1. Introduction
   1. Atarim Tel Aviv Coastline Company for the Development of Tourism Sites in Tel Aviv-Yafo Ltd.  (hereinafter: “the Company“) respects the privacy of its clients who make use of the Company’s facilities that it manages and operates, including recreational and leisure sites and various projects that it manages (hereinafter collectively: “the Company’s Facilities). In addition, the Company operates this website at the address  https://www.hatachana.co.il, or at any other address that may exist from time to time (hereinafter: “the Website“, “the Internet Website“). Accordingly, the Company is publishing this Policy regarding the protection of the privacy of the users of the Company’s Facilities and Website. It should be clarified that this Policy applies solely to the Website of Park HaTachana and the Company’s Facilities at Park HaTachana which are referred to in this Privacy Policy.
   2. This Policy describes the Company’s terms governing the protection of the privacy of its clients and, among other things, reviews the manner in which the Company makes use of the information provided to it by you, as well as the information pertaining to you that will collected while making use of the Company’s Facilities and Website, in compliance with the Privacy Protection Law, 5741-1981 (hereinafter: “Privacy Protection Law“).
   3. This Policy constitutes an integral part of the Website’s rules and regulations. The Policy is worded in the masculine gender for convenience purposes only, and applies equally to women.
   4. The division of this Privacy Policy into sections and section headings is solely for convenience purposes and should not be used for interpretation purposes.
   5. In this Policy, the term “personal information” means any data or information pertaining to you that will be provided to the Company and/or will be collected in the course of your use of the Company’s Facilities and/or its Website, and which identifies or makes it possible to identify you personally, including your first name and your last name, your address, your phone number, the license plate number of your vehicle, photographs taken on the premises of the Company’s Facilities, and more, whether that information will be provided at your initiative (such as by completing forms and the like), or whether it will be provided incidentally and by way of your use of the Company’s Facilities and its services, as well as “personal information”  and/or “information of a particularly sensitive nature” as those terms are defined in the Privacy Protection Law.
2. The Processing of the Personal Information
   1. The personal information provided by you to the Company is provided with your consent and voluntarily, and you are under no legal obligation to provide personal information to the Company. However, should you wish to make use of the Company’s Facilities and/or its Website, you will be required to provide personal information about yourself, and the very use of the Company’s Facilities and/or its Website will constitute your consent that the personal information be processed by the Company. Thus, for example, various areas and sections on the Website, such as the area intended for newsletter subscribers, for the customer loyalty club, for contacting the Company using the online contact forms found on the Website, etc. – are likely to involve registration and the provision of personal information about yourself, such as your full name, address, phone number, active email address, organizational affiliation, and other details according to the need and circumstances of the matter.
   2. The receipt of services on the Website or at the Company’s Facilities, whether on an occasional and one-time basis, and whether after registering as a subscriber to the Company’s services, including membership in the customer loyalty club, require the provision of personal information that is needed to perform those services, the collection of the payment for them (should it be necessary), safety and security. Those details may be provided over the telephone, through the Website, using online forms, and when making use of the Facilities owned by the Company. The Company may gather additional information when establishing contact and corresponding with you, for example when you submit any requests or inquiries to the Company.
   3. The provision of the details on the Website and/or on the registration forms for the services offered by the Company, will be done by your providing the details to the Company. The fields which must be filled out in order to receive the services and make use of the Company’s Facilities will be marked with an asterisk (*) and shall be a condition for receiving the Company’s services. Should the required details in those mandatory fields not be provided, you will not be allowed to register in the relevant area on the Website and/or make use of the Company’s services and the Company’s Facilities.
   4. You pledge that any information you provide to the Company will be correct, up-to-date, precise and complete, and that you hereby confirm the accuracy of the details you provided. The provision of incorrect details, or the non-provision of all the required details, could prevent you from completing the registration or making use of some of the Website’s services and the Company’s Facilities, compromise the quality of the service extended to you, and also compromise the ability to establish contact with you if needed.
   5. When providing personal information about a third party, you are declaring that you have obtained his explicit consent to provide the information to the Company for the purpose of making use of that information in accordance with this Policy and/or, alternatively, that you are the legal guardian of that third party.
3. Collecting Personal Information in the Course of Making Use of the Company’s Website and Facilities
   1. Please note that in addition to your providing information on the Website and/or in any other manner at your initiative, the Company and/or any entity acting on its behalf is collecting and retaining personal information that is received from its clients through the very use of its services, on the Company’s Website and at the Company’s Facilities, including, but not limited to, names, addresses, identity card numbers, contact information, and the like.
   2. When making use of the Website, the Company may gather information about your Website usage patterns, including about information you read on the Website, the pages you viewed, the services that were of interest to you, the location of the computer and the IP address used to access the Website, the type of operating system you use, the type of end device in your possession, etc. The Company may collect and avail itself of the services of third parties in order to gather and analyze anonymous, statistical or aggregated information in connection with the use of the Website, including information that relates to your activity on the Website. For more information, see Clause 8 below.
   3. In addition, when submitting a request through the Website to establish contact with us, you will be required to enter your choice from the drop-down menu intended for that purpose. It should be clarified that all the information details you enter as free text will be sent to us “as is,” and for that reason ask that you only enter details that are essential to your request; should you choose to enter personal information details about yourself (or about others) through that menu, it should be clarified that you are giving your consent (or that you have obtained the consent of whoever the information pertains to) to our collection and processing of the personal information that will be entered in accordance with this Privacy Policy.
   4. The Company hereby notifies you that it makes use of security and surveillance cameras in the public space and at the Company’s Facilities that it operates for reasons of security, traffic monitoring, safety and the proper management of the Company’s Facilities. The deployment of the cameras and the retention of the footage is carried out pursuant to the provisions of the law, including the provisions of the Privacy Protection Law, 5741-1981.
   5. The deployment of the cameras at the Company’s Facilities is done for the purpose of achieving the aforementioned objectives, and when needed further to a requirement by and consultation with the local authority, the Tel Aviv-Yafo Municipality, and requirements of the various security authorities, including the Israel Police.
      
      Description of the cameras’ features:
      • A closed-circuit television system that photographs the Company’s Facilities around the clock, with the footage itself being retained for a period of up to 14 days, or for a longer period of time as needed in specific cases;
      • We make use of cameras that operate according to thermal and/or infrared technology in order to capture images in the dark or in low-light conditions;
      • Use is made of adjustable cameras as a substitute for the use of multiple cameras;
      • The photography system does not make use of voice recorders.
      • The individual in charge of viewing and retaining the photographed information at Park HaTachana is Gil Klein, the Operations and Projects Manager at Park HaTachana. For more information, you can send an email to [email protected] or contact us by regular mail via the Israel Postal Company at Atarim Ltd., 21 HaArba’a Street, Tel Aviv-Yafo, Israel, or by phone to 972-3-776-4005.
4. Use of the Personal Information
   The Company will make use of the personal information you provide it with (whether at your initiative or incidental to the use you make of the Company’s Facilities) and/or will be gathered by it in the course of the use you make of the Company’s Facilities and Website, in accordance with this Policy and under the provisions of any law, and for the purposes listed below:
   
   1. To regulate your use of the Company’s Facilities;
   2. To ensure the normal and safe operation of the Company’s Facilities, prevent vandalism and locate those who cause it, and involve the law enforcement authorities as needed and pursuant to the provisions of the law;
   3. To monitor and improve the service;
   4. To enable you to make use of the Website, the content it contains and the services it offers, and to update it from time to time;
   5. To facilitate the purchase of tickets to various events held at Park HaTachana;
   6. To collect payment for the Company’s services you have used, whether the collection is carried out directly by the Company or by third parties that the Company contracts with for the purpose of receiving collection services from them (subject to Clause 5 below);
   7. To establish contact with you if needed via different means, including in response to your requests to establish contact with us or with regard to the exercise of your rights, and for the purpose of managing and running operational and other projects;
   8. To enforce the terms of use appearing in the Website’s rules and regulations and at the Company’s Facilities, in order to comply with the requirements of any law, regulation or other legislation, and also in order to assist lawful authorities and any third party;
   9. To improve the operation of the Website and the Company’s Facilities, and in this context, among other things, to process the personal information into statistical data that is not personally identifiable;
   10. The Company records and secures the personal information, and also conducts analysis and data processing in order to provide and improve the Company’s services, including security and regulation of the collection for the services it offers, and the like. In this context, the Company performs various kinds of processing with regard to the aforementioned information, including, but not limited to, statistical analyses and demand needs, whether pertaining to the information received from a single user, or whether pertaining to the sum of the information received from a number of users that undergoes anonymization (hereinafter: “Processed Data“).
   11. To resolve disputes, comply with the law and/or meet a requirement of a lawful authority. We may make use of personal information in our possession in order to enforce the terms of this Privacy Policy, and also to resolve disputes or comply with any law, in order to anchor, exercise or protect our legal rights, or the rights of others. In addition, we may make use of the information in order to comply with a request or demand from a lawful authority or court orders, or in any other manner that is consistent with the consent given by you.
5. Sharing the Information With Third Parties
   
   In order to process the information for the foregoing purposes, we may share your personal information with third parties, in Israel or abroad (including countries that supply a lower degree of privacy protection than the one stipulated in the Israeli law), as specified below:
   
   1. Public bodies to whom the Company is required by law and/or by agreement to provide information and/or for the purpose of managing and operating the Company’s Facilities, such as the local authority – the Tel Aviv-Yafo Municipality – that has access to the Company’s pool of cameras in order to safeguard and maintain security and the public order, and the like, as well as sharing information to arrange payments, including in order to grant discounts / benefits to the residents of Tel Aviv-Yafo, and the like;
   2. Outside service providers and consultants – your personal information may be shared with service providers and consultants that contract with the Company in connection with the operation and management of the Company’s Facilities and Website, such as for mailing purposes, receiving payments from clients – e.g. through applications of digital wallet companies – and with cloud storage providers, IT vendors, and other providers of services extended to the users of the Company’s Facilities, and also for the purpose of examining disputes, allegations, claims, demands or legal proceedings, should they arise, between you and the Company and/or anyone acting on its behalf, an attorney, an auditor and accountant;
   3. The Company may transmit your details and the information that was collected further to the use you made of the Website and the Company’s Facilities to other companies or organizations affiliated with the Company, as may exist from time to time, provided that they make use of that information solely in accordance with the provisions of this Policy;
   4. Should the Company organize its activity or the activity of the Website, the Company’s Facilities and/or its services under a different framework, and also should it change its legal structure, including the transfer of the activity of the Website, the Company’s Facilities, all or in part, to a third party (including in the course of negotiations leading up to transactions of this nature) – it will be permitted to transfer a copy of your personal information that was collected to the new entity, as long as that entity abides by the provisions of this Policy in all that concerns you;
   5. The legal authorities, including the security authorities, pursuant to Section 19 Privacy Protection Law, 5741-1981, for the purpose of complying with the provisions of the law, enforcing the terms of use, the Privacy Policy and/or demands made by lawful authorities, in accordance with a legal obligation or authority, pursuant to the directives of a lawful authority or court order or in accordance with any law. We will share information in those cases when we believe in good faith that we are obliged to do so, or if the disclosure of the information is vital to investigating, preventing, or taking steps against illegal activity or an act of fraud or protecting your rights or those of others;
   6. We may share information with companies that assist us in operations related to advertising, sales promotion and marketing, or with suppliers of analytical services or search engines that assist us in improving and optimizing the Website and in processing personal information in the context of providing such services;
   7. Further to an explicit request on your part, subject to the provisions of the law;
   8. Your very entry into the Company’s Facilities, and every time you make use of them and/or access the Website, you are giving your consent that the Company (and/or anyone acting on its behalf) transfer the information collected about you and the Processed Data to third parties, for various needs that are specified in this Policy. In addition, you are hereby giving your consent to the Company and to third parties to whom the information and/or the Processed Data will be provided by the Company (or anyone acting on its behalf) to establish contact with you, including by sending an electronic notification, a short text message and/or by any other means or manner;
   9. Any use made by third parties of the information that you agreed we provide to third parties is the sole responsibility of those third parties, and the Company will not bear any liability for such third parties;
   10. The Website may contain links to and from the external websites/platforms of third parties, such as social media. Should, as said above, you click on a particular link and reach an external platform, or should you make use of information found on the Website for sharing on social media and/or on other online websites, it is hereby clarified that such use of social media and online services is external to and separate from the Website and is subject to the privacy practices of those services. Consequently, should you choose to click on a link that directs to an external website/platform as said above, our recommendation is that you read the terms of use and the privacy policy of that entity.
6. Retention of the Personal Information
   1. The information that the Company collects is kept in its databases, regarding which the Company implements data security measures to store and secure them and restrict the access to them, subject to and in accordance with the law. As specified in this Policy, additional information that is provided to third parties will be collected and retained by them according to their privacy policy. You are asked to review the provisions of the privacy policy of those companies, including their terms of use when downloading applications for arranging the payment for the Company’s Facilities and its services. Your consent to this Policy also constitutes your consent to the processing of your personal information and its transfer outside of Israel’s borders, including to countries that supply a lower degree of protection than the one stipulated in the privacy laws in Israel.
   2. The Company will not retain your personal information for any longer than is necessary to achieve the aims behind the collection of the personal information, unless it is required and/or is permitted to do so in accordance with the law. Non-personally identifiable information will be kept in the Group’s information systems without a time limit (as long as it is not forbidden by law).
7. Confidentiality and Securing the Information
   1. The Company assigns utmost importance to securing the information in its systems and works to maintain the privacy of the users pursuant to the Privacy Protection Law. To safeguard the information, it implements data security systems, applications and procedures, which are designed to minimize the risks of theft, damage, loss and unauthorized access to the information. The Company takes steps and invests numerous efforts in securing the personal information held by it, while making use of the accepted security measures, encryption, and access authorization management.
   2. Although we have adopted the reasonable measures for protect the information, there is no certainty that those applications can completely guarantee that personal information will not be disclosed or stolen from the databases, and the Company cannot ensure that the level of security will block every breach, data leak, and illegal use of the information in the Company’s databases. Consequently, the Company does not undertake, nor can you reasonably expect, that the services and the information systems used by the Company will be totally immune to unauthorized access to the information stored in them. By the very use of the Website and the Company’s Facilities, you are aware of and consent to these limitations.
   3. Without derogating from the foregoing, the Company works to protect the confidentiality of all your personal information found in its possession, and will not transfer the information except in compliance with the provisions of this Policy, unless required to provide that information in accordance with any law/order.
8. Cookies
   1. The Company may make use of Cookies on its Website for the routine and proper operation of the Website, including to compile statistical data regarding the use of the Website, to verify details, to tailor the Website to your personal preferences, and also for data security and other purposes.
   2. Cookies are text files that your browser creates based on a command from the Website’s computers. Some Cookies expire when you close the browser, and others are stored on the hard drive of the end device used by you. The Cookies on your computer can contain diverse information, such as the pages you visited, the length of time you spent on the Website, from where you reached the Website, sections, information that you asked to see when accessing the Website, and more.
   3. If you do not want to receive Cookies, you can avoid them by changing the settings on your browser. To do so, please consult the Help file on the browser. For some of the services mentioned above, you can ask to be removed from the collection of Cookie files containing your information by choosing “Opt-Out.”  Please bear in mind, however, that disabling the Cookies may result in your inability to make use of some of the services and features on the Website or on other websites. Furthermore, you can delete the Cookies whenever you choose. It is suggested that you do so only if you are convinced that you do not want the Website to be customized to your preferences or share information pertaining to your activity on the Website with third parties.
   4. Third parties, including Google, may make use of Cookies that will be embedded on our Website in order to collect information about your activity on the Website, for their measurement and targeted advertising purposes, based on their privacy policy and other terms, which could apply to you if you make use of their services. Click on the following link for an explanation about how Google Analytics works:
   5. www.google.com/policies/privacy/partners
   6. Complete details regarding the Cookies that we make use of on our Website are attached as Appendix A to this Policy.
9. Your Rights to the Personal Information
   Subject to the provisions of the law, you are entitled to ask to review your personal information that has been kept in the Company’s databases, and request to update, correct or delete information that is inaccurate, incomplete, unclear or not up-to-date. To exercise your rights, you can contact us by emailing a request as specified below. Please note that the deletion of information could prevent you from continuing to receive services from the Website and from the Company. Information that is required by the Company, including documentation of the actions you performed on the Website, will continue to be held by the Company as stipulated in the law, but will no longer be used to reach out to you. As said above, a request of this nature should be emailed to Attorney Chen Matalon at [email protected], or via the Israel Postal Company to Atarim Ltd., 21 HaArba’a Street, Tel Aviv-Yafo, Israel, or by phone to 972-3-776-4005.
10. Privacy Policy Updates
    The Company reserves the right to occasionally update and revise the terms of the Privacy Policy when needed, at its sole discretion and without any obligation on its part to give notice thereof, whether in advance and/or after the fact. The continued use of the Website and/or of the Company’s Facilities following the revision of the Privacy Policy is proof of your consent to the revised Policy immediately upon its presentation on the Website. Should you not agree with the revised wording of the Policy, you must discontinue your further use of the Website and/or the Company’s Facilities and its services. You may at any time review the revised Policy by clicking on the appropriate link on the Website.
11. Contact Information of the Database Proprietors Atarim Tel Aviv Coastline Company for the Development of Tourism Sites in Tel Aviv-Yafo Ltd. (Private Company No. 520028721) Email address: [email protected]
    Regular address: 21 HaArba’a Street, Tel Aviv-Yafo, Israel
    Phone number: 972-3-776-4005

Appendix A The

Cookies Used on the Park HaTachana Website

Olim Trail – New Website [RO1]