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Privacy Policy

Effective Date: 23 March 2026

1. About Us

Aviv Capital Fund Management Partnership, Limited Partnership (“Aviv Capital”), is committed to protecting your personal information and your right to privacy. This policy describes how we collect, use, store, and protect your data when you visit or interact with our website.

2. Types of Data We Collect

We may collect and process the following types of information:
  • Personal information such as name, email address, IP address, location data, and browser identifiers (cookies or other tracking technologies).
  • Sensitive personal data, where applicable, including financial information, health-related data, geolocation, or biometric identifiers.
We do not knowingly collect data on minors under the age of 18.

3. Purposes for Processing

Your data is collected and processed for the following purposes:
  • Analyzing website usage and user behavior (pages visited, session duration, referring websites).
  • Improving user experience and functionality of our website.
  • Complying with applicable legal and regulatory obligations.
  • Securing our systems and detecting potential fraud or abuse.

4. Legal Basis for Processing

Your personal data is processed lawfully based on:
  • Your consent (when applicable, such as for cookies or newsletters).
  • Our legitimate interests, such as analytics and service improvement.
  • Legal obligations, when required by applicable law or regulations.

5. Disclosure and Data Sharing

We may disclose personal information if:
  • Required by law, regulation, court order, or official request.
  • Necessary to protect our legal rights or the safety of users.
  • Shared with service providers who assist in operating our website, subject to appropriate confidentiality agreements.
We do not sell, trade, or rent your personal data to third parties.

6. Data Retention

We retain personal data only as long as necessary to fulfill the purposes for which it was collected, including legal, regulatory, and reporting obligations.

7. Data Subject Rights (Under Amendment 13)

Under Israeli law (Privacy Protection Law Amendment No. 13), you have the right to:
  • Access and receive a copy of your personal data.
  • Request correction or deletion of inaccurate or outdated data.
  • Object to or restrict the processing of your data in certain circumstances.
  • File a complaint with the Israeli Privacy Protection Authority if you believe your rights have been violated.
You may exercise your rights by contacting us (see Section 10).

8. Data Security

We implement appropriate technical and organizational measures to protect your personal data from unauthorized access, alteration, disclosure, or destruction. These include:
  • Restricted access to stored data.
  • Encryption where appropriate.
  • Internal privacy and data protection procedures.

9. Data Protection Officer (DPO)

In accordance with the law, a Data Protection Officer (DPO) will be appointed to oversee compliance with privacy regulations and handle inquiries related to your data.

10. Contact Information

To access, correct, or delete your personal information or exercise any privacy rights, please contact us:

11. Changes to This Privacy Policy

We may update this policy periodically to reflect changes in our practices, services, or legal obligations. The latest version will always be published on our website.

Last Updated: 23 March 2026