Annual Compliance Statement


Annual Compliance Statement, March 15, 2026


As of March 15, 2026, Virtual Spirits confirms that it has reviewed its applicable obligations as a service provider, Data Holder / Processor, under its Data Processing Addendum and the Israeli Protection of Privacy Regulations (Data Security), 2017, including Regulation 15, to the extent applicable to the Services.

During the relevant reporting period, Virtual Spirits maintained administrative, technical, and organizational security measures designed to protect Customer Data processed through the Services, including account-based access controls, encryption in transit, access restrictions, data minimization practices, retention controls, anonymization options, incident-response procedures, and confidentiality obligations for personnel.

To the best of Virtual Spirits’ knowledge, and based on its internal review, Virtual Spirits has materially performed its applicable obligations under the DPA and the applicable Israeli privacy and data security requirements relevant to its role as Data Holder / Processor.

This statement is made available to Customers as the annual written update regarding Virtual Spirits’ performance of its applicable obligations under the DPA and Regulation 15 of the Israeli Protection of Privacy Regulations (Data Security), 2017.

This statement does not expand the scope of the Services, does not amend the Customer’s responsibilities as Database Owner, and does not constitute a legal opinion, external audit report, certification, or guarantee of compliance with any law or regulation not expressly covered by the DPA.





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