Privacy Notice

Privacy Policy

Phase2 Partners Ltd., Company Registration No. 515320471, a member of the Ruby Capital Group (hereinafter: “the Company” or “we” or “us“) respects your right to privacy. Your ability to make informed decisions regarding the use of your information is important to us. The purpose of this privacy policy (hereinafter: “Privacy Policy“) is to explain the Company’s policy and guidelines relating to Personal Information (as defined below) collected when you use our website and services (as defined below) and how the Company collects, uses, transfers and secures the personal information collected by it. Our website (hereinafter: “Website“) is intended to provide you with information about the Company, its products and services and to facilitate contact with the Company (hereinafter, including the Website: “Services“).

Your use of the Services and/or your approval of the Terms of Use and this Privacy Policy constitute your consent and approval to the terms of this Privacy Policy.

Terms in this document that are not explicitly defined shall be interpreted according to the definitions given to them in the Terms of Use, published at https://bit.ly/40MBHbb (hereinafter: “Terms of Use”). The terms “you” or “your” appearing in this document refer to any user of the Services. For any question or problem related to the Privacy Policy, you may contact: office@rubycapital.com.

“Personal Information” means information related to a person such as name, address, telephone number or email address or as defined by law.

The personal information will be stored in the Company’s databases, which owns and controls the databases. You are not under any legal obligation to provide us with personal information; providing personal information is done with your consent. However, if you do not agree to provide personal information, in whole or in part, some Services may not be available to you.

1. Information we collect. We collect information as necessary and according to your use of the Services, and the collection of personal information depends on the type of Services you use, as follows:
   • Inquiries and/or contact. When you contact us with a request and/or question, we may record our communication with you and thereby any information you volunteer to us, such as your name, telephone number, email address, and content of the request or question.

• Participation in conferences. We will collect any information you provided to us when you contacted us and/or provided us with personal information in the context of your participation in a conference, lecture or other framework.

• Information collected automatically. When you use the Website, certain information may be automatically collected about your computer or mobile device, including non-Personal Data, such as your operating system, and Personal Data such as your IP address, device ID, as well as your use and/or browsing history and any information regarding your use, viewing history on our Site.

2. How we use the information. You hereby agree and confirm that the company may store information collected about you, including Personal Data, in its databases. We will maintain the databases in accordance with applicable law, and use the databases as stated in the Privacy Notice, including for the following purposes:

• Services and customizations. We and/or our service providers will use your personal information for the following purposes: (1) providing access to the Services; (2) providing support and assistance in solving problems that you or other users may encounter; (3) to contact and communicate with you; (4) examining questions that arise, including through the Services and providing responses accordingly; and (5) preventing fraud attempts and protecting the security of the Services and providing responses in connection with the Services.
• Internal operations and improvements. We may use your personal information for internal business purposes, including: diagnosing and resolving technical problems, conducting internal reviews and evaluations, developing and improving our Services and content, improve our Website and Services and adapt them to meet our needs and/or the needs of the users, analyzing usage patterns and volumes, conducting financial assessments and forecasts, evaluate the potential use by our customers, use for research purposes and development activities, adjust the server capabilities to the expected scope of work, and review the usage and operations of our Website and Services.

• Statistical data and analytical tools. We and/or our service providers use analytics tools to collect and analyze information about the use of the Website and/or Services, such as how often users visit the Website, what pages they visit when they do so, and what other websites and applications they used prior to visiting the Website. By analyzing the information we receive, we may compile statistical information across a variety of platforms and users, which helps us improve our Website and Services, understand trends and customer needs and consider new services, and tailor existing services to customer desires. The data we collect is aggregated and anonymous and we will not connect it to any Personal Data. We may share such aggregated and anonymous data with third parties, without limitation, under commercial terms at our sole discretion.

• Marketing communications. We may use Personal Data collected about you to contact you with informational newsletters and promotional materials relating to our Site and Services if you have provided your consent. You may withdraw your consent by following the unsubscribe link in any communication we send you.

3. Sharing your personal information. You authorize that we will share your personal information in accordance with the following:

3.1. Service providers and third parties.

3.1.1. Third parties which provide the Company with various services including, among others, support services for security systems and information technology (IT) systems, information storage services including cloud providers, website building services, survey services, lawyers or other external professional consultants, as well as other third parties which provide services to the Company

3.1.2. International data transfers. The Company may transfer personal information to,and/or store personal information with, third parties, including outside the State of Israel, including in countries where the level of protection of personal information differs from Israeli law. Without derogating from this Privacy Policy, your approval of this Privacy Policy constitutes your consent to the transfer, storage and processing of personal information with third parties, some of whom may be located outside the State of Israel.

3.2. Transfer of ownership. Transfer of ownership can occur in cases of transfer and/or sale and/or assignment and/or acquisition of the Company and/or its assets and/or any part thereof, with or without consideration, including cases where ownership of the Website and/or its contents, in whole or in part, will be transferred to third parties, including but not limited to merger of the Company and/or its activity with third parties, and including without derogating from the generality of the above, in cases of change of control, full or partial, in the Company as well as in cases where the Company examines feasibility for the cases mentioned above.

3.3. Disclosure to law enforcement and legal compliance. We will cooperate with law enforcement authorities and comply with any judicial order that requires or instructs us to disclose the identity, conduct, digital content, or any other personal information of any user suspected of engaging in actions that appear to be contrary to law or that violate the law. We may also share your personal information with third parties if we believe in good faith that such disclosure is appropriate and intended to protect our rights, property or safety (including enforcement of this Privacy Policy) or the rights, property or safety of third parties.

3.4. Transfer of information between corporations in Ruby Capital Group. For the purpose of this section “Ruby Capital Group” means Ruby A.A.G Holdings Ltd., Ruby Equity Holdings Ltd. and/or any corporation controlled by either of them. Personal information may be shared between corporations in the Ruby Capital Group.

3.5. Additional lawful disclosures. We will share your personal data with relevant third parties in cases where: (1) we discover that any action you have taken in the Services violated the Terms or was done to commit fraud; or (2) the Company believes that providing the information is required in order to prevent harm to the Company, to the user or to any third party; for the purpose of managing legal proceedings; if an instruction, including a court order, is received ordering the Company or anyone on its behalf to provide user details or information about the user; or to comply with applicable law.

4. How we protect the information. We operate according to industry-accepted standards in order to protect the information, both during its transmission and once we receive it.. However, transmission via the Internet or electronic storage are not completely secure. Therefore, there cannot be an absolute guarantee for the security of personal information.

5. Your data protection rights. Under Israeli Privacy Protection Law 5741-1981, you and anyone on your behalf have the following rights regarding your personal information: (a) Right of access: You and anyone on your behalf may request to review the personal information we hold about you; and (b) Right to correction: You may request correction of inaccurate, incomplete, unclear, or outdated personal information. To exercise these rights or for questions regarding this Privacy Policy, please contact us at: office@rubycapital.com.

6. Data retention. We retain personal information as long as necessary for: (1) the purposes set forth above; (2) compliance with our legal obligations; (3) resolving disputes; (4) enforcing our agreements; or (5) longer periods of time, for instance where we are required to do so in accordance with legal, regulatory, tax, audit, and accounting requirements or to keep documentation of your actions to handle various complaints or if we have reason to believe that legal proceedings related to your data and/or actions in the Services may take place.

7. Information about third parties. If you provide information to the Company regarding third parties, you declare and undertake that you have received explicit written consent from that third party for the collection, processing, storage and transfer of the information in accordance with this Privacy Policy provisions and that the Company may receive, store and process that third party’s information in accordance with the Privacy Policy.

8. Cookies. The Company may use automatic information-gathering tools, including cookies, pixels, SDKs, beacons, tags and similar technologies that are sent to the device from which the user browses and automatically store various information files on it (hereinafter collectively “Cookies“). Without derogating from the above, if a user chooses to provide identifying information on the website, this information may be linked to non-identifying information collected on the website.

 he Cookies contain and collect various information such as the pages the user visited, the duration the user spent on the website, information the user viewed on the website, where the user came from to the Website, the user’s IP address (i.e., the user’s computer address on the Internet), number of entries to the Website, characteristics of the user’s device or computer including screen resolution, operating system type and version, internet browser type, version and language preference, domain names and more.

The Company or third parties operating the Cookies may access the information accumulated in the Cookies from time to time and such information may be stored on the Company’s and/or third parties’ servers.

The Company uses Cookies for the following purposes (some or all): (1) routine operation of the Website; (2) data collection regarding Website use; (3) improving browsing experience; (4) statistics, marketing and commercial purposes; (5) information security; and (6) content customization including marketing content that may interest the user, even when the user browses other websites.

Cookies are text files that the user’s browser creates according to command. Some cookies expire when the browser or relevant application closes, and others are stored on the user’s device or computer memory or sent to the Company for providing services, as detailed above.

The Company takes reasonable measures to ensure that the Company’s computers or anyone on its behalf can read and understand the information stored in them. However, it should be clarified that when dealing with cookies created or operated by third parties, the use and information collected through such cookies is subject to those third parties’ privacy policies. The Company has no control over the data stored in them and access to information, or its cross-referencing with additional information details, and such uses are subject to those third parties’ privacy policies. The Company has no control over those third parties’ policy documents or how they implement them.

Examples of use of third-party cookies –

The Company uses Google cookies, such as those embedded through the use of Google Analytics, which help customize the browsing or usage experience for users and derive statistical insights regarding use of the Website. The use of Google Analytics is subject to Google’s relevant privacy policy.

The Company uses various analytics tools and advertising systems of Google Ads, Facebook, etc. as tools to measure Website usage characteristics, measure the effectiveness of advertising campaigns, and select audiences for campaigns. Additional information about these tools can be found, inter alia, in the cookie policies of those advertising systems.

A user who does not want cookies collected on their device can avoid this by changing the settings in the device’s browser. For this purpose, you can refer to the browser’s help file.

Deletion of cookies may cause certain website services to become unavailable or result in degradation of their quality. For the avoidance of doubt, deletion of existing cookies does not affect information previously stored in cookies by the Company or third parties. Additionally, and notwithstanding the above, cookies that are essential and necessary for the Website operation and management cannot be disabled.

9. Third-party services. Some of our Services include use of third-party services and applications. Any use of these third party services is done at your own risk and your responsibility and subject to terms of use and privacy policies relating to each such service. The Company has no control over those third parties’ policy documents or how they implement them. The Company will not bear responsibility for such third-party services.

10. Limitation of liability. The Company including anyone on its behalf will not bear any liability and/or responsibility, and you relieve the Company of any such liability and/or responsibility, in connection with any damage, loss or expense, of any kind and type, whether direct or indirect and/or circumstantial and/or consequential, that were caused and/or will be caused to you and/or to a third party related to data collection, its use, transfer to third parties, its process and protection.

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11. Links to external websites and/or applications. Various advertisements and/or links to external websites and/or applications may appear while using the Services. Clicking the link is done at the user’s discretion and responsibility. It is clarified that clicking the link removes the user from the Services and redirects to an external website and/or application. The user will be subject to the external website and/or application terms, including its privacy policy. The Company has no and will have no control over information processing performed through the external website and/or application. The Company will not be liable for any matter related to the external website and/or application.

12. Minors. The Company does not knowingly collect information about children under the age of eighteen (18). In the event that you become aware that an individual under the age of eighteen (18) uses the Services without parental or guardian permission, please notify us immediately.

13. Communication and notices. We reserve the right to send you notifications related to the Services via email, SMS and WhatsApp including service and administrative notices. For any question regarding this policy, you may contact the Company at office@rubycapital.com.

14. Applicable law and jurisdiction. The terms and provisions detailed in this Privacy Policy, as well as any change or amendment thereof, as well as Website use, will be governed by the laws of the State of Israel without reference to its conflict of law provisions applicable therein. Jurisdiction regarding any dispute and/or claim that may arise in connection with the use of the Website and this Privacy Policy or related thereto, is assigned exclusively to the competent courts in Tel Aviv-Jaffa.

15. Changes to the Privacy Policy. Our Privacy Policy may change from time to time. If material changes are made to the Privacy Policy, a notice will be published on the website on this page. Continued use of the website after the change in policy indicates your consent to the amended policy.

Last updated: December 2025