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Privacy Policy

[Last updated on 09/2025]

 

Privacy

  1. We, Smart Funding Ltd., Company No. 515918811 (the "Company" or "Us" or "We" or "Our"), in its brain name "SMART BUNDLES" which operates www.smartfunding.co.il (the "Website" or "Site"), respects Users’ (the "User" and "Your" or "You") privacy and is committed to protecting the information, as defined below, which is provided to Us as part of Your use of the Website, as set forth in this Privacy Policy ("Privacy Policy"). The Privacy Policy explains Our policy with respect to information, including, but not limited to, the information collected by Us when You use the Website and the Services offered on it ("Services"), why We collect the above information, and how We use it.
  2. This Privacy Policy is an integral part of the Website’s Terms of Use (the "Terms of Use") and applies to any use and/or viewing of the Website, whether through a computer/mobile device and/or any other means. By using the Website and its Services, You consent to any use that may be made of the information collected about You (including, but not limited to, personal information) (the "Information") as set out in this Privacy Policy.
  3. We may change the Privacy Policy from time to time. In the event that changes to this Privacy Policy are made, a notice of a Privacy Policy update will appear at the top of this page. This Privacy Policy should be reviewed prior to any use of the Website. To the extent the User does not agree to any change in the Terms of Use, the only remedy is termination of the use of the Website. Any change to the Privacy Policy will take effect immediately upon posting on the Website under the Privacy Policy, unless stated otherwise in the publication regarding the Privacy Policy change.

Who we are

  1. The Company operates a Platform (the "Platform") through the Website, as an "Offering Coordinator," subject to the license granted to it by the Israel Securities Authority (the "ISA"). The Platform allows companies and entrepreneurs to raise funds from the public, in exchange for shares.

Information gathering

  1. In order for Us to provide You with the Services, you are required to provide a number of details that we require in order to fulfil our obligations under law, including the Securities Law, 1968 and the Money Laundering Law, 2000. These details will be marked as mandatory details that are required to be provided in order to receive the Services.
  2. You will also be asked to provide additional information that is not required by law. As to these details, You are not legally obligated to provide the information, and its delivery depends on Your will and consent. However, without providing such information, the quality of service provided by Us will be significantly impaired, and in some cases, we will not be able to provide You with the requested service.
  3. The information will be used for the purpose of providing the Services and the needs of the Company, as set out in this Privacy Policy. The information will not be used for purposes unrelated to the Company's activities and will not be transmitted to a third party, other than within the Company's activities and purposes, including for direct mailing.

Personal information

  1. Upon registering to the Site, You will be asked to provide personal information, including, inter alia, name, residential address, email address, telephone number, social security number, scope of annual income, interests, level of investment knowledge and experience, and other information that You wish to provide in the registration status. As part of the sign-up process, a Facebook or email account can be linked to Your account on the Site.
  2. The Company may also collect additional information regarding information related to Your activity on the Site, including, but not limited to, investments You have previously made through the Platform, IP addresses, time of Site access, the Site pages You used, technical malfunction reports and the browser used. The Company (and/or anyone on its behalf) collects the information while You visit and use the Website. The Company will collect information about browsing habits on the Site for research purposes, decision-making and enhancement of the User experience, and adaptation of the Site, its content and Services to the Users’ preferences on the Site.
  3. The Company warrants that all information about Users of the Website is maintained and protected in accordance with the Protection of Privacy Law, 5741-1981 (the "Privacy Protection Law").
  4. The above is a notice under section 11 of the Privacy Protection Law.
  5. You are responsible for the accuracy and truthfulness of the personal information and any other information You provide to Us. It is hereby clarified that inaccurate information provided by You will affect the information You receive from Us when You use the Website and/or when You receive the Services, and will affect Our ability to provide You Services and contact You as defined in this Privacy Policy.
  6. In accordance with Sections 13 and 14 of the Privacy Protection Law, 5741-1981, you are entitled to review the personal information we hold about you, subject to the provisions of the law and its regulations, and to request the correction of the information if you find it to be incorrect, incomplete, or not up-to-date. You may exercise your rights above, and update your personal information, independently through your user profile on the website or by contacting us through any of the following means: (1) sending an email to customer service (at: info@smartfunding.co.il); and/or (2) by a written request to the address 58 HaRakevet St., Tel Aviv, in any case where you: (1) wish to review the information or verify the accuracy of the personal information collected about you; (2) wish to update or correct the information

Use of information

  1. The information You provide to Us will be stored in the Company's Database (the "Database"), which is kept in accordance with the law.
  2. We use information collected from You to provide You with the Services, including for the following purposes:
    • Contacting Users for offerings, updating request statuses, and responding to Users’ inquiries;
    • Monitoring and clarifying User raising and investment restrictions;
    • Collecting and returning investment money from Users;
    • Investment management after the offer is completed;
    • Compliance with regulatory obligations applicable to the Company by law;
    • Sending alerts and notices in connection with the provision of the Services and/or for the purpose of promoting the Site and its Services and/or for violating the Website’s Terms of Use;
    • Collecting payments for the Services provided by Us;
    • Monitoring the performance of the Site and how You use the Site, in order to continuously improve its functioning, design and quality and to provide additional technical services;
    • Gathering information related to Users’ activities on the Site, such as statistical information about pages visited by a User, date and time of visit, location, page-view time, information the User sends each time he visits a site (such as his IP address), and type of browser and webpage he visited before visiting the Site. This is all in order to improve the level of Services offered on the Site and to create new Services according to Users' interest;
    • Performing various analyses with respect to said information, including, but not limited to, various statistical analyses and market segmentations, either in relation to information obtained from a single User or in relation to the aggregation of the information obtained from several Users;
    • Monitoring and conducting misuse prevention tests;
    • Storing the information in the Company's Databases in accordance with the provisions of the Privacy Protection Law and any additional law applicable to the retention of information; and
    • Distributing marketing and advertising information, including direct mailing, updates, and general and personalized messages to the various Users where the User has consented.

Providing information to third parties

  1. The Company may provide information about Users to affiliates of the Company and/or to third parties that provide the Company with Services for the purpose of operating the Website and providing the Services to Users under the Site, including:
    • Clearing and payment Services;
    • Direct mailing Services; and
    • Money laundering risk management.
  2. We will not disclose the information to third parties, except as provided in the above section, except in the circumstances set out below:
    • If the Company receives a judicial order instructing it to provide personal and/or other information to any third party;
    • In any dispute, claim, demand, suit or legal proceedings, if any, between the User and the Company and/or anyone on its behalf;
    • In order to safeguard and protect the rights and property of the Company;
    • In the event the User violates any of the Website’s Terms of Use and/or the Privacy Policy or performs or attempts to perform unlawful actions through or in connection with the Site and/or the Services provided by the Company;
    • In order to protect other Users' personal safety in any dispute, claim, demand, suit or legal proceedings, if any, between the User and the Company and/or anyone on its behalf;
    • If We sell, divest or assign part of Our business or all of Our business and/or assets to a third party, or if we acquire or merge with a third party, or if we commence a bankruptcy or insolvency proceeding, we may sell, assign or transmit to third parties all of Your information, as well as any other information provided to Us by You.
  3. These third parties act as data processors on our behalf. The Company ensures that any transfer of information to these entities is done subject to binding legal agreements. These agreements require them to maintain the confidentiality of the information, to implement appropriate security measures as required by law, and to use the information solely for the purpose of providing the services defined for them by us, and for no other purpose. The responsibility for protecting your information applies to us even when it is processed by these parties.

Direct mailing

  1. The User hereby consents to the Company’s contact in any way, including delivery, by electronic message, short text message and/or any other means or method, of advertisements intended to encourage the purchase of a product or service or to encourage other money withdrawal. The User hereby shall be deemed to have provided express prior written consent for the purpose of encouraging the purchase of a product or service or encouraging the withdrawal of funds in any other way, as well as for any other message, by electronic message, short text message and/or any other means or method. It is clarified that this User consent applies both to products and Services of a type similar to the products and Services offered or listed on the Website and to products and Services of a type different than those products and Services listed on the Website.
  2. At any time, You can opt out and stop receiving such messages by selecting the "Remove" button in the body of the message sent to You or by contacting Us through (1) emailing customer service (at info@smartfunding.co.il), and/or (2) writing to the Company at 145 Tormus, Kfar Yona. In doing so, the Company will delete the information it needs only for contacting You by direct mail. However, the remaining information You have provided to the Company and that is required for the provision of Services shall be saved, but will no longer be used for direct mailing.

Cookies and Other Tracking Technologies  

  1. Our website uses "cookies" and similar tracking technologies (such as pixels and tracking scripts) to improve your browsing experience, analyze site usage, measure the effectiveness of our marketing efforts, and present you with relevant content. These are small text files stored on your device.

  2. We use third-party services, which also place cookies on your device. Below is a list of the main tools we use::

    • Google Analytics and Google Tag Manager: These tools, provided by Google, allow us to collect statistical and anonymous information about how the site is used, such as the pages you visited, the duration of your stay on the site, and the actions you performed. Google Tag Manager helps us efficiently manage all tracking tags on the site. For more information, you can review Google's Privacy Policy.

    • Hotjar: We use Hotjar's services to better understand our users' needs and to improve the service and user experience on the site. Hotjar helps us understand how users interact with the site (for example, how much time they spend on each page, which links they choose to click) using tools like heatmaps, session recordings, and surveys. For more information, you can review Hotjar's Privacy Policy.

    • Facebook Pixel (Meta Pixel): The tracking pixel from Meta (Facebook) allows us to measure, optimize, and build audiences for our advertising campaigns on Meta's platforms. The pixel helps us track conversions from Facebook ads, display personalized ads to users who have visited the site (Remarketing), and create Lookalike Audiences. For more information, you can review Meta's Data Policy.

    • LinkedIn Insight Tag: LinkedIn's tracking tag enables us to gain insights about visitors to our site who come from the LinkedIn network, track conversions from advertising campaigns on LinkedIn, and perform remarketing to site visitors through ads on LinkedIn. For more information, you can review LinkedIn's Privacy Policy.

  3. You can control and manage the use of cookies through your browser settings. Please note that blocking certain cookies may impair your browsing experience and the availability of certain services and features on the site.

Data security

  1. Securing Your personal data is important to Us. We understand the importance of information security, as well as the techniques required to secure information. We take appropriate security measures to protect against the loss, misuse or alteration of the information we collect about You on the Site as set forth in the Company's Information and Documentation Security Procedure.
  2. You should know that browsing the Internet exposes You to many risks, such as identification theft (PHISHING), exposure to non-encrypted information, virus infection, and computer communications tapping.
  3. Using a computer with no active and up-to-date antivirus software or without updated software exposes You to viruses and/or spyware that may record or disrupt Your computer operations. The responsibility for ensuring that viruses do not infect the computer from which Your Site activity is performed is solely Your responsibility, by installing and updating antivirus tools.
  4. You should be careful of fake emails. Fake emails are messages supposedly sent from Us that ask the recipients to log in to the Site via a link provided within the message and provide or update their personal data, detailing the reasons why the update is required, i.e. security reasons, system upgrades, and the like. The link in the message can be an exact imitation of the Company's official Website from which the message was allegedly sent. In this way, unlawful attempts are made to obtain recipients’ personal data for access to their accounts.
  5. Please note that in no case will the Company contact its customers by email asking them to update their personal details, so no request to update information received via email should be answered.

Data Retention 

  1. The Company retains personal information for the period necessary to fulfill the purposes for which the information was collected, as detailed in this Privacy Policy, unless a longer retention period is required or permitted by law.
  2. Upon the termination of the contractual relationship between you and the Company, or following your request for the deletion of your information, we will proceed to delete the personal information that we no longer require.
  3. It should be clarified that certain information, including records of investment activities and details collected for anti-money laundering purposes, will be retained for longer periods (typically, at least seven years) as required by the Securities Law, 5728-1968, the Prohibition of Money Laundering Law, 5760-2000, and other regulatory provisions applicable to our activities. This information will be stored securely, access to it will be restricted, and it will be used solely for the purpose of complying with our legal obligations, for audits, or for legal proceedings.

Transfers of information outside the jurisdiction of the State of Israel

  1. We may transfer Your information outside the jurisdiction of Israel and/or the EU. It is possible that the information security and privacy laws in the jurisdiction to which the personal information is transferred will not be as comprehensive as those applicable in Israel and the EU, in which case we will take steps to ensure a similar level of protection for Your personal information. While using the Site, You agree to the aforementioned transfer.

Links to other sites

  1. You may find Links to various sites on the Internet ("Links") that are not operated by Us ("Different Sites") and which have different privacy policies. Although we strive to include Links to only reliable and trustworthy sites, we are not responsible for the privacy policies or systems and procedures for the security and protection of information applied to the various sites, and we are not responsible for the information collected by the various sites and/or third parties that are not subject to this Privacy Policy. Moreover, we have no responsibility or liability whatsoever in connection with any policies (including privacy policies), practices, actions or omissions of various websites and/or such third parties. We suggest that You review the terms of use and privacy policies of these sites.

Disclaimer

  1. The company bears no responsibility for events beyond Our direct control. The Company cannot guarantee that there will be no errors in the performance of Your personal information’s privacy security. In addition, the Company is not responsible for any damages, direct or indirect, in connection with the use and/or disclosure of personal information that includes, inter alia, disclosure of personal information due to errors and unauthorized access by third parties and any other party, beyond its reasonable control.

Contact

  1. For any questions regarding the Terms of Use or Services on this site, or this Privacy Policy, please contact Us at info@smartfunding.co.il.

 

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Privacy Policy