Privacy Policy

At Be The Bank ("we", "us", "our", "the Firm"), we are committed to protecting the privacy and confidentiality of our clients, partners, and website visitors. This Privacy Policy describes how we collect, use, disclose, and safeguard your personal information when you interact with us — whether through our website, in-person meetings, or communication with our team, including Tom Avani and other representatives.

1. Information We Collect

We may collect the following categories of personal data:

• Identity Data: Full name, professional title, company/organization, government-issued identification (for accredited investor verification where required by law).
• Contact Data: Email address, phone number (including +972732073232), and physical address (e.g., 10 Hashalom St., Tel-Aviv).
• Financial & Transactional Data: Information related to private lending, asset management, investment history, and capital sources (collected only with explicit consent and for legitimate financial services).
• Technical Data: IP address, browser type, device information, and usage patterns via cookies or analytics tools when you visit our site.
• Communication Data: Records of your inquiries, emails, meeting notes, and any information you share with our team.

2. How We Use Your Information

We use your personal data for legitimate business purposes, including:

• Providing private lending, asset management, debt advisory, and family office services.
• Responding to your inquiries, scheduling consultations with Tom Avani or other advisors.
• Verifying accredited investor status and complying with Israeli financial regulations (e.g., Israeli Securities Law, Anti-Money Laundering requirements).
• Improving our website, services, and client communication.
• Sending occasional updates about market insights, new opportunities, or events (you may opt out at any time).

3. Legal Basis for Processing (Israeli & International Law)

We process your personal data based on one or more of the following legal grounds: your explicit consent, performance of a contract (e.g., lending or advisory agreements), compliance with a legal obligation, or our legitimate interests in operating a private capital firm and delivering high-quality financial services.

4. Sharing Your Information

We do not sell your personal data. However, we may share information with:

• Professional Advisors: Legal counsel, compliance consultants, auditors, and tax advisors.
• Service Providers: IT hosting, CRM, secure communication platforms, and document management systems.
• Regulatory & Law Enforcement: If required by Israeli law, court order, or to protect our rights, property, or safety.
• Transaction Counterparties: In the context of private lending or investment transactions, only with your explicit authorization and under strict confidentiality.

All third parties are contractually obligated to respect the security of your personal data and process it only on our instructions.

5. Data Security & Retention

We implement industry-standard technical and organizational measures to protect your personal data from unauthorized access, alteration, disclosure, or destruction. Your information is retained only as long as necessary to fulfill the purposes described in this policy or as required by applicable Israeli regulations (e.g., records retention for financial transactions, anti-money laundering laws — typically up to 7 years).

6. Your Data Protection Rights

Depending on your jurisdiction (including under the Israeli Privacy Protection Law, 5741-1981, and the EU GDPR where applicable), you may have the right to:

• Request access to the personal data we hold about you.
• Request correction of inaccurate or incomplete information.
• Request deletion of your data ("right to be forgotten") under certain circumstances.
• Object to or restrict processing activities.
• Data portability (receive a copy of your data in a structured format).
• Withdraw consent at any time (where processing is based on consent).

To exercise any of these rights, please contact our Data Protection Officer using the details in section 8.

7. Cookies & Tracking Technologies

Our website uses essential cookies to ensure proper functionality and security. We may also use analytical cookies to improve user experience. You can manage cookie preferences through your browser settings. For more details, please contact us.

8. International Data Transfers

As a firm operating in Israel and potentially serving international clients, your information may be transferred to and processed in countries outside of Israel. We ensure appropriate safeguards, such as Standard Contractual Clauses or equivalent protections, are in place to maintain data security and your rights.

9. Third-Party Links

Our website may contain links to external sites (e.g., regulatory bodies, financial partners). This Privacy Policy does not apply to those third-party websites. We encourage you to review their privacy policies before providing any personal information.

10. Children's Privacy

Our services are strictly for adults (18+), typically accredited investors, business owners, and professionals. We do not knowingly collect personal information from children under 16. If you believe we have inadvertently collected such data, please contact us immediately for removal.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or operational needs. The latest version will always be posted on this page with the "last updated" date. We encourage you to review it periodically.

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By using our website, engaging with Be The Bank, or contacting Tom Avani, you acknowledge that you have read and understood this Privacy Policy.

If you have any concerns, questions, or requests regarding your privacy or personal data, please do not hesitate to contact Tom Avani directly at +972 73-207-3232 or via email at tom.avani@bethebank.co.il. We are committed to resolving any privacy issues promptly and transparently.