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Effective March 23, 2016

This privacy statement describes the privacy practices of the OurCrowd investment portal ("us,""we" or "OurCrowd") for Services and other matter offered through the OurCrowd website at www.ourcrowd.com (the “Site”). This policy is incorporated in the OurCrowd.com terms of use (the “Terms”). Capitalized terms used and not otherwise defined in this document shall have the meanings set forth in the Terms.

To better protect your privacy, we provide this notice explaining our online information practices, including the choices you can make about the way your information is collected and used at this Site.

By registering for our Site, or by using this Site or Services made available through the Site ("Services"), you thereby agree to this privacy policy (the “Policy”). If you do not agree to be bound by this Policy, you should exit and cease all use of the Site and Services.

In connection with Services, you will be signing additional agreements with OurCrowd or its affiliates or other third parties. In the event of conflicts between the terms of such agreements and the terms of this Policy, the terms of such agreements will govern solely with respect to matters specifically referenced therein, but the terms of this Policy will control all matters related to OurCrowd’s commitments related to privacy of your data collected and used at this Site.

Information Collection and Use


We respect your privacy. OurCrowd is the sole owner of the information collected through the Site, will use and disclose such information in the manner described in this Policy. The terms of this Policy are subject to all applicable laws.


User-Supplied Information

Upon performing the registration process, you will be asked to provide certain information, such as your first and last name, residence for tax purposes, social security, taxpayer id and other identifying information, email address, gender and birthday, as well as a username and password and certain financial information. The username and password are used to ensure that only you have access to any of the personal information you have provided. You are solely responsible for maintaining the secrecy of any password you use to register, and you should always be careful whenever disclosing information on line.

In addition, we receive and store any information you enter on our website or give us in any other way (for example, in the course of subscribing for particular investments, otherwise using the Site or other communications with us, or as contained in written documents you provide). This includes information that can identify you (“personal information”). The amount of personally identifying information you provide is up to you, and you are not legally obligated to provide such information. However, your use of the Site or the Services may be curtailed if such information is not provided.
You may provide information on behalf of another person or entity. If you completed the registration on behalf of another entity or if you otherwise provide information regarding another person or entity, you represent to us that you were authorized by that person or entity to give us consent to use the submitted information. We may use third party contractors to collect and aggregate this information. For more information, please see Information Collected by Means of Technology.

The Site and Services may only be used by individuals over the age of 18.

Information Collected by Means of Technology

We may collect some information automatically from your computer, without notice such as your Internet Protocol (IP) address, computer and connection information, browser type and version, operating system, Internet Service Provider (ISP), time stamps, banner ads you click, the URLs you come from and go to next, and a cookie number. 
OurCrowd, our service providers, and other members of our corporate family who provide joint Services to you with us, will sometimes place anonymous cookies or web beacons on your computer when you visit the site. Your browser must be set to accept cookies in order to access OurCrowd as a registered user. We use these cookies and web beacons to recognize returning users, provide relevant content, measure traffic and activity on the site, monitor and improve our Services and protect against fraud. You can block cookies by changing the settings on your browser (consult your browser help menu to find out how), but doing so may prevent us from delivering certain Services to you. We do not link the information we store in cookies to any personally identifiable information (“PII”) you submit while on our site. 

We also may allow advertisers to occasionally use our Site and they may also use cookies on the Site.  Advertisers’ use of cookies is subject to their own privacy policies, and we have no access to or control over these cookies. 

Use of Information.

User identifiable information will be used by OurCrowd’s and its affiliates' employees, consultants and third party service providers in connection with OurCrowd’s business (including, without limitation, as described elsewhere in this Policy), in connection with the operation and management of the Site and Services, to enhance performance of the Site, to tailor the Site to Users’ preferences, and to analyze trends, including, without limitation, as follows:

•To enable us to verify your credentials, in order to maintain reasonable security, provide developers with the information that is useful in developing new features and Services for our users, enable us to develop and improve the features, contents, and Services available, fulfill your requests for our products and Services, in connection with your use of the Site or Services, to respond to your inquiries about our Services, to offer you our products or Services that we believe may be of interest to you, to carry out transactions which you have requested, to enforce our rights and resolve disputes.

•We will retain information transmitted to us in the context of use of Services for further internal use in connection with our efforts to improve our Services and products. 
•Newsletters: If you wish to subscribe to our newsletter(s), we will use your name and e-mail address to send the newsletter to you. Out of respect for your privacy, we provide you a way to unsubscribe by following the unsubscribe link located at the bottom of each newsletter communication or by emailing us at info@ourcrowd.com. 
•We may use non-personally identifying information that we collect to provide statistical information about users of the Site or Services, to improve the quality, design and content of our Site, to analyze the use of our Site and to cooperate with law enforcement. 

Disclosure of Information



In certain cases, we may provide User information to other third parties, such as advertisers, partners or for online advertising auctions. Where we provide User information to third parties, other than for use on our behalf, it will be provided either in aggregated form that does not identify User identity, or in a form that does not link the information to Users’ PII. In certain cases, such as information provided to our advertisers, we may provide non-personally identifiable identification (for example, gender) in connection with an IP address. 

We will not sell, share, rent or trade your personal information with third parties other than as disclosed within this Privacy Policy unless we have your consent. 

We may disclose your personal information to: 

•Third-party vendors who provide Services to us or facilitate or evaluate the Sites or Services, such as e-mail service providers sending e-mails on our behalf 
•Companies within our corporate family that are involved in operating or providing the Services. We may share your personal information with our affiliates. Our affiliates will follow practices that are at least as restrictive as the practices described in this Privacy Policy, including requests that personal information not be used to provide you with Services. 

We may share aggregated or anonymous data with third parties for any use whatsoever without restriction. 

We also may share your information:

•In response to subpoenas, court orders, or other legal process or in response to a law enforcement agency’s request; to establish or exercise our legal rights; to defend against legal claims; or as we reasonably believe appropriate to comply with applicable laws, regulations, orders, legal processes or government or regulatory requests, including tax authorities in Israel, the United States and elsewhere, as well as in order to comply with anti-money laundering laws and regulations. In such cases we reserve the exclusive right to raise or waive any legal objection or right available to us.
•When we believe it is appropriate to investigate, prevent, or take action regarding illegal or suspected illegal activities; to protect and defend the rights, property, or safety of our company or this Site, our customers, or others; and in connection with our Terms and other agreements, including where we believe you may have breached the Terms or other agreements with OurCrowd or its affiliates, to detect, prevent or otherwise address fraud or illegal behavior, security or technical issues, or protect against imminent harm to the rights, property or safety of OurCrowd, its affiliates or users or the public as required or permitted by law. 
•In the event that OurCrowd goes through a business transition, such as a merger, acquisition by another company, or sale of all or a portion of its assets, your PII will likely be among the assets transferred. You will be notified via email or prominent notice on our Site for 30 days before any such change in ownership or control of your personal information. 

Other than as set out above, you will be notified when personal information about you will be shared with third parties, and you will have an opportunity to choose not to have us share such information. 

Cross-border Transfer

By using our Site or Services, you consent to transfer PII outside your country but only for purposes of performing the Services for which you provided your PII, , even to countries that might not offer a level of protection for your PII that is equivalent to the one offered in your country of residence. We will obtain your express consent, however, before using your PII for any purposes other than performing the Services for which you provided the PII.

Links

The Site contains links to other sites. OurCrowd is not responsible for and has no liability for privacy policies and/or practices on other sites. We advise you to read the privacy policy stated on other sites you link to through the Site. Our privacy policy only governs information that we collect on the Site. 

Security

We take appropriate precautions to protect Users’ personal information by using physical as well as technological security devices. Additionally, we have implemented physical, electronic and procedural safeguards that are designed to protect the security of your information in compliance with applicable U.S. federal and state regulations. These include advanced firewall and password protection for our databases, physical access controls to our buildings and files, and restricted access to your personal information to employees that need to know that information to operate, develop or improve our Services. We have invested in leading-edge security software, systems and procedures to offer you a safe and secure investing platform and protect your personal, financial and investment information. While no security system is absolutely impenetrable, we will continually monitor the effectiveness of our security system and refine and upgrade our security technology as new tools become available. OurCrowd’s employees are kept up-to-date on security and privacy practices. If you have any questions about the security measures we use on the Site please contact us by sending an email to info@ourcrowd.com. 


Notifications and Updates

The Site sends new registered Users a welcoming email to verify password and username. After you register with the Site, we may send you on a regular basis via emails information on other Services that we believe may be of interest to you. Out of respect for your privacy, we give you the option at all times to opt-out of these types of communications. Please see our choice and opt-out procedures below. By choosing not to opt out, you consent to these communications. 

The Site may also send you notifications regarding updates to the Site and Services. We may also communicate with you to provide requested Services and with respect to issues relating to your account via email or phone. You will not be able to opt-out of service announcements that contain important information about the service. 

Correction/Updating Personal Information

OurCrowd encourages you to review your information regularly to ensure that it is correct and complete.  As a registered user, you can review and change your personal information by contacting us at the e-mail address, postal address or telephone number listed on the OurCrowd Site.

Choice/Opt-out

You may ‘opt-out’ of having your personal information used for any purpose not directly related to the Site upon registration to the Site. You may not opt out of administrative emails (for example, electronic delivery of financial information, or emails about your transactions or our policy changes).  However, if you no longer wish to receive additional information or promotional materials from OurCrowd, you may opt-out of receiving these communications by sending an email with the word ‘unsubscribe’ in the subject line or otherwise sending a request to the following email address marketing@ourcrowd.com, or using the opt-out mechanism described in the relevant email. 

Notification of Changes

This policy may change from time to time and we will post the amended terms on the OurCrowd Site and notify you by email of major changes.  Amended terms will take effect immediately for new users, and 30 days after they are posted for existing users.  You should review the Privacy Policy periodically to remain informed of any changes.  You agree to accept posting of a revised Privacy Policy as actual notice to you. 

Your continued use of the Site after any changes to this Policy have been posted (or, if applicable, notified) signifies your acceptance of those changes. 

If we become involved in a merger or acquisition or sale of assets, we will provide notice before personal information is transferred or becomes subject to a different privacy policy.

We will retain your information for as long as your account is active or as needed to provide you Services or as required in accordance with applicable law. 

You can also request that we close your OurCrowd account, or request that we no longer use your information to provide you Services, by emailing Customer Service at info@ourcrowd.com.  After we close your account, we may retain some information to comply with law, prevent fraud, assist with investigations, resolve disputes, analyze or troubleshoot programs, enforce our Terms of Use and take actions otherwise permitted by law.  If your account is terminated or suspended, we may retain some information to prevent re-registration. 

Questions and Feedback

We are strongly committed to our relationship with you and want to be sure you understand the steps we have taken to protect your personal information. If you have questions or feedback regarding our privacy policy, you may direct them to info@ourcrowd.com. We will make every effort to answer your questions.


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NOTHING ON THIS WEBSITE SHOULD BE CONSTRUED AS AN OFFER TO SELL, A SOLICITATION OF AN OFFER TO BUY, OR A RECOMMENDATION FOR ANY SECURITY BY OURCROWD OR ANY THIRD PARTY. YOU ARE SOLELY RESPONSIBLE FOR DETERMINING WHETHER ANY INVESTMENT, INVESTMENT STRATEGY, SECURITY OR RELATED TRANSACTION IS APPROPRIATE FOR YOU BASED ON YOUR PERSONAL INVESTMENT OBJECTIVES, FINANCIAL CIRCUMSTANCES AND RISK TOLERANCE. INVESTORS AND USERS SHOULD CONSULT WITH LICENSED LEGAL PROFESSIONALS AND INVESTMENT ADVISORS FOR ANY LEGAL, TAX, INSURANCE, OR INVESTMENT ADVICE. PLEASE CLICK HERE FOR ADDITIONAL DETAILS.