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Vertical Privacy Policy

  1. Welcome to the online services (hereinafter: the “Website” or “Portal”) of Arbitrage Fund GP Ltd. (hereinafter: the “Company” or “We”), a fund specializing in hedged investments characterized by an asymmetrical risk-reward profile (hereinafter: the “Services”).
  2. The Company attaches great importance to protecting the privacy of its employees, service providers, clients, and anyone using its website or additional services. We make continuous efforts to ensure the protection of your personal information and to act in accordance with the privacy rights of every user.
  3. Please note that different rules may apply to specific services and/or applications, and an individual policy regarding the use of information collected in that specific service/application may be published alongside them.
  4. The Company’s Privacy Policy is an integral part of the Terms of Use of the services. From time to time, there may be updates to the Privacy Policy or the Terms of Use in accordance with technological, business, or regulatory changes.
  5. Updates will be published in this document, which is always available in its updated version on the Company’s online services, including the date of the last update. Using the Company’s services, including logging into or accessing the digital services and using the additional services, indicates your agreement to this Privacy Policy. This means you consent to the collection, processing, retention, and sharing of personal information as detailed in this document.
  6. If you do not agree to these terms, you are advised to refrain from using the Company’s services.
  7. This document is written in the masculine form for convenience only, but refers to both genders equally. We thank you for taking the time to read this document.
  8. Definitions:
    1. “The System”: An internet system (website and/or portal) including servers, databases, etc., that communicates with clients.
    2. “User Account”: A dedicated account opened for you to use the service through the digital services.
    3. “Personal Information”: Data relating to an identified person or an identifiable person.
    4. “Digital Services”: Refers to the variety of services offered in the system, including access to the user account, viewing information, and/or contacting via email and/or phone and/or the website and/or any other communication method and/or any other type of service offered therein and/or any other service that will be offered and/or added to the digital services in the future.
    5. “You” or “User”: The person using the digital services in any way.
    6. “Cookies”: A string of letters and numbers used for authentication, tracking, and storing information about a website visitor, such as saving user preferences.
    7. “Usage Data”: Refers to data collected automatically, whether generated using the service or from the service infrastructure itself (for example, the duration of a page visit).
    8. “Device”: Any component used to access the service, such as a computer and/or mobile device and/or digital tablet and/or smartwatch, etc.
    9. “Service Provider”: Any entity, company, organization, or individual that processes personal information and/or data (usage data or personal data) on behalf of the Company. This refers to third-party providers and/or individuals outsourced by the Company to facilitate and/or perform and/or provide the service on behalf of the Company, and/or assist the Company in monitoring, analyzing how the service is used, and improving the service as deemed necessary.
    10. “Database Controller”: Whoever determines, alone or jointly with others, the purposes of processing the information in the database. For this purpose, the Company is the controller of the database collected upon opening a user account and/or contacting and/or browsing the digital services.
    11. “Holder”: An entity external to the database controller that processes information on its behalf.
  9. Collection of Personal Details and Personal Information:
    1. Consent
      1. By using the digital services, you agree to this Privacy Policy. To receive the services, and in certain cases, you will be required to provide us with personal information relevant to the requested service. By providing these details, you declare that the personal details you provided to the Company are reliable and accurate.
      2. Please note that you are under no legal obligation to provide your personal details, unless stated otherwise, and providing these details is done with your consent and free will. Should you choose not to provide certain details, the Company may not be able to provide you with the requested services, in whole or in part.
    2. We invite you to read the Privacy Policy carefully. If you do not agree to the terms detailed herein, you must immediately cease all use of its digital services. In such a situation, unfortunately, we will not be able to provide you with the services available through them.
  10. Retention and Collection of Personal Details:
    1. How we collect information about you: Information about you is collected through registration forms via email or by entering details in the client portal and any other contact form that forms part of the digital services, as well as through security cameras located at the Company’s branches.
    2. The personal information you provide to the Company will be stored in its databases and used in accordance with this Privacy Policy. The Company may use the information itself or through third parties acting on its behalf, including transferring it to them, all for the needs and purposes detailed in this policy and in accordance with the law.
  11. What Information Do We Collect?
    1. Information you provide:
      1. First and last name
      2. Email address
      3. Phone number
      4. ID number
      5. Date of birth
      6. Country of birth
      7. Citizenship
      8. Source of capital
      9. Occupation
      10. Bank details
      11. Details of beneficiaries in the bank account, if any, including ID numbers
      12. Investor qualification status (CPA or external party)
      13. Security camera footage
    2. It is important that you provide only correct, accurate, and complete details. Providing incorrect details may impair our ability to provide you with service or contact you if necessary.
    3. If you provide personal information that is not yours but belongs to another person (for example, a family member), you confirm that you have obtained all necessary consents from them as required by law. Furthermore, you confirm that providing the information and using it in accordance with this Privacy Policy will not infringe upon that person’s privacy or other rights.
  12. Information collected automatically on online services
    1. The Company collects technical and anonymous information about your use of the online services. This includes, for example: which pages you visited, the IP address from which you connected, and more. This information is aggregate and statistical and is not personally identifiable. We also use Cookies and tracking pixels to collect additional anonymous information; for details about our Cookie policy, see below.
  13. Information collected when using various communication channels
    1. In addition, we collect written or vocal information that you transmit to us through various channels, such as email correspondence, phone calls, SMS messages, or any other electronic communication means. Recorded telephone calls are intended for quality control and service improvement. Any detail you disclose in a call will be recorded and kept with us, so it is recommended to provide only necessary information.
  14. Use of Information
    1. The use of collected information will be made only in accordance with this Privacy Policy and according to law, for the purposes and uses detailed below:
      1. Upon user request and/or with their explicit consent.
      2. For the purpose of providing Company services and customer service.
      3. For handling inquiries or contacting users.
      4. To improve and measure services, including user experience, content, and design of online services.
      5. For processing statistical information through collecting and analyzing anonymous, statistical, or aggregate data.
      6. For legal reasons (such as complying with a court order, law, governmental request, etc.).
      7. To identify, prevent, or address fraud, information security issues, or technical problems.
      8. To protect the rights of third parties, including intellectual property rights, privacy, and protection against defamation.
      9. For receiving inquiries from users and handling them.
      10. Direct marketing and staying in touch with service users.
      11. For contacting you should the need arise, including contacting to provide information to interested parties.
      12. Additional purposes that will be required from time to time, in accordance with the law, privacy policy, and terms of use of the Company.
      13. In cases of transferring the Company’s activity or rights to third parties, provided that they undertake to uphold the terms of this Privacy Policy.
      14. For securing the offered services.
  15. Anonymous and Statistical Information (Cookies and Log Data):
    1. When using the online services, the Company collects log data and other anonymous information about the user for statistical purposes, improving the service and website, and tailoring them to user needs.
    2. Log data is statistical, aggregate, and non-identifying information regarding user activity on online services, such as: pages viewed, the internet address (IP) accessed from, browser type and user operating system, browsing duration on the site, and more.
    3. Log data is sent from the user’s browser during site browsing and recorded automatically by the Company’s server. The data does not include personally identifiable information and will not be used by the Company in combination with personally identifiable information. The Company may retain log data indefinitely.
    4. Anonymous and statistical information is also collected by the Company through Cookies.
    5. A cookie is a string of letters or numbers used for authentication, tracking, and storing information about a website user, such as saving user preferences. The cookie represents a specific state of browsing on the site.
    6. The Company uses cookies and similar technologies for the ongoing operation of the site, checking its integrity, collecting statistical data about site usage, verifying details, information security, collecting statistical information about usage and volume that does not include personal information, and more.
    7. The user has the option to refuse cookies via the browser, unless these files are necessary to prevent fraud or to ensure the security of the website. However, refusing to accept these files may interfere with the use of the site and its services.
  16. Transfer of Information to Third Parties:
    1. Some of the services on the website and portal are provided by third parties, service providers of the Company (hereinafter: “Third Parties”). Clicking on a service may cause certain information to be transferred to service providers, in accordance with the purposes of information use as detailed in this Privacy Policy, including:
      1. Upon your explicit request, or with your explicit consent.
      2. To cloud computing service providers, which may be located outside of Israel, for data storage and backup purposes.
      3. To software and maintenance providers, for fixing faults in systems where information is stored.
      4. To various vendors providing services to the Company, such as software houses, website management, operations, mailing, marketing, and more.
      5. To lawyers, insurance companies, and accountants, as needed. All service providers and vendors receive access to personal information only for performing the services, and not for any other purpose.
      6. To competent authorities, pursuant to a court order, or when required to protect the rights and assets of the Company, and in accordance with the law.
      7. You are aware that information may be transferred to third parties located outside of Israel, including countries where privacy protection is less than that in Israel. By using the website and services, you consciously agree to this.
      8. The Company undertakes that your personal information will be transferred to third parties only for the purposes detailed in this policy, and strictly to the required extent. In addition, the Company will take all necessary measures to ensure that recipients of the information are bound to maintain confidentiality and information security in accordance with the law.
  17. Information Security
    1. The Company undertakes to comply with all legal requirements regarding information security, including the Protection of Privacy Law and Information Security Regulations.
    2. The Company implements up-to-date and strict systems and procedures for information security and invests significant efforts in implementing and maintaining the security of the website and users’ personal information (whether by us or through receiving services from qualified third-party service providers).
    3. While these systems reduce the risks of unauthorized intrusion into website computers, they do not provide absolute security. It is the user’s responsibility to take protective measures on the end device used for digital services, keep the password for the website (client portal) confidential, and not transfer it to any other party.
    4. Please note that we do not request, nor will we ever request, your credit card details, account identity, or login password via email or telephone calls.
    5. The Company will report to relevant authorities any information security incident that may jeopardize and/or harm information security immediately from the moment it becomes aware of the incident.
  18. Right of Access and Correction of Information:
    1. Subject to applicable law: You have the right to access and review the personal information we hold about you in our databases. You may request to review your information or have an authorized representative or legal guardian do so on your behalf, by contacting us. If you find that any of your information is inaccurate, incomplete, or outdated, you have the right to request its correction. The Company will respond to your request as soon as possible and allow inspection of your information in accordance with the provisions and timeframes set by law.
    2. The Company may retain a copy of the information as required by law or for legitimate business needs. Information residing in backup files may be retained in accordance with the backup policies of the Company and third parties.
    3. You are entitled, after inspecting your information and finding it to be incorrect, incomplete, unclear, or out of date, to request that your information be corrected. The Company will respond to your request as soon as possible and as required by law.
    4. For this purpose, you are welcome to contact the Company via email at: Vertical-fund@arbit.co.il
  19. Database:
    1. Collected data will be stored in the Company’s databases and under its responsibility. For this purpose, the Company is the controller of the databases, and its address is:
    2. Address: 144 Menachem Begin Rd, Tel Aviv, 23rd Floor
    3. Phone: 03-6344961
    4. Email: Vertical-fund@arbit.co.il
  20. Direct Marketing and Sending Messages:
    1. The Company may send you, from time to time, information related to the Company, its activities, and/or its services. This information will be sent to you only if you have given consent, and in any case, you can always revoke your consent and opt out of receiving further messages.
    2. Providing your details constitutes consent to store the information in the Company’s database and to receive direct marketing and advertising materials as defined in the Communications Law (Telecommunications and Broadcasting), 1982, through any communication channel and media, including your mobile phone and email address.
    3. If you wish to remove your personal details from the Company’s database or limit their use, you must write to the Website Administrator at the address provided at the end of this document.
  21. Changes to the Privacy Policy:
    1. The Company may update the Privacy Policy and Terms of Use from time to time to reflect technological, business, legal, or regulatory changes. Any update will be published in this document on the Company’s websites, along with the date of the last update.
  22. Contact Us:
    1. To contact us with any question, request, or issue related to this document, please reach out to: Vertical-fund@arbit.co.il