This Privacy Policy (the "Privacy Policy") governs how we, SHAY HAI ENTERPRISE AND INVESTMENTS LTD. ("we", "our" or "us"), use Personal Information (as defined below) that we collect, receive or retain about individuals in connection with their use of the website https://shayhai.co.il/, including its sub-domains and their content, internet landing pages, telephone inquiries, and any inquiry made to us regarding the receipt of services (collectively, the "Website").

1. Introduction. We have adopted this Privacy Policy because, as the controller of the database, we recognize the importance of privacy. This Privacy Policy sets out how we will manage the Personal Information we collect when you visit the Website, and the choices available to you regarding how such information is collected.

What is Personal Information? "Information" or "Personal Information" has the meaning given to it in the Privacy Protection Law, 5741-1981 (the "Privacy Protection Law"). It includes information relating to an identified or identifiable person, including by means of an identifier such as a name, identity number, biometric identifier, location data or online identifier, or by one or more data points relating to that person's physical, health, economic, social or cultural condition.

2. Consent and Amendments. You are under no legal obligation to provide us with information about yourself, and any information you provide is provided of your own free will. However, if you choose not to provide certain information, we may be unable to provide you with some or all of our services. For example, we may be unable to contact you to handle your inquiries.

By using the Website, you agree to the terms of this Privacy Policy and to any collection, processing and sharing of Personal Information for the purposes set out below. If you do not agree to the terms of this Privacy Policy, please do not access or use our Website in any way. We reserve the right to amend this Privacy Policy at any time, at our discretion.

3. Personal Information You Provide Directly, and the Purposes for Its Use. At present, the general information available on the Website can be accessed without providing any Personal Information. However, we receive or collect Personal Information from you in the following ways:

3.1. Contact Details. When you contact us through an online form we make available, by telephone to our customer service center, or by any other means through the Website, you may be asked to provide certain information, such as your full name, email address, telephone number, identity number, the relevant project and the content of your inquiry. We use this information to handle your inquiry and to contact you, including by leaving messages where necessary. If you do not provide the required information, we will be unable to handle your inquiry or contact you.

3.2. Social Networks. We use social networks and other tools, such as Facebook and Instagram, to provide customer service, respond to your inquiries and improve the services we offer. Any inquiry made to us through such networks and tools is also subject to the privacy policy and terms of use of the relevant social network.

4. Personal Information We Collect That You Do Not Provide Directly, and the Purposes for Its Use:

4.1. Collection Through Non-Digital Channels. In addition to collecting information through the Website, we also collect and receive Personal Information through other channels. These include telephone calls to our service centers or sales offices, meetings with our sales representatives, and our engagements with subcontractors and change coordinators on our projects. In some cases, we receive referrals from external parties, such as consumer clubs, brokers and marketers, who refer you to us without transferring any material information, or while transferring only limited information. The information collected through these channels includes, among other things, contact details, apartment details, purchase preferences, payment data and records of our communications with you.

4.2. Log Files. We may use log files. The information in log files includes IP addresses, browser type, date/time stamps, referring/exit pages, filtering actions, clicks and any other information your browser may transmit to us. We may use such information to analyze trends, administer the Website and the system, track user traffic on the Website and the system, and collect demographic information.

4.3. Cookies. As part of our services, we use cookies, anonymous identification files and other tracking technologies for information security, Website operation, tailoring our services to your needs, displaying personalized information and improving your user experience. A "cookie" is a small text file stored on your devices when you visit the Website. It is used to collect information about your activity on the Website, store your preferences and authenticate your identity.

4.3.1. Types of Cookies. There are two main categories of cookies:

• First-party cookies: cookies we place directly on your devices.
• Third-party cookies: cookies placed by third parties on our behalf, such as analytics service providers (Google Analytics), advertising networks, social media platforms and other service providers.

These cookies are used for functionality, performance/analytics, marketing and social media purposes. They may be used to collect statistical information, tailor advertising content and embed external content (such as videos or social media posts). Third-party cookies are not under our control, and their use is subject to the privacy policies of those third parties. These third parties may change their terms of use and the purposes for which they use cookies at any time, and we recommend that you review each third party's relevant policy for further information. Blocking third-party cookies may affect certain Website functions, such as the display of external content or personalized advertising.

4.3.2. Duration. Cookies may remain on your devices for different periods of time:

• Session cookies: exist only while your browser is open and are deleted automatically when you close it.
• Persistent cookies: remain after you close your browser and may be used to recognize your computers on return visits.

4.3.3. Types of Cookies by Function:

• Essential cookies: necessary for the basic operation of the Website and enable you to navigate and use its main features. They are stored for the duration of your visit and deleted when you close your browser.
• Functional cookies: improve your user experience by remembering your preferences (such as language or text size). They are stored for up to one year.
• Performance and analytics cookies: help us understand how users interact with the Website, identify errors and improve the Website. They are stored for up to two years.
• Marketing and advertising cookies: used to personalize advertising content and measure the effectiveness of advertising campaigns. They are stored for up to two years.

4.3.4. Managing Cookie Preferences. Most browsers allow you to control cookies through the browser settings. You may:

• receive a notification before cookies are placed and choose whether to accept them;
• block cookies entirely or selectively;
• delete existing cookies from your devices.

4.3.5. To manage your cookie preferences, please refer to the specific instructions for the browser you use:

• Google Chrome: Menu (three dots) > Settings > Advanced > Privacy and Security > Content Settings > Cookies;
• Mozilla Firefox: Menu > Preferences > Privacy & Security > Cookies and Site Data;
• Safari: Preferences > Privacy > Cookies and Website Data;
• Microsoft Edge: Menu > Settings > Privacy, Search and Services > Cookies.

4.3.6. Consequences of Blocking Cookies. Blocking certain cookies may affect your browsing experience and the availability of some Website features:

• blocking essential cookies may prevent you from using certain parts of the Website;
• blocking functional cookies may limit our ability to remember your preferences;
• blocking performance cookies will prevent us from improving the Website based on usage patterns;
• blocking marketing cookies will prevent the display of personalized content, but will not affect the basic functionality of the Website.

4.4. Other Tracking Technologies. In addition to cookies, we may use other tracking technologies, such as web beacons, pixels and tags, which may be embedded in digital content, videos or email messages. These technologies allow us to collect information from your devices, including data on viewing of certain content, the date and time of access, and the IP address of your devices.

4.4.1. Web beacons and pixels help us analyze patterns of use of our services and display tailored content and advertisements to you. Some of these technologies are operated by third parties, such as advertisers or analytics providers, and are subject to those parties' privacy policies.

4.4.2. By using the Website, you consent to the storage of cookies, local storage technologies, beacons and other information on your devices, and to access to such information by us and by third parties, as set out above.

4.5. Mobile Device Data and Technical Information. We may collect technical information from your devices to ensure the proper operation of the Website and our services. This information may include:

• Device characteristics: device type, operating system, hardware model;
• Technical identifiers: Device ID, MAC address, advertising identifiers (where available);
• Usage data: date and time stamps of use of the Website and the system, duration of activity, pages viewed;
• Browser data: browser type, version, browser language, display settings;
• Network data: IP address, requested URL, referring pages.

In addition, subject to your express consent and in accordance with legal requirements, we may use location-based technologies to:

• tailor content and services to your geographic location;
• collect aggregate statistical data to improve our services;
• identify regional usage patterns.

We do not use precise location data to identify you personally. Any use of location-based information is aggregate and statistical, and the information is anonymized. You may disable location services at any time through your device settings.

4.6. Google Analytics and Other Analytics Tools

4.6.1. Google Analytics:

4.6.1.1. Use of Google Analytics. Our Website uses Google Analytics, a web analytics service provided by Google LLC ("Google"), as well as other analytics tools, to collect and analyze information about the use of the Website. These tools help us understand how users behave on the Website, identify usage trends and improve the user experience.

4.6.1.2. Information Collected. Google Analytics collects a range of data about the use of the Website, including:

• the frequency and duration of visits to the Website;
• the pages users visit;
• the websites that referred users to our Website;
• the technical characteristics of the device and browser;
• general demographic data (such as general geographic location);
• behavior and navigation patterns on the Website.

4.6.1.3. Use of the Information. We use the information received from Google Analytics and other analytics tools to:

• analyze usage patterns and trends on the Website;
• measure the effectiveness of Website features and content;
• improve the user interface and browsing experience;
• identify and fix technical issues;
• develop new features and services.

4.6.1.4. Protecting Your Privacy.

• We do not combine information collected through Google Analytics with personally identifiable information;
• We use IP anonymization settings to limit the ability to identify specific users;
• Access to the collected information is restricted to authorized employees who need it to perform their duties.

4.6.1.5. Restrictions on Google. Google's ability to use and share information collected by Google Analytics about your visits to and use of the Website is restricted by:

• the Google Analytics Terms of Service, available at: http://www.google.com/analytics/terms/us.html;
• the Google Privacy Policy, available at: https://policies.google.com/privacy.

For more information on how Google collects and processes data in connection with Google Analytics, please visit: http://www.google.com/policies/privacy/partners.

4.6.1.6. Opting Out of Google Analytics Tracking. You may prevent Google Analytics from using your data by:

• downloading and installing the Google Analytics Opt-out browser add-on: https://tools.google.com/dlpage/gaoptout;
• using your browser's privacy settings to block third-party cookies;
• using your browser's private/incognito browsing mode.

4.6.2. Meta Pixels. We use Meta Pixels and/or Meta SDKs. These tools help website owners and advertisers integrate, use and exchange Personal Information with Meta for measurement, performance analysis and ad personalization. Please note that third parties, including Meta, may use cookies, web beacons and other storage and tracking technologies to collect or receive Personal Information from our Website and from elsewhere on the internet, and may use that information to provide measurement services and personalized advertising. Meta's use and sharing of Personal Information is subject to the Meta Business Tools Terms, available at https://www.facebook.com/legal/technology_terms, and to the Meta Privacy Policy, available at https://www.facebook.com/privacy/policy/. You may limit or prevent the use of your information for personalized advertising through the choice mechanisms available at https://youradchoices.com/.

4.7. Other Analytics Tools. In addition to Google Analytics and Meta Pixels, we may use other analytics tools to improve the Website and our services. Each of these tools has its own privacy policy, and we make a point of choosing providers that are committed to high standards of privacy protection and information security.

5. Purposes for Which We Collect Information.

In addition to the purposes of use set out above, we may also use the Personal Information we collect, as described above, in the following ways and for the following purposes:

5.1. To manage residential projects, including managing our relationships with prospective purchasers and residents.

5.2. To contact you, including by leaving messages.

5.3. To improve the Website and its performance, in line with its purposes.

5.4. To handle your requests of any kind and respond to inquiries and complaints.

5.5. To secure the information on the Website and to comply with applicable law.

5.6. To defend ourselves in legal proceedings.

5.7. To send you information and promotional materials about our services, either to the email address you provided us or through a call from one of our representatives to your telephone. You may ask at any time to stop receiving such information and content by clicking an unsubscribe link or by sending a removal request by email to: office@shayhai.co.il.

6. Use of Anonymous Information

We may use anonymous or statistical information (information that does not allow an individual user to be identified), such as aggregate information we have accumulated and/or generated through use of the Website. This includes sharing such information with third parties and our customers in the course of our business.

7. How We Share Personal Information

Except as set out above, we will not transfer the information you have provided to us to third parties, except in the following cases:

7.1. To service providers acting on our behalf who assist us in our operations;

7.2. If the Terms of Use or this Privacy Policy are breached, or if you carry out, or attempt to carry out, through the Website, actions that appear to be unlawful;

7.3. In the event of any dispute, claim, lawsuit, demand or legal proceedings, if any, between you and us;

7.4. In any case where we believe that disclosure of the information is necessary to prevent bodily injury or property damage (to you or to a third party), or in connection with the investigation of suspected unlawful acts;

7.5. Where we are required by law to transfer your personal details and the information collected about your activity on the Website to third parties, including where we receive a court order instructing us to disclose your details or information about you to a third party, or in response to a request from a law enforcement authority or another governmental or public authority;

7.6. If we are acquired by or merge with a third-party company, or in the course of due diligence related to such a transaction.

In certain cases, the third parties to whom information is transferred under this Section may be located outside Israel, including in the United States. You hereby consent to the transfer and storage of information relating to you outside the State of Israel, in accordance with applicable law and for the purposes set out above.

8. Information Security. We implement information security systems and procedures on the Website. Although these systems and procedures reduce the risk of unauthorized intrusion into our computers, they do not provide absolute security. Therefore, although we strive to use accepted and reasonable measures to protect your Personal Information, we do not guarantee that the Website will be completely immune to unauthorized access to the information stored on it. If you have any questions about the security of the service or about confidentiality, you may contact us by email at: office@shayhai.co.il.
9. Your Rights and the Protection of Your Privacy. SHAY HAI ENTERPRISE AND INVESTMENTS LTD. is the controller of the database containing the information described in this Policy. We respect your right to privacy and seek to retain only information that is necessary, up to date and accurate. Please note that you are entitled to inspect the information about you that we hold. If you find that this information is incorrect, incomplete, unclear or out of date, you may submit a detailed request to us to correct or delete it, in accordance with the Privacy Protection Law, 5741-1981, and the Privacy Protection Regulations (Conditions for Inspection of Information and Procedures for Appeal of Refusal of Inspection Request), 5741-1981. We invite you to contact us on this matter, and with any question about your privacy, by email at office@shayhai.co.il.

Last updated: February 2026