Zion International Properties Ltd.

Website Privacy Notice

Last updated: February 9, 2026

Zion International Properties Ltd (collectively, "ZI", "Company", "We", "Our" and/or "Us") operating the website www.zionistinvestor.com, recognizes the importance of protecting the privacy of your personal information. This Privacy Notice describes how we collect, use, disclose, retain, and transfer personal information, in connection with the operation of our business which includes real estate, marketplace and other related services. It also describes your rights regarding use, access, and correction of your personal information. We act as a "Database Owner" and in some cases, a "Database Holder" as these terms are defined under Israeli law. Personal Information may be requested and collected to deliver our services, to operate our business and to make the experience of using our website and more effectively. This Privacy Notice applies to the extent we process personal information on our own behalf.

By using our website, you consent to the terms of this Privacy Notice and to the processing of personal information for the purposes stated in this Privacy Notice, subject to the principles of proportionality, fairness, and transparency. If you do not agree to this privacy notice, you cannot use our services.

For purposes of this Privacy Notice, "Personal Information" means any information that identifies, relates to, describes, or is reasonably capable of being associated with a particular individual, household, or device. "Sensitive Personal Information" has the meaning given in applicable laws (including IPPL' GDPR and CPRA). "Services" refers to the website, marketplace, and any real-estate related services we offer. "Processing" shall mean any operation performed on Personal Information. When connecting users with third-party real estate professionals or service providers, we act solely as an intermediary platform. Such parties are independent "Database Owners" under Israeli law with respect to information you provide to them directly.

If you are a California resident, please be sure to review the section below specific for California residents for important information about the categories of personal information we collect and disclose as well as your rights under California privacy laws.

1. Scope of Privacy Notice

1.1. This Privacy Notice applies to the collection, use, disclosure, and other processing of personal information related to:

  • 1.1.1. This website, that will allow access to a link to this Privacy Notice including other services, products, and technology solutions we may provide ("Services").
  • 1.1.2. Former, current, and prospective clients, brokers, independent agents, real estate professionals, service providers, and other customers.
  • 1.1.3. Individuals who use our Services, whose personal information we receive related to the Services, and can interact or communicate with us related to our Services or our business.

1.2. The collection, use, disclosure, and processing of personal information about individuals will vary depending upon the circumstances. This Privacy Notice is intended to describe our overall privacy and data protection practices.

2. Collection of Personal Information

2.1. We collect your personal information on a voluntary basis. You are not legally required to provide us with your information, and if you do so, it is voluntary at your own free will with the purpose of using our services and getting access to our Services. If you decline to provide certain personal information that is marked mandatory by us, you may not be able to access certain Services, or we may be unable to fully respond to your inquiry. Failure to provide required information may prevent us from fulfilling contractual obligations or providing requested services.

2.2. We may collect personal information directly from individuals, automatically related to the use of Services, and in some cases, from third parties (such as social networks etc.). In some cases, we ask for your consent or give you certain choices prior to collecting or using certain personal information.

2.3. Information we collect from you directly, may include:

  • 2.3.1. When you complete a form on our website, contact us via email or telephone or attend events hosted or sponsored by us.
  • 2.3.2. Contact information and social network profile data such as your name, address, email and other contact information, as well as any personal data you post or submit through your account.
  • 2.3.3. Information about past and present property purchases and sales and other information you provide such as real estate searches and preferences, whether you plan on buying or selling real estate, home search criteria and preferences, language preferences, household members, information about financing for the purchase of real estate, and other information related to the purchase or sale of real estate.
  • 2.3.4. We may collect purchase and payment information to process payments to or from you, such as your credit card number, direct deposit or financial account number, billing address, and other account information.
  • 2.3.5. When you email, call, or otherwise communicate with us or with members of our team, we collect and maintain a record of your contact details, communications, and our responses. We also maintain records, communications and information that you post in WhatsApp or chat sessions as well as on our social media channels, and information you provide to us related to any customer support requests.
  • 2.3.6. When you participate in promotions that we offer, we will collect your name, age, email address, and other registration information, as well as your responses to any survey questions or other requests.
  • 2.3.7. If you register for or attend an event that we host or sponsor, we may collect information related to your registration for and participation in such event, including name, contact information, and professional affiliations.
  • 2.3.8. When you fill out a "Contact" form, voluntarily signup for our mailing lists, or otherwise request information from us, we collect and maintain records of your requests.
  • 2.3.9. Sensitive Personal Information. We generally request that users refrain from providing sensitive personal information unless explicitly required for service delivery and supported by a clear legal basis. Sensitive personal information includes data concerning health, biometric or genetic data, location data, criminal history, salary information, political opinions, religion, ethnicity, or other information defined as sensitive under applicable law. Where sensitive information such as kosher preferences or health-related accommodations is provided by you for service customization purposes, such information will be processed solely for that purpose and only with your express consent.

2.4. Information we collect from third parties, may include:

  • 2.4.1. Information about you and your property-from third party sources, such as public databases, social media platforms.
  • 2.4.2. If you post information about us or engage with us on third party platforms, or choose to link to or log in to our Services with a third-party account, we may collect personal information about you from that third party platform or account. We may also collect other information that you share or make public on your account.
  • 2.4.3. Information about real estate property through public databases, such as property ownership, purchase and sale transactions and data (including purchase/sale price) buyer and seller names and contact information, and tax records maintained by state, local and county agencies.

2.5. Information we collect from you automatically, may include:

  • 2.5.1. Personal data related to your use of our Services, including information we collect automatically (e.g., using cookies and pixel tags).
  • 2.5.2. Information when you visit our website or access our Services, such as IP address, general location information, domain name, page views, a date/time stamp, browser type, device type, device ID, Internet service provider, referring and exiting URLs, operating system, language, clickstream data, and similar device and usage information.
  • 2.5.3. Information related to your use of the Services, such as information about the links clicked, searches, properties viewed, features used, items viewed, time spent within the Services.
  • 2.5.4. Information about you based upon the other information we have collected, such as whether you may be interested in selling or buying a home and what types of homes you may be interested in purchasing.

3. Purpose of Use & Legal Basis for Processing Personal Information

3.1. Certain laws, including the Israeli Protection of Privacy Law 5741-1981 ("IPPL"), the Protection of Privacy (Data Security) Regulations 5777-2017, the EU General Data Protection Regulation ("GDPR"), the UK General Data Protection Regulation ("UK GDPR"), and similar laws require that we inform applicable individuals of the legal bases for our use and other processing of their personal information. We process personal information only where we have a valid legal basis to do so.

3.2. As such, we collect, use, and otherwise process personal information for the following legal bases, with your consent where required under applicable law, including the IPPL.

  • 3.2.1. As necessary to enter or carry out the performance of a contract with you.
  • 3.2.2. For compliance with legal obligations and/or defense against legal claims.
  • 3.2.3. For our legitimate business interests, such as:
    • Performance of contracts
    • Technical support
    • Customer relationship management
    • Improving our services, including marketing and analytics
    • Advertising
    • Fraud prevention
    • Network security
    • Internal compliance
    • Mergers, acquisitions, and reorganization, and other business transactions
    • To protect personal interests of any individual under threat
    • To provider real estate services
    • Analyzing our business and understanding user behavior
    • To personalize online content
    • To measure and improve ad campaigns
    • To secure and protect our business
    • To protect our legal rights
    • For auditing, reporting, corporate governance, and internal operations
    • To comply with our legal obligations

4. Sharing and Disclosing Personal Information

4.1. We may disclose the personal information that we collect to third parties, as reasonably necessary for the purposes described above or as otherwise directed or consented to by you, including:

  • 4.1.1. To third-party service providers who use this information to perform services for us.
  • 4.1.2. To third parties who provide our Services, facilitate your requests, and/or with your acknowledgement and consent, including to independent real estate professionals and owners of real estate brokerage companies.
  • 4.1.3. If we are required to do so by law or legal process (e.g., to law enforcement, courts or others, e.g., in response to a subpoena or court order).
  • 4.1.4. Where we believe it necessary to respond to claims asserted against us or, comply with legal process (e.g., subpoenas or warrants), enforce or administer our agreements and terms, for fraud prevention.

5. Aggregated & Non-Identifiable Data

We may use and disclose aggregate, anonymous, and other non-identifiable data related to our business and the Services for quality control, analytics, research, development, and other purposes. Where information is aggregated or anonymized such that it can no longer identify an individual, it is no longer considered personal information under this Privacy Notice.

6. Cookies, Tracking & Analytics

Our Services use first, and third-party cookies, pixel tags, log files, analytics tools, and similar technologies to collect device, usage, and browsing information when you visit our websites, including IP address, browser and device details, pages viewed, links clicked, and activity timestamps. We use this information for security, navigation, analytics, service optimization, personalization, and advertising performance. You can learn more about these technologies and manage most cookie preferences (except those strictly necessary) through the "Cookie Preferences" link in our website footer or by adjusting your browser settings, noting that disabling cookies may affect site functionality; Also, please view our Cookie Notice which is an integral part of this Privacy Notice. Pixel tags may be used on our websites and in emails to track actions and response rates, and third-party analytics tools such as Google Analytics may collect usage trends, with opt-out information available at Google's online privacy center.

7. Social Media

Some of our Services may integrate with social platforms and their features which let you log in to the Services or share actions you take on the Services. Your use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the social sharing service. Please refer to the privacy policies of those social sharing services for more information about how they handle the data you provide to or share through them. We do not receive or store passwords to your third-party social media accounts in this context.

8. International Data Transfers & Personal Information

We are headquartered in the State of Israel. Under Israeli law, we process personal information in accordance with the IPPL and applicable regulations. As such, We and Our service providers may transfer your personal information to, or access it in, jurisdictions, including the United States and possibly to other jurisdictions which may not provide the same level of protection under your local data protection laws. Where we transfer personal information into, or outside of Israel, we implement appropriate safeguards in accordance with applicable law, and we ensure that the recipient is obligated to maintain an adequate level of protection consistent with Israeli law, including by contract where required.

9. Data Protection & Data Security

9.1. We use technical, administrative, and physical controls in place to help protect personal information from unauthorized access, use, and disclosure, in accordance with the Protection of Privacy (Data Security) Regulations, 5777-2017. These measures include access controls on a need-to-know basis, logging of security events, regular backups and recovery procedures, and periodic audits. We maintain a database definition document and information security policy as required by law. Even so, despite our efforts, no security measure is ever perfect or impenetrable. If the security of your account has been compromised, please immediately notify us.

9.2. In the event of a serious security incident involving the disclosure of personal information or a risk of harm to data subjects, the Company will:

  • 9.2.1. Notify the Israeli Privacy Protection Authority without undue delay regarding the incident and the measures taken;
  • 9.2.2. Notify affected data subjects who may be harmed by the incident, detailing the information exposed and providing guidance for self-protection;
  • 9.2.3. Document the incident and response in a dedicated security incident management system;
  • 9.2.4. Conduct a comprehensive investigation of the incident and implement lessons learned to prevent recurrence.

9.3. Data Privacy Officer (DPO). The Company has appointed an DPO. The DPO is responsible for implementing and monitoring privacy and supervising, reporting incidents, training employees, and conducting internal audits. Contact details for the Information Security Officer are available upon request.

10. Data Retention

10.1. We will retain your personal information except for the following circumstances: (i) the information is no longer necessary for the purpose for which it was collected; (ii) consent has been withdrawn and there is no other legal basis for processing; (iii) processing is alleged to be unlawful; or (iv) you expressly request removal from our databases (particularly regarding direct marketing). However, information may be retained where: (i) required for legitimate business purposes, archiving, research, or statistics (subject to appropriate safeguards); (ii) there is a legal obligation to retain it; (iii) required to protect vital interests of the data subject or another person.

10.2. We will need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion. There may also be residual information that will remain within our databases and other records, which will not be removed. We may not always be able to fully address your request, for example if it would impact the duty of confidentiality we owe to others, or if we are legally entitled to deal with the request in a different way.

10.3. The Company will not process personal information for purposes that exceed or differ from those communicated to the data subject at the time of collection, unless a new legal basis exists and the data subject is informed accordingly.

11. Data Subject Rights

11.1. We provide several ways for you to exercise certain privacy choices regarding your personal information processed by us, as described in this section. We are committed to respecting the privacy rights of individuals under all privacy laws applicable to us, including the IPPL. Your data subject rights are as follows:

  • 11.1.1. Right to Lodge a Complaint. If you believe your rights have been violated, you have the right to lodge a complaint with the Israeli Privacy Protection Authority or your applicable data privacy regulator. Under the IPPL, a data subject may file a civil claim against anyone who violates the law and may receive monetary compensation even without proof of damage, up to the amount specified in the law.
  • 11.1.2. Right to Data Minimization and Proportionality. The Company collects and processes only the personal information necessary to provide the requested services, in accordance with the principle of proportionality.
  • 11.1.3. Right to Restrict Processing. You may request restriction of processing in situations such as dispute regarding accuracy of information, unlawful processing, or pending complaint.
  • 11.1.4. Right to Data Portability. Where processing is based on consent or contract, you are entitled to receive your personal information in a commonly used format.
  • 11.1.5. Right to Withdraw Consent. You may withdraw your consent to processing at any time where processing is based on consent.
  • 11.1.6. Right to Object to Direct Marketing Mailings. You may withdraw consent and object to use of personal information for direct marketing purposes at any time.

12. Minors

Our websites are not directed to children under the age of 18 ("Minors"), and we do not knowingly ‎collect any information, including personal information from Minors.‎‎ We do not collect information from Minors on our own initiative, and any information provided regarding minors is provided solely by the parent or legal guardian. We do not contact minors directly for marketing purposes and do not send them promotional materials of any kind.

13. Third-Party Websites

Our website may contain links to third-party services. We do not own, operate, or control the websites of third-parties, including those of independently owned and operated franchisees. Accordingly, this Privacy Notice does not apply to any services maintained or operated by third-parties. When you click on those links, you will go to a third-party website where you will be subject to that third-party's privacy policy or similar statement and terms of use, and we encourage you to read that policy statement. We are not responsible for the privacy practices of other third-party services, and we expressly disclaim any liability for their actions, including actions related to the use and disclosure of personal information by those third parties.

14. Amendments to the Privacy Notice

We may amend this Privacy Notice at any time. If we make any material change in how we collect, use, disclose, or otherwise process personal information, we will prominently post a notice regarding such change on our websites or by other means we deem appropriate. Where a change materially affects the purposes for which Personal Information is processed, we will provide renewed notice and obtain consent where required under Israeli law. Any material changes to this Privacy Notice will be effective 10 days after our posting of the updated Privacy Notice or as otherwise required by applicable law. Where required to do so by law, we may seek your prior consent to any material changes we make to this Privacy Notice.

15. Contacting Us for Correcting or Updating Personal Information, and exercising Your Data Subject Rights

You may contact us through the methods stated below for a number of purposes, including to unsubscribe from any ‎industry updates and mailing list; to receive ‎information or special offers; to provide feedback and comments; to ‎request access to your personal information, deletion of your incorrect personal information or ‎correction of your personal information; and to make inquiries whether we hold or process on ‎behalf of a third party, any of your personal information or complaints/objections regarding our ‎Privacy Notice and/or privacy practices.

We will respond to your request within a reasonable timeframe, but in no event later than 30 ‎days, or such lesser period prescribed by applicable law. In complex cases, we may extend the response period by an additional 30 days with advance notice to you.

If you are in Israel, you also have the right to lodge a complaint with the Israeli Privacy Protection Authority (Registrar of Databases) if you believe we have not complied with applicable Israeli privacy laws. The Authority's contact details are available at: https://www.gov.il/en/departments/the_privacy_protection_authority.

16. Notice to Residents of Other Jurisdictions (Such as California)

16.1. Certain privacy laws around the world give individuals additional rights regarding their personal information. These rights apply only if the relevant law covers our activities. We may fall below the thresholds for full applicability or enforcement in some jurisdictions (including under the California Consumer Privacy Rights Act ("CPRA"); however, we provide the following information in the interest of transparency and good practice.

16.2. Residents of the EEA, UK, and Switzerland. If you are in the European Economic Area (EEA), the United Kingdom, or Switzerland, you may have rights under applicable data protection laws (such as the GDPR), including the right to access, correct, delete, restrict, or object to the processing of your personal information, the right to data portability, and the right to withdraw consent. You may also lodge a complaint with your local supervisory authority. We encourage you to contact us first so we can try to resolve your concern. We commit to cooperating with data protection authorities and complying with their guidance regarding resolution of complaints.

16.3. California Residents. If you are a California resident, you may have rights under the CPRA, including the right to request access to the personal information we collect about you, to request correction or deletion, to opt out of "sales" or "sharing" of personal information (as defined by the CPRA), and to limit the use of "sensitive personal information". We do not knowingly sell personal information for monetary compensation; however, certain cookies or analytics tools may be considered "sharing" or "selling" under California law. You may opt out of such activity by using the "Cookie Preferences" link in our website footer, which we will honor for that browser. We will respond to verifiable requests as required by applicable California law and may ask for information needed to confirm your identity. The following chart summarizes the categories of Personal Information we may collect, the purposes for which we use them, and whether we "sell" or "share" them as those terms are defined under CPRA:

  • 16.3.1. Identifiers (e.g., name, email, phone): Used for account creation, communication, and service delivery.
  • 16.3.2. Commercial Information (e.g., property searches, purchases): Used for service delivery and internal analytics.
  • 16.3.3. Internet/Device Activity (e.g., cookies, IP address): Used for analytics, security, and site performance. Considered "shared" under CPRA when third-party cookies operate.
  • 16.3.4. Sensitive Personal Information: Only collected when voluntarily provided.
  • 16.3.5. Geolocation (approximate): Used to personalize listings; may be shared for analytics.
  • 16.3.6. Inferences: Used to personalize services.

If you are a California resident, you may instruct us to limit the use and disclosure of your Sensitive Personal Information to those uses authorized by CPRA by contacting us at info@zionistinvestor.com. To protect your Personal Information, we will verify your identity before fulfilling access, deletion, correction, portability, or opt-out requests by using reasonable verification steps based on the type and sensitivity of the information.

16.4. Residents of Other U.S. States. Some U.S. state privacy laws may grant additional rights such as access, correction, deletion, portability, and the ability to opt out of targeted advertising or certain types of processing. Where these laws apply to our activities, we will honor such requests in accordance with applicable state law requirements and verification procedures.

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