(Last update:  February, 2021)

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NewPace Ltd. (“Company” or “we”) is committed to transparency regarding the security measures and policies which it has implemented in order to secure and protect personal data and personal identifying information (together "Personal Data"), all as defined under applicable data protection laws, including without limitations, the EU General Data Protection Regulation (“GDPR”) and the California Consumer Privacy Act (“CCPA”) (collectively, the “Data Protection Regulation”).

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This information security policy outlines the Company’s security, technical and organizational practices related to data protection. 

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As part of our data protection compliance process we have implemented technical, physical and administrative security measures to protect the Personal Data, including the GDPR Technical Organizational Measures (“TOM”) requirements.

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Physical Access Control
The Company ensures the protection of the physical access to the data servers which store the Personal Data. The Personal Data processed by the Company is stored within the Company Servers. Further, the Company secures the physical access to its offices (i.e., - alarm systems, code locks, etc.) and maintain records of any physical access to the protected Personal Data in order to ensure that solely authorized individuals and authorized external parties (maintenance staff, visitor, etc.) can access the Company’s offices.

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Security Risk Analysis and Management
The Company conducts an accurate and thorough assessment of the potential risks and vulnerabilities of the Company’s Personal Data to ensure the confidentiality, integrity, and availability of electronic Personal Data. The Company applies a periodic testing of the Company’s disaster plan in order to ensure that the Company can cope with a consummation of any disaster and emergencies. The Company's servers include an automated back-up procedure. The Company’s office is equipped with fire detectors, fire extinguishers and other applicable measures for the case of consummation of a nature disaster. 

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System Control 
Access to the Company’s database is highly restricted in order to ensure that solely the appropriate prior approved personnel can access the Company’s Personal Data. Safeguards related to remote access and wireless computing capabilities are in implemented therein. Employees are required to comply with the Company’s password policy when composing a password in order to allow strict access or use related to Personal Data all in accordance with position, and solely to the extent such access or use is required. There is constant monitoring of the access to the data and the passwords used to gain login access. In addition, the Company implement lock-out mechanism in order to prevent any unauthorised login to the Company’s servers by the means of password guessing. Electronic procedures are set in order to terminate an inactive session are also in use by the Company.

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Data Access Control
There are restrictions in place to ensure that the access to the Personal Data is restricted to employees and service providers which have a permission to access it and solely on a “need to know” basis. Any permission is granted by the Company’s data protection officer. The Personal Data information shall not be accessed, modified, copied, used, transferred or deleted without specific authorization. The access to the Personal Data information, as well as any action performed involving the use of the Personal Data requires a password and user name, which is routinely changed, as well as blocked when applicable. The user password is fully encrypted. Each employee is able to perform actions solely according to the permissions determined by the Company. Further, the Company has ongoing review of which employees’ have authorizations, to access and whether access is still required. Company revokes access immediately upon termination of employment. Authorized individuals can solely access Personal Data that is established in their individual profiles. 

Organizational and Operational Security 
The Company invests a multitude of efforts and resources in order to ensure compliance with the Company’s security practices, as well as periodic updates regarding Company’s security procedures. The Company strives to raise awareness to the risk involved in the processing of Personal Data. In addition, the Company implemented applicable safeguards for its hardware and software, including web content filtering, firewalls and anti-virus software (“Protection Measures”) on applicable Company hardware, software or employee’s computer, in order to protect against virus, worms, Trojan identifications or any other malicious software. The Protection Measures cannot be deactivated by any user other than the Company’s cyber security officer and according to the Company’s policies.

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Transfer Control 
Except for transfer data to our business partners, The Company does not transfer any Personal Data outside of the Company’s Servers. All transfer of Personal Data between the client side and the Company’s servers is protected using encryption safeguards, as well as encryption of the Personal Data prior to the transfer of any Personal Data. The Company’s servers are protected by industry best standards. Furthermore, the destruction of Personal Data following termination of the engagement is included within the contract between the parties. In addition, to the extent applicable, the Company’s business partners execute an applicable Data Processing Agreement, all in accordance with applicable laws.

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Data Retention 
Personal Data is retained for as long as needed to provide the services or as required under applicable laws. Individuals may request data deletion; however, this request is not absolute and is limited, all as detailed in the Company Privacy Policy. 

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Job Control 
All of the Company’s employees are required to execute an employment agreement which includes confidentiality provisions as well as applicable data protection provisions binding them to comply with the Company’s policies, in particular the computer security policy. In addition, employees undergo a screening process applicable per regional law. In the event of a breach of an employee’s obligation or non-compliance with the Company’s policies, the Company includes repercussions to ensure compliance with the policies all according to the Company’s Employee's Manual. In addition, prior to the Company’s engagement with third party contractors, the Company reviews such third party’s security policies, specifically their information data security policies to ensure it complies with the Company’s standard for data security protection. Third party contractors may solely access the Personal Data as explicitly instructed by the Company.