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Privacy Policy

Privacy Policy

Generation Capital Ltd. (“The Fund”), which manages and operates the website www.generationcapital.co.il (“The Website”), respects the privacy of users of the website and other investors in the Fund (“Users”), and will act in accordance with the detailed privacy policy below and the provisions of applicable law. This Privacy Policy is part of the Website’s Terms of Use, which are available [here](insert link), unless otherwise specified. The defined terms in the Terms of Use will have the same meaning as described in the Terms of Use.

Privacy Policy

The Fund respects the privacy of the users of the website it manages and operates (“The Website”). The following terms explain the Fund’s privacy policy and review, among other things, how the Fund will use the information provided by the users of the website or collected by the Fund during the use of the website or the operation of its business. The terms of the policy are written in masculine form for convenience, but refer to both males and females.

General

While using the website, providing contact details through the website or other means from the Fund, and engaging in any communication with the Fund, information related to you is collected. Some of this information personally identifies you, such as your name, address, email address, phone number, etc. This information will be stored in the Fund’s databases for the purposes specified in this policy. You consent and give the Fund or its representatives permission to collect and store this information in the Fund’s databases. You declare that you are aware that there is no legal obligation to provide this information to the Fund and that it is provided voluntarily, such as when using the “Contact Us” feature on the website. If you do not agree to provide this information, we may not be able to provide you with all or part of the services offered by the Fund. Some information does not personally identify you and is not stored along with your identifying details. This is statistical and aggregated information, such as the ads you have read on the website, the pages you have viewed, the offers and content that interested you, your IP address, and more.

Use of the Website

Some services on the website, and expressing interest in various content presented on the website, may require providing and collecting information. Additionally, information may be collected about you through the details you provide in registration forms, phone calls, and correspondence. Some of the information collected while using the website or services of the Fund will identify users personally, and some will be statistical or aggregate data that does not personally identify users and is not stored with their identifying information. All the information will be stored in the Fund’s databases in accordance with legal requirements. The types of information that may be collected and stored in the Fund’s databases through the website include, among others:

  • Technical Information available during the use of the website, including information such as IP address (depending on the network, computer, or device used to access the website), location, device identifier, browser type, browser version, operating system, and browsing history.
  • Behavioral and Usage Information about users’ activities and usage patterns on the website, including data on pages viewed, content of interest, time spent on the website, and additional statistical and/or aggregated data.

In addition, the Fund and any third party collecting information on its behalf may collect and store personal information that you voluntarily provide while using the website, contacting the Fund, or engaging in various activities. Such information may include personal details such as full name, date of birth, home address, demographic details, ID number, contact information (e.g., phone number, email address), and other identifying details as required from time to time. Some services and activities on the website may require registration and the provision of this information.

For the avoidance of doubt, if any information collected about you is non-identifying and anonymous, the Fund may use such information in any way it deems fit.

You agree and confirm that you understand that some of the information you provide and/or that is collected about you is not required by law and is provided voluntarily in order for the Fund to provide you with certain services, and that you consent to the Fund storing this information as specified in this Privacy Policy.

Use of Information

The information collected will be used only in accordance with this Privacy Policy and for the following purposes:

  • To enable you to use the various services and products provided by the Fund, including through the website.
  • To improve and enrich the services and content offered by the Fund, including creating new services and content that suit users’ needs or eliminating existing content. Most of the information used for this purpose will be statistical and non-personally identifying.
  • For the purpose of advertising content suitable for you.
  • To tailor advertisements that will be displayed to you during your visit to the website or on other websites and apps, based on your interests.
  • The Fund may send you marketing and promotional information about its products and services via email, SMS, WhatsApp, or any other communication method. Such information will only be sent to you if you provided explicit consent during registration or any other time, or if permitted by law. You can withdraw your consent at any time and stop receiving such information. The Fund will not proactively share your personal details with third-party advertisers for direct marketing purposes.
  • To contact you through the communication channels you provided to the Fund, or to analyze and provide statistical data to third parties, including advertisers. This data will not identify you personally.
  • For any other purpose outlined in this Privacy Policy or in the website’s Terms of Use.
  • To ensure the proper operation and development of the website.
  • To protect the rights of the Fund and manage legal proceedings, fraud investigations, information security, and safeguarding the Fund’s interests.

The data and information provided to the Fund will be stored only for as long as necessary and reasonable for the purposes for which they were collected, at the Fund’s sole discretion, and in any event, as required by law. Please note that anonymous information may remain on our servers, and we are entitled to use it for analysis and statistics purposes in the present and future without time limitation.

Disclosure of Information to Third Parties

The Fund will not disclose your personal details and any information collected about your activity on the website (if such information identifies you personally) except in the following cases:

  • To its business partners and third parties for the purpose of sending you marketing and other relevant materials, provided that you have given explicit consent to disclose your information to these third parties in accordance with the law.
  • To the Fund’s service providers, to allow the Fund to provide you with services and operate its business, including third parties providing marketing, advertising, and online advertisement matching services, even if they use the information for their own purposes.
  • In the event of a claim, demand, lawsuit, or any legal dispute between you and the Fund that requires revealing your details.
  • If you perform or attempt to perform activities on the website that are illegal or suspected to be illegal.
  • If a court order requires the Fund to disclose your details or information about you to a third party.
  • If the Fund determines that disclosing the information is necessary to prevent serious harm to your body or property or that of a third party.
  • If it is statistical information about the use of the website that does not personally identify you.
  • If the Fund sells or transfers the website’s operation to another corporation, or if it merges with another entity or integrates the website’s operation with that of a third party, provided that this entity agrees to follow the terms of this Privacy Policy.

Statistical Information Collection

The Fund uses third-party companies to provide statistical analyses about the use of the website. These companies collect and analyze information on website usage, frequency, access sources, and other factors. The collected information is statistical in nature and does not personally identify you. It is used for analysis, research, and monitoring purposes.

Other Websites

The website may contain links to pages, apps, and websites that are not managed or operated by the Fund or its affiliates. The Fund does not control or monitor these pages or websites, and the fact that the Fund links to them does not indicate its endorsement of their content or guarantee their reliability, accuracy, or legality. Using these pages, apps, or websites is subject to their own privacy policies, not the Fund’s privacy policy.

Cookies

The website uses automated tools to personalize your experience and improve website navigation. These tools collect information about your use of the site, including your Internet Service Provider, IP address, device location, browser type, and other data. Cookies are used to collect statistical data about the website, validate information, personalize content, and improve security.

The Fund may also use third-party advertising services that use cookies and similar tracking technologies (e.g., Pixels, Beacons) to customize ads for you, based on your interests.

You can control the use of cookies through your browser settings, though disabling cookies may limit your ability to access certain features or services on the site.

Information Transfer Outside of Israel

The transfer of information or providing access to information held by the Fund to third parties outside of Israel will only occur if at least one of the following conditions is met:

  • The information is transferred to a country in the European Union.
  • The information is transferred to a country that the European Union allows information to be transferred to, under specific conditions.
  • The Fund has an agreement with the recipient of the information, ensuring they comply with privacy protection laws.
  • You have explicitly consented to the transfer to a specific country.
  • The information is transferred to a subsidiary of the Fund with appropriate privacy protection mechanisms.

Information Security

The Fund implements up-to-date security systems and procedures to safeguard information. However, no system can provide complete security, and the Fund does not guarantee that its services will be completely immune to unauthorized access.

Right to Access, Correct, and Delete Information

According to the Privacy Protection Law, 1981, every individual is entitled to access the information held about them in a database. If an individual reviews their information and finds that it is inaccurate, incomplete, unclear, or outdated, they are entitled, according to the law, to request correction or deletion of the information by sending a registered letter to the Fund, following the procedures specified in the regulations, and also by contacting the Fund at the address: 10 Nissim Aloni St., Floor 4, Tel Aviv, or by any other contact method provided on the Fund’s website. Additionally, if the information in the Fund’s database is used for personal outreach based on your membership in a population group defined by one or more characteristics of people whose names are included in the database (“commercial offer outreach”), you are entitled, under the Privacy Protection Law, to demand in writing that the information related to you be deleted from the database.

In this case, the Fund will delete information needed only to contact you for the mentioned commercial offers. Information needed by the Fund for managing its business — including documentation of transactions and other actions you performed on the website — will continue to be stored in the Fund’s databases in accordance with the law, but will no longer be used for outreach purposes. If within thirty (30) days you do not receive notice that the requested information has been deleted in accordance with this section, you will be entitled to petition the Magistrates’ Court as specified in the regulations under the law, to instruct the Fund to act as requested.

Sending Promotional Materials

The Fund offers and/or may offer to send electronic and other forms of promotional materials (including via the internet, cellular networks, or any other existing or future communication method, including receiving newsletters), which means sending news, general, or promotional content directly to users who have opted in, related to the Fund’s activities, both current and future (“mailing”). It will be clearly stated that the mailing content may include advertisements, publications accompanying news content, or even content without any news value.

The user declares and confirms that they are aware of the provisions of Amendment No. 40 to the Communications (Telecommunication and Broadcasting) Law, 2008, and explicitly agrees to receive mail from the Fund, through any of the methods specified by law (including fax, automatic dialing systems, electronic messages, or SMS), or through any relevant future communication method. It will be clarified that in order to send you the most suitable content, the Fund uses information about you as outlined above to allow for an optimal characterization of the types of products and services most suitable for you.

The user of the mailing service can unsubscribe from the service at any time by following the procedures set forth by law or by contacting the Fund’s Investor Relations Manager at: generationir@generation.co.il or by phone at +972-72-275-8900 during business hours, as updated from time to time. However, unsubscribing from the mailing service or from direct mail activities will not delete the information collected about you from the Fund’s databases, and the Fund will continue to use the information for the purposes outlined in this Privacy Policy. The user can re-register for the mailing service by contacting customer service on the website.

Changes to the Privacy Policy

The Fund reserves the right to make changes to the privacy policy from time to time. In the event of significant changes to the provisions related to the use of the personal information you provided, a notice will be published on the homepage of the website. If you have any questions regarding the Terms of Use and/or this Privacy Policy, or if you wish to review, correct, or delete your personal information, you are welcome to contact us via the contact methods on the Fund’s website, or by sending an email to: generationir@generation.co.il.

Last Update Date: October 2024