Privacy Policy

Welcome to the website www.almogim.co.il (hereinafter: the “Website“) of Almogim Holdings Ltd. (including its subsidiaries and affiliates, hereinafter: the “Company“). The use of the Website, of the content included therein, and of the services offered, is subject to the privacy policy detailed below (hereinafter: the “Policy“). This Policy defines, specifies, and regulates the relationship between the Company and any person browsing and/or viewing and/or otherwise using the Website or the information contained therein (hereinafter: the “User“). Please be sure to review the Policy, as the mere use of the Website and of any of the services offered therein constitutes your implied consent to the provisions of this Policy. Therefore, if you do not agree to the Policy, in whole or in part, you are not permitted to use the Website and/or the services for any purpose. The provisions of this Policy are drafted in the masculine form for convenience only, and they apply equally to both women and men.

Definitions
Information Security – protection of the integrity of Personal Data, or protection of Personal Data against processing without lawful authorization.
Database Controller – a person who determines, alone or jointly with another, the purposes of the processing of the data in the Database, or an entity or office holder authorized by statute to process data in a Database.
Database – a collection of items of Personal Data processed by digital means, other than the following:

(1)       a collection for personal use not intended for business purposes;
(2)       a collection including only name, address, and contact details, regarding 100,000 persons or fewer, which does not, by itself, reveal any additional Personal Data regarding the persons whose names are included therein, provided that the owner of the collection or a corporation under its control does not hold another collection including other items of Personal Data regarding the same persons.

Personal Data – data relating to an identified person or to a person who can be identified; for the purposes of this definition, a “person who can be identified” – a person who can be identified with reasonable effort, directly or indirectly, including through an identifying detail such as name, identification number, biometric identifier, location data, online identifier, or one or more data elements relating to his physical, health, economic, social, or cultural status.

Specially Sensitive Data – Personal Data concerning a person’s private and family life, his privacy and sexual orientation, health or medical data, genetic data, biometric identifier, origin, criminal record, political opinions, religious beliefs, worldview, location data, traffic data, salary, financial activity, or Personal Data subject to confidentiality obligations prescribed by law.

Database Manager – the Database Controller, namely, the Company in the Almogim Group managing the data.

System Data – data concerning the holding and management of Personal Data and of a Database and concerning their use, provided that they do not include Personal Data.

Processing/Use – any action performed on Personal Data, including its receipt, collection, storage, copying, review, disclosure, exposure, transfer, delivery, or granting access thereto.

General Information
The Website in its entirety – including all information appearing therein and the software underlying it – is offered to the public on an “As Is” basis.

While the Company intends that the information be correct and accurate, the information may be incomplete, or, alternatively, technical or other errors may have occurred in the information. Furthermore, the information includes drawings, simulations, and presentations, which are intended solely for illustration purposes. The Company is not responsible for inaccuracies or errors with respect to the information, nor does it undertake that the drawings, simulations, and presentations displayed on the Website will in fact be realized as they appear. The Company hereby clarifies that the information contained on the Website is for general, informational, and descriptive purposes only, and does not constitute an undertaking and/or recommendation and/or opinion and/or an offer to purchase any product or to obtain any service. Accordingly, the User acknowledges and agrees that any reliance on drawings, simulations, presentations, statements, expressions of opinion, advice, or any other information presented on the Website is made at the sole discretion of the User and at his exclusive responsibility. Some of the information may originate from third parties and/or its implementation may depend on third parties, and therefore it is understood that the Company has no responsibility for such information and does not warrant the accuracy thereof. The Company is entitled, at its sole discretion and without prior notice, to change from time to time the terms of use of the Website and/or the structure and/or content and/or appearance of the Website and/or the information on the Website, the scope and availability of the services offered therein, and any other aspect related to the Website and its operation. The version appearing on the Website shall prevail at all times, unless explicitly stated otherwise.

Submission and Collection of Information
We use cookies (small text files stored in the User’s browser) and other similar technologies to collect statistical data. At any time, you may configure your browser to block these files; however, such blocking may prevent us from providing you with the services or parts thereof. These technologies help us monitor the manner in which Users make use of our services and collect aggregated statistical information. Among other things, such information may include advertisements you have viewed on the Website, pages you have browsed, offers and services that interested you, the internet address from which you entered the Website (IP), and more. We collect certain information such as IP address, device model, operating system, and other technical data that identify the device through which you connected to the services. The Company also collects anonymous and statistical information concerning the use of the Website and the services, including User behavior on the Website, pages viewed, sharing to social networks, etc. The Company may utilize third-party services in this regard, including Google Analytics. Such information will not personally identify you.

Some of the services on the Website require registration. In the course of registration, you will be required to provide Personal Data such as: name, address, contact details, e-mail address, and other personal information (hereinafter: the “Personal Data“). It is not possible to register for certain services on the Website without providing the information requested in the mandatory fields. In addition, if you choose to register on the Website to receive mailings from the Company, such as subscription to a newsletter, we will collect the information you provide in the course of such registration. We do not knowingly collect or process sensitive Personal Data, such as information on religious affiliation, privacy of the person, medical information, and the like. If you believe that sensitive Personal Data has been mistakenly provided to us, please notify us immediately.

Database
 The provision of information depends on your will and consent. It is hereby clarified that you are under no legal obligation to provide the information, unless stated otherwise. However, the provision of some of the aforesaid information constitutes a necessary condition for the use of various services offered on the Website, and without your consent it will not be possible to provide you with the service accordingly.

All information uploaded by you to the Website is stored in the Company’s Databases, as detailed hereinafter in this Policy, and is protected by advanced measures and in accordance with strict standards intended to safeguard the information, its integrity, availability, and confidentiality. The protection and safeguarding of the information and its confidentiality are necessary in order for us to provide you with the service.

The Company’s Databases are duly registered and managed and secured in accordance with the provisions of the Protection of Privacy Law, 5741-1981 (hereinafter: the “Law”) and the Protection of Privacy Regulations (Data Security), 5777-2017. By providing Personal Data, you give your consent for the Personal Data to be included in the Database managed by the Company in accordance with the provisions of the Protection of Privacy Law, 5741-1981 (hereinafter: the “Database”) and for the use of the information by the Company, in accordance with the terms of the Policy. You are entitled to review the information concerning you contained in the Database in accordance with the provisions of the Protection of Privacy Law, and the Company undertakes to act in accordance with the provisions of said Law.

The Company attaches great importance to the protection of your privacy, and therefore makes every effort to safeguard appropriately the information provided to it.

Use of Information
The Company will make every effort, using the means at its disposal, to maintain the confidentiality of the details of Users of the Website and to prevent their disclosure to unauthorized parties. However, since these are actions performed in an online environment, the Company cannot guarantee absolute immunity against intrusions into its systems and/or against exposure of information stored by it. If, despite the security measures taken by the Company, any third party succeeds in gaining access to information relating to Users of the Website and/or in misusing such information, the User shall have no claim, demand, and/or suit against the Company and/or any of its owners and/or any of its directors and/or any of its employees and/or anyone on its behalf and/or anyone on their behalf in connection therewith. The use of the data and information collected shall be made only in accordance with this Policy or pursuant to the provisions of any law, including, inter alia, for the following purposes:

1. To improve the services and content offered on the Website, to create services or content suited to the Users’ requirements, or to cancel existing services or content, and to analyze the uses made on the Website.
2. To use the User’s details for the management of a Database and/or for carrying out direct mailing services and/or for carrying out the mailing of advertising materials in accordance with the law. The User hereby gives the Company his explicit informed consent to the performance of the aforesaid actions and to the sending of direct mailings to him, subject to his rights under the law to request his removal from the direct mailing list.
3. For the proper operation and development of the Website or of websites that may be established in the future by the Company.
4. To display advertisements of the Company through the use of various objects such as cookies on other internet pages you may browse, including on social networks. It is clarified that the information collected for the purpose of displaying such advertisements does not personally identify you, but only tailors the advertisements presented to you to topics that may be of interest to you.
5. For any other purpose detailed in this Policy.

Disclosure of Information to Third Parties
The Company shall not transfer the User’s details to any third party (insofar as such details identify him), except in the cases detailed below, and the User hereby gives his consent to the transfer of such details upon the occurrence of any of the cases detailed below:

1. If the transfer of the User’s details is required in order to fulfill the Company’s obligations pursuant to this Policy.
2. If the User has committed an act and/or omission that harms and/or may harm and/or cause damage to the Company and/or to any third parties, including other Users.
3. If the User has made use of the Website’s services for the purpose of committing an unlawful act and/or in order to enable, facilitate, assist, and/or encourage the commission of such an act.
4. If the User has breached these Terms of Use of the Website and/or any additional agreement with the Company and/or with anyone on its behalf.
5. If the Company has received a judicial order instructing it to deliver the User’s details to a third party.
6. In any dispute, claim, demand, or legal proceedings, if any, between the User and the Company.
7. If the Company merges or reorganizes its operations and/or the operations of the Website within another corporation, it shall be entitled to transfer to such corporation a copy of the information accumulated regarding the User on the Website, provided that such corporation undertakes towards the User to comply fully with the provisions of these Terms of Use.
8. It is possible that we may enable you to share your actions on the Website with your friends on social networks, such as Facebook and others, through devices and components such as Share and Like buttons. We will not disclose Personal Data to such social networks, but you should be aware that they may cross-reference such information with information already in their possession through your profile on the social network. Any such sharing is subject to the applicable social network’s terms of use.

Mailings
The Company may, from time to time, send you, by e-mail or by any other medium, information regarding its services as well as marketing and promotional information, including professional materials, updates, publications, notices, and various offers based on information contained in its Databases, including through the use of various profiling of the information (hereinafter: the “Direct Mailing“). Such information will be sent to you only if you have given your consent thereto, including within the framework of using this Website, or to the extent permitted by law. Pursuant to the provisions of the Protection of Privacy Law, 5741-1981, you are entitled to demand, by written notice to the Company, that information relating to you which is used for Direct Mailing be deleted from the Database. In such a case, the Company will delete only the information used for Direct Mailing, and such deletion will be only from the Database used for Direct Mailing. The Company may use your details for sending marketing offers on behalf of third parties, provided that your details will not be delivered or transferred in any manner to such third parties without your consent. Notwithstanding the foregoing, the Company may engage service providers on its behalf and, within this framework, transfer to them such details and information, subject to their undertaking of confidentiality.

Right of Access and Rectification
Pursuant to the Protection of Privacy Law, 5741-1981, you are entitled to review the information about you held by the Company, and if the information in our possession is not correct, you have the right to request its rectification or deletion. The CIO and the Data Protection Officer are the officials in the Company responsible for implementing privacy processes, and they shall be contacted with respect to any matter related to privacy protection, including removal from a Database, removal from a Direct Mailing distribution list, exercise of the right of access and rectification of information as aforesaid, and any matter pertaining to privacy protection.

Any inquiry on the aforesaid matters must include full contact and reply details. Inquiries on these matters shall be made directly to the CIO at the e-mail address: zoharg@almogim.co.il. A response will be provided within 30 days from the date of the inquiry.

Third-Party Advertisements
The Company permits or may permit third parties to manage for it the advertising display system on the Website and/or to assist in managing such system, and uses or may use systems of other companies to manage the advertising display system on the Website. For the purpose of managing advertisements, these companies may place on your computer various objects such as cookies and “web beacons” in advertisements or in the pages of the Website. Beacons are tiny graphic files with a unique identifier embedded in the pages of the Website, the function of which is to assist in collecting information about the use of the Website. The information collected does not personally identify you, but only tailors the advertisements presented to you to topics that may interest you. The use that these companies make of cookies and web beacons is subject solely to the privacy policies of those companies, and you are invited to review the privacy policies of those companies via their websites.

Information Security
The Company operates customary systems and procedures for information security, intended to reduce the risks of unauthorized intrusion and to enable protection of the information collected by the Company. Nevertheless, such systems and procedures do not provide absolute security, and the Company does not undertake that its systems will be absolutely immune from unauthorized access to the information stored therein. The Company shall not be liable for any damage caused due to an intrusion into information in its possession, including an invasion of privacy, unless it is proven that the intrusion was carried out willfully by the Company. In any case, the Company shall not be liable and the User hereby waives his right to compensation for any damage, whether pecuniary or non-pecuniary, and any indirect or consequential damage.

Changes to the Privacy Policy
The Company reserves the right to change or adapt the Privacy Policy from time to time at its discretion and in accordance with the provisions of any law. The changes shall enter into force as of the last update date of this document. Continued use of the services after the last update date shall constitute the User’s consent to the changes.

Contact
The Company adheres to the provisions of the law and respects the rights of Users of the Website and others. For questions regarding this Policy, please contact us by e-mail at: office@almogim.co.il, and the Company will make an effort to respond to your inquiry within a reasonable period of time.

Updated: May 14, 2025