Privacy Policy and Transparency – User Privacy Responsibility

At Elad Association – City of David (hereinafter: Foundation), we place the highest importance on protecting your privacy and secure your personal information. This document clarifies how we collect, use, store, share, and protect your personal information – in accordance with the Israeli Privacy Protection Law, 1981 (including Amendment 13), its regulations, and the GDPR of the European Union, where applicable.

The organization’s privacy policy complies with the requirements of the Protection of Privacy Law, 1981, and includes the provisions required by Amendment No. 13 to the Law, which enters into effect in August 2025.

1. Types of Information Collected and Purposes of Use

• Information you provide – name, email, phone number, address, and any other details you provide when registering, filling out forms, or contacting us.
• Technological and automatic information collection – IP address, browser type, operating system, device language, geographic location (if enabled), traffic data, cookies, and statistical usage data.
• Sensitive information – if sensitive data or “special sensitivity data” as defined under Israel Privacy law, Amendment 13 (such as biometric, health, genetic data, sexual orientation, political opinions, religious beliefs, etc.) is collected, we will request explicit consent, apply enhanced protections, and register the database in accordance with legal requirements.
• Including unique services such as special offers and activities available on the website.

We commit not to transfer credit card details to any third party.

Purposes of use include:

• Providing services, operating and maintaining the website, and technical support.
• Processing payments and engaging with essential service providers.
  Enhancing the service, analysing usability, and customizing the user experience.
• Marketing, advertising, and sending offers – subject to explicit consent.
• Compliance with legal and regulatory obligations and reporting to authorities.

2. Principles of Data Processing

In accordance with the Israel Privacy Protection Law (including Amendment 13), the following processing principles apply:

• Fairness, transparency, proportionality – data is collected and processed only for predefined purposes with full transparency.
• Purpose limitation – information will only be used for purposes disclosed in advance.
• Data minimization – only the data required will be collected.
• Accuracy and updates – steps will be taken to ensure accuracy and to update information upon request.
• Storage limitation – information will only be retained as long as required for legal, business, or operational purposes.

3. Sharing of Information

Personal information will only be shared in the following cases:

• To perform services (e.g., payment providers, hosting servers).
• When required by law or court order.
• In the event of a merger, acquisition, or transfer of business – subject to continued privacy security.
• Information will never be sold nor delivered to third parties.

4. Your Rights as Users

Under Israel Privacy law (Amendment 13) and the GDPR, you are entitled to the following rights:

• Right of access – to obtain information on the types of data stored about you.
• Right of data update or correction – to request correction or updating of inaccurate or incomplete data.
• Right of erasure (“right to be forgotten”) – to request deletion of data, except where legal obligations require retention.
• Right to restriction of processing – to request limiting the use of personal data.
• Right to object – to object to the use of data for direct marketing purposes.
• Data portability – to receive your data in a readable format and transfer it to another entity.

5. Data Management and Registration

Where personal information is collected and stored in databases requiring registration under law, we commit to registering the database with the Israeli informational Database Registrar, specifying its purposes, and appointing a Data Security Officer and/or Data Protection Officer as required.

6. Cookies and Tracking Technologies

The website uses cookies and analytics tools for:

• Service operation and improvement.
• Usability analysis and tracking browsing patterns.
• You may manage your cookie preferences via your browser settings or the website interface and delete cookies at any time. Some features may not
  work properly without cookies.

Please note: during the purchase process on the website, anonymous and operational details will be retained solely to optimize the transaction. For example, the system may preserve your selected service during the purchase flow, even if you indicated that you do not consent to the use of cookies while browsing the site.

7. Information Security

In accordance with the law and data security regulations:

• We implement security controls (such as: encrypt: policies, training, internal controls) to protect data.
• Special security controls are applied to sensitive or special sensitivity data.
• Despite our efforts, absolute protection against unauthorized access cannot be guaranteed.
• User data provided during registration will be managed and used according to this Privacy Policy.

8. Transfer of Information Outside Israel

If personal data is transferred outside Israel, this will be done in accordance with the law – ensuring adequate protection or subject to appropriate legal agreements (such as Standard Contractual Clauses under the GDPR).

9. Changes to the Policy

This policy may be updated from time to time to comply with legal and regulatory requirements or for operational needs. Any material change will be communicated to users through publication on the website.

10. Contact Us

For questions, requests, or to exercise your rights, please contact us by email at: [email protected].

This document was updated on: November 6, 2025, document version: 2.1.

Annex A: Mapping of Israel Privacy lay Requirements to This Policy