PRIVACY POLICY

Last updated on: 27-10-2025

Introduction

Reality Assets Management 2019 Ltd., including the subsidiaries and/or the companies held thereby for the setting up of the various funds through which the company provides its services (the “Company” or “we”), treats your privacy with respect and is committed to protecting the personal information it collects and holds about you. The Privacy Policy below describes the manner in which we collect personal information, the types of personal information collected, how the personal information is used, and the way in which you, as the data subject, can review it, update it or request its deletion – all in relation to the personal information collected through our Websites (as defined below). This policy is drafted in the masculine gender for reasons of convenience, but it is intended for both men and women. During use of the Company’s Websites, under the domains: reality-fund, reality-group, reality-equity, reality-debt, reality-germany, reality-proptech, reality-growth (the “Website” or “Websites”), and through the use of our investor portal (the “Portal” or the “Investor Portal”), we will collect, store and use information about you in the manner described in this policy and under the risks described in the security section.

This document applies to the activity on the Websites and the investment portal [agora], and the processing of the private information in the framework thereof. This document does not regulate the Company’s policy regarding the processing of personal information that we carry out in the context of engagements with our clients and provision of the services accordingly, which is regulated in our agreements with our clients.

Definitions
Terms which are not otherwise defined in this Privacy Policy shall be afforded the meaning ascribed thereto in the Website’s Terms of Use or in the Privacy Protection Laws in accordance with the applicable law as the case may be.
1. “User” – anyone who browses or uses the Websites and/or the Investor Portal.
2. “Privacy Protection Laws” – means (1) the Privacy Protection Law, 5741-1981, the regulations that have been and/or shall be promulgated thereunder, including the Privacy Protection Regulations (Information Security), 5777-2017, as well as directives of the Privacy Protection Authority, as shall be in effect from time to time, and (2) any relevant legislation that applies to the activity and the processing of the personal information, including, but not limited to, the provisions of the General Data Protection Regulation (GDPR) of the European Union.
3. “Private Information” – as defined in the Privacy Protection Laws, and any information through which it is possible, directly or indirectly, to uniquely identify a private individual. “Information” and “Highly Sensitive Information” are also as defined in the Privacy Protection Laws (including in relation to the various variations of these terms in the different Privacy Protection Laws).
4. “Processing” or “Use” – any action performed on or through Private Information, including: storage, retention, transfer, granting access and/or making available to another, correction, analysis, summarization, translation, review and copying, etc.

The personal information we collect through the Websites and/or the Portal and the Use thereof

Method of collection of the information	Types of personal information	Purposes of Use of the personal information	Legal basis under the GDPR
Information collected during registration for and access to the Investor Portal	When you use the link we send you to set up a user in the Portal, you will be asked to state: full name, e-mail address, and to choose a password. Information about details of the User’s investments through the Company (phone number, residential address, investment details of such investor, contact person for the investor) will be entered into the Portal, which information will be in our possession due to provision of the services.	To enable secure access for viewing the User’s information in the Portal; To enable the delivery of messages regarding the client’s investments, regarding the Portal and the use thereof, to registered Portal users; To enable clients to stay informed about their investments; through the Company’s services, and to generate reports thereon, as well as to edit and update the client’s contact details so that we can make contact with the client when we deem it necessary for the purpose of providing the services or fulfilling another legal provision regarding the Portal and/or use thereof and/or the User’s information contained therein; For the purpose of managing and configuring the technological systems on which the Portal is based; To document your consent to the Portal’s Terms of Use.	For the purpose of fulfilling our obligations to the client to provide online data viewing services, according to Section 6(1)(b), as well as to allow the information about the User to be reviewed and corrected according to Section 6(1)(c)
Information you actively provide when using the Website – filling out contact forms	Full name, e-mail address, phone number, and any additional information you choose to share with us in the form	To contact you using the means of communication you provided; To respond to your inquiry according to the subject of the inquiry, provided that you expressed your explicit consent – to send you various mailings, including advertisements, invitations to events, updates, etc.	Based on your consent, according to Section 6(1)(a)
Information you actively provide when you are contacted using the means of communication you provided	Any information that you choose to provide during correspondence or conversations with us or during the commercial engagement with us	To offer you our services in a manner tailored to your information as provided by you; To offer you various services, according to the nature and type of engagement between you and the Company; To document the information in our systems for the purpose of managing our operation; To route your inquiry to the relevant function at the Company; To provide support and handle requests or complaints; To make contact when we deem it necessary for the purpose of providing the services or fulfilling another legal provision; To manage the commercial relationship between us, including service announcements, the production and sending of accounting and operational documents, or documents required by law, in connection with our services.	Based on your consent, according to Section 6(1)(a), or based on the need to provide the services and support as part of our obligations to you, according to Section 6(1)(b), and based on our legal obligation regarding notices and documents required by law, according to Section 6(1)(c)
Information we collect about you when you visit the Websites or the Portal (through third-party services, including cookies – please see separate chapter regarding cookies)	Whether or not you agreed to accept cookies from our Website. In addition, we collect aggregated data about the use of our Website through Google Analytics cookies, and share them with Google Analytics. Such data do not personally identify you to us, but it may be added to Private Information that Google Analytics processes about you	To document your consent or non-consent to cookies Improving the services and applications offered on the Website, adapting content, services and advertisements displayed on the Website, statistical research regarding the manner of use of the Website and of the services and content offered through it	Legal obligation with respect to documenting consent according to Section 6(1)(c); Our legitimate business interest with respect to the other purposes, according to Section 6(1)(f)

You are under no legal obligation to provide us with any of the information specified above. However, without providing the information, you will not be able to use the Website fully or at all, and some of the services will not be available to you: thus, if you do not provide the information required for registration for the Investor Portal, we will not be able to grant you access to the Investor Portal, because the User must be identified before we allow access to the information included on the Website. In addition, if you do not provide us with contact details when contacting us, we will not be able to respond to the inquirer. If you do not consent to accepting cookies, your user experience on the Website may be impaired, depending on the cookies we are unable to load. In each one of these cases, your ability to receive our services (except, as aforesaid, viewing your information in the Investor Portal) will not be affected.
How else will my information be used? In addition to the purposes specified above with respect to each type of personal information, we will also use the personal information for the following purposes, and insofar as necessary according to the good faith discretion of the Company and based on the Company’s legitimate business interest (except in cases where it is expressly stated below that the Processing is based on the Company’s legal obligation): (1) In order to defend ourselves in the event of a notice or legal proceeding against us, in connection with the services and/or the Websites and/or Portal, whether initiated by you or by a third party due to your actions or omissions; or in order to investigate and even institute proceedings (including notice proceedings and formal legal proceedings) against the User with respect to a prima facie act and/or omission of the User that harms and/or may harm the Company and/or anyone on its behalf and/or any third parties, including other users, including in the event of a breach of the User’s undertakings vis-à-vis the Company and including in cases where the Company reasonably believes that the User has misused their right to use the service, or has committed an act or omission which the Company reasonably believes violates any relevant law, rules or regulations; (2) In the manner required of us by competent authorities, including delivery of information thereto, in order to comply with our obligations under the applicable law, if we are required to do so, including by a judicial order, demand of a competent authority or by law; where we believe in good faith that we are required to do so according to requirements of the applicable law; (3) In order to detect, prevent or otherwise handle fraud, security problems or technical issues on the Websites and/or the Portal and/or in order to prevent bodily injury or property damage to others; (4) In order to protect the rights, property or personal safety of the Company, its users, its clients or the general public; (5) In order to comply with our obligations and to transfer our activity if and when the Company undergoes a restructuring or a change in control, including by way of a merger or acquisition, whether of all or part of its assets, or in the event that the Company assigns or transfers all or part of its operations and consequently its rights and obligations vis-à-vis all the users to a third party; or in order to allow the management of due diligence proceedings ahead of such transactions or ahead of financing transactions of the Company, such as investment or another capital injection into the Company; (6) For the purpose of providing and/or completing a service for the User, preventing damage or resolving faults; (7) For various other purposes according to the User’s explicit approval.

To whom else might personal information about Users be provided?
1. The Company does not sell, lease or rent the Private Information of the Users to third parties for Use thereby for their own purposes.
2. In addition, the Company shall transfer the personal information to consultants and suppliers insofar as required for the activity of the Website, the Portal and the Company, and all subject to their undertakings to us to protect the privacy and security of the information, and not to use the information other than for the purpose of provision of their services to the Company. In accordance with the aforesaid, we will transfer information to our suppliers in relation to the following services: platforms for the building, storage and management of the Website, technological platform for managing the Investor Portal, tools for managing cookie consent, marketing services and marketing and client data management platforms, e-mail services, clearing services, cloud storage services, authentication and access permissions management services, instant messaging (such as SMS or chat messages) service providers, analytics and data analysis service, management of cyber protection and management of the Company’s information systems, economic, tax and accounting consulting services, and legal consulting in connection with management of our operation. The majority of such suppliers process your Private Information in Israel and/or in Europe, but the information may be stored in other countries, including in the U.S. See also Section 4 in this regard.
3. The Company may share personal information also with subsidiaries, partnerships of subsidiaries, sister companies and parent companies, insofar as exist at the relevant time, provided that this is done for the purposes specified in this Privacy Notice.
4. In the event of a change in ownership through a merger and/or acquisition, all the personal information processed by us will be transferred to the possession of the buyer or the company after the merger, provided that the said personal information is only used for the same purposes and that the transferee processes the information, at minimum, according to the standards included in this Privacy Notice.
5. We may share personal information with competent authorities in order to comply with the requirements of any legal orders, law, regulation or other legislation when we believe in good faith that we are required to do so.
6. We may transfer personal information to our consultants (legal advisors, crisis management consultants and other professional consultants).
7. If the Company organizes its activities within the framework of another entity – including selling all or part of the activity and/or merging with another entity – it shall be entitled to transfer the personal information or any other information collected about you to the other entity, provided that the other entity assumes vis-à-vis you the provisions of this Privacy Policy (or at least implements the standards set forth therein for protecting privacy and securing the personal information) and uses the information only for the purposes specified herein.
8. For the purpose of anonymization and the delivery and sharing of anonymous, aggregated and statistical information at the sole discretion of the Company.
9. To other third parties – according to your explicit request.
Global transfers and Processing of personal information
1. Why is the information transferred between countries? Since we operate in an international environment, in certain cases, the transfer of your personal information is required for Processing in systems located in other countries by our suppliers. We may do this for the purposes we defined above in the chapter “To whom else might personal information about Users be provided?”; at present, our service providers process the data in Israel, Europe and the U.S. In other words, you may have provided us with your information in a certain country, while its Processing will be carried out, among other places, also in one of these countries.
2. Measures we implement to ensure the adequate level of protection for the information when it is transferred to other countries:
  1. Transfer to countries that the European Commission recognizes as countries to which Private Information may be transferred, including, without derogating from the generality of the aforesaid, based on the recognition granted to the US-EEA Privacy Framework.
  2. Use of information security and privacy protection agreements with third parties that receive Private Information from us, which ensure compliance with required standards for handling and protecting the Private Information. If you are domiciled in one of the countries of the European Economic Area (EEA), the transfer of your personal information outside the EEA will be carried out using Standard Contractual Clauses (SCCs) approved by the European Commission. These clauses constitute binding standards for the Processing of personal data undertaken by third parties that process information for us and on our behalf, as well as additional safeguards as required according to our transfer risk assessments, according to the circumstances of each transfer.
  3. In the absence of European Union approval for a specific country as specified in Section 4.2.1 above, or in the absence of agreements as aforesaid with certain third parties as stated in Section 4.2.2 above, or in the absence of another permit or other exception in the applicable Privacy Protection Laws that allows the transfer of the information outside of Israel, we will transfer such information based on your consent.
  4. The Company will take reasonably necessary steps to ensure that your personal information is handled securely and in accordance with this Privacy Notice, and that no transfer of your personal data will be made to an organization or country unless there are adequate controls in place, including securing your personal information.
Cookies and monitoring and tracking technologies
1. During the use of the Website, we use technologies for collecting information and monitoring usage, such as cookies (small text files stored in your browser or end device). Cookies make it possible to identify the browser or device, collect information about the characteristics of the device, the browser and the network, understand how the Website is used, and adapt content and advertisements, including on third-party websites and services. Some of the cookies may be set by third parties (such as analytics services we implement for performance analysis, for example Google Analytics, which we use for some of the purposes we listed in part one).
2. The cookies we may use are generally divided into the following categories:
  1. Essential/necessary cookies: Required for loading the Website or for operating certain functions (for example: completing the message submission process, securing access, loading video files, identifying Portal users, documenting consent to cookies).
  2. Analytical cookies: Track how the Websites and the Portal are used so that we can improve performance and report on activity.
  3. Preference cookies: Save your preferences on the Website, for example if you chose a specific language for displaying the Website, or if you confirmed the cookie notice.
3. Some of the cookies may be first-party cookies, which are cookies that are set by our Website and are primarily intended for the proper functioning of the Website, saving preferences, security and basic analytics. Some are third-party cookies, meaning they are set by external domains (such as Google Analytics services) and enable, among other things, the measurement of performance and analytics of usage of and access to the Website.
4. Alongside cookies, we may also use additional tracking technologies that help understand user actions and preferences, such as web beacons / pixel tags / clear GIFs. On web pages, the use of web beacons cannot be directly disabled, but their effect may be limited by changing the settings of the cookies to which they are linked.
5. We may update the types of cookies and technologies we use on the Website from time to time.
6. Managing preferences and cookies in the browser: You have the ability to change the browser settings to delete cookies that have already been set, block the acceptance of new cookies, or receive notifications before they are stored. Review the instructions appearing in your browser or device. Additional useful information can also be found on the Website:
7. Please note: Deleting or not accepting cookies may prevent the use of all or some of the features we offer, prevent the saving of preferences, and cause some of the pages not to be displayed properly.
Collection of information by third parties
1. In the context of the use of the Website, the Company may provide links and references to various websites and pages on the internet, which are operated by third parties (“Linked Websites“), where you may, among other things, receive or purchase various products and services or obtain additional information. You may be asked to register, provide various details, etc., on these websites and pages. Details and registration on these Linked Websites are not subject to the Website’s Privacy Policy, but rather to the privacy policy of such Linked Websites and the provisions of any law. We encourage you to carefully read the terms of use and privacy policy of the third parties with which you choose to share personal information.
Information security
1. The Company implements various organizational, technical, technological and administrative measures to secure our systems and the personal information contained therein. While these measures reduce the risks to the availability, integrity, confidentiality and unauthorized access to your personal information, they do not provide absolute security. We therefore do not commit that the Website will be absolutely immune to unauthorized access to the information stored thereon, and we therefore recommend exercising discretion in choosing the information you provide to us if it is voluntary and not necessary for the purposes specified above.
Data subject rights
1. According to the Privacy Protection Law, every person is entitled to review information about them that is held in a database, either themselves or by their representative who they authorized in writing, or by a guardian. A person who has reviewed the information about them and found it to be incorrect, incomplete, unclear or outdated, may contact the data controller (and if they are a foreign resident – the database holder) in a request to correct or delete the information. If the data controller refuses, they must give notice thereof to the applicant in the manner and by the method determined in the regulations. The data controller’s refusal to allow review and a notice of refusal to correct or delete information may be challenged by the applicant by filing a lawsuit with the court, in the manner and by the method determined in the regulations.
2. In addition, depending on your location and the Privacy Protection Laws applicable to you, you may be entitled to some or every one of the following rights:
  1. Right of access – You have the right to request copies of your personal information from the Company. This right includes receiving confirmation as to whether personal information pertaining to you is being processed, and if so – access to the personal information and the purposes of the Processing; the relevant categories of personal information; recipients or categories of recipients to whom the information has been or shall be delivered; where possible – the expected period of retention of the information; the availability of a right to request correction or deletion of personal information or restriction of Processing or to object to such Processing; a right to file a complaint with a supervisory authority; where the personal information is not collected from you – any available information about the source thereof; the existence of automated decision-making processes, including profiling; and the appropriate safeguards relating to the transfer of your personal information outside the EEA. The Company may charge a nominal fee for this service under certain conditions.
  2. Right to correction – You have the right to request that the Company correct information that you believe is inaccurate. You also have the right to request that the Company add information that you believe is missing.
  3. Right to deletion – You have the right to request that the Company delete your personal information, under certain conditions.
  4. Right to restriction of Processing – You have the right to request that the Company restrict the Processing of your personal information, where:
  5. Right to object to Processing – You have the right to object to the Processing of your personal information at any time – i.e., to stop or prevent the Company from processing your personal information (regarding some or all of the information, and regarding some or all of the Processing purposes). When the Processing is for marketing purposes – the right to object is absolute; with respect to other purposes, the availability of the right depends on the legal basis on which the Processing is based.
  6. Right to data portability – You have the right to request that the Company transfer the information we have collected about you to another organization or directly to you, in a standard format, under certain conditions.
  7. Insofar as the applicable law so allows, you have the right to withdraw your consent at any time when the Company processes your personal information based on consent. However, withdrawal of the consent does not prejudice the legitimacy and validity of the information Processing carried out based on your consent prior to the withdrawal; and does not prejudice any information Processing based on another legal basis aside from your consent.
3. You can exercise these rights, insofar as they apply to you, by sending an e-mail to the Company to: office@reality-fund.com. The Company will respond to your request within the timeframes set forth in the applicable law. Although we will make reasonable efforts to grant your requests, in certain circumstances the Company may determine that your request is unfounded or does not meet the requirements of the applicable law. In such cases, we reserve the right to refuse the request. As a precondition for handling a request, the Company may require verification of your identity, by provision of identification documents or information, to ensure protection of the privacy of all the data subjects.
4. If you believe that the manner in which your personal information is processed does not comply with the requirements of the applicable Privacy Protection Laws, you are, of course, welcome to contact us, and we will examine your request, but you in any event have the right to contact the appropriate enforcement authority. Click here for contact information for the Privacy Protection Authority in Israel: https://www.gov.il/he/pages/public_inquiries_ilita. Click here for contact information for all supervisory authorities in EEA countries: https://www.edpb.europa.eu/about-edpb/about-edpb/members_en.
Information about children
1. The Company places considerable importance on providing protection for children when using the internet. We encourage parents and guardians to observe, participate, supervise and guide their children regarding their online activity. The Company does not knowingly collect personally identifiable information regarding children under the age of 18. If we discover that information about children under the age of 18 has been collected by us, we will remove this information from our records. Additionally, if you suspect that your child has provided information of this type on our Website and you wish to have it removed from our records, please contact us by e-mail at office@reality-fund.com and we will use our best efforts to promptly remove such information from our records.
Changes to the Privacy Policy
1. We may change the terms of the Privacy Policy from time to time. Changes to the Privacy Policy will take effect from the moment the updated Privacy Policy is posted. The last date on which the Privacy Policy was updated will appear at the top of the document, next to the words “Last Updated.” Continued use of the Website after the change in the policy indicates your consent to the revised policy. If you do not consent to the updated version of the policy, you must stop using the Website and any other service provided by the Company.
How to contact us
1. For any questions regarding our Website and the information we may collect about you in the context of your use of the Website, you may contact us by e-mail: office@reality-fund.com.

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