SAHEM TRADING AND INVESTMENTS COMPANY PRIVACY POLICY

1. INTRODUCTION

This privacy policy (Policy) sets out Company’s (“SAHEM”) commitment to and our policy in relation to your privacy. The provisions of this Policy apply to users of SAHEM Services through our branches, Platform ("Site"), or telephone unless stated otherwise.

This Policy is issued under the applicable laws of Palestine. SAHEM reserves the right to amend this Policy at any time without notice. Continued access or use of the Site means agreement to any changes.

By opening an account with us, you consent to the use of your personal data under SAHEM's general terms of business and this Privacy Policy.

2. PERSONAL INFORMATION

2.1 The nature of personal information

Personal information includes:

• Your name, address, date of birth, gender, marital status, employment details, assets, and income.
• Information about transactions, account balances, payment history, and website activities.
• Your opinions about products, services, and staff.
• Identification details to help verify your identity over the phone.

2.2 How we collect personal information

We collect personal information through direct contact, online forms, telephone calls, visits to our Site, cookies, and occasionally from third parties like credit agencies and public records.

2.3 Our purpose in collecting personal information

We collect information to process applications, understand your needs, respond to inquiries, manage products/services, conduct risk management, comply with laws, and other administrative tasks.

3. THE STORAGE AND PROTECTION OF PERSONAL INFORMATION

3.1 Storage and Access

We safeguard personal information with physical, electronic, and procedural protections.

3.2 Protection

We use physical security, network security measures, and staff training to protect your information. You can help protect your data by securing your personal details and notifying us of changes immediately.

3.3 Retention

We retain your personal information as long as legally or regulatorily required, even after our relationship ends.

4. DISCLOSURE OF PERSONAL INFORMATION

4.1 Disclosure to parties in the SAHEM Group

We may share your information within SAHEM entities.

4.2 Disclosure to third parties

We may disclose information to third parties such as service providers, regulatory bodies, professional advisers, and others authorized or required by law.

5. CLIENT ACCESS TO PERSONAL INFORMATION

You may request access to your personal information by contacting us:

• Fax: +972 (970) 2296 5713
• Email: sahem@sahem-inv.com
• Website: sahem-inv.com

6. EXCEPTIONS TO CLIENT ACCESS

We may deny access in certain cases, such as legal prohibitions, privacy risks to others, or commercial sensitivities.

7. UPDATING PERSONAL INFORMATION

To ensure accuracy, please notify us of any changes to your personal information.

8. RISKS IN USING THE INTERNET AND COMPUTERS

8.1 Client awareness of risks and security requirements

There are risks with online transactions. Protect your access codes and avoid public or insecure computers.

8.2 Other websites

Our Site may link to external sites with different privacy practices. Please review their policies carefully.

9. COMPLAINTS PROCEDURE

If you believe your privacy has been compromised, contact us. We aim to resolve complaints promptly, generally within three business days.

10. FURTHER INFORMATION

For more information about this Policy, please contact your usual SAHEM branch or email: sahem@sahem-inv.com.