Privacy and Information Processing Policy Last update: 05/01/2026

1. General
   • This privacy policy shall apply to use of the website owned by YOCHELMAN HOLDINGS D.B. LTD (hereinafter: “the Website” and “the Company”, respectively) known as Yochelman Arabov Group. The Company owns the database relating to the Website.
   • Yochelman Arabov Group is a leading real estate company, specializing in developing projects in unique locations and establishing breakthrough mix-use compounds. The Company is involved in residential, commercial, tourism and leisure real estate – implementing the highest and most advanced moral approaches.
   • The Website is intended to promote the Company image, present and market its activities to customers and to enable potential clients to contact the Company (hereinafter – “Website Objective”).
   • The privacy policy comprises an integral part of the Website Terms of Use. In additions, the definitions appearing in the Terms of Use apply to the privacy policy and the provisions of the privacy policy comprise part of the Website Terms of Use. The Website Terms of Use are available at the following link: [Link]
   • The privacy policy applies to all users and any use of the Website, including surfing, registration, adding information, viewing content, access to the Website code an use of the various interfaces.
   • This privacy policy also applies to Company customers and projects that it manages through the Company and Company collaborations.
   • The Company reserves the right to change, update, correct or extend the privacy policy. Any change to the privacy policy will enter into force upon posting notice thereof on the Company Website and further use of the Website after such notice will reflect consent to the updated conditions.
   • The Website is not intended for directly selling Company services and, in order to obtain proposals, you must contact the Company on the various channels, including the Website contact channels.
   • The Company respects and seriously considers the privacy of Website users. Therefore, before using it, you must carefully read the privacy policy; it is a legal document comprising a valid and binding agreement between the user and the Company.
   • The privacy policy is drafted in the masculine form for convenience only but are intended to all genders and plural.
   • Any use of or activity on the Website, including entering information in dedicated fields, comprises user consent to comply with all components of the privacy policy and Terms of Use, by mere use of the Website. If you do not agree with any item of the privacy policy, Terms of Use or guidelines published by the system, please discontinue using the Website and its services immediately.
   • The user declares that any use of the Website system and services follows his reading, understanding and confirming the Company privacy policy and Terms of Use, and subject to any relevant law.
   • The user declares that he is competent and authorized by law to sign this agreement and grant his consent to the Website Terms of Use and privacy policy.
   • The user declares that he is an adult over 18 or that he is a minor and that his use of the Website is approved by his parents or legal guardian.
   • The user acknowledges that he is not required to provide information to the Website and that any information thereby provided is provided upon his free will, for the purposes specified in the Website privacy policy and Terms of Use.
   • It is hereby clarified to the user that any compilation, use, storage, sharing and other processing measures taken by the Company regarding the personal information in its possession is subject to the Privacy Protection Law, 5741-1981 (hereinafter – “Privacy Protection Law”) and Information Security Privacy Protection Regulations, 5777-2017 (hereinafter – Information Security Regulations), Privacy Protection Regulations (Provisions on Information Transferred from EEC to Israel), 5783-2023, Communications Law (Telecommunications and Broadcasts), 5742-1982 (hereinafter – “Communications Law”), and the provisions of any other law or regulation customary in the State of Israel.
2. Information Compilation
   • By using the Website, the user authorizes the Company to compile information using the following methods:
     • Information that the user proactively provides when using the Website: Including full name, company, e-mail and telephone number for contact, reason for inquiry or any other detail that the user will be required to disclose in order to use the Website.

(*) It is hereby emphasized that the Website enables users to enter free text in a field dedicated to describing the reason for inquiry, in order for the user to describe why he is interested in the Company’s services. Avoid entering personal information in this field and others, if not required.

• Information that the user proactively provides when receiving service from the Company: Full name, telephone no., e-mail, address, marital status, bank account details and other details for the provision of services.
• Information compiled by the Company from user use of the system: User surfing habits, including usage times, features used, searches, clicks, pages displayed, URL’s from which the user was referred to the system, ads viewed or clicked, information derived from the user’s browser, user IP, cookies and any information that may be compiled of use of the Website.
• Information compiled by User contact with the Company: Whenever the user contacts the Company in any manner, including telephone, e-mail, chat, the Website itself or in any other manner. The Company may retain user conversations, messages, e-mail messages, contact details and any information provided for any purpose, including customer service and service improvement.

3. Use of Information
   • Use of the information compiled by the Company shall be subject to law and compliant with the provisions of this privacy policy, including for the purposes set forth below:
     • For proposing customized services and content and for contacting the user regarding the services provided, by e-mail or any other manner.
     • The Company will use the information to contact its customers and will use it in order to tailor its services to the user.
     • The Company will use the information in order to customize its advertising and marketing information based on user preferences and interests, including Website ad display, delivering promotional mail on services and content and for other services. Promotional mail will be sent upon user consent only. The user may grant such consent by marking the field to approve receipt of marketing material and registering to the Company databases, appearing in various parts of the Website.
     • It is hereby clarified that the user may instruct the Company to discontinue his subscription to promotional mail at any time by responding to a message with the word “Remove” by e-mail or text message.
     • It is hereby clarified that the Company uses the information for direct mailing purposes, including as set forth in Articles 3.1.1 and 3.1.2 of the privacy policy, in accordance with the Privacy Protection Law and Communication Law, and the user may instruct the Company to discontinue the direct mailing according to the provisions of the said law.
     • The Company shall use the information for customer service purposes, including response to feedback and complaints, contacting a user when needed and conducting research, data analysis and statistics. This use shall be conducted to improve service or disclose information to third parties, including advertisers.
     • The Company will use the information for staging a defense in any proceeding relating to dispute, argument, claim, compliance, complaint investigation, legal litigation and suspected fraud or prohibited conduct contravening the Terms of Use.
     • The Company will use the information in order to deal with the ramifications of prohibited use of the Website by the user, according to the definition of “Prohibited Use” in the Website Terms of Use.
     • The Company will use the information toward complying with the provisions of law and regulation applying thereto.

4. Information Retention
   • The information compiled by the Company will be retained in the databases kept by the Company or third party service providers according to the provisions of the law and specifically the Privacy Protection Law and regulations thereof, including Information Security Regulations.
   • As stated above, the Company may also retain personal information for direct mailing purposes.
   • The Company will retain the personal information thereby compiled for the period required to exercise the usage objectives specified in the Privacy Policy.
   • The Company takes customary and reasonable information protection and security measures as set forth in the Information Security Regulations, noting the scope and type of information thereby compiled, and invests great efforts in protecting user privacy and minimizing the risk of information leakage to other factors. However, it is hereby clarified that the Company cannot commit to full and absolute protection of the information and to third parties not gaining unauthorized access thereto. As such, the Company shall bear no liability for damage caused to users due to information theft, alteration or inappropriate use thereof by third parties, inter alia by hacking, penetration, Website faults and disruptions, which our outside of Company control.
   • To help the Company optimally protect user private information, the user is responsible for avoiding the transfer or disclosure of his personal details, including to third parties. The Company shall bear no liability for damage caused to a user due to user omissions in protecting his said personal details.
5. Information Sharing
   • The Company may transfer information thereby compiled to third parties in a manner that may personally identify the user in one of the following instances set forth below:
     • Transferring information for the purpose of providing users with services offered by the Company and issuing proposals to users regarding the said services that may be of interest to the user.
     • Transferring information required for sending users publications as set forth in this policy, by direct mail or otherwise; and transferring information for various statistical analyses that serve the Company for customer service and service improvement purposes.
     • Transferring information required in order to prevent damage to users or third parties, all upon the Company’s exclusive discretion.
     • Transferring information required by law, judicial order or by force of an instruction issued by the legally competent authority.
     • Transferring information where the user has violated or is about to violate the Website Terms of Use or Privacy Policy, performs illegal actions etc., all in order to address such acts and violations.
     • Transferring information for legal proceedings in which the Company is involved.
     • Transferring information to other companies of the Company group, provided the other companies comply with this Privacy Policy.
     • Transferring information to another corporation in case of Company restructuring or merger with a third party, provided the receiving corporation complies with the Company Privacy Policy.
     • Transferring anonymous, pseudo-anonymous or statistical information to other companies or organizations for ongoing Website operation, upon the Company’s exclusive discretion, provided the Company does not reveal user identity when transferring this information.

6. Cookies
   • As part of ongoing Website operation and in order to improvement performance and services, the Company uses cookies and other monitoring technologies. These files may compile the user’s identification details, IP address, pages visited, duration therein, the source from which he was referred to the Website, information preferred by the user and more.
   • Cookie files enable the Company to streamline system performance and services, enable access to information that may interest the user and his personal preferences, compile statistical data on Website use, cancel the need for reentering user information whenever accessing Website pages requiring registration, and more.
   • The information in cookie files is encrypted but, in addition, the user can prevent cookies by changing the settings of his browser or deleting cookies from his computer at any time. It is important to note that such changes and deletions might impair the user experience and some of the Website services.
   • Where the user did not specify blockage of cookies on his browser, it shall be considered user consent to use of the Website, the Company may use cookies and similar monitoring technologies for ongoing operations, statistical data compilation and adapting the Website to user personal preferences.
7. Information Review, Correction and Deletion
   • Pursuant to the provisions of the Privacy Protection Law, every user may contact the Company to review the information compiled in his regard and held in the Company database. In addition, the user may request the amendment, correction or deletion of the said information.
   • The request must be prepared in writing and sent to the e-mail address noted in this Privacy Policy.
   • Where requests to review, change, correct or delete information are received, they will be handled as set forth by law and specifically the Privacy Protection Law, and Privacy Protection Regulations (Conditions for Reviewing Information and Legal Procedure in Appeal of Review Request Rejection), 5741-1981 and Privacy Protection Regulations (Provisions on Information Transferred from EEC to Israel), 5783-2023.
   • Notwithstanding the above, the Company may retain in its database user information thereby compiled independently or which is not required for contacting the user, such as information needed for the Company for its business operations.
   • Upon rejecting a user request of information deletion, amendment or review, the Company will specify the reason for refusal in a manner set forth by law and in the Privacy Protection Regulations.
   • Where the Company failed to respond to the user’s request to review, amend or delete information within the period set forth by law, failure to respond must be considered a rejection of the user’s request pursuant to Articles 5 and 7 of the Conditions for Reviewing Information and Legal Procedure in Appeal of Review Request Rejection, 5741-1981.
8. Third-Party Links
   • The Website may contain links to third party sites or services that are not controlled by the Company and are not subject to the provisions of this Privacy Policy. The Company shall bear no liability for damage caused to a user by the disclosure of information or violation of privacy procedures by a third party accessed through the link. The Company recommends that users verify the privacy policy of every website thereby used.
9. Assignment of Rights
   • The Company may transfer and assign its rights or liabilities to any third party, including the transfer of information relating to the user, all in accordance with this Privacy Policy, provided the said third party confirms its undertaking to comply with this Privacy Policy in writing.
10. Privacy Policy Updates
    • The Company reserves the right to update its Privacy Policy at any time, upon its discretion and with no prior notice. Every update shall be binding as of its publication online. Where a user chooses not to approve the updated Privacy Policy, he must immediately discontinue use of the Website and its services. As stated in Article 1.6 of the Privacy Policy, further use of the Website comprises user consent to the Privacy Policy, including the changes thereto.
    • The date on which the Privacy Policy was last updated appears at the top of this page.

11. Governing Law and Jurisdiction
    • This Privacy Policy and any dispute related thereto is governed by Israeli law only. The Tel Aviv District Courts shall hold unique and exclusive jurisdiction over any legal proceeding conducted between the parties to the agreement.
12. Contact Details

Tel: +972-9-955-0330 Fax: +972-9-743-5340 E-mail: office@y-group.co.il