Terms of Use

Summary of the Terms of Use

This summary of the terms of use of the Websites of Altshuler Shaham is intended for your convenience only. Reviewing the summary is not a substitute for reviewing the complete terms of use, which are presented immediately after this summary -

• The Websites of the Altshuler Shaham Group include information and online services of the group companies. The use of the Websites, including the content and services therein, means that you agree to these terms and other binding documents, including the Privacy Policy of the group's Websites. Please read them carefully, as they are binding agreements between you and the group.
• The Website serves as an online access gateway to broad information about the group and it includes diverse information, content and services. The Website even allows you to digitally join various products of the group, subject to the individual terms for joining each product and the provisions of any law.
• The information and content on the Website do not constitute an opinion, recommendation or offer for the purchase, sale or holding of any financial assets or pension assets and they are not intended to be used as investment marketing, advice, personal pension marketing, etc. In any doubt regarding the need to receive a professional opinion, you should contact the relevant professional entities.
• You may use the Website and participate in any activity of the group in accordance with the provisions of the law only and in a manner that does not harm the group or the rights of any third party.
• The use of the Website does not require registration. However, different areas and sections on the Website, such as the online mechanisms for joining the group's products, contacting the group, registering to receive information on various topics, and more - may involve registering and providing personal information. Registration on the Website is allowed for only users who are 18 years old and over.
• Altshuler Shaham respects the privacy of the Website users, as shown in the PrivacyPolicy of the group’s Website.
• Use of the sections that require registration, registration to distribution lists, as well as your approval of the binding documents, constitutes your express consent to receive advertising and direct mail from the group, including each of its companies. The advertisement will be sent to you using the contact information you provided to the group.
• All intellectual property rights on the Website belong to Altshuler Shaham, or to third parties who have granted the group the necessary rights of use. The trademarks of Altshuler Shaham group companies are the property of the group only.
• The group may place content of a commercial or advertising nature on the Website, including content originating from business partners and sponsors.
• The Website is made available to you for use on an as is basis ("AS IS"). The use of the Website and any content, or service therein will be made under your sole and full responsibility. The group will not be held responsible for any damage caused to you, or to anyone on your behalf, or to any other third party.
• The group does not guarantee that the Website's services and contents will not be interrupted, will be provided in an orderly fashion or without interruptions, safely and without errors, and will be immune from unauthorized access to the group's computers and databases, or from damage, breakdowns, malfunctions or failures.
• The group may periodically change the terms of use or any of the binding documents.
• The use of the Website will be governed exclusively by the laws of the State of Israel. The exclusive place of jurisdiction for anything and everything arising from the binding documents, or from the Website, is granted exclusively to the competent courts in the District of Tel Aviv, Israel.

Introduction

Welcome to the Websites of the Altshuler Shaham Group. The Websites include information and online services related to the Altshuler Shaham Group and its areas of activity (in these terms: the “Website”). This Website operates at www.as-invest.co.il. The Website as well as other sites of the group also operate at other addresses at the discretion of the group.

The Altshuler Shaham Group includes the following companies: Altshuler Shaham Ltd., Altshuler Shaham Finances Ltd., Altshuler Shaham Provident Funds and Pension Ltd., Altshuler Shaham Investment House Ltd., as well as all subsidiaries, affiliates and related companies (as defined in the Securities Law, 5728- 1968) and any other company or partnership held by the controlling shareholders of any of these companies, or a company held by them ("Altshuler Shaham", the "Group" or "We").

The use of the Website, including its contents and services, including registration or entry to the various sections that allow this, constitutes your express consent to these terms, to the Privacy Policy of the Website and additional instructions and rules that may be presented to you ("You" or the "User") during use of the various sections of the Website (together: the "Binding Documents").

The binding documents are worded according to the male gender for convenience only and they refer to all genders equally. Everything stated in singular, also refers to plural, as applicable.

Please read the binding documents carefully, as they are a binding agreement between you and the group and define your rights and obligations when using the Website. The binding documents may periodically change, so we recommend keeping up to date with them. If you do not agree to the terms of the binding documents, you are requested to refrain from any use of the Website.

The binding documents apply to use of the Website using any computer or other end device (such as smart phones, smart watches, tablet computers, etc.). Nothing in the provisions of the binding documents derogate from the provisions of any other agreement entered into between Altshuler Shaham and you, physical or online, or from the provisions of any law.

The Website includes a translation of its contents into different languages. In any case of a contradiction between the content of the Website in the Hebrew language and its content in any other language, the Hebrew version is the binding version.

About Altshuler Shaham and the Website in Brief

Altshuler Shaham engages in managing investment portfolios for others and for itself, managing provident and pension funds, managing mutual funds and more. The group's Website provides information, content and various online services regarding the group, its fields of activity and its various products, intended for the general public as a whole as well as for interested parties in various fields, such as agents, employers, investors, members of the press, job seekers and other parties. In particular, the Website includes digital processes for joining the various activities in the group.

The use of the Website is free of charge. Altshuler Shaham's Website serves as an online gateway to extensive information about the group and it includes diverse information, content and services. The Website allows you, inter alia, to digitally join various products of the group, subject to the individual conditions for joining each product and the provisions of any law.

The group has the discretion to decide which services, contents and information will be displayed on the Website, the length of time they will be displayed, what their location and design will be, and any other matter related to them.

The information and content on the Website do not constitute an opinion, recommendation or offer for the purchase, sale or holding of any financial assets or pensions and are not intended to be used as investment marketing, advice, including tax advice, personal pension marketing, or a substitute for such marketing that takes into account the unique information and needs of each person. You agree that any reliance on statements, opinions, advice or any other information displayed on the Website is at your own discretion and under your sole responsibility.

The Website includes information and content in various fields, including professional, legal fields or those involving one expertise or another. For the avoidance of doubt, the contents of the Website are intended to provide general information and guidance only. In any case of doubt regarding the need to obtain a professional opinion or guidance, you must contact the relevant professional authorities. The statements on the Website should not be regarded as a commitment by Altshuler Shaham to obtain excess returns.

Although Altshuler Shaham takes measures to ensure that the information and data that appears on the Website is correct, based and reliable, Altshuler Shaham does not guarantee the degree of accuracy, entirety and the up-to-dateness of the information as well as its suitability for any need.

Registration Procedures and Providing Details

The Website is intended for the general public. However, the sections of the Website that require registration, providing details, or entering access details provided to you ahead of time, are intended for users of the age of 18 and over only, or in accordance with the provisions of the law. You acknowledge and represent that you are 18 years of age or older when using any of these Services.

The use of the Website does not involve registration. However, various areas and sections of the Website, such as the online mechanisms for joining the group's products, contacting the group through online contact forms, registering to receive information on various topics (including information brochures and marketing content), and more - may involve registering and providing personal and identifying information, such as full name, telephone, active email address, and other details according to need and the circumstances of the matter.

In most cases, the details of the person that will be a member or customer must be filled in, so that the group can contact him, transfer documents related to his account or to the joining procedure, and more. It is possible that when providing the aforementioned details you will be required to actively and explicitly confirm your consent to the terms of the binding documents, or documents that specifically relate to the relevant product.

You will be able to complete the registration in each of these cases after providing the details requested during it and after receiving your consent to the relevant documents, to the extent requested. If you are asked to provide details in order to use any of the Website's services, you must provide only correct, accurate and complete details. Incorrect details may prevent you from using the full features of the Website, foil the desired contractual engagement and, if necessary, foil making contact with you.

The use of different parts of the Website, such as the Personal Area (as set forth hereafter) may involve entering a username and password (as chosen by you during registration or as provided to you by the group), which will identify you each time you enter the relevant section. The group may determine, from time to time, additional or other identification methods. Keep your username and password confidential to prevent their misuse. Be sure to change the password as often as possible.

The group will use your details, including any information you enter or update in the Personal Area, in accordance with the Privacy Policy of the Website, which is an integral part of these terms of use.

The group may prevent you from using the sections of the Website that require registration, including the Personal Area, at its discretion. Without derogating from the aforesaid, the group may block your access to the sections as mentioned, or cancel your registration to them, in any of the following cases -

• if you intentionally provided incorrect information;
• If you have committed an act or omission that harms or may harm the group, or any of its companies, or any third parties, including other users or suppliers of the group;
• If you have used the Website, its services, or any of its contents, to attempt to commit an illegal act according to the laws of the State of Israel, or an act that is considered illegal as stated, or to enable, facilitate, assist or encourage the performance of such an act;
• if you have violated the terms of the binding documents;
• If you take any action that prevents others from registering to the Website or using it in any way;
• According to a judicial order or instruction of a competent authority;
• If you have provided or disclosed the username and password assigned to you for use by a third party.

The group may exercise various measures to monitor the activity on the Website in order to detect cases of fraud or its misuse. Without derogating from any other provision, the group reserves the right to block or cancel your access or registration to the Website, at its discretion, if it believes that your account on the Website was used to perform such acts.

Personal Area

As part of the Website's services, we may allow you to have access to a Personal Area on the Website ("Personal Area"). The Personal Area on the Website will often allow you to view personal information concerning you, located in the group's databases, as well as to perform various actions.

In addition to any other provision in the binding documents, the following rules apply to your use of the Personal Area on the Website:

• Do not share the Personal Area and do not allow any third party access to the Personal Area. Furthermore, do not do anything that would jeopardize the security of your Personal Area;
• In the event that you become aware or reasonably suspect that the security terms have been breached, including, without limitation, any loss, theft or unauthorized provision of details of your Personal Area or unauthorized access to your Personal Area, you must immediately notify Altshuler Shaham, change the details of your Personal Area or act in accordance with the group's instructions;
• You are solely responsible for keeping your Personal Area information confidential and for any use of your login information or the results thereof;
• You are responsible for all actions that occur through your Personal Area, whether or not such actions are performed by you, including, for the avoidance of doubt, actions performed by third parties;
• You undertake to monitor your Personal Area and prevent its use by any third party;

Sending Information, including Marketing Information

The use of the sections of the Website that require registration, registration to various mailing lists, as well as your approval of the required documents, constitutes your express consent to receive advertising and direct mail from the group, including each of its companies, as defined in section 30A of the Communications Law (Bezek and Broadcasting), 5742-1982 and in the Privacy Protection Law, 5741-1981. Advertisements will be sent to you using the contact information you provided, by any means, existing or future. For the avoidance of doubt, these mailings may include newsletters, surveys, contacting on social media and similar and future technologies. At any time, you may withdraw your consent and notify your refusal to receive advertisements, in general or of a certain type, by sending a notice of refusal. The way to send the notice of refusal will be set forth in the advertisement.

Intellectual Property

All intellectual property rights and in particular copyrights, on the Website, in the services provided therein and in all its contents, including graphic design, diagrams, photographs, computer code, images, texts, multimedia and more, belong to Altshuler Shaham only, or to third parties who have permitted the group to use them (such as business partners). You may not copy, distribute, publicly perform, transmit, make available to the public, create derivative works, sell or lease any part of these, in any way or by any means, without obtaining prior written consent from the group or the other rights holders, as applicable and subject to the terms of the consent (if given). The trademarks of the Altshuler Shaham group companies are the property of the group only. Altshuler Shaham's registered and unregistered trademarks may not be used without prior written consent. Trademarks and advertisements of advertisers on the Website (if any, including business partners and sponsors) are the property of the aforementioned parties and may not be used without consent.

The Use of the Website

You warrant and confirm that you have the full right and authority to use the Website and to commit to the binding documents. You agree to fully follow the provisions of the binding documents and obey the instructions of any law. You may not use the Website in any way that is not set forth in the binding documents, unless you have received the group's express consent to this, in advance, in writing and subject to the terms of that consent (if given). In particular –

• You many not use the Website in a manner that constitutes or may constitute a criminal offense or a civil wrong in accordance with the provisions of any law, or that violates the rights of any third party, including the right to privacy or intellectual property rights;
• You may not copy and use content from the Website, including in other Websites and applications, in electronic publications, in printed publications, etc.;
• You may not use measures to bypass, neutralize or overcome the security mechanisms on the Website, and you may not harm or interfere in any way with its proper operation;
• You may not run any computer application, or any other means, including crawlers, robots, etc., to search, scan, copy or automatically retrieve content from the Website. This includes not creating and not using the aforementioned means to create a compilation, collection or database that will contain content or information from the Website;
• You may not display content from the Website in any way, including by any software, device, accessory or communication protocol that changes their design or removes any content from them;
• You may not link to the Website and its contents from any source that contains pornographic content, content that encourages racism or illegal discrimination, or that is against the law, or that encourages activity that is against the law, or whose publication is against the law.

You undertake not to mislead, defraud, make false representations or provide incorrect information when using the Website and that you will act in good faith towards the group and towards any other user when using the Website. When you use the Website or in any other case of contacting the group, or any other user, you must refrain from transmitting or writing any content that is illegal, of a sexually explicit nature, harassing, insulting, hostile, harmful, threatening, rude, racist, hurts the public's feelings, encourages the commission of a criminal offense, may be the basis for a lawsuit or civil liability, is defamatory, violates privacy or constitutes another violation of Israeli law.

Liability

Wherever the liability of the group, or any of its companies, or the absence of said liability is set forth in the binding documents, this shall also mean the liability of its employees, managers and those acting by its virtue or on its behalf.

The content and services on the Website are available to you to use as they are (AS-IS). They cannot be adapted to the needs of any person or user. You will not have any claim, lawsuit or demand against the group regarding the features of the content, the services and the Website, their capabilities, their limitations, the rules that apply to them and their suitability to you and to your needs. The use of the Website is done by the user and at his exclusive and full responsibility.

Although Altshuler Shaham makes and will make an effort to ascertain the quality, reliability, completeness and level of accuracy and currentness of the contents on the Website, it is possible that the information on the Website may contain disruptions, errors or inaccuracies. Altshuler Shaham is not liable and will not be liable for any disruption, mistake or error in the contents of the Website or its services, and will not be liable for any direct or indirect, consequential or incidental damage caused or to be caused due to access to the Website and its use, or due to any prevention of access to the Website or its use.

The group does not guarantee that the Website's services and contents will not be interrupted, will be provided in an orderly fashion or without interruptions, safely and without errors, and will be immune from unauthorized access to the group's computers and databases, or against damage, breakdowns, malfunctions or failures - and all, in hardware, software, communications lines and systems, at the group or at any of its suppliers. Altshuler Shaham implements accepted security measures for the purpose of maintaining the confidentiality of personal information on the Website. Despite this, there is a risk of intrusion into the databases on the Website, to the information displayed on it.

Links

Links may appear on the Website to various pages, Websites and content on the internet, which are not owned by Altshuler Shaham or on its behalf, and the group does not control or supervise them. The group is not responsible for the content, completeness, reliability, up-to-dateness and legality of these contents, their suitability to your needs, the practices of the content owners in the field of privacy, or for damage of any kind that may be caused to you due to relying on or using information on the sites to which the links will direct. The group does not guarantee that the links on the Website will be correct and will lead you to an active web page and it is entitled to remove from the Website links that were included in the past and add new links, at its discretion.

Social Media Channels

Altshuler Shaham provides the Website users with tools for sharing and linking content from the Website through social networks and various online services, and we also refer Website 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. The use of these online services is done at your own risk and it is naturally subject to the legal agreements (such as the terms of use and the privacy policy) that regulate the activities of each of these platforms (which are not on behalf of the group or under its control).

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 party services. 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 his 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.

Commercial / Advertising Content

The group may place content of a commercial or advertising nature on the Website, including content originating from business partners and sponsors. Altshuler Shaham will not be responsible at all for this type of content published on the Website by third parties. The group does not write, check, verify or edit the content of these publications. The advertisers are responsible for the commercial contents and for any result resulting from their use or reliance on them. Publishing this type of content on the Website does not constitute a recommendation to purchase the services or products that are the subject of the publication. Any transaction you make as a result of commercial content on the Website will be linked directly between you and the advertiser. Except where expressly stated otherwise, the group is not a party to any such transaction and it will not be held responsible for any such transaction.

Jobs

The Website includes information about job vacancies in the group. Job ads on the Website usually include the job description and requirements, the manner and conditions for submitting an application, etc. Job ads, by their nature, will change from time to time according to the group's needs. The publication of job ads does not constitute any kind of commitment on the part of Altshuler Shaham to fill the position.

Changes and Termination of Website Activity

Altshuler Shaham may periodically remove, correct, update, change or add any part of the information and content on the Website, at its discretion, as well as terminate the activity of the Website for maintenance purposes. The group is also entitled to change the structure of the Website, its appearance and design, the scope and availability of the services therein and will be entitled to change any other aspect involving the Website - without the need to notify in advance. By their nature, changes of this type may involve malfunctions or cause inconvenience at first. You will not have any claim or demand against the group due to such changes or malfunctions that will occur when we implement them. The group may at any time stop providing services on the Website, all or in part, subject to the provisions of any law.

In any case of a contradiction between the information you viewed while using the Website, and the information in the Altshuler Shaham offices, whether in its official documents or whether provided to you in writing or orally by employees of Altshuler Shaham, the information in the Altshuler Shaham offices, in its official documents or provided to you by employees of Altshuler Shaham - will be considered binding.

Law and Jurisdiction

By using the Website, you agree that all the laws of the State of Israel, without the rules of choice of law set forth in them and regardless of your actual location, will govern the binding documents and any dispute between you and Altshuler Shaham. The competent courts of the Tel Aviv - Jaffa district, Israel have exclusive jurisdiction in anything and everything arising from the binding documents, or from the Website, or in any dispute between you and Altshuler Shaham.

Changing the Binding Documents

The group may periodically change the terms of use or any of the binding documents. If we make material changes to the binding documents, we will publish a notice on the Website's home page about this, or we will notify you via the contact information you provided us. 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 the Website after the change indicates your agreement to the current binding documents, but we may ask you to confirm the current binding documents. If you do not agree with the updated version of the relevant binding document, you must stop using the Website. You can review the latest binding documents at any time by clicking on the appropriate link on the Website.

Privacy

The group respects your privacy when using the Website and various services of Altshuler Shaham. The Privacy Policy of the Website is an integral part of the binding documents. Since the privacy policy may change as needed, it is recommended that you re-review it from time to time.

Assignment

You may not assign any right or obligation according to the binding documents, and you may not encumber, assign, pledge, or give any rights to any third party without Altshuler Shaham's prior written approval. Any act or omission contrary to the aforesaid - is null and void. You agree that Altshuler Shaham may transfer its rights and obligations according to the binding documents, at its discretion, provided that the recipient of the transfer assumes the group's obligations towards you according to the binding documents.

Miscellaneous

Even if Altshuler Shaham does not enforce any provision in any of the binding documents, this does not derogate from the binding force of the provision and any right or remedy given to the group. If, for any reason, a competent court determines that any provision in the binding documents is invalid or unenforceable, this provision will be enforced to the extent possible and the other provisions in the binding documents will remain in full force and effect.

Contact Us

The group adheres to the provisions of the law and respects the rights of the Website users and the general public. If you have any questions, suggestions, complaints, etc., please contact us using any of the contact methods set forth on the Website, or any of the following methods, and we will try to handle your request as soon as possible:

• Telephone: *5054 (08:00 – 16:00);
• E-mail sherut@altshul.co.il;
• By using the online contact form on the Website;
• Post: Altshuler Shaham - 19A Habarzel St., Ramat Hachayal, Tel Aviv-Jaffa 6971026.

Last updated: 1.3.2023