Privacy Policy

1. Introduction

We respect the privacy of users of our services. The purpose

of this Privacy Policy document is to outline, in principle, the types of personal information we collect, the

purpose of its collection, the uses and processing that are or may be performed with it, and its transfer to third

parties. We will also provide information regarding your rights concerning the personal information we collect about

you. These actions are carried out by us in accordance with the provisions of the Protection of Privacy Law,

5741-1981 (hereinafter: “the Law”) and the regulations enacted thereunder, the Communications Law

(Telecommunications and Broadcasting), 5742-1982, and other applicable legal and regulatory provisions, including

the licenses under which we operate.

This document is drafted in the masculine form for convenience only and is intended for both

women and men alike.

This Privacy Policy pertains to Gigante (Company Number 516716834), hereinafter

referred to as “GigaNet,” “the Company,” and in the first person as “we” or “us.”

When we use the terms “information” or “personal information” in this Privacy Policy, we

refer to data about the private affairs of an identified or reasonably identifiable individual, which is protected

by the Law. This Privacy Policy does not apply to data that does not pertain to the private affairs of an identified

individual (e.g., aggregate data) or to corporations.

This Privacy Policy applies to users (as context dictates) and does not apply to the

Company’s employees, job applicants, or suppliers.

This Privacy Policy supplements specific provisions provided to you, for example, on

websites, specific consents you have agreed to, and similar contexts.

We may update this Privacy Policy from time to time as needed. The updated Privacy Policy

document will take effect upon its publication on the GigaNet 972.

You are not legally obligated to provide us with information, but if you refuse to do so, we

may not be able to provide you with services.

2. Types of Information We Collect

New GigaNet 972 collects, holds, and processes various types of information about users. This

information may vary depending on the services and products. Examples of the types of information we collect or may

collect include:

Personal details, identification details, contact information, and personal data –

including, for example: name, ID number, residential addresses, postal and email addresses, and phone

numbers.

Additionally, GigaNet 972 may collect information about you when you respond to

identification and security questions or contact GigaNet’s customer service, including telephone

recordings and information derived from them.

Financial and economic information – credit card number and expiration date, etc.

Public information and information usable under the law – such as data from state

databases, the Central Bureau of Statistics, credit data service providers’ databases, other databases, and

information publicly available through various media, the internet, social networks, etc.

Preference information – spoken language, preferences regarding housing and

information use, areas of interest, preferred channels and programs, etc.

Location information – information regarding the location where the service is used.

Information regarding service usage – this may include, among other things, details

about how you use the services provided by the Company, such as internet infrastructure usage (e.g., usage

volume, IP addresses, usage times, usage patterns, equipment and infrastructure used, third parties such as

internet or communication providers through which our services are used, etc.).

Information about equipment, including routers – this may include details about

various types of equipment (e.g., routers and other components) used with the Company’s services or provided

or purchased from the Company. This information may vary depending on the type of equipment and service and

may include, for example, device model, identifying information such as serial number and communication

equipment address (MAC), information stored on the equipment such as applications and software, and the

systems used, etc.

3. How GigaNet Collects Information

New GigaNet collects information directly from the user, from the network, from usage, from

end-user equipment, and from third parties. For example:

Information you provide – GigaNet will collect information you provide about

yourself and others, including at the time of registration, during inquiries about engagement, while using

the services, when contacting customer service, participating in surveys or promotions, and through any

other means by which you choose to provide us with information.

Information collected automatically – When you register for or use services and

equipment, including the GigaNet website and applications, information about you is automatically

collected by GigaNet’s systems and those of third parties involved in providing the services.

Additionally, customer service calls are automatically recorded, and service centers are secured with

surveillance cameras.

Information received from third parties – GigaNet receives information about you

from third parties, such as state authorities, other communication companies, subcontractors, outsourcing

providers, surveyors, marketing consultants, any legal source permitting the transfer of information, legal

databases, public information, and any other information you have consented to transfer to the Company.

Subject to your privacy settings, GigaNet may receive information you have uploaded or that has been

uploaded about you to the internet and/or social networks, as well as information from social network

operators where you have an account. We may process the information stored in our databases and

cross-reference it with information received from third parties.

GigaNet will retain the information for as long as necessary to fulfill the

purposes of its use as detailed in this Privacy Policy, or for a period required by law, or as needed to

protect GigaNet’s rights and legitimate interests, whichever is longer. To ensure that personal

information about you is not retained beyond the necessary period, GigaNet conducts periodic reviews and

deletes excess information that is no longer required.

4. Use of Information

The information collected by GigaNet is used for various

purposes, including providing services to you and others, personalizing services, analyzing, managing, developing,

optimizing, and improving services, systems, customer service, and marketing for all or some users, communicating

with users on various matters (including via direct mail), processing information for GigaNet’s needs or those of

third parties, complying with legal requirements, and protecting GigaNet’s legitimate interests. Among other

things, we will use the information for the following purposes (the division into subsections is for convenience

only):

1. Ongoing Operations, Service Provision, Marketing, and Tailored Offers,

including:

Providing services, operating them, and tailoring them to your needs and

characteristics, including offering recommendations (e.g., based on location, equipment used, or usage

patterns).

2. Communication with Users, Marketing, and Advertising, including:

Communicating with you and others (including via direct mail) for various purposes,

including marketing and advertising existing and new products and services, informing you about various

matters—including notifications we are required or permitted by law to send—and other information related to

GigaNet or third parties. Communication between us will be conducted via electronic means (e.g., email,

chat, etc.), mail, SMS, automated dialing systems, and any other communication method.

Providing service and performing marketing activities.

Subject to applicable law (including the Protection of Privacy Law and the

Communications Law (Telecommunications and Broadcasting), 5742-1982), we may send you marketing and

promotional content and additional information based, among other things, on your personal characteristics

(e.g., the type of router you own, preferred language, services you’ve used, network usage, or location).

Handling inquiries, complaints, issues, and responding to questions you direct to

us.

3. Management, Oversight, Development, and Improvement of Operations, Services,

Marketing, and Systems, including:

Performing management, oversight, and improvement activities for all Company

systems.

Monitoring and controlling the scope and nature of usage of various services.

Improving services, products, and marketing tools, and developing new products

(including through market research, surveys, and statistical processing and analysis).

Processing and analyzing information, including using advanced data analysis tools

regarding the usage of GigaNet’s services and products by users and others, aimed, among other things, at

analyzing and understanding the user base, their preferences, and needs, improving the service experience,

and providing services for the benefit of third parties based on such information processing.

For documentation, training, monitoring service quality, preventing fraud, and

misuse. Maintaining procedures and policies, such as recordings, audits, information security, billing and

collection, business continuity, disaster recovery, and record-keeping.

Using third-party databases as permitted by law, including official authority

databases that GigaNet is entitled to use to verify and enhance the personal information it holds.

4. Fraud Prevention, Information Security, and Data Minimization,

including:

Performing oversight and information security activities for various purposes,

including protecting personal and commercial information, safeguarding systems against attacks and misuse,

and ensuring proper system functionality.

Detecting, preventing, and addressing cases of theft, fraud, non-compliance with

Company procedures, misuse, illegal activities, and activities prohibited under the engagement agreement,

including identifying cases and activities with unusual or differing patterns.

Performing processing activities for personal data minimization, including

anonymization, pseudonymization, and aggregation of data for analysis, marketing research, and development

(for GigaNet and third parties), and oversight.

For your authentication and identification purposes.

5. Legal Purposes, including:

Compliance with legal requirements, including record-keeping and performing actions

GigaNet is required to undertake by law, including requirements from foreign authorities if GigaNet

deems it necessary to comply.

Providing information to authorized entities (e.g., government authorities and law

enforcement).

Providing information pursuant to judicial orders (in all types of proceedings) and

administrative directives.

Protecting GigaNet’s legitimate interests and legal rights, as well as those of

others, including settlements, defending against claims, and enforcing agreements.

Handling requests to access and correct information as needed.

6. Monitoring for Network Protection, Pricing, Operations, and Enforcing Our Legal

Rights:

As part of operating the services, we employ various monitoring measures, including traffic

monitoring, to protect the network, determine pricing, operate, bill, settle accounts, and enforce our legal and/or

contractual rights. We may act at our discretion and in accordance with the law based on monitoring findings (e.g.,

blocking traffic, rerouting, etc.). It is clarified that monitoring measures cannot guarantee certainty regarding

their findings or operation, and GigaNet will not be liable in cases where an action is or is not taken due to

these monitoring measures.

5. Transfer of Information to Subcontractors, Authorities, Other Communication Companies,

and Additional Parties

We may transfer information about you or parts thereof within GigaNet entities, to

related corporations, and to third parties (in Israel and abroad) to fulfill purposes permitted to us by law, with

your authorization, or as outlined in this Privacy Policy.

We undertake to take the necessary measures to ensure that third parties receiving

information are obligated to protect it as required based on the type of information transferred and the purpose of

the transfer.

Information will be transferred to entities such as the following:

1. Subcontractors, Suppliers, and Communication Companies, such as:

To communication companies or other service providers for the purpose of service

provision, billing, and collection.

To third parties acting as suppliers to GigaNet and/or collaborating with it,

providing GigaNet with various services that involve access to and/or processing of personal information

that GigaNet is permitted to handle itself, such as invoice issuance, debt collection, data processing,

marketing, and customer service.

To external suppliers with whom GigaNet collaborates for statistical and research

purposes, including advanced data analysis tools, and suppliers who assist GigaNet in converting

information into statistical and aggregate form for use by GigaNet and third parties.

To third parties, including business partners providing you with services and

products at your request, such as suppliers of ancillary services and products, including for service

provision, marketing, advertising, and direct mail.

To subcontractors in areas such as customer service and sales centers, information

systems, communication providers, cloud computing service providers, printing houses, postal and mailing

service providers, surveyors, marketing consultants, risk managers, lawyers, accountants, translators,

service providers, and other outsourcing providers.

To a person or entity you have authorized to receive information about you.

2. Mergers, Business Transfers, and Assignment of Rights:

Subject to legal provisions, GigaNet may transfer all information it holds about

you to a third party as part of transferring or assigning its business (in whole or in part) to that third

party, or as part of reorganization, full or partial transfer of operations, merger, joint ventures, or

other transactions related to GigaNet’s business (including during negotiations for such transactions),

and for the continued provision of services, customer service, sales, collection, etc., by the third party.

In such cases, the third party receiving the information will be subject to the same restrictions on its use

as apply to GigaNet, as detailed in this Privacy Policy.

We may transfer information about you in any case where GigaNet is permitted by

law to assign its obligations or rights to another party.

3. Law Enforcement Authorities, Legal Proceedings, Judicial Orders, and Legal

Authority, including:

GigaNet will transfer information about you to state authorities or any other

person or entity when the transfer is required or authorized by law, pursuant to an order from a competent

authority, or based on appropriate judicial orders and decisions (including in response to orders from

foreign authorities and courts), and as part of transferring information to credit data companies.

GigaNet will transfer information about you to third parties to protect its legitimate

interests (e.g., in the context of legal proceedings or dispute resolution processes in which GigaNet is a

party).

4. Other Communication Networks, Websites, and Emergency Centers, such as:

Websites, applications, and communication networks through which your communication

passes will be able to identify your internet address (IP).

If required or permitted by law, or if GigaNet believes in good faith that it is

an emergency and necessary to protect you or others, information about you (including contact details and

your location, if known to GigaNet) will be provided to the appropriate entities (e.g., Israel Police).

The above does not detract from our right to transfer anonymous and/or aggregate data and/or

data that does not reasonably identify a specific individual to third parties. GigaNet may anonymize personal

information for research, statistical, and analytical purposes for the benefit of GigaNet or third parties.

Please note that since the services involve direct engagement between you and a third party,

the transfer of information by you to a third party is subject to the terms of engagement with that third party.

This policy does not apply to the collection of information by the third party, and GigaNet bears no

responsibility for it.

Therefore, whenever terms of use or a third party’s policy are brought to your attention,

and whenever you are asked to agree to such terms (e.g., when downloading an application or installing software), we

recommend reviewing them carefully, particularly the terms related to the third party’s privacy policy, the

information it is exposed to, and the uses made of it. For example, since your engagement is with internet access

providers, the terms applicable to you are also governed by their terms of use and privacy policies, which regulate

your usage, and the transfer of information is done directly by you, with no responsibility on the part of Future.

6. Personal Information About Others

Whenever you allow another person (e.g., an employee or family member) to use the products

and/or services we provide, you must inform them that you may be exposed to information about them and their usage.

In addition, in such cases, and whenever you provide us with information about other

individuals, you must ensure that the information is provided with their consent. You must also inform them in

advance, before they begin using the services or before providing information about them, of the contents of this

Privacy Policy, including the collection and use of information about them.

If you provide GigaNet with any preference (see below) or consent to the use of

information that actually pertains to a third party, including a user of the services, you must ensure in advance

that they consent to it.

If you use services registered under someone else’s name, you should be aware that this

Privacy Policy also applies to information accumulated by GigaNet about you and that information about you may be

disclosed to the registered customer.

7. Advertisements, Direct Mail, and Contact Methods

We may contact you through various means and channels,

including based on the identifying details you provided us, such as contact methods. Our communications may include

offers and various promotional messages from us and/or suppliers or third parties, including direct mail

(personalized mail based on your personal characteristics). We may also contact you with various service-related

messages and notifications we are required to send by law, licenses, and/or regulatory guidelines.

Such communication may be conducted via any means GigaNet deems appropriate, including

mail, email, landline phone, mobile phone, automated dialers, SMS, multimedia messages, electronic messages, fax,

social networks, and other means.

You may contact our customer service to set your preferences, which will limit some of the

communications directed to you. For information on how to choose your preferences, see Section 13 below.

Please note that the preferences available to you apply only to certain types of

communications and channels. For example:

We may send you notifications we are required to send by law, license, and/or

regulatory guidelines, or any other message we are permitted by law to send despite your preferences.

We may send you advertisements through channels for which you are not entitled by

law to refuse, such as via postal mail.

Use of Cookies and Automatic Data Collection Technologies on Websites

To provide you with faster and more efficient service, identify you upon re-entering the

website and/or applications, and save you from repeatedly entering personal details you previously provided, New

Future uses a technology called “Cookies,” which are unique internal markers stored in the end user’s browser, as

well as other technologies (e.g., Web Beacons, Pixels, SDK, etc.) (hereinafter: “Automatic Collection

Technologies”). These technologies are not computer software and cannot read other information or perform actions on

your computer or mobile phone. Some automatic collection technologies expire when you close your browser, while

others are stored on your device or computer.

Automatic Collection Technologies enable GigaNet to monitor your activity on the website

and applications, enhance your browsing and service experience, and improve information security. Additionally,

these technologies assist GigaNet in optimizing marketing activities on the website and/or applications. For

example, they allow Future to collect and characterize various data about users and their usage of online services,

actions performed, usage preferences, advertisements you were exposed to, tailoring services and products to your

personal preferences or needs, targeting advertisements and marketing content based on the collected and processed

information, and cross-referencing this data with other uses of online services and platforms provided by or through

GigaNet.

To this end, Automatic Collection Technologies collect and transmit information, including

about your activities on websites and applications, as well as information about the computer (or smartphone) from

which you browse. This information includes, among other things, operating system version, browser type, IP address,

time spent on the site or a specific page, location, and more.

GigaNet uses several Automatic Collection Technologies:

For more information on how data is collected and used, you are welcome to review examples

at: http://policies.google.com/privacy?hl=en, http://www.facebook.com/policies/cookies, http://www.google.com/analytics/terms/us.html

This list is not exhaustive, and GigaNet uses additional data collection technologies as

noted.

GigaNet may allow companies and third parties to use the website and/or applications to

advertise their services (hereinafter: “Advertising Companies”). The publication of content by Advertising Companies

may involve the use of Automatic Collection Technologies. The use of these technologies by Advertising Companies is

subject solely to their privacy policies, not GigaNet’s.

Additionally, GigaNet may choose to advertise information about itself on various

websites and applications you visit, using Automatic Collection Technologies for personalized advertising.

While using these sites, information may be collected, and GigaNet may use it to tailor

the promotional content displayed to you based on your interests. GigaNet is not responsible for the operation of

other websites you browse or the content offered therein. These are entirely independent sites, and you should

review the privacy policy documents of each such site.

If you do not wish to allow us to collect information about you using Automatic Collection

Technologies, you can prevent this by adjusting your browser and/or end-device settings. You can also delete these

technologies from your computer at any time. However, disabling Automatic Collection Technologies may prevent you

from using some services and features on the website, applications, and/or other websites. Changing browser or

computer settings is your sole responsibility.

Security Measures, Information, and Encryption

GigaNet employs appropriate security measures for the information it holds, in accordance

with all privacy protection laws and confidentiality requirements, and to prevent unauthorized access to the

information. GigaNet uses administrative, physical, and technical tools collectively designed to protect the

information stored in its systems and periodically assesses the system’s resilience.

Despite the above, there remains a risk of breaches into data repositories. As long as New

Future takes reasonable security measures, it will not be liable for damages caused by unauthorized breaches or the

transfer of information to a third party due to such breaches.

Effective security also depends on you. Therefore, we recommend taking various steps to

protect your personal information. It should be emphasized that the following are partial recommendations only and

are not intended to be exhaustive regarding the protection of personal information:

Protecting Login Details – In cases where we provided you with, or

you defined, a username and password enabling access to private information about you (e.g., accessing a

personal area on the website or application), you must safeguard these details, refrain from sharing them

with others, and periodically change your password. You are responsible for the use made of your username

and password, even in cases of unauthorized use by others without your consent (including if such details

are used with GigaNet).

Various entities may attempt to fraudulently obtain your identification details, for

example, by sending you a fake email mimicking GigaNet’s trademarks and design or through a counterfeit

website that closely imitates GigaNet’s official site. This way, these entities unlawfully attempt to

gain your identification data to access your accounts.

You should pay particular attention to unsolicited messages not personally tailored

to you, those containing spelling or grammatical errors, or unexpected communications. If a message contains

links, it is advisable to hover your mouse over the link. In many cases, although the link may appear to

direct to the official site, hovering over it will reveal a different address, sometimes similar to the

original (to mislead you). In any case of doubt, access GigaNet’s official site by manually typing the

full address into your browser (or searching via a search engine) rather than clicking a link sent to you

via email.

Updating Residential and Email Addresses – If the residential

address and/or email address known to GigaNet are outdated, mailings containing personal information will

be sent to an outdated address. You should update GigaNet regarding any changes to your residential

address and/or email address.

Protecting End-User Equipment (e.g., Router) – End-user equipment

infected with malicious software may allow others to access and potentially transmit personal information.

We recommend taking additional security measures, such as utilizing the security features of your device’s

operating system, using security software (firewall, antivirus, etc.), installing available operating system

updates, exercising caution on the internet (e.g., downloading content only from reliable sources), and

using social networks prudently (e.g., avoiding the exposure of personal details on social networks). The

security measures employed otpby GigaNet are primarily designed to protect GigaNet’s systems.

To provide services, you may be required to provide identification details, such as

payment method information you provided to us. If you are concerned about potential misuse of your

identification details or to prevent fraud, you may request a dedicated identification code. You should

immediately contact GigaNet’s customer service if you suspect that your identification details or

information about you have fallen into unauthorized hands.

8. Use of Advanced Data Processing Systems for GigaNet’s Needs and Third Parties’ Needs

As part of its ongoing operations, GigaNet receives information about you as described in

this Privacy Policy. Advanced data analysis tools enable the processing and analysis of this information. GigaNet

will collect, use, and process the information it holds, including information gathered from or due to users’

activities within the services (e.g., location data or browsing data). This analysis will be conducted by GigaNet

itself or through subcontractors or other third parties, after GigaNet implements appropriate information

security measures. This information will be used for GigaNet’s activities as outlined in this Privacy Policy.

Additionally, GigaNet may use the information for third parties and their needs. Using

data for third parties’ purposes can provide significant public and personal benefits. For example, browsing data

can yield insights that enable planning and tailoring promotional content to the characteristics of those exposed to

it, identifying the spread of epidemics, and more.

Before transferring data derived from advanced data analysis tools to third parties, New

Future will implement privacy protection measures to reasonably prevent the identification of specific individuals,

such as converting the data into statistical and aggregate form.

In this context, a “third party” refers to an entity receiving data for its own purposes,

such as local authorities, government entities, government companies, or private commercial entities (for this

purpose, a contractor or service provider to GigaNet or an entity receiving data for purposes related to services

provided by GigaNet is considered to be receiving the data for GigaNet’s needs, not its own).

Specific consents you have provided, which allow additional and/or identifiable uses of data

about you, will override this section in case of any contradiction.

The generation of insights using location data for third parties and their needs is

performed by us in accordance with specific regulations: the transfer of such data will be conducted with

appropriate information security measures to maintain the anonymity of users on the GigaNet network, under the

supervision of a special expert committee on information security and privacy (e.g., transferring only aggregate

data that does not reasonably allow identification of the customer). For more information, please refer to New

Future’s website.

If, despite the protective measures detailed above, you prefer that GigaNet not use

information about you for processing and generating insights for third parties’ purposes, you may notify us as

detailed in Section 13 below.

9. GigaNet’s Privacy Policy Does Not Apply to Linked Sites

(Links)

GigaNet’s website includes links to other websites. GigaNet is not responsible for the

privacy policies or information security of these sites. The policy outlined in this document applies solely to New

Future’s services, unless a different policy is specified for a particular service.

10. Your Rights, Control Options, and Preferences Regarding

the Use of Information About You

Israeli law grants you certain rights regarding the management of personal information, and

GigaNet, respecting your privacy, enables you to exercise them. To this end, we have established a team

responsible for handling privacy protection matters. You may contact this team via email at:

info@con972.cloudareus.com.

It is important for you to know that rights concerning personal information are generally

relative. Any request you submit to us will be reviewed in accordance with relevant laws, and we will inform you of

the results of this review and act accordingly.

Direct Mail and Advertisements – You may request to be removed from direct mail

(mailings based on specific personal characteristics, as per the law) through all mailing channels. To do

so, you may contact our customer service. Please ensure to include the necessary identification details in

your request.

You may request that we not send you advertisements (as defined in Section 30A of the

Communications Law (Telecommunications and Broadcasting), 5742-1982) via electronic messages, SMS, fax, or recorded

phone messages. To do so, you may contact our customer service. Please ensure to include your identification

details, the phone number or email address in question, and the list from which you request removal. You may also

opt out using the removal method specified in each advertisement sent by us. In such cases, the removal applies to

that specific channel.

Cookies and Third-Party Advertising Networks – You can prevent the receipt of

cookies through options offered by browsers or certain operating systems. Changing these settings is your

responsibility (note that some services may not be available or may require re-entering login details).

Additionally, third-party services such as Google Analytics and Facebook offer further

control options through user settings on their websites.

Right to Access and Correct Information – You are entitled to review the information

(as defined in Section 7 of the Protection of Privacy Law) we hold about you. If the information we hold

about you is inaccurate, incomplete, or incorrect, you may request that we correct it. To do so, please

contact us via one of the following methods: phone call to 6702*, email to info@giganet.net.il, or registered

mail to Haela 1 , Harish

The right to access is subject to legal provisions and the rights of others besides you

(e.g., if granting access could infringe on a third party’s privacy, such as a user requesting access without the

registered user’s approval). Future may decline to fulfill your request to access information about you (in whole or

in part) or fulfill it in a limited manner.

Use of Information for Processing and Generating Insights for Third Parties –

Although GigaNet undertakes to implement appropriate safety measures to protect your privacy and

anonymity, you have the right to notify GigaNet that you do not wish future use to be made of information

about you for processing and generating insights for third parties’ needs, as detailed in Section 11 of this

document. You may submit this notification (including your name, residential address, ID number, and phone

line number) via one of the following methods: phone call to 6702*, email to info@giganet.net.il, or registered mail to 11

Haela 1 , Harish

11. Use Abroad is Also Subject to Other Countries’ Privacy Laws

The laws of other countries may apply to you when browsing the

internet (e.g., when accessing a website located abroad). Generally, GigaNet’s systems are located in Israel and

managed in accordance with Israeli privacy laws. However, GigaNet relies on various suppliers located abroad to

provide services. If information about users is transferred outside Israel’s borders, GigaNet will export the

information in accordance with Israeli law. Under Israeli law, information may be exported abroad when appropriate

security measures are in place or when the export ensures adequate legal protection. In such cases, the information

may also be subject to the laws of the country where it is stored and processed.

12. Notices Regarding Changes

GigaNet reserves the right to amend this

Privacy Policy as needed or in response to changes in the law or regulatory guidelines under which we operate. The

updated document detailing our privacy and security policy will be available on our website at all times. You should

take note of these changes, as they will apply to you.