What is the Privacy Policy?
Altshuler Shaham Group respects the privacy of its customers, and inter alia, users of the website operating at www.as-invest.co.il, of any of the Group’s websites (which also operate at additional addresses), and of the Group’s services as a whole, which include its digital services (including, but not limited to, the various apps of the Group companies, software, webpages, digital forms, trading systems, and any other online service of the Altshuler Shaham Group), as well as other non-digital or offline services (in this Policy, collectively and individually: the "Group Services"), and it 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 or other service of the Altshuler Shaham Group, where the terms of use of that service, its engagement document, or any other content refer 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 all subsidiaries, associated companies and affiliated companies (as defined in the Securities Law, 5728-1968) of these companies, and any other company or partnership owned by the controlling shareholders of any of these companies, or a company held by such company or partnership ("Altshuler Shaham", the "Group", or "We").
This Privacy Policy (the "Policy") is intended to inform and educate you about how 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 judgment and extra caution when you provide Personal Information that could identify you or others.
The Policy also describes the measures we take to protect the Personal Information we collect and how we may be contacted for anything pertaining to privacy within the Group. This Policy constitutes an integral part of the Terms of Use or Engagement Document for the Group Services that refer hereto, and it is intended to allow you to have 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. Where a specific privacy policy or other arrangement exists for one or more of the Group companies, or for any of the Group products or services, the specific privacy policy shall prevail over or add to this Policy in any case of discrepancy between the two policies. For the avoidance of doubt, the information contained in this Policy is in addition to privacy provisions provided to you separately, for example in the context of products you have purchased from any of the Group companies.
The Privacy Policy is drafted in the masculine form for convenience only and refers to all genders equally. Any reference in the singular form also imports the plural form, as applicable.
For the purposes of this Policy, the term "Personal Information" means any information, dataset, or data relating to an individual, which identifies that individual or can reasonably be used to identify that individual, such as your full name, email address, telephone numbers, I.D. number, date of birth, gender, residential address, marital status, employment status, payment details, and the like.
Providing Details and Personal Information to the Group
General use of the Group’s website and viewing of content posted on the site do not require registration or subscription.
However, various areas and sections of the site, as well as use of the various Group Services, including the online subscription mechanisms for the Group's products, the submission of online applications, contacting the Group via online contact forms, signing up to receive information on various topics (including newsletters and marketing content), etc., may require registration and the provision of Personal Information and personal and identifying details, according to need, circumstances and the relevant online service. Some sections may include a user interface that allows you to update your Personal Information or identification details. Some will also allow you to pay for the relevant financial service. Similar subscription mechanisms may be found in other services of the Group companies.
In most cases, you will be required to fill in the details of the person who is the designated member or customer of the Group, so that the Group may contact him, send account-related documents or documents related to the subscription process, etc. Fields that must be filled in will mostly be marked specifically.
Without derogating from the generality of the foregoing, below is a non-exhaustive list, solely for illustration purposes, of examples of cases where we will ask you to provide us with Personal Information -
- When logging in and accessing your personal area: Accessing your personal area on the site will usually require entering a one-time password, or additional identification details, which may include Personal Information. We will collect your identification details and contact details to send you your personal area access details to facilitate use thereof. Your personal area will generally allow you to view Personal Information that pertains you and is found in the Group's databases, and to carry out various acts and actions.
- When subscribing to various Group Services, including via online platforms: If you choose to subscribe to one of the Group Services offered on the site and/or through the Group Services, or when you submit an online application, we will collect your identification details, contact details, marital and employment status, details of your family members (insofar as relevant), beneficiary details (insofar as relevant) and any additional Personal Information we require in order to complete our engagement with you. Among other things, we may collect biometrics, such as face recognition, to verify your identity and comply with various regulatory obligations and anti-money laundering laws – all according to the nature of the service sought.
- Appointment of an attorney-in-fact: If you wish to appoint an attorney-in-fact to receive information about your accounts with the Group, we will collect your identification details, contact details, the identification details of the attorney-in-fact and the contact details of the attorney-in-fact.
- Signing up to receive updates, landing pages and online campaigns: If you wish to receive updates, marketing messages and advertising about various products and services on behalf of the Altshuler Shaham Group, we will collect your identification details and contact details, so that we may send you such information. We may also collect such information through various landing pages or similar forms within third-party online services, including social media, apps and various 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 matter, using any of the contact methods specified in this Policy, we will usually collect your identification details and contact details, as well as preliminary information about the nature of your inquiry.
- Recording calls for service control purposes: 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.
- Careers: When you contact us in response to job postings we post within the Group’s services, we will usually collect your identification information, contact details and information about your professional qualifications (résumé, references, etc.), so that we may assess and consider your candidacy for the relevant position.
We are required by law to request and retain some information (e.g., a copy of an identification certificate), we need other information in order to provide service, and we may occasionally request additional information, for example, to offer you a more suitable service. Except where provision of the Personal Information originates from a legal obligation – you are not required to provide us with the Personal Information details described in this Policy. The provision of such details is voluntary and subject to your consent; however, in order to subscribe to and use the services of the Altshuler Shaham Group in an optimal manner, you are requested to provide the Group with the Personal Information details as requested of you when you use the relevant service. Providing incorrect information or failing to provide the Personal Information that is requested and which we are under a duty to obtain may result in our inability to provide you with a certain service or with any service. Failure to provide information the provision of which is optional may negatively affect the quality of the service provided to you, our ability to offer you suitable services, and our ability to contact you when necessary.
If you provide us with Personal Information of third parties, such as your family members, employees, customers, etc., you must inform them of the provision of their details to the Altshuler Shaham Group, and you confirm and represent that you have received their explicit consent to the provision of Personal Information about them in order for it to be used 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 when you use the Group Services, particularly the digital services, we may collect information about your habits in relation to such use, including information or content you have you read, the pages you have viewed, your search queries, the online services and sections in which you have taken an interest, the frequency of your use, the location of your computer and the data of the IP address by means of 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 specified 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 details in order to get back to you with 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 may be found under the "Cookies" chapter of this Privacy Policy below.
How do we use Personal Information?
Altshuler Shaham shall use the details and Personal Information you provide, as well as 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 companies, or according to the provisions of any law, inter alia, for the following purposes –
- To enable you to use the Group Services, the various contents, and services and sections offered by the Group, and, inter alia, to enable you to subscribe to the various services and products provided by the Altshuler Shaham Group and enable the Group to provide you with these services and products, or to consider your subscription.
- To identify you or verify your identity in accordance with the law and with the regulations applicable to the Group, e.g., for the purpose of subscribing to certain Group Services or during repeated access to areas that require registration.
- To improve and enhance the services and the content, and, inter alia, to create new services and new content that meet the requirements and expectations of Users, and to modify or discontinue existing services and content.
- To enhance the data quality in the Group's databases.
- To allow you to customize the Group Services to your preferences, where possible.
- For marketing, advertising, including segmented advertising, personalized advertising, and direct mailing — on the Group’s various platforms, in apps and/or on websites that are not affiliated with the Group — for the Group’s products and services. Additional information about the use of data for direct mailing purposes may be found below.
- To occasionally send you information regarding the Group’s operations and services, advertising materials, direct mailing communications, surveys, newsletters, and the like. Such information may be promotional in nature and may be sent to you in writing, via text messages (SMS), emails, or other electronic means, as extensively specified in the Terms of Use of the Group’s website or in the relevant document of engagement.
- For conducting research and measurements — such as market segmentation, activity measurement, marketing campaign planning, and the promotion of products or services.
- To contact you as we deem necessary.
- For proper operation and development of the Group Services and identification of malfunctions, including technical support and customer service.
- To enforce the provisions of the binding documents or the relevant document of engagement, to comply with the requirements of any law, regulation or other legislative act, and to assist competent authorities and any third party, where the Group believes in good faith that it is required to do so.
- For legitimate business interests of the Group.
- For any other purpose as specified in this Privacy Policy, in any of the binding documents, or in the relevant document of engagement.
- For adjusting the Group Services and investment policy to the Group's customers – Altshuler Shaham may use the details and Personal Information you provide in order to assess the suitability of the Group's products and services for you, and to offer to tailor your investment policy to your personal characteristics, voluntarily and subject to your consent. For this purpose, the Group may also use algorithm-based decision-making systems and artificial intelligence (AI) tools.
- To assist with technical issues (e.g., if you began but did not complete the entry of details (and did not click "Confirm", "Send", etc.), or to contact you further to your interest.
Providing your Personal Information
Other than as set out in this Policy, the Personal Information you provide to the Group or the Group collects will not be provided to, sold to or shared with third parties without your consent, with the exception of the following cases –
- To the extent necessary for proper provision of the Group Services – we are permitted and may share Personal Information with third parties on our behalf, which assist us in operating the Group Services, managing the Group's business or providing the services that are being provided to you on behalf of any of the Group companies, such as subcontractors. Such third parties may use and process your Personal Information only to the extent required for the performance of the services they provide to us and in accordance with the Group's instructions, and they must take information security measures to protect and maintain the confidentiality of your Personal Information.
- For example, and solely for illustration purposes, we use the identification and verification services of a third party that uses tools and means of biometric recognition to comply with various regulatory obligations and anti-money laundering laws, in relation to some of the Group Services and digital subscription mechanisms.
- We may share Personal Information with third parties that have been authorized by you, in the context of the services provided to you on behalf of any of the Altshuler Shaham Group companies or in the context of another engagement between you and the Group.
- If you breach the provisions of the Terms of Use of the Group Services or any of the binding documents, or if you commit or attempt to commit, by means of or in connection with the Group Services, acts deemed by the Group to be in violation of the law.
- If the Group receives a judicial order or a demand by a competent authority ordering the Group to hand over to a third party or to the relevant authority your details or the Personal Information that pertains to you.
- 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 where 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, Group companies may transfer and share your Personal Information between them, provided that they use this information only according to the provisions of this Policy.
- For the purpose of providing and sharing information with companies or other organizations related to the Group and with suppliers, business partners, advertisers and any third party. The Group will not knowingly disclose your identity to such parties without your consent.
- If the Group or any of its companies organize their operations or the operations of any of the Group Services in a different framework, and in the event that the Group changes its legal structure, including where the Group's operations or part thereof are transferred to a third party – we may transfer a copy of the Personal Information about you to the new entity, provided that such entity undertakes the provisions of this Policy with respect to you.
- Pursuant to your express request.
Where is the Information Stored?
The information the Group or any of its companies collects is kept in Altshuler Shaham's databases, which are stored with data backup and server hosting providers, which may also be situated outside of Israel, unless and to the extent that the law requires that the information be kept locally. Additional information, as specified in this Policy, is collected and stored by other companies (such as statistics companies, companies that provide identification and verification services, etc.), which may also keep the information outside of Israel. Your consent to this Policy also constitutes consent to the information being kept abroad and to transfer of the information outside of Israel, including jurisdictions where the law may provide a lower level of information protection than the level prevailing under Israeli law, and all in accordance with the provisions of the law.
Information Security
The Group considers the security of the information in its systems to be of utmost importance. To safeguard and protect the information, the Group operates information security systems, applications and procedures that are designed to minimize the risks of theft, damage, loss or unauthorized access to information, including Personal Information. However, there is no certainty that such applications provide an absolute guarantee against the exposure or theft of Personal Information from the databases. Therefore, the Group does not guarantee, and you cannot reasonably expect, that the services and information systems that are used by Altshuler Shaham will be immune from unauthorized access to the information stored in them. By using the Group Services, you acknowledge and agree to these limitations.
'Cookies' in Digital Services
We use 'cookies' and other data analysis tools within the Group's digital services. As part of using the Group Services (even without personally identifying yourself as a customer), information about you will be collected by various collection tools, including web beacons, pixel files and cookies. Such information may also include information about the end device from which you browsed (including the device ID), IP address, duration of time spent on the site or on a specific 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 another end device, such as tablet or phone) where it is stored. Cookies may contain a range of diverse information, such as information about the pages you visited, the duration of time you spent with the service, the point from which you reached the service, the information you wish to see when logging into the service, and more. The use of cookies is intended for several purposes, inter alia, for tracking 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 by these means will be used for marketing purposes, including displaying ads for and offers of various products and services of the Group, including personalized ads, when you visit the Group Services and/or other websites. The Group also uses cookies to cross-check information collected about you in the context of 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 specified in this section above and in this Privacy Policy.
Some of the cookies we use in the Group Services are our own cookies (first-party cookies) and others belong to third parties (third-party cookies).
In this context, it is noted that the Altshuler Shaham Group also uses the collection technologies of third parties, such as Google, Meta, and Taboola, and the statistics and tailored advertising services of LinkedIn (including the Firebase system), Google, Taboola, Meta, TikTok, X, RTB House and Outbrain. Within this framework and for the aforesaid purposes, Altshuler Shaham may transfer information about you to such third parties, which shall use the same for their own purposes. Third parties such as Google, Meta and Taboola will use collection tools like 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 such third parties use information collected by means of cookies and/or the information they receive from Altshuler Shaham may 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 the settings of your browser or end device to disable certain types of cookies or remove them manually. However, after you disable the cookies or remove them from the end device, it is possible that you will not be able to derive the maximum benefit from the services provided to you by the Altshuler Shaham Group, or that some of these services will not be available to you.
You may 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 funds in your child's name, if any, will be stored in the databases of the Altshuler Shaham Group companies and will be used, inter alia, for purposes of management, operation and marketing of the products and services of the Altshuler Shaham Group; management and improvement of the efficiency of customer service and relations data cleansing, processing and production of information for operational, marketing and statistical purposes; direct mailing; offers of content and services that are provided by the Altshuler Shaham Group and provision of the information to third parties for the purpose of accomplishing the aforesaid objectives or pursuant to any law or your explicit consent.
As concerns Personal Information that is collected as part of the use of the Group Services, the "Database Controller", within the definition of this term under the Protection of Privacy Law, 5741-1981, is the Altshuler Shaham Group company with which you engaged to receive services and/or products and/or other information. For additional information, please contact us as specified at the bottom of this Policy.
Social Media
Altshuler Shaham provides users of the Group Services with tools for sharing and linking content by means of social media and various online services, and we also direct Users to Altshuler Shaham’s various social media accounts, such as the pages operated by the Group on Facebook, YouTube, LinkedIn, Instagram, X and elsewhere. Please note that the use of such social media and online services is external and separate to the Group Services and it is subject to the privacy practices of such services and the respective privacy policies of each such service. This Policy does not apply to the operations of said social media nor to any third party-operated online service.
Third Party Communication Services
Some of Altshuler Shaham's services entail the use of third-party communication services (e.g., WhatsApp and connection to cellular providers’ internet services) ("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, performance or quality of these Third-Party Services. The Group shall not be responsible for the availability, content or operations of Third-Party Services. The User is exclusively responsible for the decision to use a service that entails the use of Third-Party Services. Furthermore, the use of Third-Party Services shall be subject to any policies and terms of use, including privacy policies, of the relevant Third-Party Services.
Right to Inspect Information and Amendment of Information
According to the Protection of Privacy Law, every person has the right to inspect, in person or by an attorney authorized by him in writing or by a guardian, information about him that is held in a database. A person who inspects the information about him and finds it to be incorrect, incomplete, unclear, or out of date may contact the Database Controller with a request to amend or delete the information, all in accordance with the provisions of the law. If the Database Controller refuses, it must notify the applicant in such manner as specified in the Regulations under the Protection of Privacy Law. Refusal by a Database Controller to allow inspection and a notice of refusal to amend or delete information may be appealed by the information applicant in such manner as prescribed by the said Regulations. For inquiries on this matter, please email: DPO@altshul.com.
Please note that the deletion of information may prevent you from continuing to receive services from the Group or negatively affect the service provided to you. Information that is required by the Group for the purpose of managing its business – including records of acts you have carried out – shall continue to be retained by Altshuler Shaham by law but shall no longer be used for the purpose of contacting you. If you do not receive, within 30 days, notice that the information the Group had been requested to delete was indeed deleted according to this section, you shall be entitled to petition the court to order the Group to do so in such manner as specified in the Regulations under the Protection of Privacy Law.
Furthermore, if the information in the Group's databases is used for the purpose of contacting you personally, based on your belonging to a demographic determined according to one or more characteristics of persons whose names are included in the database ("Direct Mailing Communications"), you are entitled under the Protection of Privacy Law to demand in writing that the information relating to you not be used for direct mailing purposes. To opt out of the Company’s Direct Mailing Communications, please email: DPO@altshul.com. However, the Company may still send you operational notices and/or notices that it is permitted or obligated by law to send you, even if you opt out of direct mailing.
Privacy of Minors
Altshuler Shaham is committed to protecting the privacy of Users of the Group Services in general, and the privacy of minors in particular. We encourage parents and legal guardians to take an active interest in and monitor their children's online activities. 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 the collection and use of such information in the services provided by the Group or for the purpose of any activity or service provided via any of the Group companies.
Revisions of this Policy
The Group may revise the terms of this Policy from time to time (just as it may revise any of the binding documents, as set out in the Terms of Use). If we incorporate material changes into the Policy, we shall post a notice on the homepage of the Group’s website or send you notice according to the contact details you provided to us, at our discretion. If we incorporate such changes based on the provisions of any law or a demand by a competent authority – the revisions will take effect according to the provisions of the law or such demand.
Continued use of any of the Group Services after the change constitutes your consent to the current Policy, but we may ask you to confirm the current Policy, or all the binding documents or the engagement document that is relevant to the service. If you do not agree to the updated version of the Policy, you should stop using the relevant service. You may review the up-to-date Policy at any time by clicking the appropriate link in the relevant service or on the Group's homepage.
Contact Us/Report a Privacy Violation
If you have any questions, suggestions, requests, complaints, etc., or if you believe that your privacy was violated while using any of the Group Services, or with respect to the Policy or the Group's privacy practices, please contact us by using any of the contact methods specified on the Group’s website, or any of the following, and we will do our best to address your inquiry as soon as possible:
- Telephone: *5054 (08:00 – 16:00).
- To contact the Privacy Protection Officer directly, email: DPO@altshul.com.
- Online contact form on the Group’s website.
- Postal address: Altshuler Shaham – 19A HaBarzel St., Ramat HaHayal, Tel Aviv-Jaffa 6971026 (please note on the envelope "Attn.: Privacy Protection Officer").
Last Updated: 26.10.2025
