with third parties for their own purposes.
● The parent can change the child’s user name at any time in the App. A parent should contact us at support@heyvimi.com to permanently delete the child’s information from our systems.

7. WHERE DO WE TRANSFER OR STORE YOUR PERSONAL INFORMATION?
Your information may be transferred to, maintained, processed and stored by us and our authorized affiliates and service providers in Israel, the EU or the United States. Please note that the data protection laws in the above jurisdictions may not be as comprehensive as those in your country of residence. Residents of certain countries may be subject to additional protections, as set forth below.
GDPR (EEA Users): This section applies only to natural persons residing in the European Union, EFTA States, or the United Kingdom (for the purpose of this section only, “you” or “your” shall be limited accordingly). It is the Company’s policy to comply with the EEA’s General Data Protection Regulation (“GDPR”) and the UK GDPR. In accordance with the GDPR, we may transfer your Personal Information from your home country to the U.S. and/or other countries, provided that the transferee has provided appropriate safeguards, and on condition that enforceable data subject rights and effective legal remedies for data subjects are available.
Specifically, we may cause such transfer if we ensured that at least one of the following applies:
– The country to which Personal Information has been transferred, has been determined by the EU Commission to be a country providing adequate protection to the privacy rights of EU residents.
– Application of Standard Contractual Clauses where appropriate.

8. WHAT ARE YOUR RIGHTS?
Under certain Data Protection Laws individuals have rights regarding their personal data. You can exercise your rights at any time via the Services or by contacting us at support@heyvimi.com. Those rights may include the following:
– Right of access. You may have a right to know what information we hold about you and, in some cases, to have the information communicated to you. We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any information.
– Right to correct Personal Information. We endeavor to keep the information that we hold about you accurate and up to date. Should you realize that any of the information that we hold about you is incorrect, please let us know and we will correct it as soon as we can. The setting for a particular forum may also allow you to close your account, on the setting page for your account.
– Data deletion. In some circumstances, you have a right to request that some portions of the Personal Information that we hold about you be deleted or otherwise anonymized.
– Data portability. In some circumstances, you may have the right to request that we will provide you with the Personal Information you have made available to us, so you can transfer it to another party.
– Restriction of processing. In some cases, you may have the right to request restriction of the processing of your Personal Information, such as when you are disputing the accuracy of your information held by us.

Vimi may refuse requests to exercise data subject rights if there is a legitimate reason, such as if we cannot authenticate your identity, if the request could violate the rights of a third party or applicable law, or prevent us from delivering a service you requested.

9. HOW DO WE KEEP YOUR INFORMATION SECURE?
We have implemented administrative, technical, and physical safeguards to help prevent unauthorized access, use, or disclosure of your Personal Information. We limit access of your information only to those employees, third party service providers or partners on a “need to know” basis, and strictly in order to enable us to perform the agreement between you and us.
personal data is stored in a highly-secure server facility operated by Google Cloud Services, protected by a wide range of security measures, including passwords, security tokens, bank-level encryption and others Despite these measures, Vimi cannot provide absolute information security or eliminate all risks associated with Personal Information, and security breaches may happen. If there are any questions about security, please contact us at support@heyvimi.com.

10. HOW LONG WILL WE RETAIN YOUR INFORMATION
We will retain your Personal Information only for as long as you are a registered user. If you withdraw your consent to our processing your Personal Information, we will delete your Personal Information from our systems (except to the extent retaining such data in whole or in part is necessary to comply with any applicable rule or regulation and/or to respond to or defend against legal proceedings brought against us or our affiliates).

11. UPDATES TO THIS PRIVACY POLICY
This Privacy Policy is subject to changes from time to time at our sole discretion. The most current version will always be posted on our Services. You are advised to check for updates regularly. By continuing to access and use our Services after any updates become effective, you accept and agree to be bound by the updated Privacy Policy.

12. DIRECT MARKETING
● Email communications. We may, from time to time, send you email regarding our products and services, or products and services we think you may enjoy. Only We (or our vendors or service providers operating on our behalf) will send you these emails. You can choose not to receive these emails by clicking the unsubscribe link in any email. Please note that you are not permitted to unsubscribe or opt-out of non-promotional messages regarding your account, such as account verification, changes or updates to features of the App, or technical or security notices.
● Interest based advertising. We do not display any targeted advertising in the App. We do not permit third parties to collect information about your use of the App for the purpose of sending you targeted advertisements on other websites or applications. Although we are unable to recognize Do Not Track signals set by your browser, we do not engage in activities which track our users across other websites or mobile apps over time. However, outside of the App, we may engage in interest-based advertising to deliver online advertisements about our App, and may use third party advertising companies to serve targeted advertisements on other websites, apps or services, including on Facebook and other social networks. These advertisements are not based on the personal data we collect from you or on your activities on our App, though you may see one of these advertisements based on your activities on other websites or services (for instance, if you type “learning mobile app” into an online search engine, you may see an advertisement for Vimi). To learn about interest-based advertising and your choices, you may wish to visit the Network Advertising Initiative’s online resources here, and/or the DAA’s resources here.

13. GENERAL INFORMATION
This Privacy Policy, its interpretation, and any claims and disputes related hereto, shall be governed by the laws of the State of Israel, without respect to its conflict of law principles. Any and all such claims and disputes shall be brought in, and you hereby consent to them being litigated in and decided exclusively by a court of competent jurisdiction located in Tel Aviv, Israel.

14. HOW CAN I CONTACT YOU?
If you wish to exercise any of the aforementioned rights or receive more information, please email us at support@heyvimi.com.