PRIVACY POLICY

1. SCOPE

This Privacy Policy applies to information collected through the Site and to information provided when a person contacts HOLZ through the contact form, the Qualified Client declaration form or directly using the email address displayed on the Site.

HOLZ, Private Capital Partners is the controller of personal information collected through the Site. Privacy enquiries may be directed to the email address set out in Section 15 below.

The Site does not currently provide user accounts, online transactions or payment facilities.

2. INFORMATION PROVIDED DIRECTLY

If you contact HOLZ through the contact form, the Qualified Client declaration form or by email, we may receive information that you choose to provide, including:

• Your name;
• Email address;
• Telephone number, if provided;
• Selected enquiry category;
• Company or organisation details, if provided;
• Professional or business details;
• Israeli identification number, when supplied through the Qualified Client declaration form;
• The eligibility criterion or criteria selected;
• Signer name, date and drawn signature;
• Information included in your communication; and
• Any other information you voluntarily provide.

You are not legally required to provide personal information through the Site. However, without certain information, HOLZ may be unable to respond to an enquiry, consider whether its services may be relevant, or receive and document a Qualified Client declaration.

Please do not submit account credentials, passwords or highly sensitive financial documents through the contact form or unsecured email. An identification number and signature are requested only through the dedicated Qualified Client declaration form, subject to the privacy notice shown on that form.

3. TECHNICAL INFORMATION

When the Site is accessed, limited technical information may be processed automatically by the Site’s hosting and infrastructure providers. This may include:

• Internet Protocol address;
• Browser and device type;
• Operating system;
• Date and time of access;
• Pages requested;
• Referring website;
• General location derived from an Internet Protocol address; and
• Security, diagnostic and performance information.

Such information is generally processed to deliver the Site, maintain security, diagnose technical problems and protect against misuse.

4. PURPOSES OF USE

Information may be used for the following purposes:

• Responding to enquiries;
• Communicating with persons who contact HOLZ;
• Conducting an initial assessment of eligibility and potential suitability for HOLZ services;
• Operating, maintaining and securing the Site;
• Preventing misuse, fraud or unlawful activity;
• Maintaining appropriate business and communication records;
• Complying with legal, regulatory or professional obligations; and
• Establishing, exercising or defending legal rights.

HOLZ will not use personal information for an unrelated purpose unless permitted or required by law.

5. QUALIFIED CLIENT ELIGIBILITY

HOLZ services are offered exclusively to Qualified Clients, in accordance with the Advisory Law.

If a person contacts HOLZ regarding its services, information may be requested or reviewed for the limited purpose of determining whether the person meets applicable eligibility requirements. When a Qualified Client declaration is submitted through the Site, the information is also used to generate a signed PDF, document the declaration and maintain evidence of the eligibility classification.

Contacting HOLZ, providing information or submitting a Qualified Client declaration does not guarantee eligibility and does not create a professional or client relationship.

6. DISCLOSURE OF INFORMATION

HOLZ does not sell personal information.

Information may be disclosed only where reasonably necessary:

• To hosting, technology, email, storage or other service providers supporting the Site or HOLZ’s business operations;
• To professional service providers subject to appropriate confidentiality obligations;
• To banks, custodians, investment managers or other institutions where requested or authorised by the relevant person and appropriate to the contemplated relationship;
• To comply with applicable law, regulation, court order or a request from a competent authority;
• To protect the rights, property, security or legitimate interests of HOLZ or others; or
• In connection with a reorganisation, transfer or succession of the HOLZ business, subject to appropriate protections.

Service providers may process information only for the purposes for which it is provided and subject to applicable contractual and legal obligations.

For the Qualified Client declaration form, the signed PDF is stored in private Cloudflare R2 storage and sent through Resend to an authorised internal HOLZ mailbox. Resend receives the complete signed document for delivery, including the identification number and signature. HOLZ does not expose the document through a public R2 address or public download link.

7. INTERNATIONAL PROCESSING

Certain service providers or institutions may process information outside Israel. In particular, Resend states that customer data and message content are stored in the United States.

Where information is transferred internationally, HOLZ will take reasonable steps to ensure that the transfer is made in accordance with applicable law and subject to appropriate safeguards where required.

8. DATA RETENTION

Personal information will be retained only for as long as reasonably necessary for the purposes described in this Privacy Policy, including responding to enquiries, maintaining business records, complying with legal or regulatory obligations and resolving disputes.

As an operational policy, a Qualified Client declaration that does not lead to a professional relationship and is not relied upon for activity requiring regulatory records will be retained for up to 12 months from submission. If the declaration is relied upon for investment marketing, advice or other regulated record-keeping activity, or if a professional relationship is established, it and the related records will be retained for the period applicable to that activity — including seven years where such a record-keeping requirement applies — unless applicable law requires or permits a different period.

Temporary or technical copies held by external service providers are also subject to those providers’ retention cycles. HOLZ will seek to delete or minimise information once it is no longer required, subject to applicable record-keeping obligations.

9. DATA SECURITY

HOLZ applies reasonable organisational and technical measures designed to protect personal information against unauthorised access, loss, misuse, alteration or disclosure.

No website, electronic communication or storage system can be guaranteed to be completely secure. Users should exercise care when sending information electronically.

10. COOKIES AND ANALYTICS

The Site does not currently use advertising cookies, behavioural-tracking tools or marketing analytics.

The Site’s hosting or infrastructure providers may use strictly necessary technologies or process technical data for security, network operation and delivery of the Site.

The contact form uses Cloudflare Turnstile to distinguish legitimate submissions from automated or abusive activity. Turnstile may process limited technical, browser and device information for security and fraud-prevention purposes.

If analytics, optional cookies or similar technologies are introduced in the future, this Privacy Policy will be updated and any consent mechanism required by applicable law will be implemented.

Users may manage or delete cookies through their browser settings.

11. THIRD-PARTY LINKS

The Site may contain links to third-party websites.

HOLZ does not control the privacy or security practices of those websites. Users should review the relevant third party’s privacy policy before providing information.

12. USER RIGHTS

Subject to applicable law, individuals may have the right to request access to personal information held about them and to request correction or deletion of information that is inaccurate, incomplete, unclear or outdated. Requests concerning a Qualified Client declaration may be submitted to HOLZ using the contact details below.

Certain information may need to be retained where required by law, regulation, professional obligations or legitimate record-keeping needs.

Requests may be submitted using the contact details below. HOLZ may request reasonable information to verify the identity of the person making the request.

13. CHILDREN

The Site and HOLZ services are not directed to children.

HOLZ does not knowingly seek to collect personal information from persons under the age of 18 through the Site.

14. CHANGES TO THIS PRIVACY POLICY

HOLZ may update this Privacy Policy from time to time to reflect changes in the Site, business practices, service providers or applicable requirements.

The updated version will be published on the Site and will take effect from the date stated at the top of the page.

15. CONTACT

Questions, requests or concerns regarding this Privacy Policy may be directed to: