PRIVACY NOTICE

1.  PURPOSE OF THIS PRIVACY NOTICE  

   

This Privacy Notice explains how Ofer Investments collects and processes your personal data through your use of the Website.

 

We encourage you to read this Notice carefully, and to regularly check this page to review any changes we might make to the terms of this Privacy Notice. This Privacy Notice supplements other notices we may provide as part of our interactions with you and is not intended to override such notices.

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2.  THE DATA WE COLLECT ABOUT YOU  

 

Personal data means any information about an individual from which that person can be identified.

When you use this Website, we may collect the following types of personal data on you:

 

• Identity Data includes first name and last name.

• Contact Data includes email address and telephone number.

• Usage Data includes information about how you use our Website (such as, when you entered the Website and how long you stayed in the Website).

• Additional Inquiry Data includes additional information that you may provide when you contact us through the Website.

• Technical Data includes browser type and version, time zone setting and location, browser plug-in types and versions and other technology on the devices you use to access this Website.

 

We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Such information does not reveal your identity and therefore is not considered personal data. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Website feature.

 

3.  HOW WE COLLECT YOUR PERSONAL DATA  

 

We use different methods to collect data from and about you including through:

 

• Direct interactions. You may provide us your Identity Data and Contact Data by entering your details on our Website, or by providing such details to Ofer Investments representatives in meetings, events and conferences.

• Automated technologies or interactions. As you interact with our Website, we may automatically collect Technical Data on equipment, browsing actions and patterns. We collect this data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.

• Third parties or publicly available sources. We may receive personal data about you from third parties, such as Usage Data provided by analytics providers.

 

4.  HOW WE USE YOUR PERSONAL DATA  

 

We will only use your personal data when permitted by law. We will commonly use your personal data in the following circumstances:

 

• Where the processing is necessary in connection with the performance of any contract we have entered into with you or where it is necessary for taking steps at your request prior to entering a contract. 

• Where the processing is necessary for our legitimate interests (or those of a third party), and such legitimate interests are not overridden by your interests, fundamental rights, or freedoms. Legitimate Interest means our interest in managing and conducting our business.

• Where the processing is necessary for compliance with a legal or regulatory obligation.

• Where you have provided your consent for such processing.  

 

PURPOSES FOR WHICH WE USE YOUR PERSONAL DATA  

 

Below is a description of the ways we intend to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate:]

 

• To respond to your request that we will contact you or provide information on our projects, products or services to you. We will do so where it is necessary for our legitimate interests (to promote a business relationship with you, pursuant to your request).

• To manage our relationship with you, including by notifying you about changes to our Website Terms of Use or Privacy Notice. We will do so for the performance of a contract with you, if it is necessary to comply with a legal obligation or if it is necessary for our legitimate interests (maintaining our relationship with you).

• To enter into a contract or to perform a contract with you.

• To deliver or display relevant advertisements, marketing and other content to you, including via email or on social media or third party websites, and to measure or understand the effectiveness of our marketing efforts. We will do so where it is necessary for our legitimate interests (to grow our business and to inform our marketing strategy); or where we have obtained your prior consent.

• To use data analytics to improve our Website, products/services, marketing, customer relationships and experiences. We will do so where it is necessary for our legitimate interests (to keep our Website updated and relevant, to develop our business and to inform our marketing strategy).

 

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.

 

CHANGE OF PURPOSE  

 

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider there is a need to use it for another reason and that reason is compatible with the original purpose.

 

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis that allows us to do so.

 

PROMOTIONAL OFFERS

 

We may use your Identity, Contact and Usage Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you ("Marketing Communications").

 

You will receive marketing communications from us if you have requested information from us or purchased services from us and, in each case, you have not opted out of receiving marketing communications.

 

If you wish to stop receiving marketing communications from us, you may ask us to stop sending you marketing communications at any time by following the opt-out link on any marketing message sent to you or by contacting us.

 

COOKIES

 

When you visit our Website, we may place cookies onto your device, or read cookies already on your device, subject to your consent where required by applicable law. For further details, please see our Cookies Policy.

 

THIRD-PARTY LINKS 

 

This Website may include links to third-party websites, plug-ins and applications. Clicking on those links or interacting with such content may allow your data to be shared with the relevant third-party. We do not control these third-party websites and are not responsible for their privacy statements; we therefore recommend that you read the privacy notice of every website that you visit.

 

5.  SHARING YOUR PERSONAL DATA WITH THIRD PARTIES                                                                                                                                         

We share personal data with third party service providers that provide us services in connection with the purposes listed above (such as sales, business management and marketing services).

We may also share your personal data with:

• legal and regulatory authorities to the extent required by applicable law;

• Contractors or service providers on our behalf, for the purpose of providing us the services in connection with the Website or in connection with your application to us via the Website (e.g. we may store a message that you leave on the Website in a customer management system offered by an external company);

• our professional advisors (e.g. lawyers, accountants) to the extent necessary for the provision of their services;

• In the event of a legal dispute between you (and / or a party on your behalf) to us (and / or a party on our behalf), to the extent necessary in connection with such dispute; and

• third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets, or parties whose business we wish to acquire.

 

We require such third parties to respect the security of your personal data and to treat it as required by applicable law and/or in accordance with binding contractual obligations of confidentiality. We permit our third-party service providers to process your personal data for specified purposes and in accordance with our instructions.

 

 

6.  INTERNATIONAL TRANSFERS  

 

We generally process you personal data in Israel, where our activity is based. We may transfer your personal data to other countries outside of the European Economic Area, which do not provide the same level of data protection as the country in which you reside and are not recognized by the European Commission as providing an adequate level of data protection. We do so for the performance of a contract or implementation of pre-contractual relations with you or subject to safeguards that ensure the protection of your personal data, such as standard contractual clauses approved by the European Commission.

 

7.  DATA SECURITY  

 

We have put in place appropriate security measures to prevent your personal data from accidental or unlawful loss, use, alteration or disclosure.

 

In addition, we take steps to ensure that the personal data we collect is limited to what is reasonably necessary in connection with the purposes set out in this Notice.

 

We limit access to your personal data to those employees, agents, contractors and other third parties who have a need to know. We require them to only process your personal data on our instructions and as allowed by applicable law.

 

8.  DATA RETENTION  

 

We retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for accounting, legal or reporting requirements.

 

In order to determine the appropriate retention period for personal data, we consider the following criteria: the volume, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of personal data, the purposes for which we collect and process personal data, the timeframe during which we may require such personal data in connection with potential litigation, and applicable legal requirements.

 

 

9.  YOUR RIGHTS  

 

Under certain circumstances, and depending on the country from which you are accessing the Website, you have rights under applicable data protection laws in relation to your personal data, as described below:

 

• Request access. This means that you may receive a copy of the personal data we hold about you.

 

• Request correction. This means that you may ask us to correct or complete inaccurate or incomplete data that we hold about you.

 

• Request erasure. This means that you may ask us to delete or remove personal data that we hold about you. If we are unable to comply with such request, we will notify you of the specific legal reasons for our decision.

 

• Object to processing. This means that you may object to the processing of your personal data where it is used for direct marketing purposes, or where we are relying on a legitimate interest and you feel that such interest is overridden by your rights and freedoms.

 

• Request restriction of processing. This means that you may ask us to suspend the processing of your personal data if you believe that such data is inaccurate, if our processing is unlawful or if we no longer need to process such data for a particular purpose, but you need us to continue to hold the data.

 

• Data Portability. This means that you may request that we transfer your personal data to you or to a third party. This right applies where we have obtained and processed the data from you based on your consent or where we used the information to perform a contract with you.

 

• Withdraw consent at any time. This means that you may withdraw your consent where we are processing your personal data based on your consent.

 

If you wish to exercise any of the rights set out above, please contact us.

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WHAT WE MAY NEED FROM YOU

 

When you approach us with a request to exercise one of your rights, we may request that you provide us with information needed to confirm your identity as a security measure to ensure that your personal data is not disclosed to any person who has no right to receive it.

 

TIME LIMIT TO RESPOND  

 

We try to respond to all legitimate requests within one month. Where it takes us more than one month to respond (for example, where your request is particularly complicated or where you have made a number of requests) we will notify you and keep you updated.

 

10.  CONTACT DETAILS  

 

Ofer Investments Ltd.  

Postal address: Ofer Investments Ltd., 1 Abba Eban Blvd., Herzliya Pituach.

 

You have the right to make a complaint at any time to data protection authorities. We would, however, appreciate the chance to address your concerns before you approach a data protection authority, so please contact us in the first instance.

 

11.  CHANGES TO THIS PRIVACY NOTICE 

 

This Privacy Notice may be amended or updated from time to time to reflect changes in our practices with respect to the processing of personal data, or changes in applicable law. We will provide notice of substantial changes to this Privacy Notice. Such substantial changes will take effect seven (7) days after such notice was provided on the Website. All other changes to this Privacy Notice are effective immediately upon publication of the updated Privacy Notice on the Website.

 

This version was last updated on May 23, 2023