Privacy Policy of P.E. Palmo Ltd.

(Updated in accordance with the provisions of the Privacy Protection Law, 5741–1981, including Amendment No. 13, 5784–2024)

1. P.E. Palm Ltd. (hereinafter:“the Company,”“Palm,” or“we”), Company No. 516838794, with offices at 6 Sheshet HaYamim Street, Bnei Brak, operates a corporate website and landing pages for lead generation (hereinafter:“the Website”).
2. The purpose of this policy is to clarify to website users, potential customers, registrants, and/or anyone who provides information to the company, how information is collected, used, stored, and protected, as well as the rights of data subjects, all in accordance with the provisions of the Privacy Protection Law, 5741–1981 (hereinafter:“the Law”) and Amendment No. 13 to the Law (hereinafter:“Amendment 13” ), and any other relevant legal provision in Israel and in the countries where the company operates.
3. The company is committed to protecting users’ privacy and operating with full transparency regarding the use of personal information. This policy is intended to outline the guidelines that govern the company and to help you understand your rights and our obligations.
4. This policy is written in the masculine form but applies to all users of the website, both women and men.
5. The headings and/or section titles in this document are provided solely for the user’s convenience and/or reference and shall not be used in any way to interpret these Terms and Conditions.

Settings

6. Personal Information – Any data relating to an identified or identifiable individual, directly or indirectly, including name, identification number, contact information (phone, email), location data, or other data that enables identification, as defined in the Act and Amendment 13 (Section 3 of the Act).
7. Data controller – as defined in Amendment 13, the person who determines the purposes for which the data in the database is processed.
8. Processing of information –any operation performed on personal information, including collection, recording, organization, storage, adaptation, alteration, retrieval, use, disclosure, transfer, dissemination, or any other operation performed on the information

Providing Information to the Website

9. As a user of this website, you may subscribe to our newsletter or fill out a contact form. If you choose to subscribe to the newsletter and/or submit a contact form, you will be asked to provide us with your full name, email address, and phone number so that we can contact you and/or send you our newsletters.

Information Collected While Using the Website

10. When you use the Company’s website and/or landing pages, the Company collects and processes the following types of information:
    • Usage data: IP address, device type, browser, pages viewed, location data, and time spent on the site.
    • Identifying information: full name, phone number, email address, and any other information you provided in the contact forms.
    • In addition, the Company may collect and use the services of third parties to collect and analyze anonymous, statistical, or aggregate information regarding the use of the Website, including information related to your details and your activity on the Website.
11. The company does not collect "sensitive personal information" unless it is provided voluntarily and with explicit consent.

Cookies (Cookies)

12. The Company may use "cookies ("Cookies") for the ongoing and proper operation of the website, including to collect statistical data, verify details, tailor the website to your personal preferences, and to provide you with fast and efficient service while saving you the need to enter your personal information each time you visit the website. Cookies are small text files stored on the Company’s server and/or on servers maintained and/or stored on the hard drive of the computer you use to access the website via your browser (or any other accepted technology for the purpose of storing information locally on your device). They contain various types of information, such as the pages you visited, the length of time you spent on the site, where you came from, the information you request to view when logging in, and more. However, it should be clarified that cookies do not contain any information that personally identifies you.
13. If you do not wish to receive cookies, you can change your browser settings so that cookies are not stored on your computer, and you can also delete any cookies that have been stored so far. However, please note that disabling cookies may prevent you from using some of the services and features on this website or other websites.
14. The company uses cookies, tracking files, as described below, and related technologies such as Google Analytics and similar tools to improve its services, perform statistical analysis, and provide personalized content.
15. The company also uses a combination of pixels, SDKs, and targeted advertising tools for marketing and improving its offerings.

Use of Information

16. The information you have provided to us, as well as any information we collect regarding your activity on the website, will be stored in the Company’s databases. By using the website, you authorize the Company to collect such information about you and store it in its databases.
17. Your information will be used in accordance with this Privacy Policy, including for the purposes listed below:
    • To operate and manage the website and the services offered on it, and to enable you to use the website;
    • To provide you with service and contact you when necessary;
    • To improve and enhance our services and create new services and content that meet customer requirements and expectations, as well as to modify or discontinue existing services;
    • To tailor the content and ads you see while using this site and other sites across the web to your interests and browsing habits;
    • To help us advertise to people with similar characteristics to yours who may be interested in purchasing from us;
    • To send you, from time to time, via email, text messages, or any other means, information regarding the Company’s services and products. Such information will be sent to you in accordance with the consent you provided when you submitted your details on the website. If you do not wish to receive these messages, you may choose not to join the website’s mailing list, or remove your information from the website’s mailing list at any time using the method provided in any email you receive from the company.
    • If you are not the only user of the email address to which marketing content is sent, by agreeing to receive marketing messages from the website via email, you confirm that you have obtained the consent of all other users of the aforementioned email address and that your consent also constitutes their consent to receive marketing messages via email from the website. It is clarified that consent to this Privacy Policy constitutes consent for the purposes of the provisions of Section 30A of the Communications (Bezeq and Services) Law, 5742-1982;
    • For the purposes of analysis, monitoring, and providing statistical information to third parties. This information will not identify you personally;
    • For any other purpose specified in this Privacy Policy.
18. The information about you collected in the Company’s databases will be retained for as long as is necessary and reasonable for the purposes for which it was collected, at the Company’s sole discretion, or until the Company receives an explicit request to delete it, and in any case, as required by law.

Disclosure of Information to Third Parties

19. The company will not share your information with third parties except in the following cases:
    • To the extent necessary to provide you with the services and/or information in accordance with the details you have provided.
    • When required by law or by a court order;
    • In any dispute, claim, lawsuit, demand, or legal proceeding between you and the Company and/or anyone acting on its behalf;
    • In any case where the Company believes that the disclosure of the information is necessary to prevent serious harm to your person or property, or to the person or property of another;
    • to companies and organizations affiliated with the Company or to companies that are part of the Company’s group, provided that they use your information only in accordance with this Privacy Policy;
    • When it comes to statistical information about website usage, or any information that does not personally identify you;
    • In the event that the Company reorganizes its operations or the Website, the Company shall be entitled to transfer the information collected about you, as part of the Company’s databases, to purchasers and potential purchasers of all or part of its operations, assets, or shares, including a merger of the Company with another company, as well as in the context of negotiations and due diligence in connection with such transactions, provided that the purchasers or potential purchasers treat the information about you in accordance with the provisions of this Privacy Policy.
20. To the extent that information about you is transferred to third parties, as stated above, it is clarified that these third parties may be located outside the borders of the State of Israel and, as a result, may be subject to the privacy laws of other countries around the world, including countries that do not provide the same level of protection for your privacy as Israeli law does. Your consent to this Privacy Policy constitutes your express consent to the storage of the information collected about you, in accordance with the Privacy Policy, abroad and to its transfer outside the borders of Israel.

Information Security

21. The Company implements systems on the website and takes standard precautions to ensure, to the extent possible, the security of the information. However, although the Company takes measures and devotes resources to minimizing the risks of unauthorized access to its computers, it cannot guarantee that the website and services will be completely immune to unauthorized access to the information it stores. Therefore, subject to the provisions of any law, it shall not be liable for any damage caused as a result of unauthorized access to the information in its possession.
22. Although the company does not maintain a database that requires registration or notification to the Authority under Amendment 13, it will adopt a basic procedure for identifying and addressing security incidents, which includes documenting the incident, conducting an internal investigation, and reporting to the Authority and data subjects in exceptional and serious cases, in accordance with Section 17 of the Law and the Information Security Regulations.

Right to access information

23. Under the Privacy Protection Law, 5741–1981 (the “Privacy Protection Law”), you have the right to request access to the information the company collects about you, as well as to request that it be corrected if such information is incorrect, incomplete, or inaccurate.
24. The Company retains the information for as long as necessary to fulfill the purposes of processing or as required by law. The user may submit a request to have the information deleted (“the right to be forgotten”), and the company will delete the information accordingly, except for information necessary for business management or to comply with a legal obligation. Deletion requests will be documented, and the company will notify the requester upon completion of the process.
25. Inquiries regarding the exercise of rights should be sent via email to office@palmo-group.com, along with appropriate identification details. The company will respond to all inquiries within 30 days, as required by law. The company will reject requests only in accordance with the provisions of the law and will provide a reasoned response.
26. Please note that deleting your information may prevent you from continuing to use the website's services.
27. Information necessary for the company to conduct its business—including statistical, anonymous, or aggregated information used for statistical analysis and to document commercial and other activities you have performed on the site—will continue to be retained as required by law, but will no longer be used to contact you.

Links to third-party content

28. The website may contain links to pages, apps, and websites of various third parties on the Internet, which are not managed or operated by the Company or anyone acting on its behalf.
29. The Company does not control or oversee these pages, apps, and websites, and cannot guarantee that third parties will protect your privacy in the same way that the Company does.
30. Please exercise discretion when providing personal information to third parties, and keep in mind that your use of these pages, apps, and websites is subject to their respective privacy policies, not to the terms of this Privacy Policy.

Change to the Privacy Policy

31. The Company may amend this Privacy Policy from time to time. We will endeavor to notify you of any changes to the Policy as soon as possible, but in any event, the changes will take effect in accordance with the provisions of the law. Your continued use of the website following any changes to the terms indicates your consent to the new terms of the Privacy Policy. If you do not agree to the new terms, you must cease further use of the website.
32. You can view the current Privacy Policy at any time by clicking the appropriate link on the website.

Last updated on August 24, 2025