Shoval Invesment & Management - Pricavy Policy

The Company provides services of shared coworking spaces and/or offices and related services, and offers flexible rental solutions to individuals and/or corporate entities (potential and/or existing customers), including under Membership Agreements with the Company and/or through anyone on their behalf including representatives and affiliated parties, and/or website users and/or on Company sites and/or social networks (hereinafter: “Customer(s)” and/or “Member(s)”). The Company specializes in the rental of private and shared office spaces, workstations, and conference rooms, and provides supplementary services to existing and potential customers (hereinafter the “Operation”).

The Company’s Websites provide information about the Company’s services and the workspaces and offices managed by the Company, as well as allowing contact with our representatives and to offer updates and information on the Company’s activity and related services. This Privacy Policy applies to every service provided to our Customers at any time, including services provided at any of the Company’s sites/premises and elsewhere, e.g. the BE ALL Website (www.be-all.com) and/or Shoval Investment & Management Website (www.shovalh.com/en/) (the “Website”) or the Company’s special, restricted-access online community (the “Online Community”). This Privacy Policy includes information about how the Company processes personal and particularly sensitive information (as defined by law) in the framework of its Operation. The Company seeks to protect your personal data during your use and browsing of the Website and your engagement as Customers/potential Customers and/or representatives and affiliated parties on their behalf.

The Company respects the privacy of every individual, including Customers and visitors to the premises managed by the Company, the users of the Company’s websites and/or of any other Company websites managed by the Company and/or in collaboration with others. This policy reviews the various types of collected data, data collection methods, the uses made of that data, and your rights with respect to information that is available to every user and/or Customer. The policy also applies to the Company’s secondary sites, landing pages, the Company’s activities on social media, and other digital assets, mutatis mutandis and with the required changes.

In this Privacy Policy, “Customer Information” and/or “Personal Information” means any personal information and/or information of special sensitivity that can identify the Customer and/or anyone on their behalf, directly and/or indirectly, which is processed by and/or through the Company and/or anyone on its behalf, as detailed in this Privacy Policy and as defined in the Privacy Protection Law, 5741-1981 (the “Law”) and the Amendment to the Privacy Protection Law (Amendment No. 13), 5784-2024 (the “Amendment to the Law”).

This Privacy Policy does not derogate from the Website’s Terms of Use, or from any other agreement, policy, or terms and conditions that shall bind the Customer or anyone on their behalf. The Company applies certain privacy policies to other cases, including the Privacy Policy that governs agreements with Customers, suppliers, and labor agreements related to the privacy of the Company’s employees, etc. For specific details, please contact us.

We use “cookies” and similar technologies to improve our users’ experience, provide personalized content, analyze Website user behavior, and optimize our marketing efforts, including personalized ads on various platforms, websites, and social networks that are tailored to the user’s interests. The Company may use cookies in its online services. Cookies are small data files sent to the Customer’s browser or related software programs from a web server, and stored on the Customer’s computer hard drive. Cookies are used to track and store the Customer’s browsing history. Whenever you access the Website, you may choose to block/manage your cookies; however, such measures might adversely affect your use of online services, and some services on the Website may not be accessible to you, and/or your user experience might be restricted, and/or you may have to enter your credentials every time you use the Website. For further information about cookies and how to manage them, please visit the website: All About Cookies at (https://allaboutcookies.org/).

It should be noted that your consent to the Privacy Policy on the Website is recorded by means of cookies. Therefore, if you decide to block or delete cookies, your consent to the Privacy Policy will still be retained in the Company’s systems for the purpose of documenting your consent

The Company shall be entitled to collect and store information that may identify a Customer or Member in their capacity as a Customer or Member of the Company, provided that this information is provided by the Customer and/or Member of the Company (as applicable) directly.

The types of Personal Information about a Customer that the Company shall be entitled to collect include those detailed in this section below. The Company also collects information that Customers add to their member profiles, and information that they post to or share with the online community and/or the Company platform, including photos, professional backgrounds and education history, and any other information that Customers chooses to include in their profiles or that they post on or share with or through the online community on the platform.

However, there may be cases in which additional or other information is collected, depending on the circumstances and on justified grounds, and all in accordance with the provisions of applicable law and those of this Policy as amended from time to time, and subject to our receiving your informed consent to any amendment to this Privacy Policy and to our processing your Personal Information for the purposes defined in this Privacy Policy.

Information that cannot be associated with your real identity, such as websites you have browsed or the number of Website users, shall not be considered Personal Information.

1. General information that may be collected from all types of Customers / potential Customers – general identifying information:
   • Identifying information: full name, ID number, passport number (for non-Israeli residents), and date of birth.
   • Contact details: telephone/mobile numbers, email address, residential address and mailing address.
   • Photographs (Self-photo to enable the use of facial recognition systems).
   • Financial details and bank account details and/or credit card information for billing purposes, including VAT account information and/or Income Tax ID/VAT/WTAX numbers.
   • Corporate ID information, including private company numbers, certificates of incorporation, articles of association, documents listing authenticated authorized signatories, agreements, and other related legal documents.
   • Marketing information: IP addresses, USER AGENT and cookies for Customer preferences regarding assets (e.g., size, location, price range, etc.), as well as history of customer service interactions or interest in Company sites.
   • Identifying documents: copies of ID card and appendix, driver’s license, passport, etc.
   • Professional information: credentials, certificates, permits, licenses, insurance.
   • Information provided by Customers that belongs to other parties, such as information about Company’s employees, representatives, consultants and visitors to the office premises, including various professionals who represent Customers and/or third-party guarantees (including the guarantors’ full information, ID numbers and/or photocopies of ID cards). Such information may include identifying details, photographs (that include faces) and additional information detailed above.
   • Background checks and credit risk assessments: credit rating information used to assess the financial capacity and authorizations to debit accounts (this information may be obtained from Customers or from public and authorized databases).
   • Insurance-related documents and certificates, including insurance policies/ Certificates of Insurance, etc.
   • Security cameras: throughout the Company’s premises, to the exclusion of the private offices and restrooms, may be subject to security camera surveillance at all times. In addition, the Company may, from time to time and subject to the provisions of this Privacy Policy and the Membership Agreement, take photographs and/or videos at any location on the premises, including office or public spaces, excluding restrooms.
   • Disclosure of Personal Information to the Company that belongs to other parties:
     To the extent the Customer provides the Company with any personal, confidential, or proprietary information that belongs to another person or entity, the Customer represents that they have received the consent of such person or entity to provide such information to the Company, as well as for its processing in accordance with the terms of this Privacy Policy. The Customer will be held fully and exclusively liable and responsible in any case where such information is provided without authorization.

2. Independent data gathering or data gathering by service providers

The Company may collect and store various types of information about Internet use whenever a Customer uses online services, primarily to protect the online services from damage and malware. Below are the types of use-related information that the Company may collect and the manner in which the Company may use such information. Such information may be collected and/or used by the Company or by service providers acting on its behalf.

• IP address, browser type, operating system, and other data. While providing online services, the Company may collect the Customers’ IP addresses. The Company may also collect other information about the Customer, including domain names; Internet browser types and the technology used by the Customer; website pages that link Customer to the Company; the Customers’ browsing history and websites visited by Customer after they visit the Website; ads that the Customer viewed and/or clicked on; search terms entered by Customer on the Website or websites that link to it; and other online activity and usage data recorded by the Company’s web servers.
• Monitoring and analysis tools: We use monitoring and analysis tools such as Google Analytics, which help us collect statistical data on user behavior on the Website and on other platforms. These tools collect information such as Website visit frequency, the pages visited by users, and the duration of time spent on each page. This information helps us understand usage trends, improve the Website, and optimize the user experience and marketing efforts. The Google Analytics Privacy Policy is available at: https://policies.google.com/privacy. You can prevent the use of your data by Google Analytics by downloading and installing the Google Analytics Opt-out Browser available at: https://tools.google.com/dlpage/gaoptout.
• Clear GIFs: the Company may use clear GIFs (also known as “Web Beacons” or “Pixel Tags”) or similar technologies as part of the Company’s online services and/or communications with Customers. Clear GIFs allow the Company to ascertain that a Customer has viewed a web page or received a message sent to them by the Company.
• The Company may collect information about Customers from publicly or commercially available sources and from other third parties to the extent permitted by law.
• Anonymized information: we may use data that does not allow the identification or attribution of a specific user with reasonable efforts for various purposes, including personalized content on the Website and elsewhere. This information may also be disclosed to external parties supporting our operations. We are entitled to share anonymous information, such as aggregated or statistical data, with third parties, including advertisers and business partners, for various purposes, whether for consideration or without consideration.
• Except as stated above, the Company will not collect, track, and/or use any information regarding the Customers’ use of online services without the Customers’ approval.

3. How Manner of Personal Information Collection

Information is collected and processed in accordance with any applicable law that governs the Company. The Company receives and collects various types of Personal Information using a variety of methods, both on the Website and elsewhere, within the engagement process with the Company’s Customers, as detailed below:

• Information provided directly by users: Contact information for initial contact, appointment scheduling, price quotes, etc. Information that allows us to contact you, chats with bots on the Website, and secondary websites.
• Communications with Company representatives: the information you provide may be collected during telephone, email, or WhatsApp conversations with the Company or its representatives, such as: personal details, preferences, interest in projects or properties, requests for additional information, and full content of the conversation. This information will be used to accommodate your inquiries and for marketing purposes, as needed and in accordance with applicable law. Phone calls with Customers may be recorded by the Company or its service providers to improve our services, monitor service quality, review our customer journeys, etc.
• Communications with Company as Customers: Membership Agreements or leases (including drafts), new potential customer files, customer support, services on Company premises, messages relating to services and/or your contract, conference room invitation systems, printing and scanning systems, systems used to open service tickets, supervision, control, customer satisfaction surveys, payment systems, invoices, etc.
• Marketing service registration: Personal information such as name, email, and telephone provided when registering to receive updates, mailings, or a newsletter through registration forms on the site.
• information provided within the framework of promotions, campaigns, physical or digital conferences, surveys, or dedicated forms on landing pages.
• Personal information provided by subscribing to and registering for the Company’s social media pages or communications with the Company on such pages. We clarify that any sharing of content from the Website on social media and/or browsing the Company’s pages on social media may be subject to those social networks’ terms and conditions and privacy policies.
• Automatically collected information: the Company is committed to protecting your privacy while you use the Website. The Company may collect online IDs that may be used to identify users, namely, information that can identify users or, with reasonable effort, identify a user while they are using the Website, such as an Internet Protocol (“IP”) address. These data are needed temporarily during a visit to the site to enable the site to be displayed to you.
• Additional storage in log files to enable Website functionality and to protect our IT systems. (Mainly to maintain data security and set up smooth connections). Such additional Personal Information as names, addresses, telephone numbers or email addresses is not collected, unless provided voluntarily, e.g., when you fill out an online contact information form or as part of a registration process, survey, competition, or request for information.

Without derogating from any other provision in this Policy, or any right granted to the Company under any applicable law, the Company may use Customer information in accordance with applicable law and this Policy for any of the following purposes:

• Creating, maintaining, and managing engagements and contracts to facilitate the provision of services to our Customers and/or visitors and/or interested parties, including responding to, handling inquiries, and providing requested information. Keeping in touch with Customers and responding to questions or requests, including by way of proactively contacting our existing Customers or users who previously expressed interest in similar services and/or premises.
• Compliance with and enforcement of agreements, payment processing, collection, audits, reporting, accounting, credit checks/credit risk management, contract reviews, repayment capacity assessment, etc.
• Offering, managing, marketing, providing, and improving our services, learning about users’ interests and/or preferences, and/or needs to show and tailor ads. Sending marketing and promotion materials.
• Analyzing the customer journey and reviewing feedback about marketing and our representatives, improving marketing processes and tailoring services to the needs of Customers and users, including, inter alia, providing the Customer with advertising content and sales promotion content.
• Compliance with applicable law or regulatory requirements, orders or requirements prescribed by government agencies, including documents, legal defenses, and protecting the privacy, safety, or property of any party;
• Securing the regular operation of the Website, promoting data security, monitoring and enforcing compliance with any of the Company’s policies, and meeting the Company’s legitimate business needs. Records of commercial and marketing activities in connection with the Company’s operations.
• Without derogating from the above, the Company may use images and/or videos collected and/or created by it in accordance with the Privacy Policy for marketing, advertising and sales promotion purposes, including photographs and/or videos that depict Customers, members, and/or their guests.

The Company will not share Customer-related information with other parties without their consent, except as specified in this Privacy Policy or as required or permitted by law, as follows:

• The Company may share Customer-related information with directors, officers, employees, consultants, agents, and related parties. The above will continue to apply in the event of the Company’s merger, acquisition, or restructuring, subject to our commitment to protecting our Customers’ privacy.
• External service providers and consultants directly or indirectly involved in operating the Company’s business and providing the Company’s services and products. The Company may share information about a Customer in cases where the Customer requests a service offered by the Company that requires it to share this information with a third party.
• The Company may share Customer-related information with service providers and third parties that provide technological services and uses, e.g., software suppliers, cloud storage, service operation, data monitoring, improving user experience on websites, cookies, social networks, call recording systems, and/or cameras. We should note that the disclosure of information to such providers is solely intended for the purpose of achieving the objectives contemplated in this Policy, and they will not be allowed to make independent use of such information beyond what is required in connection with the provision of their services. However, some providers may be required to make limited use of Personal Information, such as to comply with legal requirements or record-keeping obligations.
• In connection with images and/or videos collected and/or created by the Company under this Privacy Policy, the Company may share information about Customers with third parties and/or publish such information to market, advertise, and/or promote its products and/or services, subject to the provisions of this Privacy Policy below.
• The Company may share information about Customers to the extent required by law, by any governmental agency, judicial order, or per regulatory requirements, or if the Company deems it necessary in connection with any proceeding. The Company may share Customer-related information with third parties to investigate, prevent or take action against any illegal activity or activity suspected to be illegal by the Company, actual risks to the Company’s property or the physical safety of any person or any perceived threat thereof, any violation of the Company’s Terms and Conditions, or other terms of use, rules or policies, or otherwise as permitted by law.

Some third parties may operate outside the country’s borders, including regions where privacy protection laws may differ from those applicable in Israel, such as the United States. We take accepted measures to ensure the protection of the information even after it is disclosed to parties abroad, including suitable contractual arrangements.

As a rule, you are not required to provide us with any Personal Information. Information will only be provided by you on a voluntary basis and for the purpose of contacting us, receiving services, communications relating to our service agreements or leases, or any other collaboration or any other agreement between us.

However, information may sometimes need to be disclosed to comply with legal requirements, such as reporting to tax authorities, local authorities, and/or various authorities.

By accepting this Privacy Policy, you hereby accept this Privacy Policy in its updated version, including the collection, processing, and sharing of Personal Information as stated herein.

Implications of non-consent. Your refusal to disclose information may prevent us from being able to provide you with certain services or enter into a contract with you!. Without receiving your information or certain documents that need to be attached to our agreement, we will not be able to enter into a service and/or lease agreement with you. Failure to provide details may prevent us from disclosing information or reports to subcontractors that are needed to provide these services. Refusal to provide the financial and banking information we require may affect registration procedures or other procedures that we need to enter into a contract with you. Without information about transactions and certain contact information, we will not be able to maintain documentation and records, conduct internal audits, monitor or improve our services, or use the information for legal and other legitimate business purposes.

The Company shall have the right to amend this Policy at any time, and it will provide the Customer with electronic notice of any such amendments. The Customer’s receipt of services and/or their continued use of the Website after sending such notice to the Customer by the Company shall constitute the Customer’s consent to such changes. An update or material change will be made to the processing of Personal Information and its purposes will be made after we receive your prior consent.

As per applicable law, you may review the Personal Information about you that is retained on the Company’s and/or suppliers’ computers, which are used to complete the requisite processing operations, and you may seek the correction or deletion of information that is either inaccurate or irrelevant, provided that such information is not required by the Company to meet legal requirements and/or its obligations under its contracts with its Customers in the framework of its Operation. Moreover, to the extent relevant to you, you may remove yourself from any mailing lists by means of a dedicated link in the messages sent to you or in any other way, and retract your consent as stated in this document at any time and in accordance with this Privacy Policy. For any request or question on the subject, please contact us using the contact information found below.

We should note that the Company will cease sending you marketing materials only after you submit a removal request. However, the company may continue to send you service-related messages (e.g., in response to your questions or requests). It should be clarified that the information needed by the Company to conduct its business and the Operation and to provide the aforementioned service will be retained for that purpose and for as long as the Company requires.

To exercise this right, a written request must be sent to the Company at the address listed below in this Policy. The Company may deny this request, subject to the provisions of applicable law. Additional information about privacy protection laws in Israel and your rights to your information is available on the Privacy Protection Authority website at:

https://www.gov.il/he/Departments/the_privacy_protection_authority. You may file a complaint with the Privacy Protection Authority at: https://www.gov.il/he/pages/contact_us_1

To exercise this right, you may contact us using the contact information listed under “Database controller; contact information”.

The Company will retain Customer-related information for as long as the Personal Information is needed to attain the company’s goals in the framework of its Operation, to comply with its legal obligations, and to properly conduct its business in accordance with applicable law.

The Company seeks to minimize the retention period of Personal Information whenever the purpose thereof, the law or the applicable contract allows it. Customer-related information that we process based on consent will be retained on the basis of regulatory or other operational needs. The Company upholds a policy of minimizing data retention times, and complies with that policy as much as practicable.

The company takes data security very seriously, implementing strategies, controls, policies, various measures, and operating systems and procedures in order to protect the Personal Information of its Website users, information about our customers that is stored on BE ALL’s computer systems and those of providers that support our processing as detailed in the Privacy Policy (including on social media), and it invests considerable efforts in protecting this information.

However, we should clarify that no computer system can be fully secure. Therefore, we cannot guarantee absolute protection against security risks or unauthorized access to information or against similar risks, and the Company and any of its subsidiaries and/or affiliates will not be held liable for any damage caused, to the extent caused, to Customers, users, and/or their Personal Information and/or to any other party.

CCTV cameras (both video and audio in some cases) are installed throughout the Company’s premises in order to maintain the security and safety of Customers, employees and visitors. The data captured by cameras is retained for the minimum period of time necessary to achieve the aforementioned purposes and in accordance with Company policy. Should that be necessary, you may contact the company’s Privacy Officer to receive additional information.

With respect to the Company’s Operation, the Company’s services, including its Website, are intended for users aged 18 and older, and we have no intention of collecting the Personal Information of users under that age. However, the use of the Website and of the social networks by users under the age of 18 will only be permitted subject to the express permission of a parent or legal guardian, and only after that parent or legal guardian has reviewed the Website’s terms of use and the Privacy Policy. The continued use of the Website and the social networks in such cases shall constitute a declaration that the approval was received as required after marking the approval as required in the consent process.

• Posting content on public forums via online services: If a Customer posts any content on any public forum or area of online services (or any part thereof), such as chat rooms, bulletin boards, or blogs, the Customer agrees and consents that any content submitted may be visible to the public, including to other users of the internet services.
• Identification methods and access to the Website/online community: It is the Customer’s responsibility to safeguard and maintain the strict confidentiality of any usernames and passwords related to the Website, the Online Community, and the Platform.
• Additional terms of use, rules, or policies: additional terms of use, rules, or policies may be posted on the Website, in the online community and the platform, or may be otherwise provided to Customers. The Customer agrees that such additional terms of use, rules, or policies are hereby incorporated into and included in this Policy by way of reference.
• Section headings; interpretation: Section headings in this Privacy Policy are for the purpose of convenience only and shall not be used for the interpretation of any provision in this Policy under any circumstance. The words “including”, “for example”, or “such as” in this Policy shall be read as if they are followed by the words “without limitation.” Words importing the singular shall include the plural and vice versa. Words in this Policy importing the masculine gender shall include the feminine gender and vice versa.
• Severability: To the extent it is determined in any court proceeding or arbitration proceeding that one or more provisions in this Privacy Policy are unenforceable, such unenforceability shall not affect any other provision of this Privacy Policy. In such cases, the parties shall replace any unenforceable provision with a provision as close as possible to the intent in the original provision.
• Waiver: The Company shall not be deemed, due to any act or omission of its own, to have waived any right or remedy available to it under this Policy, unless the Privacy Policy has been amended by the Company in the manner set forth above, in order to explicitly waive such right or remedy.
• Assignment: Customer may not assign or attempt to assign any of its rights or obligations under this Internal Privacy Policy, in whole or in part, without the Company’s prior written consent. Any purported assignment of their rights or obligations under this Policy that is made without the Company’s prior written consent shall be null and void. The Company may assign this Policy or delegate its rights or obligations thereunder, in whole or in part, to any third party, without the Customer’s consent.
• Governing law: This Privacy Policy shall be solely governed by and construed in accordance with, the laws of the State of Israel, without giving effect to any other choice of law or conflict of law provision or rule (whether of the State of Israel or otherwise) that would cause the application of the laws of any jurisdiction other than the State of Israel. The United Nations Convention on Contracts for the International Sale of Goods shall not govern this Privacy Policy. Any matter arising from or in connection with this Policy will be exclusively subject to the jurisdiction of the competent courts in Tel Aviv-Jaffa.

Data protection laws in other countries- Customer Information may, as set forth in the Privacy Policy, be disclosed to, or managed or processed by, parties in other countries, and may be subject to the laws of countries where data protection laws are less stringent than the laws governing in Israel or the Customer’s country of residence.

Both, Shoval Investment & Management, Ltd., Company No. 513686634, and BE ALL Centers Ltd., Company No. 515504611, are the joint controllers of the databases with regard to the operations described in this Policy. You may contact us if you have any questions regarding the Company’s Privacy Policy. If you have any questions, requests, complaints, or suggestions regarding this policy, you may contact us at [email protected] and/or through the “Contact Us” page on the Website.