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Valor-Byron - Website Privacy Policy

The company Valor-Byron (hereinafter – “the company” or “we”) respects the privacy of the
users (hereinafter the “users”) on the valor-byron.com website (hereinafter the “Site”) and
considers it very important to maintain it, and for this purpose acts by the privacy policy
below and the provisions of the law. The purpose of this privacy policy, which is an integral
part of the terms of use, is to review, among other things, how the company keeps and
makes use of the information provided to it by the users of the website and/or collected
about them while using the website. Therefore, the terms appearing in this privacy policy
(hereinafter the “Privacy Policy”) will have the meaning given to them in terms of use unless
explicitly stated otherwise in the privacy policy.

1. Collection of information when using the website

1.1 As part of browsing the website, registering for it, opening an account, entering the
property owners’ area, and using the services offered therein, including as part of a contract
with the company other than through the website to purchase assets or through the
company’s forms or other means of collecting information, users may be asked to provide
information and/or various information details will be collected about them. Some of the
information identifies the users personally, and some are statistical/aggregative information
that is not identified and is not saved together with their identifying information. The types of
information that may be collected within the website are full name, contact details such as
phone number, email address, and residential address, social security number, age, gender,
username, password, information about behaviors on the website including data about areas
of activity and interest, how the site is used, including the source of the referral, the length of
the visit to the site, the content viewed, as well as information about the users’ computers,
including their IP address, geographic location, time zone, type of operating system and its
version, browser type, and version, language preferences, etc.

1.2 The site has an area designated for property owners to get details about the properties
they have purchased. The users who have access to this area must keep their username
and password completely confidential, and they undertake not to reveal them to any other
person and not to allow any other person to use them. Furthermore, it is clarified that the
users will be fully and exclusively responsible for any use made on the website using their
username and password.

1.3 The website allows users to contact the company. In this context, users will be required
to enter information that identifies them: full name, contact information such as phone
number and email address, as well as the content of their request. Users declare that any
information they provide through the website is true, reliable, and accurate and that
establishing contact and/or receiving the offered service on the site will be performed in their
name and for them only. In the meantime, it will be clarified that to the extent that the users
provide personal information about third parties, they declare that they have received all the
necessary consent for providing this information.
1.4 The information collected by the company and/or provided by the users will be stored in
the company’s legally registered database, for the purposes listed in section 2.1 of the
privacy policy below and in accordance with the law’s provisions. The users are aware that
they are not obliged to provide personal information by law, and they hereby agree and
declare that the personal information collected about them and/or that they provided to the
company was provided with their consent and free will.

1.5 By actually entering and/or using the website, users express their consent to the terms
appearing in the privacy policy, including their consent to the collection of their information
and its processing, as described in the privacy policy. If the users do not agree to any of the
conditions listed below, they must immediately, refrain from continuing to use the website
and/or from entering it.

1.6 The users declare that all the information they provided on the website is true, reliable,
and accurate and that they made the contact and/or received the service offered on the
website on their behalf and for them only.

2. The use of information
2.1 The use of the information will be done in accordance with the provisions of the privacy
policy, and for the purposes listed below: (a) in order to operate and manage the company’s
activities, the website and the various services therein; (b) in order to provide an answer to
the users’ inquiries, to provide them with service and support and to maintain contact with
them; (c) in order to improve and enrich the services offered by the site and to create new
services and content that match the requirements and expectations of users as well as to
update, change or cancel existing services; (d) for the purpose of sending operational
messages and alerts to users by various means, including via email, text messages, etc.; (e)
for the purpose of sending marketing offers on behalf of the company, subject to the consent
of the users and subject to the fact that they can request at any time not to receive such
mailings; (f) to adapt the ads that will be presented to users when using the website and
other websites to their areas of interest; (g) in order to adjust the browsing and use
experience of the users of the website and other websites and to generate statistical insights
in these aspects; (h) in order to prevent illegal and/or unauthorized use of the website; and
(i) for any other purpose required or permitted by law or detailed in the privacy policy.

2.2 The details and information about the users will not be handed over to third parties
without their prior consent, except to the extent permitted by the privacy policy, as updated
from time to time. Notwithstanding the above, the company may transfer to third parties the
information about the users in the cases listed below: (a) by obtaining consent from the
user(s) to transfer such information; (b) to the company’s service providers and suppliers, in
order for the company to be able to manage its activities or provide users with the services,
in accordance with the purposes specified in section 2.1 above; (c) To its business partners
and other third parties for the purpose of sending marketing, advertising and other materials
that may be of interest to the users, provided that their express consent to the delivery of
such information has been received subject to the provisions of the law; (d) to third parties
such as interactive advertising companies, for the purpose of adjusting marketing offers and
dedicated advertisements on the website and on other websites throughout the Internet for
the users, provided that this information is collected and/or accumulated through ‘cookies’ as
specified in section 4 below; (e) In the event that a user has violated the terms of use of the
website or has performed illegal actions through the website or attempted to perform such
actions; (f) If the company receives a judicial order instructing it to hand over the users’
details to a third party; g) In the event that the company believes that the delivery of the
information is necessary in order to prevent serious damage to the body or property of the
users, the company or any other party; (h) if it is statistical/aggregate information about the
use of the website, which does not identify the users personally; and (i) in the case of the
transfer of shares in the company or the main part of its assets, insofar as the transfer of the
information is necessary for the performance of such action.

2.3 It is clarified that as long as the users choose to join and register in the personal area of
the website, in the area of property owners on the website, or through any other registration
form, and in this context provide their contact information, such as an e-mail address and/or
a mobile phone number, this will constitute the consent of the users to receive advertising
messages and marketing material on behalf of the company, among other things regarding
updates, services, promotions, discounts, and exclusive benefits, and among other things
through email and/or SMS messages that will be sent directly to users, and to be included
for that purpose in the company’s and website’s mailing list. It is clarified that the users will
be able to remove themselves from receiving such promotional mailings at any time.

2.4 The users confirm and agree that the information about them can and will be transferred
even outside the borders of the State of Israel, including to countries that do not grant the
same protection as that granted by the law applicable in Israel about the privacy and security
of the users’ information. The users expressly authorize the company to transfer the
information they provided and/or collected about them to these countries as well, and the
company will act to the best of its ability and by the privacy policy and/or the law to maintain
the privacy of the users.

2.5 The data and information collected and/or provided to the company will be kept only for
the necessary and reasonable time and for the purposes for which they were collected, at
the sole discretion of the company, and in any case – as required by law. It should be noted
that anonymous information may remain on the company’s servers, and it will be entitled to
use it, among other things, for analysis and statistics in the present and in the future without
a time limit.

3. Other websites
3.1 The website may include links to various pages and websites on the internet which are
not managed and/or operated by the company and/or anyone on its behalf. The company
does not control and/or supervise these platforms, and the fact that the company links to
these contents does not indicate its approval of their content and does not constitute a
guarantee of their correctness, accuracy, reliability, up-to-dateness, or legality. The use of
those pages and websites is subject to the terms of use and the privacy policy that only
refers to them and/or appears in them.

4. Use of Cookies
4.1 The website may use accepted technologies, such as ‘cookies’ (hereinafter “cookies”), to
store information locally on the users’ computers, and sometimes also on the company’s
servers or on the servers of the company’s service providers, in connection with their use of
the website, pixels (Pixels) or digital beacons (Beacons), all to make the website users’
browsing experience simpler, more relevant and more convenient.

4.2 In the meantime, the website may also use Google Analytics to collect anonymous
browsing data to improve the services offered through the website and adjust the browsing
experience and use of the users of the website, and generate statistical insights into these
aspects. More information on this topic can be found on the Google website at
https://www.google.com/intl/iw/policies/technologies/ads/. In addition, the site may use
analytics tools to collect information about the use of our site and types of technical data in
the context of the use of the site, including information about the user’s computer or mobile
device or any other device and system, software, location data, time zone, Internet Protocol
(IP) address, language preference and the like.

4.3 The use of ‘cookies’ will be done for the regular and proper operation of the website,
including collecting statistical data about the use of the website, verifying details, and
adapting the website or its contents to the personal preferences of the user’s information
security needs. “Cookies” are text files which the browser creates according to a command
from the site’s computers. Some of the `cookies` will expire when the user closes the browser
and others are saved on the hard drive of the users’ computers. The `cookies` contain

various information such as the pages the users visited, the length of time they stayed on the
site, where they came from, sections, and information they want to see when entering and
using the site, etc. The information in ‘cookies’ is encrypted, and the company takes
precautions so that only its computers can read and understand the information stored in
them. The company may occasionally operate advertising services through third parties such
as interactive advertising companies. The company may transfer the information
accumulated through the cookies to these companies, which will use it to adjust marketing
offers and dedicated advertisements for the users on the website and other websites
throughout the Internet.

4.4 If a user is not interested in receiving cookies, he can avoid this by changing the
browser settings. The user must remember, however, that deactivating the `cookies` may
result in him not being able to use some of the services and features on the website or other
websites. In addition, deactivating the `cookies` does not affect information that has already
been collected through them and transferred to the company’s servers or the servers of
service providers on its behalf. Such information will not be deleted.

5. Use by children
5.1 To use the website, users must be over the age of eighteen (18). The company reserves
the right to request proof of age at any stage to verify that users under these ages are not
using the site. If you are the parent of a child under these ages and believe that your child
has provided personal information to the company, you may contact us using the contact
information provided in the privacy policy and request the deletion of such information. If it is
brought to our attention that a person under these ages is using the website, we will be
entitled to block it and will make every effort to delete any personal information regarding it

6. User rights
6.1 Users have the right to review identifiable information about them that is held and saved
in the company’s database, and even request to correct or delete it, as long as they find that
the information is not correct, complete, or updated. Users interested in exercising these
rights shall contact the company in writing in the ways prescribed by law or by contacting the
email address: office@valor-byron.com, and the company will make a reasonable effort to
comply with the users’ requests, and in any case, will act by the provisions of the applicable

7. Information security
7.1 Information security systems are implemented on the website, and the company invests
reasonable and acceptable efforts in implementing and maintaining information security on

the website. However, while the company`s systems and efforts reduce the risks of
unauthorized intrusion, they do not provide absolute security. The company cannot
guarantee that the website and the services within it will be immune from any damage, and
the company will not be responsible for any damage caused to the users and/or anyone on
their behalf as a result. The users agree to the delivery of the information and its collection
by the privacy policy and/or the law and assume the risk of the existence of information
security events that will affect the confidentiality, integrity, or availability of the
aforementioned information.

8. Changes to the privacy policy
8.1 The company may change the provisions of the privacy policy from time to time, partly to
reflect technological, business, legal, or regulatory changes. It is clarified that as substantial
changes are made, in the instructions regarding the use of personal information of the users,
a notice to this effect will be published on the site’s home page. The use of the website after
the changes have been made will indicate the users` agreement to these changes, and
therefore it is recommended to review this policy from time to time.
8.2 If any user has any questions regarding the terms of use and/or the privacy policy, he
may contact the company by sending an e-mail message to the address: office@valor-

Privacy policy update date: February 2022.

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