Table of Contents

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Introduction

We in Haaretz attach great importance to our consumers' privacy.

As a company based in Israel, Haaretz enjoys the EU Commission decisions of 31 January 2011 and 15 January 2024, which determined that the state of Israel provides an adequate level of protection for Personal Data transferred from the EU (please see definitions below). In practice, this means that the legal process of transferring Personal Data from the EEA (European Economic Area) to Israel is similar to data transfers within the European Union.

Bearing this in mind, our company makes significant efforts to comply with the European Union General Data Protection Regulation (GDPR) as well as with the California Consumer Privacy Act and the California Privacy Rights Act of 2020, when relevant.

This Privacy Policy goal is to explain to the users ofHaaretz.com internet site andHaaretz - Israel News, Haaretz Tablet Edition, Haaretz English Edition (hereinafter: “the websites”) how and why we collect, use, retain and disclose Personal Data (and in GDPR terms, also as a controller) about the websites' consumers or any otherData Subjects of us, in a lawful and transparent way.

We also encourage you to read the “Your rights concerning Personal Data” section in this Privacy Policy, where you can find a further explanation about your lawful rights.

Legal Definitions

Herein some legal definitions in plain language for your convenience, before taking further reading of this Privacy Policy (in alphabetical order):

Haaretz Fundamental Principles concerning Users’ Privacy and Data Protection

We acknowledge our consumers’ privacy is a fundamental right. As a result, we take significant technical and organizational measures to ensure the appropriate security of our consumers’ Personal Data. However, while information security reduces risks of unauthorized intrusion, it cannot provide complete immunity from all intrusions.

All our consumers’ Personal Data is being collected and processed in fair and lawful manners only, with great emphasis on transparency.

We make sure to limit the processions of Personal Data collected from our consumers to the purposes disclosed to the consumers, and use this data in an adequate and relevant manner only.

Nevertheless, further processing for archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes, shall, in accordance with Article 89(1) of the GDPR, not be considered as incompatible with the initial purposes.

It is essential for us to ensure the accuracy of the Personal Data we process. Therefore, and according to law, we enable the rectification and erasing of inaccurate data whenever our consumers wish us to do so.

We do not store information that enables the identification of data subjects longer than necessary.

How Haaretz Collects Personal Data, Why We Do So & Lawful Grounds

When using the websites, several types of Personal Data are being collected and processed for various purposes, subject to lawful grounds.

However, you should also know that in some cases the GDPR and the CCPA allow us, under the basis oflegitimate interest, acontract orvital interests only, to use the Personal Data for another purpose as long as it is compatible with the original purpose, and appropriate safeguards are in place.

Personal Data You Provide to Haaretz

This type of Personal Data may include:

• Your contact data, including full name, residential address, shipping address, e-mail address, ID number and phone number.
• Your educational status, professional or job title and your workplace organization's name and field of activity – when relevant or when you wish to provide it to us voluntarily.
• Log-in details you use to enter the websites and specific user areas, such as user's personal account in the websites.
• Some partial billing information, such as four last digits of credit card number.

Our lawful grounds to collect and process the above-mentioned types of Personal Data include:

• Performance of a contract you are a party to when the processing is necessary to perform the contract (including when taking necessary steps prior to entering into a contract): in order to fulfill our contract with you when you wish to consume our products or services, including contracts with your employer which entitle you as a beneficiary, and to supply you with the products and services you paid for.
• Legitimate interests: such as defending against and filing lawsuits and recovering an unpaid debt you may owe us.
• Consent: for example, when you register for a professional conference and allow us to contact you by email to update you about similar conferences in the future.

We use the above-mentioned type of Personal Data for the following purposes and activities:

• To subscribe you to a newsletter or to one or more of our other services or to allow you to consume any of our products, such as – printed or digital newspapers, restricted content on the websites, conferences or other events, for example – conferences that are intended for professionals in a specific field (Doctors, hi-tech managers, investment managers etc.).
• For billing purposes, when it is relevant, including when you are entitled to unique discounts or prices according to a specific arrangement you or your employer may reach with us, and to recover an unpaid debt you may owe us.
• To store your username and relevant log-in details (also via cookies) in order to verify you whenever you return to the websites and have already logged in. This allows us to give you better user experience.
• To allow you access to your personal accounts on the websites.
• To inform you, when needed, about changes concerning your engagement with us.
• To provide you with the services and products you purchased or you are interested in purchasing, and to contact you about it.
• To respond to your different requests, including requests concerning your Personal Data as part of the rights you are entitled to, and when our customer service must reach you.
• To protect our lawful rights and legitimate interests and those of others.

Personal Data Collected to Enable You to Generate and Publish Independent Content

While browsing the websites, you may have the option to voluntarily upload content, for example: by posting a comment on an article or on other users’ content, or when expressing yourself via our WhatsApp or our other social media platforms.

The Company is not obligated to publish such content, and even if published, the Company reserves the right to remove it, all subject to applicable law, the Company’s Privacy Policy, and the Terms of Use of the relevant platform.

The Company may collect Personal Data in connection with such content and its viewing, for the purposes of improving the user experience and enhancing the quality of its platforms, preventing, as much as we can, fraud and abusive messages towards third parties, monitoring, as much as we can, compliance with the Terms of Use of the Company’s websites, and complying with legal requirements (such as responding to court orders and requests from enforcement authorities that may force us to provide your IP or other related data to law enforcement authorities).

Please note that content published by you may be exposed to other users, who may use it in several ways, including by sharing it, and the Company has no control or responsibility in this regard.

The above-mentioned Personal Data regarding this section will be collected and processed due to the following lawful grounds:

• Legitimate interests:
  • Ensuring as well as we can, that consumers use the websites and our social media platforms lawfully and in accordance with our terms of use.
  • Defending against and filing lawsuits when relevant.
• Protection of vital interests of the data subject or another natural person.
• When the processing is necessary for thepublic interest or in the exercise of official authority.

Other Personal Data We Collect Automatically

As you use the websites, and subject to lawful grounds, technical and behavioral data may be collected for several purposes, as explained in the table below:

Personal Data We Collect for the Purpose of Direct Marketing

Some information, like the types of articles you consume, may be used by us to personalize you in order to send you more accurate and suitable marketing and advertising offers. We will not send you such kind of marketing and advertising offers unless you opt-in for it in advance. Also, when you do get a direct marketing offer you will always have the option of opting out, and we will respect it.

Social Media Third Parties (Meta, X and Others)

By using relevant social media via the websites, you also approve that we may inform some other third parties, including other users, about content you read or like on the websites, and are aware that we may disclose some of your Personal Data to the social media provider, depending on your settings at the social media platform, and the social media provider's privacy policy should apply on him.

Personal Data Collected Directly by Third Parties

To create target audiences for tailoring content and advertising on the company's websites and sometimes on other websites as well, some third parties that operate in the websites, such as YouTube, X, Facebook, Instagram, Google Analytics, Outbrain, First Impression etc., collect your Personal Data for their own disclosed purposes, mainly through embedded scripts, cookies and other similar technologies. That information may include, among other things: display preferences, domain addresses you viewed, the length of time you spent on those domains and the links or buttons you clicked on the various pages, products you purchased or added to the shopping cart on the site, limited geographic location data, the name of your Internet provider and your terminal device data, such as the type of browser and operating system, the type of device you browsed from (tablet, mobile phone, smart TV, Android or IOS, etc.).

Please note that the collection of such information is managed by the third parties and not the Company. Therefore, you may use your browser settings and the relevant third parties' websites to manage your preferences and consents regarding that information.

Cookies and Similar Technologies

The Company allows certain use of cookies and other similar technological means in the websites, for the purposes of securing and maintaining the websites, improving the user experience, tailored advertising and marketing, as well as for the proper and continuous operation of the websites, such as for payment processing, remembering your privacy preferences, identifying your subscription and granting access thereto, and more.

Some of the information collected about you through these technologies will be shared with third parties, in accordance with the purposes stated above (such as advertisers, data analytics companies, and various service providers, including information security services and technical support services).

What Are Cookies?

“Cookies” are small pieces of information sent from the websites via your web browser and stored on your computer or other terminal device you possess, while you are accessing the websites. Some cookies (“Session Cookies”) expire once you close your browser, while others are stored on the hard drive of your computer. For example, a user operating Microsoft Windows and browsing with Microsoft Internet Explorer may find such cookies in the directoryc:/windows/cookies, as well as inc:/windows/temporary internet files.

Cookies contain information such as the pages you visited, the duration of your visits on the websites, the source from which you browse to the websites, sections and content read by you on the websites, and more. Cookies also eliminate the need to repeatedly enter your details upon revisiting sections or pages of websites that require registration.

When the Company uses cookies to directly collect personal information about you, this will be done with the implementation of various information security measures, such as encryption, and subject to this Privacy Policy and the Terms of Use of the Company’s websites. However, some cookies as well as other similar information collecting technologies are operated by third parties, and in such cases their operation is subject to their privacy policies.

How Can I Manage My Cookies and Other Similar Technologies Preferences?

As you enter the websites, you will see a "Cookies" banner that will allow you to manage your cookies and other similar technologies preferences. Except of some "strictly necessary cookies" that are essential to the proper operation of the websites (such as security cookies, transaction cookies and some preferences cookies), any other use of cookies will be subject to your prior consent in an opt-in format, as it described in the banner.

For your knowledge, we may use both “session cookies” and “persistent cookies.” While session cookies expire once you close your web browser, persistent cookies will stay on your terminal device until you delete them. Please be aware that although your terminal device’s exposure to both kinds of cookies can be managed by you via your web browser help files directions, it may also affect your user experience when you use our products. Disabling the "strictly necessary cookies" will not allow you to use the websites at all.

Retention of Personal Data

Haaretz will retain your Personal Data for a period of time that is reasonably necessary and proportionate to achieve the purposes for which the Personal Data was collected or processed, including our legitimate interests and third parties legitimate interests as the law permits, and in some cases, for another disclosed purpose that is compatible with the context in which the personal information was collected, and will not further process it in a manner that is incompatible with those purposes. It also means that same type of information can be retained for different time periods, depending on its usage purposes.

Subject to compatible law, we may de-identify the Personal Data rather than delete it.

The Types of Third Parties We Share Your Personal Data With & Types of Personal Data Shared

• Technical browsing data, sites usage information and other identifying data when it is needed to be share with IT security providers, for a proportionate period of time and scope – in order to protect your Personal data and that of other users and to prevent fraud, hacking, identity theft and other types of damage that may harm you or other users.
• Payment gateway and accounting system – to charge consumers in accordance with services and/or products they bought and to recover unpaid debts.
• Email distributing systems providers – to send useful information, be in touch with you concerning your engagements with us, to improve user experience, and for advertising & marketing purposes.
• Related companies and re-organization – Personal Data that is being collected by Haaretz, may be shared with other related companies to Haaretz, as part of a re-organization process and related due diligence, or whenever Haaretz sells or transfers its business operations or assets, all or part, to a third party, as part of a merger, acquisition, etc. Personal Data can also be shared, in a similar manner, in the event of bankruptcy re-organization. In such cases, Haaretz will undertake to ensure, subject to applicable laws, the consistency and continuity of the Personal Data storage, purposes and processing terms during the data transfer process.
• Technical service providers – such as cloud computing service providers, information security providers, technical support and maintenance to our different systems. All subject to a commitment to maintain the privacy and security of the data in accordance with the type of data in question.
• Any third party concerning an engagement you initiated via the websites – when you purchase services or products on the websites from a third party, the necessary information about you will be transferred to that third party for the purpose of providing the said products or services and maintaining contact with you. Also, if you participate in a joint activity between the Company and a third party, the third party may also be entitled to be exposed to information relating to your browsing and participation due to the said activity.
• Statistical information analysis providers – subject to a commitment to maintain the privacy and security of the data in accordance with the type of data in question.
• Any third party Haaretz will be legally obligated by the authorities to provide your Personal Data or if it receives a judicial order to do so, or whenever Haaretz believes that providing the data is necessary to prevent significant harm to you or a third party.
• Law enforcement authorities and judicial tribunals etc. – in the event that you violate and/or attempt to violate our Terms of Use and/or any of the services offered therein, or in a situation where you operate on the websites and/or in connection with them and their activities in violation of the law, and due to a contractual dispute, claim or legal proceeding, if and to the extent that there are any between you and Haaretz.
• To a relevant third party, such as law enforcement authorities or medical personnel – when it appears necessary to prevent significant harm to you or another person.
• Digital advertising and marketing services platforms – such as Google Ad Manager, Google Analytics, and advertising services from companies such as Taboola, Outbrain, Facebook, X, YouTube, etc.
• Other third parties subject to your consent or direction.
• Aggregated or de-identified information – in some cases and subject to applicable laws, the use of your personal Data will be allowed to third parties when the information is de-identified or aggregated.

Personal Data We Receive from Third Parties

The Company can obtain Personal Data about you also from third parties, such as: social media providers, including content you choose to disclose by yourself, public available sources which are permitted by law, your employers or other enterprises related to you or any other users of the websites (e.g. when they engage with us in order to buy a subscription for your benefit).

International Transfers of Your Personal Data

In certain cases, Personal Data can be collected by Haaretz and be transferred, for processing or storage necessity, to countries rather than Israel or an EU member state. In such cases, Haaretz will protect your Personal Data as described in this Privacy Policy and will take measures to comply with the legal requirements regarding international transfer of information as stipulated in the Israeli Protection of Privacy Law, 5741–1981, including allowing third parties to process the Personal Data only for reasons and in a way that compatible with the purposes disclosed in our Privacy Policy and/or as part of a specific engagement between you and Haaretz, which its terms had been disclosed to you.

For the avoidance of any doubt, if you are an EU member state citizen, Haaretz will only transfer your Personal Data outside Israel if one of the below is in place:

• The recipient of the data is located in the US and had certified to the EU-U.S. Data Privacy Framework.
• The country to which the Personal Data will be transferred had been granted an adequacy decision from the EU Commission, as required by article 45 to the GDPR. An up-to-date list of countries which have been granted such an adequacy decision can be found in the Official Journal of the European Union and on its website.
• Haaretz has provided appropriate safeguards in respect of the transfer and has verified that enforceable data subject rights and effective legal remedies for data subjects are available in accordance with article 46(1) to the GDPR. For example, Haaretz has engaged with the third party in a binding and enforceable safeguards contract, which complies with the GDPR requirements.

Moreover, if you are recognized as a California resident, Haaretz will only transfer your Personal Data outside Israel if one of the below is in place:

• An agreement between Haaretz and the third party has been put in place to ensure, inter alia, the following:
  • The third party is obligated to fulfill its relevant obligations under the CPRA and to provide a similar level of protection concerning Personal Data.
  • The third party is obligated to inform Haaretz whether it can meet its relevant legal obligations.
  • The appropriate cases when the third party is obligated to enforce security measures on another third party.
  • Haaretz's right to take reasonable measures to prevent and/or fix unauthorized use of Personal Data in certain circumstances.
  • Haaretz had ensured the third party's obligation to allow Haaretz to conduct an audit overview to verify its compliance with the provisions of the law, and, when appropriate, to implement certain systems.

Your Rights Concerning Personal Data

As our consumer and subject to your identification via our verification procedures, the applicable laws and the adequate circumstances, you enjoy the herein rights, which we encourage you to exercise when you wish to do so, without having to fear from unlawful discrimination or any retaliation acts:

Right to Know

You are entitled to obtain confirmation of whether Personal Data concerning you are being processed.

Right to Access

You have the right to request access to your Personal Data and the following information, including the right to get a copy of the Personal Data we possess about you, free of charge, and subject to law provisions and adequacy (please notice that for any further requested copies we may charge you with a reasonable fee based on administrative costs). Please bear in mind that in cases you make such a request via electronic means, and unless otherwise requested by you, we will provide you with the information in a commonly used electronic form.

The information you can access includes the following (some of it you can also find in this Privacy Policy):

• The purposes of the processing;
• The categories of Personal Data concerned;
• The recipients or categories of recipient to whom the Personal Data have been or will be disclosed, in particular recipients in third countries or international organizations;
• Where possible, the envisaged period for which the Personal Data will be stored, or, if not possible, the criteria used to determine that period;
• Where the Personal Data hasn't been collected directly from you, you have the right to obtain any available information as to the data's source;
• The appropriate safeguards relating to your data when and if it being transferred to a third country or to an international organization.
• Specific pieces of Personal Data that have been collected about you.

Right to Rectification

You have the right to obtain from Haaretz the rectification of inaccurate or uncompleted Personal Data concerning you. Haaretz will do its best to rectify the data without undue delay.

Under some circumstances subject to section (14) of the Israeli Protection of Privacy Law, 5741–1981, you may be entitled to the deletion of your Personal Data from our databases.

Right to Complain to Supervisory Authority

If you have any complaints about how we manage your Personal Data, please feel comfortable to contact us and we will do our best to resolve the issue where possible. However, you also have the right to complain about any use of your information with the Privacy Protection Authority of Israel, which is the Israeli data protection regulator, or to seek a suitable remedy via courts decisions, when applicable.

We promise you to do our best to answer your requests regarding the rights mentioned above. However, there can be various circumstances in which we will not be able to fulfill your request. For example, if it prevents us from complying with our regulatory obligations or impacting other legal matters, or when we cannot verify your identity, or even if it requires extraordinary cost or effort. Nevertheless, in such circumstances, we will inform you in a reasonable time and give you an explanation.