Dear Users:

The Electra Group (“the Group” or “we”) respects your privacy and is committed to protecting and safeguarding the personal data it collects and stores about you. This Privacy Policy describes how we collect data, the types of data we collect, how we use this data, and how you, the data subject, can review, update, or request the deletion of this data.

Please note that this document uses masculine pronouns solely for convenience and applies equally to all users, male and female.

By visiting the Group’s websites and/or contacting the Group through or via the internet, you agree that the Group may collect, store, and use data about you in the manner described in this Privacy Policy and agree to the risks detailed in the Information Security section.

In this policy, the term “personal data” refers to any information collected by the Group or provided to it by you or by someone acting on your behalf, or to information that you provide to the Group’s business partners, through which you can reasonably be identified, and/or to information protected under the Protection of Privacy Law, 5741-1981, including, but not limited to, first name, last name, ID number, passport number, home address, telephone number, email address, financial status, any other information provided when contacting and corresponding with the Group, and so forth.

You are not legally obligated to provide personal data to the Group and the provision of personal data is done of your own free will and with your consent. However, you acknowledge that, if you do not provide this data, the Group may not be able to offer you its services and/or may not be able to respond appropriately to your inquiry and/or contact you.

Some of the information collected about you does not identify you personally, and this information is not stored together with your personal data. This is statistical and/or aggregated information, such as: advertisements you have seen, pages you have viewed, offers and services that interested you, the Internet Protocol (IP) address from which you requested information, and so on.

Without derogating from the aforesaid, if you provide personal data about any third parties, you undertake that you have and will retain in your possession for the entire period that this personal data is in the possession of the Group, all the consents required from those third parties for the provision of their details and personal data to the Group and/or to anyone acting on its behalf and/or to its business partners and other relevant third parties (as applicable), and that you will bear sole responsibility in this regard.

Purposes

The data collected about you will be stored in the Group’s database (“the Database”) under its responsibility. The use of the data stored in the Database will be in accordance with the provisions of this Privacy Policy or in accordance with the provisions of any law, for the purposes detailed below.

Personal data will be stored in the aforementioned Database for the following purposes, among others:

• Enabling you to use the Group’s websites
• Contacting you following your inquiry to us, or when we believe that it is necessary in order to comply with another legal provision
• Providing support and handling inquiries or complaints
• Complying with the requirements of any law, regulation, or other legislation, as well as assisting competent authorities and any third party when we believe in good faith that we are obligated to do so

Without derogating from the aforesaid, we will be entitled to use data that does not personally identify you for various legitimate purposes, such as: to improve services and applications; to adapt content, services, and advertisements; to conduct statistical research; and so on.

Provision of Personal Data to Third Parties

We will not pass on your personal data and the information collected about you to third parties without your consent, except in the cases detailed below:

• To the extent necessary for the proper provision of services, products, and content
• If we are obligated to do so by a judicial order, a demand from a competent authority, or by law
• If we receive a notice of legal proceedings against us for actions you have performed, as well as in any dispute, claim, lawsuit, demand, or legal proceedings, if any, between you and the Group and/or anyone acting on its behalf
• As part of a change in the organizational and operational structure of the Group (including in a situation where one of the Group’s companies organizes its activities under the auspices of another entity, such as through a merger with another entity) – in this case, we will be entitled to transfer the personal data, or any other information collected about you, to the other entity, provided that the other entity assumes the provisions of this Privacy Policy as regards your rights
• If a claim is made, or suspicion arises within the Group that you have committed an act and/or omission that harms and/or may harm it and/or anyone acting on its behalf and/or any third parties
• Upon your express request

You agree that the Group will be entitled to transfer, at its discretion, your personal data, outside the borders of the State of Israel, even if the law of the country to which the personal data is transferred or in which it is stored guarantees a level of protection different to the level of protection stipulated in Israeli law.

Direct Marketing

The Group may, but is not obligated to, send you advertisements, special offers, discounts, updates, news, and so forth (collectively: “Direct Marketing”) from time to time, including via email and SMS messages, subject to receiving your consent under Section 30A of the Communications (Telecommunications and Broadcasting) Law, 5742-1982. This Direct Marketing may relate to the products and services of the Group or to the products and services of third parties, such as the Group’s business partners.

If you do not want to receive Direct Marketing messages, you may notify the Group at any time, in accordance with the contact details shown below, or in accordance with the details shown in the Direct Marketing messages themselves, at your discretion. It is hereby clarified that the Group will be entitled to send you Direct Marketing messages based on the results of processing and analyzing the personal data provided by you and/or on information regarding your activity on the website and/or information stored in the Group’s systems, in order to offer you various products and services that may be of interest to you.

Cookies

The Group and/or those acting on its behalf use files known as cookies and pixels and other software tools (hereinafter: “Cookies”) on the website that originate from third parties, in accordance with the terms of use and privacy policies of those third parties, which are installed on your systems and software when you use the internet. These are used for various purposes, including to define, monitor, and track your activity, identify usage patterns, determine your preferences, provide the option of displaying advertisements customized to your preferences in accordance with analyses, and in order to adapt the website to your experience, needs, and unique characteristics. These files enable to the Group and/or those acting on its behalf to attribute information relating to the use of the website to a specific user, and to data relating to that user.

Cookies are actually text files (or lines of code) that are created on the end device, insofar as you permit this in your device settings, and collect data such as the length of time you remain on a specific website page/screen, your browsing habits on the website, the actions you take on the website, your IP address, location, connection times, and so on. It is hereby clarified that you can update or change your device settings at any time and block the use of Cookies in whole or in part, but it is possible that this will result in certain services, in whole or in part, not functioning properly. Changing such settings is the sole responsibility of the user.

Right to Review Data

Under the Protection of Privacy Law, 5741-1981, everyone is entitled to review in person, or through his attorney, with written authorization, or guardian, the data held about him in a database. Anyone who has reviewed the data held about him and found it to be incorrect, incomplete, unclear, or not up to date, may contact the owner of the database with a request to correct or delete the data. If the owner of the database refuses to do so, the owner must notify the applicant in the form and manner prescribed by the regulations. The data applicant may appeal a refusal by the owner of the database to correct or delete the data, or notice of any such refusal, in the form and manner prescribed by the regulations.

Any such appeal must be directed to the Group via email: Privacy@electra.co.il.

In addition, if the data in the Database is used for the purpose of personally contacting you, you are entitled under the Protection of Privacy Law to demand in writing that the data relating to you be deleted from the Database.

Changes to the Privacy Policy

The Group may change the terms of the Privacy Policy periodically. If material changes are made to the policy, a notice will be published on the Electra Ltd. homepage 7 days prior to the changes coming into effect.