Privacy Policy

Last updated: August 2026

1. Introduction, Application and Purpose of the Policy

Psagot Equity Ltd., Psagot Equity Trustees Ltd. (together, hereinafter: "Psagot Equity") and Psagot Equity Financial Services Ltd. ("Psagot Equity Financial Services") respect the privacy of their clients, of those interested in their services and of any other party whose information is collected by them. Accordingly, this Privacy Policy is intended to clarify how Psagot Equity and Psagot Equity Financial Services collect, receive, retain, process, use, transfer and protect Personal Data, each separately and jointly as the case may be, in the course of their business, financial and operational activity and in accordance with the regulatory obligations applicable to each of them.

For the purposes of this Policy, the "Group" means: Psagot Equity, Psagot Equity Financial Services, the subsidiaries of each of them, companies affiliated with them, companies under their joint control, and any other corporation that joins the Group in the future and engages in trust services, financial asset services, payment services, financial operations services and/or ancillary services and/or any other service that the Group decides to provide, all in accordance with the licenses held by the Group companies.

This Policy is intended to serve as a broad notice and consent document in respect of the Group's websites, digital assets and digital systems, the services of the Group companies, engagement documents, identification processes, trust services, custody, financial asset services, payment services (subject to holding an appropriate license) and any additional, ancillary or complementary service that is or will be provided by the Group companies.

This Policy applies to any person who provides information to the Group, or whose information is provided to, collected or processed by the Group, including existing and potential clients, beneficiaries, payees, offerees, employees participating in equity compensation plans, shareholders, rights holders, borrowers, guarantors, providers of collateral, controlling persons, authorized signatories, corporate representatives, developers, contractors, members of purchasing groups, website users and visitors, persons applying for service, and any other person connected with the Group's services.

This Policy is intended to reflect the Group's compliance with the requirements of Israeli law, regulation, the directives of the supervisory authorities, the provisions of the prohibition on money laundering and terrorist financing laws, tax laws, information security and privacy protection requirements, and all of the Group's contractual undertakings, and further to enable the Group to provide existing and future services subject to the provisions of law.

2. Identity of the Group Companies and Their Status in Relation to the Information

Depending on the relevant service and the purposes of processing, any of the Group companies, or companies affiliated with them, may act as Database Controllers, whether separately or under joint control, or as Database Holders.

In trust services in which the Trust Company (as defined below) provides the services on behalf of a third party (for example, an employing company under an equity compensation plan), it will be the Database Holder; and in other trust services, in which it acts as trustee directly for the beneficiary, it will be the Database Controller. Its status in relation to the information will be determined on a case-by-case basis, in accordance with the circumstances of the service and the engagement.

It is clarified that, unless expressly stated otherwise, Psagot Equity Financial Services will be the Database Controller, or the Database Holder, in accordance with the circumstances of the service and the engagement in respect of the services it provides.

Where Services are provided on a combined basis by more than one Group company, such companies may act as joint Database Controllers of the relevant databases. In such cases, such companies shall be entitled to process the Personal Data for the purposes of providing the Services; complying with the provisions of law; risk management; information security; the prevention of fraud and embezzlement; the prohibition on money laundering and terrorist financing; the prevention of the use of inside information; marketing, subject to the provisions of law; and the other purposes set out in this Policy.

3. Definitions

Personal Data: Any data relating to an identified or identifiable individual, whether directly or indirectly.
Client or Service Recipient: Any person or corporation that receives services from the Group, applies to receive services, is in the course of an onboarding or disclosure process, or is connected with the services provided by the Group.
Data Subject: Any person whose Personal Data is processed by the Group, including a person who is not a client of the Group.
Beneficiary or Payee: Any person or body that is entitled, or may become entitled, to a right in funds or other assets.
Services: All existing or future services offered by the Group to clients, including trust services, financial asset services, payment services (subject to obtaining a license), and the operation of all of these.
Other terms: Unless otherwise provided, all terms shall have the meaning ascribed to them by law.

4. Is There an Obligation to Provide Information?

As a rule, there is no legal obligation to provide personal information to the Group. However, the provision of certain information may be a condition for receiving services, opening an account, carrying out a transaction, joining an equity compensation plan, receiving consideration from a trust, receiving payment services and any other action in respect of which the Group is required, under its contractual undertakings or by law (the anti-money laundering provisions, the directives of the Israel Tax Authority and other provisions), to obtain information in order to carry out the action.

Accordingly, failure to provide information, the provision of partial or outdated information, and/or a refusal to provide documents required by law or under the Group's procedures, may prevent the Group from providing the services in whole or in part, delay the performance of actions, prevent the transfer of rights or funds, prevent the exercise of options or shares, prevent the provision of various services and/or lead to the termination of the engagement, all in accordance with the circumstances and the provisions of law.

5. Categories of Data Subjects to Whom the Policy Applies

The Group may collect and process Personal Data relating to a wide range of data subjects, including:

Clients and potential clients.
Users of the Group's websites and digital systems.
Issuing companies, employing companies, merging companies and the like.
Employees, office holders, directors, consultants and offerees under equity compensation plans.
Shareholders, holders of securities, rights holders, payees and recipients of consideration.
Borrowers of various types: private, business, members of purchasing groups, developers, contractors and holders of rights in projects.
Guarantors, providers of collateral, interested parties, authorized signatories, members of representative committees and representatives of various corporations.
Attorneys-in-fact, lawyers, accountants, trustees, consultants, intermediaries, management companies and parties to transactions.
Contact persons on behalf of clients, suppliers, service providers and other business parties.
Beneficiaries as defined in the Prohibition on Money Laundering Law, 5760-2000.
It is clarified that, in some cases, the person about whom information is collected is not a direct party to the engagement with the Group – for example, an employee who is an offeree under an equity compensation plan, a shareholder in a sale transaction, guarantors under loans and others. Nevertheless, the processing of the information may be required for the provision of the services and/or for compliance with the provisions of law.

6. Services and Activities Covered by This Policy

This Policy applies to all of the Group's services, including the following services, as provided from time to time and subject to the relevant licenses, permits and provisions of law:

Trust services and custody services.
Commercial or financial trusts.
Management and operation of equity compensation plans – options, restricted shares, bonus shares and share-based plans.
Financial asset services, including holding, managing, transferring or performing any other action in a financial asset that is permitted by law.
Provision of credit – subject to obtaining an appropriate license.
Payment services, management of payment accounts, execution of payment instructions, clearing, handling of deposits, withdrawals and transfers – subject to obtaining an appropriate license.
Brokerage services with brokers or stock exchange members through whom the activity is carried out.
Operations, technology, customer service, information systems management and regulatory services ancillary to the activity of the Group companies and to the services set out above.

7. Categories of Personal Data Collected and Processed

The Group may collect and process the following categories of information, as applicable and in accordance with the type of service:

Identification particulars: full name, identity number, passport number, date of birth, citizenship, residency, gender (where required), copies of identification documents and signature specimens.
Contact particulars: address, telephone, email, mailing address and contact person details.
Employment / business information: employer name, position, employment status, employment commencement and termination dates, business activity; controlling persons and authorized signatories on behalf of corporations.
Financial information: bank accounts, means of payment, balances, movements, income, liabilities, assets, sources of equity, repayment data, collateral and guarantees.
Credit information: credit data, ratings, credit history, repayment data, arrears, guarantees, information from credit bureaus (reports and indications) and from credit data systems.
Information required for compliance with FATCA or CRS requirements, including: tax residency, tax certificates, exemptions, withholding rates and reports to the income tax authorities.
Information regarding equity compensation plans: number of options or shares allocated, allocation dates, vesting dates, exercise prices, exercise status, sales, consideration and gains.
Particulars of various types of transactions: information regarding trusts, adjustment mechanisms, entitled parties, trust documents and more.
Documents required for compliance with anti-money laundering requirements: beneficiary declarations, responses to KYC questions, source of wealth, source of funds, information required for verification and identification, documents for in-person identification or remote identification by digital means and more.
Browsing data: cookie data, device identifier, IP address, login data, logs, data on the use of the systems or the website and more.
Communications information: call recordings, correspondence across various media, service enquiries, meetings, video calls, text messages and any other documentation of a data subject's interaction with the Group.

8. Sources of the Information

The information may be collected directly from the data subject or from other sources, including sources authorized by the client, sources from which the law permits information to be obtained, or sources required for the provision of the service. The information may be received, inter alia, from the following sources:

The data subject or a party connected with the data subject.
Employing companies, issuing companies, companies granting equity compensation and companies connected with the compensation plan.
In mergers and acquisitions transactions – the acquired company, the acquiring company, sellers, purchasers, shareholders and parties to the transaction.
Advisers – lawyers, accountants, tax advisers, financial advisers and other professionals.
Financial institutions – banks, other financial institutions, stock exchange members, brokers and the like.
Credit bureaus, the credit data system, authorized databases, business information providers and financial information sources (such as financial information service providers).
Regulatory authorities – the Israel Tax Authority, the Israel Securities Authority, the Capital Market, Insurance and Savings Authority, the Bank of Israel, official publications and any other body from which information may lawfully be obtained where such information is required by the Group.
Public information – websites, public registries, social networks and any other source lawfully available to the public.
Technology parties – system providers, cloud service providers, information security providers, payment service providers, identification service providers, operations service providers, technology services provided by one Group company to other Group companies, and any other party that provides technology services to the Group.

9. General Purposes of Processing Information

The Group may process Personal Data for the following purposes, in whole or in part, subject to the relevant service and to the provisions of law:

Engagement and/or negotiation processes with clients, client relationship management, provision of service to clients, support, responding to enquiries and documenting actions.
Identification, verification and account opening processes, permissions management, user management and management of access to systems.
Provision of financial asset services, various types of trust services, risk assessment, credit risk management, determination of engagement terms, pricing of services, acceptance or rejection of a client, and any additional service that the Group elects to provide.
Management of funds, transfer of payments, collection, debits, credits and calculations of consideration and entitlement.
Opening of trust accounts – opening accounts for clients, offerees and beneficiaries, including with affiliated companies within or outside the Group.
Tax computations and examination of tax liabilities, withholding tax at source, reporting to the authorities, reporting to employers, reporting to clients and reporting to regulatory bodies.
Compliance with anti-money laundering provisions – ascertaining the source of funds, monitoring unusual activity, performing the KYC process and any other action entailed in complying with the requirements of law.
Management of various risks – risk management, internal and external audit, prevention of fraud and embezzlement, prevention of impersonation, monitoring of prohibited activity, monitoring of cyber risks, and monitoring of operational and compliance risks.
Conduct of various legal proceedings, including claims, disputes, arbitration and mediation, enforcement of agreements and preservation of evidence.
Business development – improvement of products and services, development of new products, examination of and investment in products and services, and the building of digital platforms, including PEaX, applications and future services.
Data analysis, generation of insights, use of analytical models, automated systems, statistical reports, anonymization of information and its conversion into anonymous and aggregate information, use of artificial intelligence and any other means of analyzing data and generating insights.
Marketing, mailings, offering of services, tailoring of products and services, and cross-marketing between Group companies, subject to the provisions of law and subject to providing the option to opt out of receiving information from a company that does not provide a service to that data subject.

10. Purposes of Processing Information in the Context of the Principal Services Provided by the Group Companies

10.a. Equity Compensation Plans

In the context of trust and operational services for equity compensation plans, including the allocation of options, restricted shares, bonus shares and any other share-based compensation plan, the Group may collect and process Personal Data relating to employees, office holders, directors, consultants and offerees (hereinafter: the "Participants"), as well as employing companies and issuing companies.

In the management of trust accounts and vesting, the purposes of processing will include, inter alia: the allocation of options or shares, management of the vesting of options, sale of shares, calculation of consideration and gains, withholding tax at source, reporting to the tax authorities, reporting to employing companies, management of payments and transfers of funds, documentation of activity, regulatory controls, operation of trading and brokerage systems, and customer service and support for all Participants.

Information in this context may be received from the Participant, from the employing company, from the issuing company, from the trustee, from brokers, from system providers, from tax authorities and from regulatory bodies. Failure to provide information may prevent participation in the plan, the exercise of rights, the execution of a sale or the receipt of consideration.

10.b. Trust Transactions of Various Types and with Various Mechanisms (M&A, Earn-Out, Escrow or Holdback)

In the context of trust services in such transactions and the operation of the mechanisms described in the heading of this section, the Group may process information relating to beneficiaries, payees, shareholders, sellers, purchasers, rights holders, trustees, companies, advisers and additional parties to the transaction.

The purposes of processing include the identification and verification of the particulars of the entities described above, maintenance of entitlement and consideration registers, calculation of the share of beneficiaries or payees in the consideration, management of adjustments, verification of compliance with the required conditions, management of the trust accounts, handling of enquiries, customer service, anti-money laundering processes, transaction agreements, withholding tax at source, reporting to the authorities and compliance with the provisions of law.

For the purpose of providing the services, the Group will be required to collect and process data regarding the source of funds, holdings, KYC, identification particulars, contact particulars, particulars of accounts at financial institutions, various documents concerning tax liability, amounts of consideration, transaction documents and additional information required in order to carry out the transaction.

10.c. Financial Asset Services

Psagot Equity Financial Services holds a license for the provision of financial asset services and acts in accordance with the terms of that license, and will act in accordance with the terms of any license granted to it in the future.

The services of Psagot Equity Financial Services may include the processing of information for the purpose of managing the assets of clients or beneficiaries; for the purpose of holding, transferring, converting, purchasing, selling or performing any other action in clients' assets; and for the purpose of opening accounts at financial institutions, monitoring activity, managing risks and complying with anti-money laundering provisions.

The information processed may include identification particulars, particulars of accounts at financial institutions, data regarding the source of funds or assets, wealth data, data regarding beneficiaries, controlling persons and authorized signatories, instructions and actions given by the client, data regarding transfers, conversions and sales, counterparties, and any other information that Psagot Equity Financial Services is required to obtain by law and/or for the purpose of providing the service.

The processing of information may also be carried out for clients of Psagot Equity and as part of services combining several Group companies.

10.d. Provision of Services for Real Estate Activity

In the context of the Group's services for real estate activity, the Group may provide various services. In this framework, the relevant company or companies will be required to collect and process information regarding private and business borrowers, members of purchasing groups, contractors, developers, holders of rights in projects, guarantors, providers of collateral, controlling persons and authorized signatories.

The purposes of processing include the opening of accounts, risk assessment, safekeeping of funds, execution of transfers of funds, controls, regulatory reporting and risk management.

The information may include, inter alia, ownership of various rights (rights in land, ownership percentages and the like), sources of equity, financing documents, collateral, guarantees, valuations, project cash flow, data regarding bank accounts and additional information that may be required for the purpose of providing the service.

10.e. Provision of Credit, Subject to Holding a License

Subject to obtaining an appropriate license, Psagot Equity Financial Services will provide credit to its clients, and in such case the provisions of this Policy will apply to those services as well, subject to the provisions of law, the terms of the license and specific directives of the Capital Market, Insurance and Savings Authority.

For the purpose of providing the services, the Company will be required to process information for the purpose of examining the credit application, performing credit underwriting, determining the credit terms, transferring the credit funds, collection, verification of users in the systems, risk management, prevention of fraud and embezzlement, information security and compliance with the requirements of law.

For this purpose, the Company will collect personal particulars regarding recipients of the service, guarantors, beneficiaries, payers and any other party to credit provided by it. The information will include identity particulars, family information, economic and financial data, contact particulars, particulars of accounts at financial institutions, and any other information required by law for the purpose of providing the service.

It is clarified that these services may be provided as part of combined services provided by the Group – for example, the provision of credit for the purpose of exercising rights under a compensation plan and the like.

10.f. Payment Services, Subject to Holding a License

Subject to obtaining an appropriate license, Psagot Equity Financial Services will provide payment services and credit incidental to a payment transaction. In such case, the provisions of this Policy will apply to those services as well, subject to the provisions of law, the terms of the license and specific directives of the Israel Securities Authority.

For the purpose of providing the services, the Company will be required to process information for the purpose of opening and managing a payment account, executing instructions, handling withdrawals and deposits, transferring funds, clearing, managing means of payment and digital wallets, performing conversions, monitoring transactions, verifying users in the systems, risk management, prevention of fraud and embezzlement, information security and compliance with the requirements of law.

For this purpose, the Company will collect personal particulars regarding account holders, authorized signatories, attorneys-in-fact and beneficiaries, comprising identity particulars, family information, economic and financial data, contact particulars, and any other information required by law for the purpose of providing the service.

It is clarified that these services may be provided as part of combined services provided by the Group, including for the purpose of managing trust accounts for various purposes for clients of Psagot Equity Ltd.

11. Credit Data System and Credit Bureaus

For the purpose of various checks and risk management, the Group may receive information from credit data systems, credit bureaus, various databases, banks, financial bodies, financial information providers, public sources and governmental and regulatory bodies.

To the extent that the Group is obliged to do so, or permitted to do so by law, it will be entitled or required to transfer information regarding the client, the engagement with the client, the client's compliance with its obligations, credit data, repayment data or any other information required by law, to the credit data system or to any other body authorized to receive it.

Credit information may be used for the purpose of making decisions regarding the scope of the services to be provided to the client, risk management, risk monitoring, updating engagement terms, collection, management of collateral and identification of unusual activity.

12. Information Required for the Group's Compliance with Anti-Money Laundering Laws and with the Prevention of Fraud and Embezzlement

The Group companies may be subject to various provisions of law, in Israel and abroad, in the field of the prohibition on money laundering and terrorist financing. For this purpose, they are required to carry out identification and verification processes, know-your-client procedures, retention of documents, reporting, monitoring of activity and risk management.

To that end, the Group will be required to collect and process identification documents, declarations regarding beneficiaries and controlling persons, documents evidencing sources of funds, information regarding source of wealth, information regarding controlling persons, guarantors, beneficiaries and counterparties, financial activity, various reports and any other information required for the Group's compliance with the provisions of law.

The processing of information for these purposes may be carried out even without obtaining further consent from the data subject, to the extent that the processing is required for compliance with the provisions of law.

This information may be transferred and reported to the various regulatory authorities, in accordance with the provisions of law.

13. Transfer of Information Within the Group and Combined Services

13.a. Personal Data collected by one of the Group companies may be transferred to and processed by another Group company, for the purposes of providing services, group-wide risk management, prevention of fraud, information security, prevention of money laundering, group-level client management, audits, controls, compliance and regulatory processes, customer service, offering of additional services, complementary services, marketing and more.

13.b. In the course of the activity of Psagot Equity Trustees Ltd. (hereinafter: the "Trust Company"), the Trust Company is required to open or manage trust accounts for the purpose of executing transfers of funds, holding assets and more. The Trust Company may carry out this activity in accounts managed at Psagot Equity Financial Services Ltd. and/or at Psagot Securities Ltd. and/or through other financial institutions. For that purpose, the Trust Company will be entitled to transfer and process personal and financial information, identification documents, documents regarding the source of funds, data regarding beneficiaries, data regarding controlling persons and rights holders, and any other information of a client held by any of the Group companies.

13.c. The process of onboarding to the services of the Group companies may be carried out through the PEaX system. This system is a system of Psagot Equity Tech Ltd., into which client data, including Personal Data, is entered. This system will be operated by Psagot Equity Tech Ltd. on behalf of the other Group companies and will serve for them as a "Database Holder" of the information, in accordance with the provisions of law and the arrangements applicable between them.

13.d. The Group will enable its clients to restrict or prohibit the sharing of information between the Group companies. It is clarified, however, that in some cases such an opt-out will prevent or limit the ability of a Group company to provide the services, in whole or in part, to the recipient of the service.

13.e. Transfer of information for marketing and mailing purposes – to the extent permitted by law, and provided this is not restricted by agreement, license, undertaking or any other regulatory and/or legal impediment, the Group may use the information and transfer it between the Group companies for the purposes of tailoring products and services, marketing trust services, marketing financial asset services, marketing payment services (subject to obtaining a license), the provision of credit and crypto services (subject to obtaining a license) and any other service offered by one of the Group companies. The Group will be entitled to send its clients, and those who apply to it, professional information, updates, invitations to events, publications, service offers and advertising material, all in accordance with the provisions of law.

Every marketing mailing will include the option to request removal, or it will be possible to apply to the Group with a request to cease receiving marketing communications.

It is clarified that removal from a marketing mailing list will not remove the applicant from distribution lists for the purpose of sending operational, regulatory, legal or service notices that are required for the provision of the services, the performance of the engagement, compliance with the provisions of law or any other obligation.

14. Transfer of Information to Third Parties

The Group, and each company within the Group, may transfer information to third parties where this is required, mandatory or permitted for the purpose of providing the services, performing the engagement, complying with the provisions of law or realizing the purposes of this Policy. Such third parties may include one or more of the following:

Banks, financial institutions, financial asset service providers and payment service providers.
Brokers, stock exchange members, clearing houses, trustees, escrow agents and any other party providing securities trading services.
Credit bureaus, the credit data system, authorized databases and providers of Personal Data.
Providers of professional services: lawyers, accountants, tax advisers, auditors, internal auditors, compliance advisers and risk management advisers.
Providers of computing services: cloud services, information security services, identification and digital signature service providers and the like.
Regulatory authorities: the Israel Securities Authority, the Capital Market, Insurance and Savings Authority, the Israel Tax Authority, the Bank of Israel, the Israel Police, enforcement authorities and regulatory bodies.
Transfer of information pursuant to a judicial order lawfully obtained.
Issuing companies, employing companies, parties to transactions, purchasers, sellers, shareholders and parties involved in the processes that are the subject of the services (mergers and acquisitions, structural changes, capital raisings, purchases, sales and the like), subject to confidentiality undertakings and the provisions of law.
Any other party not included in this list, where the transfer of information to it is required by law or for the purpose of providing the services, and subject to the provisions of law.

Each Group company will act, where required, to obtain appropriate undertakings from third parties with respect to confidentiality, information security and the protection of privacy, and compliance with all provisions of law on these matters.

15. Transfer of Information Outside Israel

Personal Data may be transferred, stored or processed outside Israel, as the circumstances require, both for operational purposes (storage, information security and the like) and for the purpose of providing the services (brokers abroad, trustees abroad, clients or parties to a transaction located abroad and the like). The transfer of information will be carried out in accordance with the provisions of law and subject to the existence of appropriate protective mechanisms, to the extent required.

16. Use of Artificial Intelligence, Analytical Models and Automated Decisions

The Group regards consent to this Privacy Policy as consent to the use of processes based on artificial intelligence, including generative artificial intelligence, voice agents, machine learning systems, statistical models, automated underwriting systems, advanced analytical tools, risk-rating mechanisms and tools for making data-based decisions or recommendations.

The use of such tools will include service management and client relationship management, onboarding processes, underwriting, pricing of services and products, determination of clients' risk levels, detection of fraud, monitoring of unusual activity, forecasting of events, risk assessment, analysis of business needs, generation of insights from activity carried out, improvement and development of products and services, streamlining of processes and improvement of the user experience.

For these purposes, the Group will use information provided to it, information created in the course of providing the services, and information from external and public sources, all subject to the provisions of law.

17. Use of Anonymous, Statistical and Aggregate Information

The Group may carry out anonymization, pseudonymization (the replacement of identifying particulars with artificial particulars), statistical processing, the generation of insights and the creation of aggregate information that does not enable the personal identification of an individual, for the purposes of research, business analysis, product development, service improvement, risk management, quality testing, artificial intelligence and any other legitimate business use of the information. It is clarified that information that has undergone anonymization or the replacement of particulars as described above is not defined as personal information, and the Group will therefore be entitled to use it even without specific consent.

18. Use of Cookies and Tracking Technologies

The Group's websites use cookies and similar technologies for the purposes of their proper operation, their security, measurement of their use, statistical analysis and improvement of the browsing experience. In addition, the Group may use these technologies for the purposes of campaign measurement, audience creation and the display of advertisements tailored to the user on third-party websites and platforms.

In this framework, information such as the following may be collected: IP address, device and browser type, time and duration of browsing, the source of arrival at the website, the pages and content viewed and the actions performed on the website.

Some cookies are deleted when the browser is closed, while others are stored on the device for the period specified in them. Cookies may be restricted or blocked through the browser settings or through the consent management tool on the website. Blocking certain cookies may impair the functioning of some of the services on the website.

The Group uses third-party measurement and advertising services, including Google Analytics, Google Ads and Meta Pixel. These providers may place cookies or use online identifiers, process the information in accordance with their own privacy policies and store it outside Israel.

The information may be used for statistical and aggregate analyses, for measuring the performance of the website and of campaigns, and for tailored advertising on external platforms. The Group does not display advertisements on its website based on the user's browsing activity.

For the purpose of providing these services, the companies that provide the tools and the information use cookies of their own, and this information may be stored in the databases of those companies outside Israel. Information regarding the manner in which these companies use cookies, and the options available to you to change the settings, can be found on the companies' own websites at the following links:

Google Analytics: https://policies.google.com/technologies/partner-sites
Google Ads: https://policies.google.com/technologies/ads
Meta Pixel: https://www.facebook.com/privacy/policies/cookies/

19. Call Recording and Documentation of Communications

The Group may document, record and retain telephone and video calls, documentation of meetings, email correspondence, text messages, online messages, service enquiries and any other communication with clients, representatives, beneficiaries, suppliers or parties acting on their behalf.

Such documentation and recordings may be used for the purposes of providing the service, quality control, employee training, resolution of disputes, compliance with regulatory requirements, compliance, information security, risk management, prevention of fraud, legal defense and the preservation of evidence.

20. Information Security

The Group takes reasonable and accepted information security measures, in accordance with the nature of the information, its sensitivity and the risks entailed in its processing, including permissions management, access controls, encryption, monitoring of systems and activity, documentation of activity, multi-factor authentication, segregation of duties, supplier reviews, employee training, work procedures and periodic audits.

Notwithstanding these measures and the resources invested, it is not possible to guarantee absolute immunity from data security incidents, intrusion, malfunctions, unauthorized use or various cyber risks. The Group will act in accordance with the provisions of law in respect of any data security incident that requires handling, documentation, reporting or notification to data subjects.

21. Retention and Destruction of Information

The Group will retain Personal Data for the period required for the purpose of providing the services and complying with the provisions of law. It is emphasized that, in some cases, the Group acts as a "Database Holder", and in such cases the retention period of the information will be determined by the Database Controller.

Information may be retained by the Group even after the termination of the engagement with the client, for the purpose of the Group's ability to defend itself or pursuant to specific regulatory provisions. For example, in light of the fact that the Company is subject to the provisions of the prohibition on money laundering and terrorist financing laws, and to other provisions of law in respect of which the limitation period for offenses is ten years, the Group may retain the information for at least that period from the termination of the engagement. Consent to this Privacy Policy will also be regarded by the Group as consent to the retention of the information as stated. This Policy will also apply to information that was lawfully collected and held by the Group prior to the publication of this Policy, to the extent that its continued processing is required by law, by agreement, by a legitimate interest or for one of the purposes of this Policy.

22. Rights of Data Subjects

Every data subject is entitled to apply to the Group with a request to review the information held about them and, if they find that it is incorrect, incomplete, unclear or not up to date, to apply to the Group with a request to correct it. In granting the right of review and correction, the Group will act in accordance with the provisions of law, with a view to assisting the applicant in exercising their rights.

In cases in which one of the Group companies acts as a "Database Holder" (for example, in a trust for equity compensation plans), the issuing company, the client or another trustee is the Database Controller. Accordingly, the application may be transferred or referred to the relevant Database Controller, and the Group will assist it in accordance with the law and the applicable agreements.

Without derogating from the rights of the data subject, any complaint concerning the processing of Personal Data may also be addressed to the Privacy Protection Authority.

23. Changes to the Policy

The Group may update this Policy from time to time, inter alia as a result of changes in the law, in regulation, in the Group's activity, in its services, in technologies, in licenses, in its organizational structure or in its business needs. The binding version will be the most recent version as published on the Group's websites or as delivered to data subjects, as applicable.

24. Contact

Requests to review or correct information, requests for removal from mailings that have not been handled, and/or enquiries on other matters, may be addressed to: help@psagotequity.co.il.

The Group will handle enquiries in accordance with the provisions of law, the nature of the enquiry, its status in relation to the information, the identity of the Database Controller and other relevant circumstances, as applicable.

25. Digital Consent Declaration

By approving this Policy, by marking a consent box on the website or in any other digital system, by providing information to the Group, by using the Group's services or by entering into an engagement with any of the Group companies, I confirm that I have read the Privacy Policy, that I have understood its contents, and that I consent to the collection, receipt, use, processing, retention, transfer and sharing of Personal Data about me in accordance with this Policy and with the provisions of law.

To the extent that I provide information about another person or act on behalf of a corporation, I declare that I am authorized to provide the information, and that the data subject has been given the notice required by law or that another lawful authorization exists for the provision of the information.