What is the Privacy Policy?
Altshuler Shaham Group respects the privacy of its clients, including Users of the Website www.as-invest.co.il, on any of the Group’s Websites (which may operate under additional addresses), and across all of the Group Services (as defined hereinafter). This includes its digital services (including, but not limited to, the Group’s various mobile applications, software, web pages, digital forms, trading systems, and any other online service provided by the Altshuler Shaham Group), as well as other non-digital or offline services (collectively and individually in this Policy: the "Group Services"). The Group is committed to protecting and maintaining the privacy of Users of the Group Services ("You" or the “User”).
This Privacy Policy applies to the use of Altshuler Shaham Group Services, including any digital service or any other Service of the Altshuler Shaham Group, where the terms of use, engagement document, or any other content related to that Service refers the User to this Policy.
The Altshuler Shaham Group includes the following companies: Altshuler Shaham Ltd., Altshuler Shaham Finance Ltd., Altshuler Shaham Provident Funds and Pension Ltd., Altshuler Shaham Investment House Ltd., Altshuler Shaham Portfolio Management Ltd., Altshuler Shaham Mutual Funds Management Ltd., Horizon Digital Assets Ltd., Altshuler Shaham Financial Services Ltd., Altshuler Shaham Trade Ltd., Altshuler Shaham Real Estate Ltd., Altshuler Shaham Alternative Investment Funds Ltd., Altshuler Shaham Credit Ltd., Altshuler Shaham Credit for Business Ltd., Altshuler Shaham Construction Loans Ltd., Altshuler Shaham Finance – Pension Insurance Agency Ltd., Altshuler Shaham Guidance for Pension – Pension Insurance Agency Ltd., and any of their subsidiaries, affiliated and related companies (as defined in the Securities Law, 1968), as well as any other company or partnership owned by the controlling shareholders of any of the above companies, or owned by any of these companies ("Altshuler Shaham", the "Group", or "We").
This Privacy Policy (the "Policy") is intended to inform and teach you about the way we manage, collect, store and use personal information that you provide to us through the Group Services, or that we collect when you use the Group Services. You should always exercise caution and judgment when providing personal information that could identify you or others.
The Policy also describes the measures we take to protect the personal information that we are collecting and how to contact us regarding anything and any matter related to privacy in the Group. This Policy constitutes an integral part of the Terms of Use or Engagement Document for the Group Services that refer to it, and it is intended to provide you with a complete picture before you decide whether to provide personal information to the Group.
This Policy is the General Privacy Policy of the Group Services. In any case where a specific privacy policy or other arrangement exists for one or more of the Group’s companies, or for any of the Group Services or products, the specific privacy policy shall prevail over this Policy or supplement it in the event of any contradiction between the two policies. For the avoidance of doubt, the information in this Policy is in addition to private instructions given to you separately, for example in the framework of the products you purchased from any of the Group’s companies.
The Privacy Policy is worded according to the male gender for reasons of convenience only and it refers to all genders equally. Everything stated in singular, also refers to plural, as applicable.
The term "Personal Information" in this Policy means any information, set of information or data that relates to a person, identifies that person or can reasonably be used to identify that person, such as your full name, email address, phone numbers, national number, date of birth, gender, residential address, marital status, employment status, payment details, etc.
Providing Details and Personal Information to the Group
General use of the Group Website and viewing the content published on it - do not require a subscription.
However, different areas and sections of the Website, as well as the use of the various Group Services, including, the online mechanisms for joining the Group's products, online applications, contacting the Group using online contact forms, registering to receive information on various topics (including newsletters, magazines and marketing content), and more - may involve registration and/or the provision of personal information and personal and identifying details, according to necessity, the circumstances of the matter and the relevant online service. Some sections may include a User Interface that will allow you to update your personal information or identification information. Some of them will even allow you to pay for the relevant financial service. Similar subscription mechanisms may be found in other Services offered by the Group’s companies.
You will usually have to fill in the details of the person who will be the member or client of the Group, so that we can contact him, transfer documents related to its account or the joining procedure, and more. The fields that must be completed will often be explicitly marked.
Without derogating from the generality of the aforesaid, the following is a non-exhaustive list of examples, for illustration only, of cases where we ask you to provide us with personal information -
- When logging in and accessing the personal area: Accessing your personal area on the Website will usually involve entering a one-time password, or additional identification information, which may include personal information. We will collect your identification information and contact details, in order to send you the access information to the personal area and allow you to use it. The personal area will often allow you to view personal information concerning you, located in the Group's databases, as well as to perform various actions.
- When joining online the various Services of the Group, including online subscription: If you choose to join one of the Services that the Group offers on the Website and/or via the Group Services, or by submitting an online application, we will collect your, identification information, contact details, employment and family status, details of your family members (to the extent that the information is relevant), details of a beneficiary (to the extent that the information is relevant) and any additional personal information that we need in order to complete the contractual engagement with you in general, we may collect biometric information, such as a facial photograph, to verify your identity and comply with various regulatory obligations and anti-money laundering laws – all in accordance to the nature of the requested Service.
- Appointment of an attorney-in-fact: If you are interested in appointing an attorney-in-fact to receive information from your accounts in the Group, we will collect from you your identification information, contact details, the identification information of the attorney-in-fact and the contact information of the attorney-in-fact.
- Signing up to receive updates, landing pages and online campaigns: If you are interested in receiving updates, marketing messages and publications about various products and Services on behalf of the Altshuler Shaham Group, we will collect your identification and contact details from you, so that we can send you the aforementioned information. We may also collect such information through various landing pages or similar forms within third-party online services, including social networks, apps, and other websites, in order to enable our representatives to contact you or respond to your inquiry.
- Contacting us: If you wish to contact us, on any subject, and through any of the contact methods set forth in this Policy, we will usually collect your identification and contact details, as well as preliminary information about the nature of your inquiry.
- Recording calls for purposes of service control: Some of the calls with the Group's customer service centers may be recorded for identification, verification, supervision and control purposes. The content of the conversations may include personal information.
- Jobs: When you contact us in response to job ads that we publish on the Group’s Website, we will usually collect identification information, contact information and information about your professional training (resume, references, etc.) from you, so that we can evaluate and examine your candidacy for the relevant position.
We are legally required to request and retain certain information (for example, a copy of an identification document), need other information in order to provide Service, and may occasionally request additional information – for example, to better tailor the Service to your needs. Except where the provision of the personal information is due to a legal obligation – you are not required to provide us with the details of the personal information described in this Policy. The provision of such information is subject to your consent and free will; however, in order to join and optimally use the Services of the Altshuler Shaham Group, you are requested to provide the personal information as required when using the relevant Service. Providing incorrect information or failing to provide the requested personal information, that we are required by law to obtain, may result in our inability to provide you with certain Services, or any Service at all. Failure to provide optional information may affect the quality of the Service provided to you, our ability to tailor certain Services to your needs, and our ability to contact you when necessary.
If you convey personal information of third parties to us, such as your family members, employees, customers, etc., you must inform them that their details will be conveyed to the Altshuler Shaham Group and you confirm and declare that you have received their express consent to give their personal information for the purpose of using it in accordance with this Policy.
Information We Collect When You Use the Group Services
When you visit the digital services (even if you are not a customer) and use the Group Services, particularly the digital services, we may collect information about your practices in relation to its use, including information or content you read, the pages you viewed, search queries you made, the online services and sections that interested you, the frequency of their use, the location of your computer and the data of the internet address (IP address) through which you accessed the Service, the type of operating system you use, the type of end device you have, unique device identifiers (such as Device IDs), and more, all in accordance with the purposes detailed in the Group’s Privacy Policy.
We may collect information during your visit and while you enter details (for example, on pages where we request contact information to follow up with you regarding various offers), even if you do not complete the submission of such details. Altshuler Shaham utilizes Third Party Services to collect and analyze information related to the use of digital services, such as Firebase Analytics. Extensive information about this activity can be found under the "Cookies" Section in this Privacy Policy below.
How do we use Personal Information?
Altshuler Shaham will use the details and personal information you provide, and the details collected by the Group when you use the Group Services, in accordance with the provisions of this Policy, the purposes of the relevant database of any of the Group's companies, or according to the provisions of any law, inter alia, for the following purposes -
- To allow you to use the Group Services, its contents, and the various Services and sections the Group offers, including allowing you to join the various Services and products provided by the Altshuler Shaham Group and to allow the Group to provide you with these Services and products, or to assess your eligibility for subscription.
- In order to identify you or to verify your identity in accordance with the law and regulations that apply to the Group, for example, for the purpose of subscribing to certain Group Services or during your repeated access to registration-required areas;
- In order to improve and enrich the Services and content, including creating new services and new content that match the Users' requirements and expectations, and to change or cancel existing Services and content;
- For improving the information in the Group's databases;
- In order to allow you to adjust the Group Services on the Website to your preferences;
- Marketing and advertising, including segmented advertising, personalized advertising, and direct mailing — on the Group’s various platforms, in apps and/or on websites not affiliated with the Group — regarding the Group Services and products. Additional information regarding the use of data for direct mailing can be found below.
- To occasionally send you information regarding the Group Services and activities, advertisements, direct mail messages, surveys, newsletters, and similar content. Such information may be of a promotional nature and may be sent to you in writing, via SMS messages, email, or other electronic means, as further detailed in the Group Website’s Terms of Use or in the relevant engagement document.
- Conducting research and measurement — such as market segmentation, activity measurement, marketing campaign planning, and the promotion of products or Services;
- To contact you when we believe it is necessary;
- For the proper operation and development of the Group Services and for the identification of malfunctions, including technical support and customer service;
- To enforce the provisions of the binding documents, in order to comply with the requirements of any law, regulation or other legislation, and in order to assist authorized authorities and any third party, when the Group believes in good faith that it should do so;
- Legitimate business interests of the Group;
- For any other purpose, as detailed in this Privacy Policy, in any of the binding documents, or in the relevant contractual document.
- For adapting the Group Services and investment Policy to the Group's customers - Altshuler Shaham may use the details and personal information you provided in order to examine the suitability of the Group's products and Services to you, as well as to offer you to adapt the investment Policy to your personal characteristics, voluntarily and subject to your consent. For this purpose, the Group may also use decision-making systems based on algorithms and artificial intelligence tools (AI - Artificial Intelligence).
- To assist with technical issues (for example, in the event that you have started but not finished entering details (and have not clicked "OK", "Send", etc.), or to contact you further regarding your interest.
Providing your Personal Information
Except as set forth in this Policy, the personal information you provide to the Group or that the Group collects will not be given, sold or shared with third parties without your consent, except in the cases hereafter-
- To the extent necessary for the proper provision of the Group Services - we are permitted and may share personal information with third parties on our behalf, who assist us in operating the Group Services, managing the Group's business or providing the Services provided to you on behalf of any of the Group's companies, such as subcontractors. These third parties may use your personal information and process it only as necessary to perform the Services they provide to us and in accordance with the Group's instructions, and they must take information security measures in order to protect and keep your personal information confidential;
- For example, and for illustration purposes only, we use third-party identification and verification services, which use biometric identification tools and means to comply with various regulatory obligations and anti-money laundering laws, in relation to some of the Group Services and digital opt-in mechanisms;
- We may share personal information with third parties who have the power to do so, as part of the Services provided to you on behalf of any of the Altshuler Shaham Group companies or as part of your other engagement with the Group;
- If you violate the provisions of the Terms of Use of the Group Services, or any of the binding documents, or if you perform, through or in connection with the Group Services, actions deemed by the Group to be unlawful or attempt to perform such actions;
- If the Group receives a judicial order, or a demand from an authorized authority, instructing it to hand over your details or the personal information about you to a third party or to the relevant authority;
- In any dispute, claim, lawsuit, demand or legal proceedings, if any, between you and the Group, any of its companies, or anyone on their behalf;
- In any case that the Group believes that providing the personal information is necessary to prevent serious damage to your body or property, or to the body or property of a third party;
- For the avoidance of doubt, the Group’s companies may transfer and share your personal information between themselves, provided that they use this information only according to the provisions of this Policy;
- For the purpose of providing and sharing information with other companies or organizations related to the Group and with suppliers, business partners, advertisers and any third party. The Group will not knowingly reveal your identity to these parties without your consent;
- If the Group, or any of its members, organizes their activities or the activity of any of the Group’s companies in a different framework, as well as in the event that the Group changes its legal structure, including in the event that the Group's activity, or part of it, is transferred to a third party - we will be entitled to transfer a copy of the personal information to the new entity about you, provided that this entity accepts on itself the provisions of this Policy towards you;
- According to your express request.
Where is the Information Stored?
The information that the Group collects, or any of its companies, is stored in Altshuler Shaham's databases, which are stored at server hosting and data backup providers, which may also be located outside the borders of Israel, except to the extent that the law requires that the information be stored locally. Additional information, as set forth in this Policy, is collected and stored by other companies (such as statistics companies, companies that provide identification and verification services, etc.). They may also keep the information outside the country's borders. Your consent to this Policy also constitutes consent to the storage of the information abroad and its transfer outside the borders of Israel, including in countries where the law may provide a lower level of protection for information than that provided for in Israeli law, all in accordance with the provisions of the law.
Information Security
The Group attributes utmost importance to the security of the information in its systems. In order to preserve and protect the information, the Group operates systems, applications and procedures for the security of information, designed to minimize the risks of theft, damage, loss or unauthorized access to information, including personal information. However, there is no certainty that these applications absolutely guarantee that personal information will not be disclosed or stolen from the databases. Therefore, the Group does not guarantee, and you cannot reasonably expect, that the services and information systems used by Altshuler Shaham will be immune from unauthorized access to the information stored in them. By using the Group Services, you are aware of and agree to these limitations.
'Cookies' in Digital Services
We use 'Cookies' and other data analysis tools in the Group's digital services. As part of using the Group Services (even without personal identification as a customer), information will be collected about you through various collection methods, including Web Beacons, Pixel files, and Cookies. Such information may also include information about the end device from which you browsed (including Device ID), IP address, duration of stay on the site or on a particular page, location, and the like. A 'Cookie' is a piece of information that is sent from the Group Services to the Visitor's/User's computer (or other end device such as a tablet or phone) and stored on your end device. Cookies can contain a variety of information, such as information about the pages you visited, the length of time you spent on the Service, where you came to the Service from, the information you request to see when logging into the Service, and more. The use of the Cookie is intended for several purposes, including, among other things, to track repeat visits to the Group Services for measurement and statistical purposes, including analyzing the nature of use of the Group Services and measuring the Group's marketing campaigns. In addition, the information collected through these tools will be used for marketing purposes, including displaying ads and offers for various products and Services of the Group, including personalized ads, when you visit the Group Services and/or other websites online. The Group also uses Cookies to cross-reference information collected about you within the general pages of the Group Services (which are not within the personal area) with other information collected about you when using the Group Services, including offline communication channels, in order to identify you as a customer of the Group and for additional uses, as detailed in this section above and in this Privacy Policy.
Some of the Cookies we use on the Group Services are our own Cookies (First-Party Cookies) and some are from third parties (Third-Party Cookies).
In this context, we note that the Altshuler Shaham Group also uses third-party collection technologies, such as Google, Facebook, and Taboola, and the statistics and tailored advertising services of LinkedIn (including the Firebase system), Google, Taboola, Facebook, TikTok, X, RTB House, and Outbrain. Within this framework and for the purposes detailed above, Altshuler Group may transfer information about you to those third parties, who will use it for their own purposes. Third parties such as Google, Facebook and Taboola will use collection tools such as Cookies to collect information about you from the Group Services’ Website or app and elsewhere online, for their own purposes, in accordance with their privacy policies or other documents that may apply to you, for example because you have opened an account with them. Additional information about Cookies and how those third parties use the information collected through them and/or the information they receive from Altshuler Group can be found on the following pages:
Privacy Policy – Privacy & Terms – Google
Terms of Service for Firebase Services
How Google uses information from sites or apps that use our services – Privacy & Terms – Google
https://help.x.com/en/rules-and-policies/x-cookies
https://www.rtbhouse.com/privacy-notices/personal-data-processing-notice-email-signatures-usa
https://www.outbrain.com/privacy/
https://dsr.outbrain.com/recommendations-settings/home?utm_source=www.outbrain.com%2Fprivacy%2F
https://www.tiktok.com/legal/page/row/privacy-policy/en
If you prefer not to have Cookies stored on your computer or end device, you can change your browser or end device settings to reject certain types of cookies, or remove them manually. However, after rejecting the cookies or removing them from the end device, you may not be able to derive the maximum benefit from the Services provided to you by Altshuler Shaham Group, or some of these Services may not be available to you.
You can use automated tools to make choices regarding the use of Cookies or other tools:
Google Analytics Opt-out Browser Add-on Download Page
WebChoices: Digital Advertising Alliance's Consumer Choice Tool for Web US
Databases
You agree that personal information provided by you and/or collected about you, including in children’s savings fundson your child's name, if any, will be stored in the databases of the Altshuler Shaham Group and it will be used, inter alia, for the purposes of management, operation and marketing of the Group's products and Services; Managing and and improving service and customer relationships; data enhancement, processing and production of information for operational, marketing and statistical purposes; Direct mailing; Offering content and Services provided by the Group and transferring personal information to third parties for the purposes of fulfilling the aforementioned objectives or as required by law.
With respect to personal information collected as part of the use of the Group Services, the "Data Controller ", as the term is defined under the Protection of Privacy Law, is the company within the Altshuler Shaham Group with which you entered into an agreement to receive Services and/or products and/or other information. For more information, please contact us as detailed at the bottom of this Policy. Social Networks
Altshuler Shaham provides the Group Services Users with tools for sharing and linking content through social networks and various online services, and we also refer Users to various social media channels of Altshuler Shaham, such as the pages operated by the Group on Facebook, YouTube, LinkedIn, Instagram, Twitter and more. Please note that the use of such social networks and online services is external and separate to the Group Services and subject to the privacy practices of those Services and the Privacy Policy of each such Service. This Policy does not apply to the activity of these social networks or any online service operated by a third party.
Third Party Communication Services
Some of Altshuler Shaham's Services involve the use of third-party communication services (such as: WhatsApp and a link to cellular company) (hereinafter: "Third Party Services"). Third Party Services are provided by entities that are not part of the Group, and the Group is not responsible for the correctness, accuracy, level of performance or quality of the services provided by these Third Parties. The Group will not be responsible for the availability of Third Party Services or for their content or activities. The decision whether to use the Service, which involves the use of Third Party Services, is the User's only and under its own responsibility. In addition, the use of Third Party Services will be subject to all policies and terms of use, including the privacy policy, of the relevant Third Party Services.
Right to Review the Information and Correcting the Information
According to the Privacy Protection Law, every person has the right to review by himself, or by his attorney that he authorized in writing, or by a guardian, the information about him held in a database. A person who has reviewed the information about him and finds it to be incorrect, incomplete, clear, or up-to-date may contact the Data Controller with a request to correct the information or delete it, all in accordance with the provisions of the law. If the owner of the database refuses, it must notify the applicant in the manner and in the manner prescribed in the regulations. Under the Privacy Protection Law, the applicant for the information may appeal a refusal by the owner of a database to allow inspection and a notice of refusal to correct or delete information in the manner and in the manner prescribed in these regulations. For inquiries regarding this matter, please email: DPO@altshul.com.
Please note that deleting information may prevent you from continuing to receive Services from the Group, or impair the Service provided to you. Information needed by the Group for the purpose of managing its business - including documentation of actions you performed on the Website, or in the personal area - will continue to be kept by Altshuler Shaham according to law, but will no longer be used for contacting you. If within 30 days you do not receive notification that the information that the Group was asked to delete was indeed deleted according to this Section, you will be entitled to apply to a court in the manner stipulated in the regulations by virtue of the Privacy Protection Law, to order the Group to act as stated.
In addition, if the information in the Group's databases is used for the purpose of contacting you personally, based on your belonging to a population group, determined according to one or more characteristics of people whose names are included in the database ("Contacting by Direct Mail"), you are entitled under the Privacy Protection Law to demand in writing that the information relating to you will not be used for direct mailing purposes. To request that the Company not make direct mail inquiries to you, please email: DPO@altshul.com. However, the Company will be entitled to send you operational notices and/or notices that it is entitled or obliged to send you by law, even if you have refused to receive direct mailings.
Minors' Privacy
Altshuler Shaham is committed to protecting the privacy of the Users of the Group Services in general, however in particular the privacy of minors. We encourage parents and legal guardians to take an active role in their children's online activities and interests. The Group does not knowingly collect personal information from minors under the age of 18 without the consent of a parent or legal guardian to collect and use this information in the Services provided by the Group or for any activity or Service provided through any of the Group’s companies.
Changes to this Policy
The Group may change the terms of this Policy from time to time (just as it may change any of the binding documents, as set forth in the terms of use). If we make material changes to the Policy, we will post a notice on the home page of the Group Website, or notify you via the contact information you provided to us, at our discretion. If we make such changes in accordance with the provisions of any law, or a requirement of a competent authority - the changes will enter into force in accordance with the provisions of the law or such requirement.
Continued use of any of the Group Services after the change constitutes your consent to the current Policy, however we may ask you to confirm the current Policy, or all the binding documents or the relevant contract document for the Service. If you do not agree with the updated version of the Policy, you must stop using the relevant Service. You can review the latest Policy at any time by clicking on the appropriate link in the relevant Service, or on the Group's homepage.
Contacting Us / Reporting a Violation of Privacy
If you have any questions, suggestions, requests, complaints, etc., or if you believe that your privacy has been violated during the use of any of the Group Services, regarding this Policy or the Group's privacy practices, please contact us using any of the contact methods detailed on the Group Website, or in any of the following ways, and we will endeavor to handle your request as soon as possible:
- Telephone: *5054 (08:00 – 16:00);
- To contact the Privacy Protection Officer directly, you can contact them via email: DPO@altshul.com;
- An online contact form on the Group Website;
- Mail: Altshuler Shaham – 19A HaBarzel St., Ramat HaHayal, Tel Aviv-Yafo 6971026 (please note on the envelope "To the Privacy Protection Commissioner").
Last Updated: 14.8.2025
