This Privacy Policy (the “Privacy Policy“) details how we at G City Ltd. (“G City“, “we”) process personally identifiable information, as defined below (“Personal Information”) and constitutes an integral part of the Terms of Use available here (hereinafter collectively the “Terms”). In this policy, “Personal Information” means data relating to an identified or identifiable individual. Terms not defined herein shall have the meaning ascribed to them in the Terms of Use.

This Privacy Policy applies to Personal Information collected and processed by G City and/or anyone on its behalf, including when using our website at https://g-city.com, landing pages, and other digital assets (the “Website”), when visiting G City complexes, and in any communication with G City, including via phone, email and regular mail, text messages, social networks, and face-to-face conversations (the “Services”).

For the purposes of this Privacy Policy, the “User”, “you”, or “your” means any person using the Website or its content, visiting G City complexes, and/or contacting G City as stated.

Please note that, as a rule, you have no legal obligation to provide G City with any information or to allow the collection of information. However, failure to provide certain information may prevent us from providing you with some of the Services. If you do not agree with the processing practices detailed herein or with any of the Terms of Use (including this Privacy Policy), you must cease making any use of the Services, including the Website, the content therein, G City complexes and sites, and/or abstain from entering G City complexes and sites.

Without derogating from G City’s rights under applicable law, your consent herein regarding “Information” as defined in the Protection of Privacy Law, 5741-1981 (the “Privacy Protection Law”) shall also apply to other data related to an identified or identifiable individual and to any other information.

Our Privacy Policy is intended to describe our privacy practices in 10 sections written in plain and clear language. Please read them carefully and contact us if you have any questions.

1. How is Personal Information collected?

• Personal Information provided by the User: This collection method is relevant when users provide G City with certain data or information (such as their contact details in the relevant fields of the Website), which may be retained and used for the purposes detailed herein (not only to respond to user requests). Examples of such data: “Name”; “Company”; “Email address”; “Phone number”; subject of the inquiry (e.g., investor relations, collaborations, leasing, press releases, legal, etc.), details listed in a message provided by you, etc. You declare and warrant that all data and/or Personal Information provided by you or available to G City is true, accurate, complete, and is provided by you in accordance with the law.
• Personal Information collected automatically: Certain Personal Information or data may be collected automatically during the use of the Website. Such data may consist of information about a device and its use, device name, IP address, usage analysis, crash and error reports, browser and device characteristics, operating system functionality information, language preferences, URLs, location, information about how and when you use the Website and your internet usage before and after such use, content preferences, other technical information, and/or data that may not necessarily be linked to you.
• Parking Lots: When using G City parking lots, we collect and process Personal Information about parking lot visitors, as detailed below:
  • Information obtained from security and operational cameras: Security and operational cameras are installed in G City parking lots, recording the parking lots 24 hours a day (24/7). These cameras operate a License Plate Recognition (LPR) system that records the license plate numbers of vehicles entering and exiting the parking lot, as well as their entry and exit times. G City uses this information for providing, operating, and improving parking services, responding to inquiries received regarding parking lot services, and for the security purposes of G City parking lots and maintaining public safety. This information is retained for 30 days and will be transferred to third parties only in accordance with the provisions of the law.
  • Payment details: When paying for parking services, the license plate number, parking times (arrival and exit from the parking lot), the location of the parking lot used, and the payment method details, including the name of the payment method owner, are collected. The name of the subscriber is also collected from subscribers. G City does not typically retain payment method details (except for the last four digits of the credit card and the date of the transaction) in its databases. The clearing services are performed via third parties who retain the information securely in their databases in accordance with their respective privacy policies. In this context, we note that these third parties may use Personal Information about you as part of the clearing services they provide, for research and analysis, and to support, provide, and develop the services of those third parties.

2. How might G City use Personal Information?

G City uses Personal Information in order to:

• Manage its business operations, including the customer club;
• Operate the complexes it owns, including Wi-Fi services;
• Facilitate your use of the Website and to respond to your inquiries, resolve any potential problems you may have with the use of the Website, and for other legitimate business purposes while improving your user experience and that of other Website users;
• Make Website content available to you and update you regarding G City projects, products, and services;
• Enforce and/or protect our legal and/or other rights, property, and/or interests, and to protect the safety of Website users and/or visitors to the complexes and/or any other person and/or entity associated with G City;
• Comply with and evaluate compliance with laws, rules, regulations, judicial decisions, internal policies, and procedures applicable to users;
• Send you content, information, and data that we believe may be of interest to you, such as data regarding G City, the Website, and information about our achievements and policies;
• Conduct ongoing testing, improvement, and development of the Website, content services, and/or our products, including measuring and analyzing Website usage levels, assisting in diagnosing server problems, and managing the Website. It should be clarified that we treat IP addresses, server log files, and related information that does not personally identify you as non-Personal Information, unless we are required to do otherwise by law;
• Ensure information security. These purposes include conducting the analysis required to detect malicious data and understand how it might affect the user and/or G City’s IT system, for the purpose of monitoring and statistical analysis of ongoing attacks on devices and systems, and for the ongoing adaptation of solutions provided to secure devices and systems against various attacks.

3. Security Cameras

Security cameras are stationed at G City complexes, and in certain cases, body cameras mounted on security guards on its behalf are also used. These cameras record what is happening at all hours of the day (24/7). The information collected by the security cameras may include images of customers and/or passersby and/or visitors to G City complexes and/or vehicles entering and exiting the parking lot complexes. G City uses the security cameras in order to:

• Serve security, safety, and guarding purposes, including the protection of contents and property located in the complexes.
• Provide customer service for the complexes (for example, through payment collection carried out by parking management and traffic control systems).
• Monitor the use of the company’s facilities, services, and products it offers and/or that are offered in the company’s complexes, to manage them (including collecting payment for them), and to improve them.
• Maintain the legitimate interests of the company (for example, preventing vandalism and locating its perpetrators, detecting fraud and/or infringement of rights, etc.). Prevent unauthorized access to these complexes, prevent offenses, infringement of rights, and/or causing damages in connection with these complexes and those present within them.
• Comply with the requirements of the law and/or law enforcement authorities and/or enforce the rights of the company and/or the rights of others (at its discretion).
• Secure sensitive personal information, business information, and the systems used to manage them.

4. Disclosure and/or Transfer of Personal Information to Third Parties

G City may transfer Personal Information to third parties for the following purposes:

• For the purposes listed in the Terms of Use.
• To provide and contact you via direct mailing (as defined in the Privacy Protection Law) (“Direct Mailing”) and advertisement as defined in the Communications Law (Telecommunications and Broadcasting), 5742-1982 (“Advertisements”), which includes content relating to data and/or content that G City believes may be of interest to you.
• In the event that G City merges with a third party or is acquired by a third party, in whole and/or in part, and/or enters into a contract with a third party to offer and/or sell assets and property rights in whole and/or in part.
• To respond to your inquiries, and to resolve any potential problems you may have in using the Website and for other legitimate business purposes that G City may have.
• To send you information regarding the Website and changes to it, as well as information about updates to G City’s Terms of Use, procedures, and policies.
• To enforce and/or protect the legal rights, property, and legal and/or other interests of G City and/or of any third party, and the safety of users, or any other person or entity.
• If required by law and/or a competent authority and/or a judicial order.
• To comply with and examine compliance with laws, rules, regulations, judicial decisions, internal policies, and procedures applicable to users.
• For the security purposes of G City complexes and sites, prevention of offenses, and infringement of rights.

5. Use of Data Collection Technologies

G City may use a variety of data collection technologies such as cookies (“Cookies”), Flash, Web Pixels, Web Beacons, and/or other tracking technologies (hereinafter collectively: “Data Collection Technologies”). In certain cases, Data Collection Technologies are stored on your device and/or computer and may be used, among other things, to verify information, secure information, select the content displayed to the user, and automatically activate certain features. In most cases, Data Collection Technologies store information that does not directly identify the user, such as the web pages and other sites the user has visited, the duration of their search, etc. In some cases, the Data Collection Technologies are installed in the user’s own browser. Although modern web browsers include the option to avoid receiving “Cookies” and the option to delete existing “Cookies,” it should be noted that choosing not to allow the receipt of “Cookies” or alternatively deleting existing “Cookies” may impair your enjoyment of using the Website. In addition, the deletion of said Data Collection Technologies or the user’s choice not to allow their storage or the alteration of Flash characteristics may result in a limited experience on the Website (in whole or in part). We may use Data Collection Technologies for advertising and remarketing purposes, on the Website and on the internet in general (via AdWords or other products/services). We may also use services such as “Google Reports” on social media referrals and “Analytics Reports” on demographic data and interests, “Facebook Pixel” to personalize advertising on social media, etc. It should be noted that third parties used by G City to operate the Website may also use Data Collection Technologies. The user acknowledges that this Privacy Policy does not address the activities of these third parties or the contents to which links and/or references to other websites lead, and G City is not responsible for any outcome caused by their use or reliance upon them. Therefore, it is suggested that the user review the terms of use and privacy policy on the websites of those third parties, which are provided below for your convenience only, and G City assumes no responsibility for their being up-to-date. Such third-party Data Collection Technologies may include Google and Facebook technologies, for analyzing the use of the Website, content, and/or services/products of such third parties and for personalized advertising purposes. The services/products of these third parties may include Google Firebase, Google Analytics, and Google Tag Manager. For more information regarding Data Collection Technologies used by some of the third parties, please refer to the links provided below for your convenience:

• https://www.facebook.com/policies/cookies
• https://policies.google.com/technologies?hl=en

These links can also be used to find information about the options the companies offer you to manage their use of “Cookies,” including the option to opt-out of the use of these tools, for example through the following sites:

• http://www.aboutads.info/choices/
• http://www.youronlinechoices.eu/

You can also choose to use the Google Analytics opt-out browser add-on.

6. Commercial Content

When you provide or make Personal Information available to G City, you hereby confirm and agree to receive advertisements, ‘newsletters’, surveys, and other promotional messages from G City via various types of media, including email and/or SMS and/or MMS and/or fax and/or phone and/or recorded message and/or mail, Direct Mailing, Advertisements, and/or other means of communication. By agreeing to subscribe to the Direct Mailing service, you waive any claim and/or demand regarding the receipt of Direct Mailing of any kind, whether from G City and/or from third parties acting on its behalf, until after the user requests to be removed from the Direct Mailing service and receives confirmation of removal from the mailing list as detailed below. If necessary, you may indicate that you do not wish to receive any communication from G City. Furthermore, you may request at any time to be removed from G City’s mailing lists by getting in touch using the contact details provided below.

7. Information Security

G City takes various measures to protect and secure Personal Information and implements what it considers to be commercially reasonable technical and administrative security measures designed to protect Personal Information. However, it should be noted and clarified that no method of transmitting information over the Internet, or method of electronic storage, is 100% secure or protected. Therefore, and as stipulated in the Terms of Use, the user’s use of the Website and the content is at the user’s sole risk, and if you believe that your Personal Information may have been compromised, please notify us immediately by contacting us using the details below. G City makes efforts it deems reasonable to prevent prohibited data scraping from the Website. The user acknowledges the risk of data scraping on the Internet and agrees to use the Services while aware of this risk.

8. Changes to the Privacy Policy

G City reserves the right to change its Privacy Policy from time to time and at its sole discretion. Therefore, the user is advised to review the Privacy Policy frequently to keep track of any changes and updates that may be published. Changes and clarifications to the Privacy Policy will take effect immediately upon their publication on the Website.

9. User Rights

The user may, under certain circumstances, be entitled to review the information held by G City regarding the information about them, in accordance with Section 13 of the Privacy Protection Law, 5741-1981, and you may also have the right to request the correction or deletion of Personal Information collected about you if you find that it is incorrect, incomplete, unclear, or outdated in accordance with Section 14 of the said law. For more information, you can contact us on the matter using the contact details below, and we will act to respond to you within a reasonable time.

10. Transfer of Information Outside Israel

Personal Information may be stored/processed in Israel, in European Union member states, in EEA member states (Norway, Liechtenstein, and Iceland), and in the UK (collectively, the “EEA”), and in countries offering an equal level of data protection within the framework of or subject to adequacy decisions published by the relevant data protection authorities, and without the need for additional protection. However, in certain cases, G City may store or process Personal Information outside of Israel, the EEA, or such countries with adequate protection. Please note that such jurisdictions may have legislation that protects or provides less security for your privacy rights, and you hereby give your consent to such transfer/processing. You consent to the transfer of your Personal Information to countries outside your country of origin, which may have different data protection rules than your country.

11. Questions and Contact

For questions, requests, and any other inquiry, you are welcome to contact G City using the details in the “Contact Us” tab or using the details below, and G City will act to handle your inquiry as required and in accordance with the law. To contact by mail, please send to G City Ltd., 8 Aharon Becker St., to the Legal Department; to contact by email, please send to [email protected].