Capital 38 Privacy Policy

Effective Date: [Insert Date]

At Capital 38 (“we,” “us,” or “our”), we are committed to safeguarding your privacy and protecting your personal information. This Privacy Policy outlines how we collect, use, share, and protect your personal data in connection with your use of our website (the “Site”) and any related services.

We are committed to complying with applicable privacy and data protection laws, including the Israeli Protection of Privacy Law, 5741-1981, U.S. privacy laws (e.g., California Consumer Privacy Act - CCPA), and international privacy regulations where applicable.

By accessing or using this Site, you agree to the terms of this Privacy Policy.

1. Information We Collect

We may collect personal and non-personal information from you in a variety of ways, including directly from you, automatically when you use our Site, or from third-party sources.

1.1 Information You Provide to Us:

• Full name
• Email address
• Phone number
• Company/Organization name
• Job title
• Communication preferences
• Any additional information you voluntarily provide through contact forms, email, or other interactions with us.

1.2 Information We Collect Automatically:

When you visit or interact with our Site, we may automatically collect:

• IP address
• Browser type and version
• Device information
• Location data (if enabled)
• Usage data (e.g., time spent on the Site, pages viewed, clicks, and referral URLs)

1.3 Cookies and Tracking Technologies:

We use cookies, web beacons, and similar tracking technologies to:

• Improve website functionality and performance
• Understand user behavior and preferences
• Customize your browsing experience

You can manage your cookie preferences through your browser settings. Disabling cookies may affect your experience on our Site.

2. How We Use Your Information

We use the information we collect for legitimate business purposes, including:

• Providing Services: Delivering requested services, responding to inquiries, and managing our relationship with you.
• Improving Our Website: Enhancing the functionality, usability, and performance of our Site.
• Communications: Sending updates, newsletters, and other marketing communications (subject to your preferences).
• Compliance: Meeting legal, regulatory, and contractual obligations.
• Security: Detecting, investigating, and preventing fraud, security breaches, and unauthorized activities.
• Research and Analytics: Conducting data analysis and improving our services and offerings.

3. How We Share Your Information

We do not sell your personal information. However, we may share your information in the following scenarios:

3.1 Third-Party Service Providers:

We may share your information with trusted third-party service providers who assist with:

• Hosting and managing our Site
• Data analysis and performance tracking
• Marketing and communication services
• IT and security support

These third parties are contractually obligated to handle your data securely and only for specified purposes.

3.2 Legal and Regulatory Requirements:

We may disclose your personal information to:

• Comply with legal obligations, court orders, or regulatory requirements.
• Respond to lawful requests from government agencies or law enforcement.
• Protect our rights, privacy, safety, or property.

3.3 Business Transfers:

In the event of a merger, acquisition, or sale of assets, your personal data may be transferred as part of the transaction.

4. International Data Transfers

Your information may be transferred to, stored, and processed in jurisdictions outside your country of residence, including Israel and the United States.

We take appropriate safeguards, such as implementing Standard Contractual Clauses (SCCs) and adhering to applicable data protection laws, to ensure your information remains secure during these transfers.

5. Your Privacy Rights

You may have certain rights under applicable privacy laws. These rights may include:

5.1 Under Israeli Privacy Law (Protection of Privacy Law, 5741-1981):

• Right of Access: Access your personal information.
• Right of Correction: Correct inaccuracies in your personal information.
• Right to Deletion: Request the deletion of your data, subject to legal obligations.

5.2 Under U.S. Privacy Laws (e.g., CCPA):

• Right to Know: Understand what personal data we collect, how we use it, and who we share it with.
• Right to Access: Request copies of your personal data.
• Right to Deletion: Request deletion of your personal data.
• Right to Opt-Out: Opt-out of the sale of personal data (Note: Capital 38 does not sell personal data).
• Right to Non-Discrimination: Exercise your rights without facing discrimination.

5.3 Exercising Your Rights:

To exercise any of these rights, please contact us at:

• Email: [Insert Contact Email]
• Phone: [Insert Contact Number]

We may require proof of identity before fulfilling your request.

6. Data Retention

We retain personal information only for as long as necessary to:

• Fulfill the purposes outlined in this Privacy Policy.
• Comply with legal, regulatory, and contractual obligations.
• Resolve disputes and enforce agreements.

Once no longer required, your data will be securely deleted or anonymized.

7. Data Security

We implement reasonable administrative, technical, and physical safeguards to protect your data from unauthorized access, disclosure, or misuse, including:

• Encryption protocols
• Access control measures
• Regular security audits

While we strive to protect your personal data, no method of storage or transmission is completely secure.

8. Children’s Privacy

Our Site is not intended for individuals under the age of 18. We do not knowingly collect personal information from minors. If you believe we have inadvertently collected data from a minor, please contact us immediately.

9. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in legal, operational, or technological requirements.

When updates are made, the “Effective Date” at the top of this policy will be revised.

We encourage you to review this Privacy Policy periodically.

10. Governing Law and Jurisdiction

This Privacy Policy is governed by:

• Israeli law for users accessing our Site from Israel, with disputes resolved in Tel Aviv courts.
• New York State law for users accessing our Site from the United States, with disputes resolved in New York courts.

11. Contact Us

If you have any questions, concerns, or requests about this Privacy Policy, please contact us:

• Email: [Insert Contact Email]
• Phone: [Insert Contact Number]
• Address (Israel): [Insert Address in Israel]
• Address (U.S.): [Insert Address in the United States]

We are committed to addressing your inquiries promptly and transparently.