This privacy policy (hereinafter: the “Privacy Policy“) applies to the way in which we, Brosh Equity Partners, L.P. (hereinafter: “Brosh”, “we“, “our” or “us“), use Personal Data (as defined below) that is collected, received or stored by us about individuals regarding the use of the website: https://www.broshcapital.co.il/ including sub-domains of this site, and their contents (hereinafter: the “Site”). This Privacy Policy is provided in accordance with applicable privacy and data protection laws, including the Israeli Privacy Protection Law, 5741-1981 (hereinafter: the “Privacy Protection Law”), the Cayman Islands Data Protection Act (As Revised) (hereinafter: the “Cayman Data Protection Act”), and the U.S. Gramm-Leach-Bliley Act, Public Law No. 106-102 (hereinafter: the “GLBA”) (collectively, the “Applicable Privacy Laws”).

1. Introduction. This Privacy Policy is implemented because we, as the controller of the database, recognize the importance of privacy. This Privacy Policy details how we manage Personal Data that will be collected during your visit to the Site, and the choices you can make regarding how this data will be collected.

What is Personal Data? “Personal Data” means data as defined in the Privacy Protection Law, the Cayman Data Protection Act, and any other Applicable Privacy Laws, including data relating to an identified person or an identifiable person, including by means of an identifying detail such as name, ID number, biometric identifier, location data, online identifier, or one or more details relating to a person’s physical, health, economic, social or cultural condition.

2. Consent and Changes. You are not under any legal obligation to provide us with data about yourself, and the provision of data is done of your own free will. However, if you decide not to provide certain data, we may not be able to provide you with services or some of them. For example, if you do not provide requested information, we may be unable to process your subscription, maintain your investment, carry out payments or communications, or otherwise provide services to you.

By using the Site, you agree to the terms of our Privacy Policy, and to any collection, processing and sharing of your Personal Data, for the purposes detailed below. If you do not agree to the terms of this Privacy Policy, please do not enter or make any use of our Site. We reserve the right, at our discretion, to change this Privacy Policy at any time.

3. Type of Personal Data Collected that is Directly Provided by You and Purposes of its Use. Currently, general data available on the Site can be accessed without providing Personal Data. However, we receive or collect data from you in the following ways:
   • Contact Details. When contacting us, by sending an online form that we will make available to you, by sending an email to the email address displayed on the Site, or any other means within the Site, you may be asked to provide us with certain data such as first name, email address, phone number, and the content of the inquiry, in order for us to handle your inquiry and contact you, including when leaving messages, if necessary. If you do not provide the required data, we will not be able to handle your inquiry and we will not be able to contact you.
   • Investor Information. When subscribing for interests in the fund or in connection with your investment, you may be asked to provide us with certain personal information such as your full name, residential address, email address, contact details, nationality, place of birth, date of birth, tax identification number, passport number, bank account details, source of funds details, and details relating to your investment activity. Certain personal information is required by applicable law, regulation, anti-money laundering and know-your-customer requirements, tax reporting obligations, or is necessary in order to enter into and perform our contractual relationship with you.
   • Social Networks: We may use social networks and other communication tools to provide service, respond to your inquiries, and improve the services we offer. Any inquiry to us made through such networks and tools will additionally be subject to the privacy policy and terms of use of that social network.
4. Type of Personal Data Collected by Us that is Not Directly Provided by You and Purposes of its Use:
   • Recorded Calls
   • Log Files. We may use log files. The data appearing in the log files includes IP address, browser type, date/time stamp, referring/exit pages, filtering actions, clicks and any other data that may be provided to us from your browser. We may use such data for the purpose of analyzing trends, managing the Site and system, tracking visitor traffic on the Site and system, and for collecting demographic data.
   • Cookies. we use Cookies on the Site and other tracking technologies for the purposes of data security, operation of the Site, adapting the services to your needs, displaying personalized data, and improving your user experience. A “Cookie” is a small text file that is saved on your devices when you visit the Site and is used to collect data about your activity on the Site, save your preferences, and verify your identity. For more information about the types of Cookies and managing preferences, see Section 5 below.
   • Additional Tracking Technologies. Beyond Cookies, we may employ additional tracking technologies such as web beacons, pixels, and tags, which may be embedded in digital content, videos, or email messages. These technologies allow us to collect information about how you interact with our services, including the pages or content you view, associated usage and interaction data (such as access times), the time and date of access, and the IP address used to access the services. The use of web beacons and pixels helps us analyze usage patterns of the services and present you with tailored content and advertisements. Some of these technologies are operated by third parties, such as advertisers or analytics providers, and are therefore subject to the privacy policies of those parties.
   • Mobile Device Data. We may collect technical data from your devices for the proper operation of our site and services. This data may include: Device characteristics: device type, operating system, hardware model; Technical identifiers: Device ID, MAC address, advertising identifiers (when available); Usage data: date and time stamps of site and system usage, duration of activity, pages viewed; Browser data: browser type, version, browser language, display settings; Network data: IP address, the requested URL, referral pages.
     Additionally, in accordance with legal requirements, we may use location-based technologies for the purpose of: adapting content and services to your geographical location; collecting aggregated statistical data to improve our services; identifying regional usage patterns. We do not use precise location data for your personal identification, and any use of location-based information is done in an aggregated and statistical manner, while ensuring the anonymization of the information. You may disable the use of location services at any time through your device settings.

 

 

• Google Analytics
  • Use of Google Analytics: Our Site uses Google Analytics, a web analytics service provided by Google LLC (“Google“), as well as other analytical tools, for the purpose of collecting and analyzing information about the use of the Site. These tools help us understand how users behave on the Site, identify usage trends, and improve the user experience.
  • The Data Collected: Google Analytics collects a variety of data about the use of the Site, including: frequency and duration of visits to the Site; the pages users visit; the websites that referred users to our Site; technical characteristics of the device and browser; general demographic data (such as general geographic location); and patterns of behavior and movement on the Site.
  • How the Data is Used: We use the data received from Google Analytics and other analytical tools for the following purposes: analyzing usage patterns and trends on the Site; measuring the effectiveness of features and content on the Site; improving the user interface and browsing experience; identifying and correcting technical issues; and developing new features and services.
  • Protecting Your Privacy: We do not combine the data collected through Google Analytics with Personal Data. We use IP address anonymization settings to limit the ability to identify specific users. Access to the collected data is restricted to authorized employees only who need the information for their role.
  • Limitations on Google: Google’s ability to use and share data collected by Google Analytics about your visits and use of the Site is restricted by: the Google Analytics Terms of Service, published at: http://www.google.com/analytics/terms/us.html https://marketingplatform.google.com/about/analytics/terms/us/; and Google’s Privacy Policy, published at: https://policies.google.com/privacy?hl=en. For more information about how Google collects and processes data within the scope of Google Analytics, you can visit: https://policies.google.com/technologies/partner-sites?hl=en.
  • Opting Out of Google Analytics Tracking: You can prevent your data from being used by Google Analytics by: downloading and installing the Google Analytics Opt-out Browser Add-on: https://tools.google.com/dlpage/gaoptout; using the privacy settings in your browser to block third-party Cookies; or using your browser’s private/incognito browsing mode.
• Meta Pixels: We use Meta pixels or SDKs, which are tools that provide help to website owners and publishers, developers, advertisers, business partners (and their customers) and others to integrate, use and exchange personal information with Meta, as such the collection and use of personal information for ad targeting. Please note that third parties, including Meta, use cookies, web beacons, and other storage technologies to collect or receive personal information from your websites and elsewhere on the internet and use that personal information to provide measurement services and target ads. Meta’s ability to use and share personal information is governed by the Meta Business Tools Terms, available at: https://www.facebook.com/legal/technology_terms/. You can prevent your data from being used by Meta Pixels and SDKs by exercising your choice through these mechanisms: http://www.aboutads.info/ o or http://www.youronlinechoices.eu/.
• Additional Analytical Tools: In addition to Google Analytics and Meta Pixels, we may use other analytical tools to improve our Site and services. Each of these tools has its own privacy policy, and we are careful to select providers who are committed to high standards of privacy protection and information security.

5. Cookies
   • Types of Cookies. There are two main categories of Cookies: First-party Cookies – issued directly by us to your devices. Third-party Cookies – issued by a third party on our behalf, such as data analysis service providers (Google Analytics), advertising networks, social media platforms, and other service providers. These Cookies are used for functionality, performance/analytics, marketing, and social media purposes, and may be used to collect statistical information, tailor advertising content, and integrate external content (such as videos or posts from social networks). These Cookies are not under our control, and their use is subject to the privacy policies of those third parties. These third parties may change their terms of use and the purposes for using Cookies at any time, and we recommend reviewing the relevant policy of each third party for more information. Blocking third-party Cookies may affect some of the functions on the Site, such as the display of external content or the personalization of advertisements.
   • Cookies may remain on your devices for different periods of time: Session Cookies – exist only as long as your browser is open and are automatically deleted when it is closed. Permanent Cookies – are saved even after the browser is closed and can be used to recognize your computers on return visits.
   • Types of Cookies by function: Essential Cookies – necessary for the basic functioning of the Site, enabling navigation and use of its main features. They are stored for the duration of your stay on the Site and are deleted when the browser is closed; Functional Cookies – improve the user experience by remembering your preferences (such as language, text size). They are stored for a period of up to one year; Performance and analytics Cookies – help us understand how users interact with the Site, identify errors, and improve the Site. They are stored for a period of up to two years; Marketing and advertising Cookies – are used to personalize advertising content and measure the effectiveness of advertising campaigns. They are stored for a period of up to two years.
   • Use and Management of Cookies: When you enter the Site, a Cookie banner will be displayed, allowing you to choose which types of Cookies will be activated during your browsing. Essential Cookies, which are required for the proper functioning of the Site, will always be activated and do not require consent, while other Cookies will be activated only after receiving your consent. You can change your preferences at any time through the Cookie preferences center on the Site or through your browser settings. Most browsers allow control over Cookies, including: receiving a notification before accepting Cookies and choosing whether to approve them, blocking Cookies entirely or selectively, and deleting existing Cookies from your devices.
   • Managing Cookie Preferences. Most browsers allow you to control Cookies through the browser settings. You can: Receive a notification before accepting Cookies and choose whether to approve them; Block Cookies entirely or selectively; Delete existing Cookies from your devices.
   • To manage your Cookie preferences, please refer to the specific instructions of the browser you are using:
     • Google Chrome: Menu (three dots) > Settings > Advanced > Privacy and security > Content settings > Cookies;
     • Mozilla Firefox: Menu > Preferences > Privacy & Security > Cookies and Site Data;
     • Safari: Preferences > Privacy > Cookies and Website Data;
     • Microsoft Edge: Menu > Settings > Privacy, search, and services > Cookies.
   • Consequences of Blocking Cookies: Blocking certain Cookies may affect your browsing experience and the availability of some features on the Site: Blocking essential Cookies may prevent the use of certain parts of the Site; Blocking functional Cookies may limit our ability to remember your preferences; Blocking performance Cookies will prevent us from improving the Site according to usage patterns; Blocking marketing Cookies will prevent the display of personalized content, but will not affect the basic functionality of the Site.
6. For What Purposes We Collect the Personal Data.

In addition to the purposes of use detailed above, we may use Personal Data collected by us as detailed above, also in the following ways and for the following purposes:

• To provide you with services, including processing your subscription and investment in our fund, administering or managing the fund, and facilitating the transfer of funds.
• For the purpose of contacting you, including when sending messages.
• In order to improve the Site and its performance, according to its purposes.
• For the purpose of handling your requests of any kind and responding to inquiries and complaints.
• For the purpose of securing data on the Site, complying with legal provisions, including undertaking investor due diligence, anti-money laundering and counter-terrorist financing checks, sanctions screening, and complying with requests from regulatory, governmental, tax and law enforcement authorities.
• For the purpose of defense in legal proceedings.
• For the purpose of investigating any complaints, or pursuing or defending any claims, proceedings or disputes.
• For the purpose of complying with audit requirements and maintaining statutory registers.
• For the purpose of sending data and advertisements regarding our services to the email address you provided us or through a call from our representative to your phone. You may request at any time to stop receiving such data and content as stated above by clicking on an unsubscribe link or by sending an unsubscribe request to the email: Pnina@broshcapital.co.il.

7. Use of Anonymous Data

We may use anonymous or statistical data (which does not allow for the identification of an individual user), such as aggregated data that has been collected and/or generated by us as a result of the use of the Site, including sharing it with third parties and our clients within the scope of our business activities.

8. How We Share Personal Data

Apart from the above, we will not transfer the data you have provided to us to third parties, except in the following cases:

• To our affiliates, delegates, and service providers on our behalf, who assist us in our activities, including our banks, attorneys, accountants, auditors, placement agents, business operation system providers, and electronic mailing system providers;
• In the event of a violation of the terms of use or this Privacy Policy or if you perform through the Site, actions that appear to be contrary to law, or an attempt to perform such actions;
• In the event of any dispute, claim, lawsuit, demand or legal proceedings, if any, between you and us;
• In any case where we believe that the disclosure of the data is necessary to prevent bodily harm or property damage (to you or to a third party) or in connection with an investigation into suspicions of illegal acts;
• In the event that we are required by law to transfer your personal details and data collected about your activity on the Site to third parties, including if we receive a judicial order directing us to provide your details or data about you to a third party or in response to a request from a law enforcement authority or other governmental or public authority;
• In the event that we are acquired by a third-party company or merge with a third-party company.

Due to the international nature of our business, your personal data may be transferred to jurisdictions that do not offer equivalent protection of personal data as under the Applicable Privacy Laws. In such cases, we will process personal data or procure that it be processed in accordance with the requirements of applicable data protection legislation, which may include having appropriate contractual undertakings in legal agreements with service providers who process personal data on our behalf.

9. Data Security. We implement systems and procedures for data security on the Site. While these systems and procedures reduce the risks of unauthorized intrusion into our computers, they do not provide absolute security. Therefore, although we strive to use acceptable and reasonable means to protect your Personal Data, we do not guarantee that the Site will be absolutely immune from unauthorized access to the data stored in it. If you have any questions regarding security in the service or regarding confidentiality, you can contact us at the email address: Pnina@broshcapital.co.il.
10. Data Retention. We will keep your personal data for as long as it is required by us. For example, we may require it for our legitimate business purposes, to perform our contractual obligations, or where law or regulation obliges us to. We will generally retain your personal data throughout the lifecycle of the investment you are involved in. Some personal data will be retained after your relationship with us ends. We expect to delete your personal data once there is no longer any legal or regulatory requirement or legitimate business purpose for retaining your personal data.
11. Children’s Privacy
12. Your Rights and Protection of Your Privacy. Brosh Equity Partners, L.P. is the controller of the database containing the data detailed in this policy. We respect your right to privacy and are interested in keeping only required, up-to-date and accurate data. Under the Applicable Privacy Laws, you have the following rights with respect to your personal data: (i) the right to access and review your personal data; (ii) to request that we rectify any information we hold about you that is inaccurate or misleading; (iii) the right to object, or to request restriction of the processing of your personal data; (iv) to request that decisions made about you will not solely be based on processing by automated means; (v) to request to stop the processing of your personal data for direct marketing purposes; and (vi) a right to lodge a complaint with the applicable data protection supervisory authority. Individuals who believe that their rights under the Cayman Islands Data Protection Act (As Revised) have been infringed have a right to complain to the Office of the Cayman Islands Ombudsman (https://ombudsman.ky). We ask that you please attempt to resolve any issues with us before you contact your local supervisory authority. We invite you to contact us on this matter and any question regarding your privacy by sending an email to the address Pnina@broshcapital.co.il.

Last updated: May, 2026.