PRIVACY POLICY

Eltive ITMC Ltd. (“the Company”) takes measures to safeguard information security and protect your privacy and hereby commits to maintaining the policy set forth below (“Privacy Policy” or “the Policy”).

The purpose of this Policy is to explain how the Company collects, uses, processes, and shares personal information, and how it handles matters relating to the privacy of users of the website and the Company’s various services (“Services”), as well as how the Company acts in connection with “personal information” as defined under the Privacy Protection Law, 5741-1981 (“Privacy Protection Law”), which is provided to the Company by you or collected by it when you use the website or when you use or receive the Services.

This Privacy Policy constitutes an addendum to, and forms an integral part of, any agreement or terms of use document related to the website or the Company’s services. Specific terms of use applicable to services you consume from the Company shall prevail over this Privacy Policy in the event of a conflict between the two.

The Company may update this Privacy Policy from time to time, and we therefore recommend that you periodically check whether any changes have been made. Updates or changes to this Policy shall take effect immediately, and we recommend staying informed. The Company will make efforts to publish a notice on the website if essential changes are made. You may view the updated Privacy Policy at any time by clicking the “Privacy Policy” link on the website.

Your continued use of the Site or Services after a change to this Privacy Policy will be deemed as your full acceptance of the updated policy.

You are under no legal obligation to provide personal information. However, please note that some information is required in order to use the website and our Services properly. If you choose not to provide personal information that is requested through the website or the Services, you may be unable to use the website or the Services, receive certain information, or carry out certain actions. Personal information will be used in accordance with the purposes and uses described in this Policy. For the avoidance of doubt, this Privacy Policy applies to all information, including all identifying personal information provided by you, as well as information collected about you while you browse the website or use the Services. If you do not wish the Company to use information about you, you are asked not to use the website or the Company’s Services.

The Company also operates in cooperation with financial entities, businesses, and various operational parties such as tourism suppliers in Israel and abroad, International commercial airlines, international credit card organizations, clearing companies, service providers, and other business partners. In some of these cases, such third parties may act as independent controllers of personal information or as joint controllers together with the Company. In such cases, the applicable privacy policies of those entities shall also apply.

 

This Privacy Policy applies to all genders.

Section headings are for ease of reading only and shall not be used for the interpretation of this document.

1. Information We Collect

1.1       In order to provide the Services conveniently and efficiently, you may be required to provide the Company with certain details about yourself, whether directly and/or indirectly through third-party systems and/or business partners (including but not limited to group companies) and/or third parties associated with the Company. Such details may include, inter alia, and depending on the type of service requested or the use of the website: your full name, email address, mobile phone number, address, credit card details, curriculum vitae, passport scans, identity card numbers, date of birth, identification documents etc.

This information is used for the purpose of providing the Services and for the other purposes set out in this Policy and enables you to make proper use of the Company’s systems.

1.2       As part of the Services, the Company may send you emails or text messages from time to time, for example upon registration for the Services and when there is any update and/or change related to the Services. Additionally, we may occasionally send you communications, including direct e-mails, links to professional articles, updates related to the website, the Services and the Company, information about promotions, special offers etc., all subject to your consent or as permitted by the applicable law.

1.3       In addition, the Company may send you marketing information from time to time via various means such as email, SMS, social media, and WhatsApp regarding its services and/or those of its business partners that may interest you, as well as other marketing and promotional content, subject to your consent and authorization for the Company to use the information for such purposes. You may at any time request that we cease sending you such marketing communications, using the means specified in those communications or by contacting us at: [please enter the email address associated with removal-from-mailing-list requests], and we will remove you from the requested channel.

Please note that a request to stop receiving marketing communications does not, in and of itself, constitute a request to access and/or correct your information from the Company’s database. If you wish to access and/or correct such information from the Company’s database, you may do so by contacting us as set out below.

1.4       Information about others – If you provide the Company with any data relating to third parties, it is your responsibility to ensure that such data is provided to us with their knowledge and consent to this Privacy Policy. For example, when ordering a vacation package or other service from the Company that includes details of additional travelers, it is the user’s responsibility to obtain the consent of those additional travelers to the transfer of their information to the Company and to the sharing of their booking details with the person making the reservation.

1.5       In the context of providing services to business clients, the Company may receive personal information about the user directly from their employer or the business client, including through HR files or direct transfer from internal organizational systems that manage employee data, for the purpose of creating a profile, managing travel, and providing the service.

1.6       The Company may collect operational information related to travel bookings, booking modifications, cancellations, issuance of travel documents, invoices, vouchers, and additional components required for the actual provision of the service.

1.7       The Company may collect non-personal information, such as usage data, statistical data, and system data, for the purpose of improving services, operations, analysis, and oversight.

1.8       The website may use cookies or similar technologies for the purpose of website operation, customizing user experience, usage analysis, and service improvement. You may prevent this through your browser settings.

1.9       When user leaves contact details on the website (for example, through a contact form), the information will be used for the purpose of handling the inquiry, making contact, and providing a business response.

1.10    Information submitted through a contact form may be stored in CRM systems for the purpose of documentation, inquiry management, recording of business activity, and oversight.

1.11    Marketing communications will be carried out in accordance with the applicable law and subject to the user’s consent at the time of providing their details.

2.  Use of Information

2.1       The Company uses information collected about you for the following purposes, and by using the Services you agree and authorize the Company to use the information as described:

2.1.1   To provide you with the various Services, including to carry out the booking you have requested.

2.1.2   To offer you similar, complementary, or supplementary proposals in connection with the Services you have expressed interest in and/or purchased.

2.1.3   To advertise our products and services, offer benefits, conduct personalized marketing and mailing by us or on our behalf, or to advertise third-party products and services provided in cooperation with us, unless you have requested otherwise by contacting us through one of our contact channels. Such advertisements and mailings may be sent via various media channels such as email, SMS, social media, WhatsApp, and other means. You may opt out of receiving advertisements by contacting our customer service or by following the instructions in the marketing communication itself.                      Please note that even after a refusal or deletion request has been submitted, we will continue to send you, via the channels specified above, in whole or in part, notifications that we are required or permitted by law to send without your consent.

2.1.4   For information security purposes and fraud monitoring, as well as to prevent unlawful use.

2.1.5   For mailing and communications purposes.

2.1.6   For analysis of information, providing personalized recommendations and alerts, including using artificial intelligence (AI) tools, and for improving such tools to enhance your experience with Eltive ITMC Ltd.services, including by training and improving the tools based on data entered and generated.

2.1.7   For service improvement purposes.

2.1.8   For data presentation.

2.1.9   For ongoing monitoring of service usage and for management purposes.

2.1.10 For compliance with legal proceedings, including but not limited to civil or criminal orders, court orders, or other required disclosures; and for handling of various requests including access, correction, and deletion.

2.1.11 To respond to claims of infringement of third-party rights, whether such third party is a user, a private individual, or a government agency.

2.1.12 To respond to customer service inquiries.

2.1.13 To protect the rights, property, or personal safety of the Company, its users, or the public in general.

2.1.14 For billing in respect of the Services.

2.1.15 For detecting and preventing theft, fraud, and unlawful activity.

2.1.16 In the context of providing travel services to business clients, the Company also uses information for the purpose of generating reports for the employer, monitoring travel budgets, implementing organizational travel policy, and billing the business client in accordance with applicable agreements.

2.1.17 Operational information is used for the purpose of issuing travel documents, coordination with suppliers, operational communications with travel service providers, and providing information to the business client and the user.

3. Disclosure of Information to Third Parties

3.1       We may transfer personal information about you to third parties in order to fulfill the purposes set out in this Privacy Policy, in accordance with the applicable law, and subject to your authorization. Transfer of personal information to third parties are subject to the third party’s commitment to process the information lawfully and as required, depending on the type of information transferred. Information may also be transferred abroad, including to countries where the level of protection of personal information may be lower than that provided under Israeli law, including to the United States. The Company will not transfer personal information to third parties except for the purposes set out in this Policy and in the following cases:

3.1.1   Disclosure of information or part of the information to third parties or partners  who are involved in the services offered or to be offered, including subcontractors and suppliers who enable us to provide the Services. It is emphasized that, unless otherwise stated, such parties have no right to use this information beyond the purpose for which the Company provides it.

3.1.2   Suppliers such as payment systems (domestic and international), information systems, cloud systems, financial institutions, consultants, lawyers, accountants, service centers, communication providers, or entities such as WhatsApp (whose use is also subject to its own terms), printing houses, and providers of postal and mailing distribution services, suppliers of ancillary services and marketing products, advertising, and mailing purposes, etc.

3.1.3   In the event of a legal dispute between you and the Company that requires disclosure of your details.

3.1.4   If an appropriate court order is received, or in any other case where a legal obligation exists.

3.1.5   In the event of the sale and/or transfer of the Services and/or any part thereof to a third party, including by way of merger or reorganization, provided that the receiving party undertakes to comply with the obligations under this Privacy Policy.

3.1.6   In the event that you request the Company to transfer your details to any third party.

3.2       In addition, as part of its ongoing operations, the Company may utilize and/or make use of systems belonging to third parties or other companies within the group that provide services in connection with the Services, such as collection services, management, data analysis, service improvement, etc. In all such cases, we ensure that we use suppliers and systems that maintain high levels of security and privacy protection, and we ensure that only the information necessary for the performance of the requested activities is transferred to such third parties or external suppliers, subject to their commitment to maintain the confidentiality of the information at least to the standard required of the Company.

3.3       Information provided by you or collected about you will be stored in the Company’s database, on servers located in Israel and abroad.

3.3.1   In the context of providing the Services, personal information will also be transferred to travel service providers such as airlines, car rental companies, hotels, and global distribution system (GDS) providers, to the extent required for the purpose of processing the booking and providing the service.

3.3.2   Information may be transferred to the employer (under the B2B model) for the purpose of generating reports, accounting adjustments, billing, oversight, and compliance with organizational travel policy.

4.  Your Rights Regarding Your Information

4.1       Under the Privacy Protection Law, every individual is entitled to review information stored in a database that relates to them. This right applies to you as well, following submission of a formal request to the Company. If you review the information we hold about you and find that it is incorrect, incomplete, unclear, or outdated, you are entitled to contact us and request correction of the information, and in certain cases, its deletion. Additionally, where the information relates solely to direct marketing communications addressed to you, you are entitled to demand that we delete your information from our database used for direct marketing purposes.

In such cases, we will delete the information used to send commercial offers to you; however, certain other information about you may continue to be stored in the Company’s systems and database in accordance with the requirements of applicable law.

4.2       Requests regarding the right to access and correct information may be submitted to the Company in writing by email at: [please enter email address]. The Company may request certain identifying details from you in order to verify your identity before responding to your request.

5.  Jurisdiction

Exclusive and sole jurisdiction over all matters arising from or related to this Privacy Policy and the Services shall be vested solely in the competent court located in Tel Aviv-Jaffa, Israel. This Privacy Policy shall be governed by Israeli law, regardless of the user’s location.

6.  Information Security

The Company employs accepted and appropriate security measures to maintain and protect the integrity and confidentiality of information. However, the Company cannot guarantee the complete and absolute security of the Services, and therefore we do not undertake that the systems and services will be entirely immune from any intrusion and/or unauthorized access.

To the extent that your particular field of activity and/or the information you provide requires unique and/or non-standard information security and/or confidentiality measures, the obligation to verify that the website and Services meet your needs rests with you, and the Company shall not be liable in any way for any consequences arising from your use of the website or Services.

7.  Data Retention

The Company will retain information about you for as long as such information is necessary to achieve the purposes set out above, or for the period permitted by law, in accordance with applicable legal requirements. The duration for which the Company retains information depends on the purposes for which it was collected, the manner in which it is used, and applicable compliance requirements. Your information will be used by the Company subject to the provisions of applicable law, including, inter alia, for the purpose of responding to regulatory requirements and defending against claims for as long as required.

8.  Contact Details

For additional information and questions regarding this Privacy Policy, you may contact the Company by email at:

limorlevy@gbtil.co.il

This Policy was last updated in: May 2026