בבקשה. להלן המסמך באנגלית, מסודר, מנוקה מקטיעות שורות ומאורגן לפסקאות הגיוניות וקריאות, מוכן להעתקה:

BS”D

Introduction

Privacy Policy This Privacy Policy (“Policy”) applies to the services provided by Achuzat Schneller Ltd., Company No. 512688268 address 2 Hapoalim St, Jerusalem, and its affiliated companies (including but not limited to ISA Holdings Ltd. and Dankron – Schneller Ltd.) (together ”The Company”). The Company provides project development and marketing services in the real estate sector, as well as accommodation services at the Company’s hotels (collectively, the “Services”).

Definitions For the purposes of this Policy:

• “Website Use” means any use of, or attempt to use, the Company’s websites, landing pages, or any other digital platform operated by the Company.
• “Contacting the Company” means any communication with the Company other than through the Website, including by telephone, email, fax, in-person visits or calls, or any other means.
• “You” or “User” means any individual who uses the Services as abovementioned, including any person who accesses the Website or contacts the Company through any channel.

By accessing or using any of the Services, you acknowledge that you have read, understood, and agree to be bound by the terms of this Policy. If you do not agree to any provision of this Policy, you must immediately cease all use of the relevant Services. This Policy may be updated from time to time. We encourage you to review it from time to time, to stay informed of any changes.

Collection of Personal Information The Company respects your privacy. In the course of providing the Services, we collect personal information about you – that is, information that identifies you or may reasonably be used to identify you. Personal information is collected both when you voluntarily provide it to the Company through direct contact, and automatically through data collection technologies when you use the Website, as described below.

Unless expressly stated otherwise, you are not legally required to provide personal information. However, failure to provide certain information, or providing incomplete information, may prevent the Company from delivering the requested Services. By providing information – including by continuing to browse the Website or use the Services – you consent to the processing of such information in accordance with this Policy. If you do not agree to the terms set forth herein, you must discontinue all use of the Services.

Types of Information Collected, How It Is Collected, and Where It Is Stored The Company processes, among other things, data regarding the content and information transmitted in connection with your use of the Services, as well as any other data or information about you or related to you, whether provided by you directly or by third parties.

• Personal Information You Provide Directly: Information collected in connection with the Services and direct communications with the Company may include, without limitation: personal details (full name, gender, address, telephone number, email address), marital status, contact details, the content of conversations and correspondence, business and financial information (such as the last four digits and expiration date of a credit card, bank account number, and similar details) provided in the course of receiving the Services, and any other information submitted when contacting the Company. Communications with the Company may be recorded and retained for quality assurance, service improvement, and legal purposes.
• Communications via Various Channels: Information you provide when contacting the Company via WhatsApp or when requesting information about projects, or through any other channel – including your telephone number, the content of your inquiry and correspondence, and any files you upload – is stored in the Company’s systems. Your use of WhatsApp or other third-party communication channels is also subject to those providers’ own privacy policies and terms of use, as updated from time to time. We expressly disclaim any responsibility for the processing of your information by WhatsApp or other third-party providers. For further information regarding their data practices, please consult their respective privacy policies and terms of use. Additionally, calls with the Company may be recorded for quality assurance and service improvement purposes.
• User Portal Access and Use: Certain Company websites allow Users to access a user portal (including, without limitation, a resident portal). In connection with the registration, login, and use of such dashboard, the Company may collect, store and process personal and operational information about the User, including authentication credentials such as username and password, full name, unit/apartment number, contact details, profile information, login and activity logs, inquiries, requests, correspondence, and any documents or files uploaded through the portal, as well as any other information provided or generated in the course of using the portal.
• Room Reservations and Payments: When booking rooms or making payments, we collect reservation and purchase details, personal information such as your full name, email address, and telephone number, and any additional information required at the time of purchase or payment that is marked as mandatory. Upon completion of these details, you will be redirected to a secure payment page operated by a third-party payment processor, where you will be asked to enter your payment information. The Company does not store payment method details (other than the last four digits and expiration date of a credit card) in its own databases. Payment processing services are provided by third parties, and such information is stored securely by those parties in accordance with their own privacy policies. Information regarding the services you have purchased or payments you have made will be retained in the Company’s systems.
• Information Collected Automatically: In addition to information you provide directly, when you use the Website, the Company also collects information automatically. This may include device and usage data, your IP address, usage analytics, crash and error reports, browser and device characteristics, operating system functionality, language preferences, referring URLs, location data, information about how and when you access the Website, your internet activity before and after such use, content preferences, and other technical data that may not necessarily be personally identifiable. You acknowledge that the Company may share aggregated statistical data regarding user activity on its websites with third parties, including advertisers. Such statistical data will not personally identify you. You consent to the sharing of such data.

Data Collection Technologies In the course of your interactions with the Company or your use of the Services, the Company and its agents may automatically collect additional information, including the date, time, and duration of your inquiry and the communication channel used.

We may use certain tracking technologies, such as cookies, pixels, tags, and scripts (collectively, “Cookies”), embedded on the Website. These technologies collect and analyze data about how the Website is used for the purposes described below. Some Cookies are set by us (“first-party Cookies”), while others are set by external partners who provide analytics, advertising, and marketing services (“third-party Cookies”) and who may use the collected data for their own business purposes.

• Essential Cookies: Used for the routine operation, proper functioning, and security of the Website. These Cookies do not collect information that can identify you or be attributed to you (targeting). These cookies cannot be disabled.
• Performance and Analytics Cookies: Used to measure how the Website is used, in order to analyze, evaluate, and improve its performance. These Cookies allow us to understand how visitors interact with different pages, how long they spend on the Website, and which content is most popular, and to derive insights that enable us to maintain, measure, and improve our marketing, advertising, and sales activities. For these purposes, we embed third-party Cookies such as those provided by Google Analytics and Clarity.
• Functional Cookies: Used to remember your settings and preferences, in order to enhance your user experience. These Cookies enable, among other things, retention of your interface language, display settings, login details, and the operation of essential Website features.
• Marketing and Advertising Cookies: Used to display advertisements and content tailored to your interests, including on third-party websites and services, based on your browsing and usage history. For these purposes, we embed third-party Cookies such as those provided by Google Ads, Clarity, and social media platforms.

You may delete or prevent the creation of Cookies on your device by adjusting the relevant settings in your browser.

Purposes of Data Collection and Use The Company may process your personal information for purposes related to the provision of the Services and the conduct of its business operations, including, without limitation:

• Operating and Providing Services – Using information you provide when contacting the Company in order to respond to your inquiries, provide information about Services, manage relationships with existing and prospective customers, resolve any issues you may encounter, and track inquiries, requests, and service delivery.
• Documentation of inquiries, requests and the Company’s Services.
• Improving the Company’s Services.
• Facilitating hotel room reservations at the Company’s hotels and collecting information about the duration and quality of your stay and reservation details.
• Using data collected through data collection technologies in the course of operating and enhancing the Website.
• Enforcing the terms of use of the Website and protecting the rights, property, legal interests, and safety of the Company, third parties affiliated with the Company, you, or any other person or entity.
• Defending against legal claims, demands, or proceedings, and acting in accordance with applicable law and the Company’s internal policies.
• Data security – Conducting analysis necessary to detect malicious data and understand potential threats, monitoring and statistically analyzing ongoing attacks on devices and systems, and continuously adapting security solutions to protect devices and systems against various attacks.

Sharing Your Information with Third Parties The Company works with various third parties from time to time and may share your personal information with them in furtherance of the processing purposes described above, including in the following circumstances:

• Where the Company determines that your activities in connection with the Services are carried out for the purpose of committing fraud of any kind, or appear to be in violation of applicable law, or constitute an attempt to engage in such activities.
• Where the Company is required to do so pursuant to a legal obligation, court order, or directive from a competent authority requiring the disclosure of your information.
• Where the Company faces a threat of legal proceedings (criminal or civil) in connection with actions you have taken through the Services.
• In connection with any dispute, claim, demand, or legal proceedings, if any, between you and the Company or relating to the Services.
• To service providers (including those located outside of Israel) engaged to perform services on behalf of the Company, including customer service management, marketing campaigns, and advisory services. The Company requires all such service providers to agree to process your personal information in accordance with this Policy.
• Your information may be transferred outside the jurisdiction of Israel, including to jurisdictions where privacy and data security laws may be less comprehensive than those in Israel. Any such transfer will be carried out in accordance with the Protection of Privacy Protection (Transfer of Data to Databases Abroad) Regulations, 5761-2001.
• Where the Company reasonably believes that the disclosure of your personal information is necessary to prevent harm to its rights or the rights of third parties, or to other entities within the Company.
• In the context of business collaborations with companies commercially affiliated with the Company, including contractors.
• In the event of a merger, acquisition, or restructuring of any kind, including the management of the Services by a different entity, the Company shall be entitled to transfer the information collected about you to the new entity or a relevant third party, provided that such entity assumes obligations consistent with this Policy or obligations of substantially similar effect.

In addition, the Company may share non-personally identifiable information (for example, statistical or aggregated data), whether for consideration or otherwise, with third parties with which it maintains business or other relationships, for any purpose.

Marketing Communications The Company may contact you (directly or through its agents) in response to a “Contact Us” request or a request for information about projects, through any form and by any means, including by telephone, email, text message, or otherwise. The Company may also send you content, including marketing communications by way of direct mailing as defined under the Protection of Privacy Law, and commercial advertisements as defined under the Telecommunications Law, 5742-1982 (respectively, “direct mailing” and “advertisements”), as well as invitations to events or conferences.

If you no longer wish to receive direct mailing and advertisements, or if you wish to request removal from the Company’s database (subject to applicable law and the Company’s policies), you may withdraw your consent at any time by sending notice to the Company at the following email address: [email protected] , or as otherwise indicated in any communication you receive.

Third-Party Links The Website may contain links to third-party websites. The inclusion of such links does not constitute a recommendation or endorsement; they are provided solely for your convenience. When you navigate to a third-party website, you are subject to that website’s own privacy policy and terms of use. We recommend that you review those terms carefully before using any third-party website. The Company is not responsible for the content of any linked third-party websites or the quality of services provided therein, and assumes no liability in connection with such websites.

Data Retention We retain personal information for as long as it is necessary to provide the Services, to support our ongoing business operations in accordance with the Company’s internal policies, and as required by applicable law. We may also continue to retain your personal information where there is a legitimate need to do so – for example, in anticipation of potential legal proceedings, or for documentation, archiving, and other legal purposes. Your personal information will be stored in the Company’s database, which may be maintained and managed on its behalf by a third party.

Data Security The Company places great importance on safeguarding your privacy and employs commercially reasonable measures under the circumstances to protect the personal information you provide. However, while these measures reduce the risk of unauthorized access to the Company’s systems, no method of electronic transmission or storage is completely secure. The Company cannot guarantee that unauthorized access to the Website or its systems will not occur. If you believe that your personal information may have been exposed to unauthorized parties, you must notify the Company immediately using the contact details provided below.

The Company makes efforts it considers reasonable to prevent unauthorized access to information collected in connection with the Services.

Where you are required to provide login credentials (such as a username and password) to access Services on any of the Company’s websites, you bear sole and exclusive responsibility for all activities conducted using your credentials. You are advised to keep your login credentials confidential and not to disclose them to any third party. If you choose to share such information with a third party, you assume full responsibility for all activities carried out using your credentials. You are further required to notify the Company immediately of any suspected unauthorized use of your credentials or any breach of confidentiality or privacy related to your account.

Minors The Services are generally intended for users aged 18 and over. To the extent that certain Services are also available to users under the age of 18, such users must obtain the consent of a parent or legal guardian before using those Services or submitting any personal information through the Website. If you (or your parent or legal guardian) do not agree to this Policy, in whole or in part, you are requested to refrain from any use of the Website for any purpose.

Right of Access and Correction Under certain circumstances, you may have the right to access personal information collected about you, in accordance with Section 13 of the Protection of Privacy Law, 5741– 1981. You may also have the right to request the correction or deletion of information collected about you if you find it to be inaccurate, incomplete, unclear, or outdated, in accordance with Section 14 of said law. For further information, please contact us using the details provided below.

Changes to This Policy The Company reserves the right to amend the terms of this Policy from time to time, at its sole discretion, without prior notice. The Company reserves the right to notify you of changes that materially affect your rights, if any, through one of the communication channels you have provided. Notwithstanding the foregoing, in the event of material changes to this Policy, a notice will be published on the Website. Your continued use of the Company’s Services following notification of such changes shall constitute your acceptance of the amended Policy.

Miscellaneous If any provision of this Policy is found to be invalid or unenforceable by a final and binding court judgment or ruling, only that provision shall be void, and all remaining provisions of this Policy shall remain in full force and effect and continue to bind you. You agree that this Policy shall be construed as broadly as possible to give effect to its terms, in whole or in part.

This Policy shall be governed exclusively by the laws of the State of Israel. The exclusive jurisdiction for any matter arising out of or in connection with this Policy and the Services shall vest in the competent courts in the Jerusalem district.

Contact Us If you have any questions or requests regarding this Policy, you may contact the Company by email at: [email protected] or by telephone at 02-6447113.