My Tower – App Privacy Policy
  1. General
    1. My Tower Ltd. (“the Company”) respects the privacy of all users of, and persons expressing interest in, the services made available through the MyTower application (the “User(s)” and the “App”, respectively). The Company places great importance to the protection of Users' privacy and is committed to safeguard the personal information disclosed to it by Users, all in accordance with the provisions of this Privacy Policy and applicable law.
    2. The App is intended to facilitate the management of condominiums, residential complexes, and office buildings, and enables management companies, condominium committees, service providers, and/or any person acting on their behalf, to provide Users with a variety of services in such fields (the “Services”).
    3. The Users are hereby informed of the Company's policies and procedures concerning the collection and use of information received from them or collected in relation to them through the App. The purpose of this Privacy Policy is, inter alia, to set forth the Company's practices with respect to User privacy and to describe the manner in which the Company collects, uses, and otherwise processes personal information provided by Users or collected in connection with their access to and use of the App.
    4. Initial access to, or use of, the App, shall constitute the User's acknowledgement and acceptance of the terms of this Privacy Policy, including, without limitation, for the purposes of the collection, management, processing, storage, and other handling of information as described herein. If a User does not agree to these terms, such User must immediately cease and refrain from any further access to or use of the App.
  2. What Data and Personal Information Do We Collect?
    1. The Company collects, receives, and stores the following categories of information relating to Users of the App, as further detailed below:
      1. Any visible technical information available to the Company and/or incidentally provided by Users or generated in connection with any use of the App by the Users, including the following:
        1. Information concerning User behavior - such as patterns of activity within the App, browsing times, browsing paths, visits to pages and advertisements before, during, and after accessing the App, actions performed or received in connection with the App, and the like;
        2. Information concerning Users' devices - such as the IP address of the network, computer, or mobile device used to access the App (the “Device”), device identifiers, browser type, and geographic location data, whether the Device or any of its components are active or inactive, subject to the Device settings.
      2. In the course of browsing the App, registering thereto, opening an account, logging into a personal area, and expressing interest in and/or using the services made available thereunder, Users may be requested to provide personal information, and such information may be collected in relation to them, including full name, contact details such as telephone number, email address, and residential address, ID number, date of birth, gender, credit card details (TOKEN), reviews and feedback, requests, information relating to the ordering of services, and the like. The Company, and any third party acting on its behalf, may collect, process, and store personal information knowingly and voluntarily provided by Users in connection with their use of the App. Such personal information shall be collected from the data furnished by the Users.
    2. For the avoidance of doubt, the provisions of this Privacy Policy shall apply solely to personal information, as such term is defined under the Protection of Privacy Law. To the extent any information is collected in a manner that does not identify Users and constitutes non-identifiable and/or aggregated information, the Company shall be entitled to make any use thereof, without restriction.
    3. Users acknowledge that certain information provided by them and/or collected in relation to them is not required by applicable law and is disclosed to the Company voluntarily and with their consent, inter alia, for the purpose of enabling the Company to provide certain Services, and Users hereby consent to the retention of such information in the Company's databases, as further described in this Privacy Policy. Notwithstanding the foregoing, it is hereby clarified that failure to provide certain information may prevent Users from registering for the App and/or from receiving the Services offered thereunder.
    4. In order to open an account and register for the personal area in the App, Users shall be required to enter their email address and a personal password, or alternatively to enter a telephone number in the App and complete an identification process by means of such telephone number and a one-time password sent by text message (OTP). By entering a telephone number and continuing the registration or login process and/or requesting a verification code, Users consent to the receipt of such text message. A verification text message may be sent in connection with each login or verification attempt undertaken through this process. If Users elect not to receive such text messages, they may be unable to complete registration or login. Users shall maintain the strict confidentiality of their username and password and undertake not to disclose them to any third party or permit any third party to make use thereof. It is hereby clarified that Users shall bear full and exclusive responsibility for any use of the App effected through their username and password. In this context, it is further clarified that, to the extent Users upload and store personal information relating to third parties within the personal area (for example, additional family members and the like), such Users represent and warrant that they have obtained all consents and approvals required by law for the use of such information and its transfer to the Company.
  3. How Do We Use Your Personal Information?
    1. The Company uses non-personal information, namely information that does not personally identify Users, for statistical, analytical, and research purposes, including for the adaptation, development, enhancement, and improvement of the App and the Services offered therein, as well as for the Company's internal, operational, and commercial purposes.
    2. The Company uses personal information in accordance with the provisions of this Privacy Policy, including for the following purposes:
      1. To adapt, improve and enhance the App and the Services offered therein, to create services tailored to the needs and expectations of Users, to modify or discontinue existing services, to develop, train or retrain machine learning-based models, and to use other technologies for research and development;
      2. To respond to Users' inquiries regarding use of the App, to provide service and technical support, to address requests, and to maintain ongoing communications with Users;
      3. For the purpose of making decisions, whether by human review or algorithmic means, with respect to Users, including for the examination of engagement with the Company, the performance of evaluation and risk management checks, the conduct of surveys, and the making of business decisions;
      4. For the purpose of sending operational messages and notifications to Users by various digital means, including email, text messages, push notifications, and the like, including in relation to the App and the Services offered therein, means of identification, password recovery, actions and confirmations;
      5. For the purpose of transmitting, including by email, instant messages, telephone calls, push notifications, and the like, various content, including marketing offers and advertising materials from the Company, subject to the User's consent and to the User's right to request, at any time, removal from the mailing list and cessation of such advertising messages;
      6. In connection with any transfer of shares in the Company, sale of the Company's holdings or a substantial portion of its assets, including in the context of a sale or merger transaction, and/or in the event any digital asset is operated by another entity, or the Company's activity is transferred or assigned to any third party in case of business negotiations, including where the transfer of information is necessary for such purpose, provided that such third party undertakes to comply with the provisions of this Privacy Policy and to preserve the rights of Users as set forth herein;
      7. To detect, prevent, investigate, or otherwise address any unlawful and/or unauthorized use of the App or of the Services offered therein, including in cases of fraud, deception, misuse, security or safety concerns, and technical malfunctions;
      8. To comply with the requirements of any applicable law, including for the purposes of legal proceedings, orders, including disclosure orders, or requests from any governmental, regulatory, and/or other competent authority, where required or permitted by law;
      9. For any other purpose required or permitted by law or otherwise specified in this Privacy Policy.
    3.  For the avoidance of doubt, it is clarified that the Company may engage with third-party service providers who act on behalf of and for the Company in order to process data, and may include various service providers, cloud services, and other business partners who assist in operating the App and the services offered within it, among other things, to ensure its proper management and operation, to complete actions requested by Users on an ongoing basis and for security and service improvement.
    4. Users hereby confirm that all information provided by them, or collected in relation to them through the App and the Services offered therein, is true, reliable, and accurate, and that they use the App and the Services solely in their own name and for their own benefit, except where expressly authorized otherwise by the Company in writing.
    5. Users acknowledge and agree that personal information relating to them may be transferred outside the borders of the State of Israel, including for storage and processing in jurisdictions that may not provide the same level of protection as that afforded under the laws of the State of Israel with respect to the privacy and security of personal information. Users expressly consent to the transfer of the information provided by them and collected in relation to them to such jurisdictions.
    6. The data and information collected from, or provided by, Users shall be lawfully retained, at the Company's discretion, in its databases for such period as is necessary to fulfill the purposes for which such data and information were collected. It is further clarified that, in appropriate circumstances, all or part of such information may be retained in the Company's databases for an unlimited period.
  4. Is Information Transferred to Third Parties?
    1. Users' personal information shall not be disclosed to third parties without their consent, unless otherwise permitted under this Privacy Policy. Notwithstanding the foregoing, the Company may disclose and transfer personal information relating to Users to third parties, from time to time, in the following circumstances:
      1. Upon receipt of the Users' consent to such transfer;
      2. In the context of, or in connection with, the provision of the Services offered through the App, including to service providers and vendors assisting in their operation, and, where applicable, to SMS service providers and telecommunications carriers solely to the extent necessary for the delivery of a requested verification text message; it being clarified that, unless expressly stated otherwise, such parties shall have no right to make any use of the information other than for the purpose for which it was provided;
      3. In connection with the Company's collaborations with its business partners, inter alia, for the purposes of data enrichment, creation of a user profile, and transmission of operational messages and, subject to applicable consent, advertising messages, through channels other than verification text messages; provided, however, that such transfer of information shall be accompanied by explicit notice to Users where required, including as set forth in this Privacy Policy; and provided further that telephone numbers collected for verification text messages, SMS opt-in data, and SMS consent records shall not be shared with third parties or affiliates for their marketing or promotional purposes;
      4. For the purpose of responding to support or service requests submitted by Users;
      5. For the purpose of enforcing this Privacy Policy and/or the Terms of Use, including in connection with the investigation and clarification of suspected breaches thereof;
      6. For the purpose of detecting, preventing, investigating, or otherwise addressing fraud, deception, misuse, security or safety concerns, and technical problems;
      7. For the purpose of complying with the requirements of any applicable law, including in connection with legal proceedings, orders, including disclosure orders, or requests from any governmental, regulatory, and/or other competent authority;
      8. In any case in which the Company believes, in good faith, that disclosure of the information is necessary to prevent serious harm to the Company, other Users, or third parties;
      9. If the Company transfers and/or assigns its business activity, rights, or obligations toward Users to any third party, including in the course of business negotiations, and in cases involving a transfer of shares in the Company or a substantial portion of its assets, to the extent disclosure of information is necessary for the execution of such actions, provided that such third party undertakes to comply with the provisions set forth in this Privacy Policy.
  5. Information Collection Technologies
    1. In connection with the use of the App, or as part of the process by which a User arrives at the App, the Company may use automated tools and information-gathering technologies, including tags, beacons, SDKs, pixels, and similar technologies commonly known in the industry as "cookies" ("Cookies"), through which information concerning Users' activity in the App or on other digital platforms may be collected and accumulated. By way of example, such information may include activity patterns within the App, browsing times, browsing paths, visits to pages and advertisements before, during, and after arriving at the App, and the like. To the extent personal information is collected through Cookies, such information shall be subject to the provisions of this Privacy Policy, and the Company shall be entitled to use it in accordance therewith.
    2. Cookies are stored on the Device and enable the Company to automatically activate certain functions, as well as to facilitate and streamline the user experience in the App and the Services offered therein.
    3. Cookies generally consist of text files and small graphic images created by command of the Users' browser or platform and placed in connection with the App, thereby enabling identification of whether a particular action has been performed. When a User accesses the App and/or any of the Services offered therein, the Cookies generate a message regarding such action. Certain Cookies expire upon closure of the relevant browser or application, while others remain stored in the memory of the User's platform or are transmitted to the Company, including to service providers acting on behalf of and for the Company and, where relevant, to the Users' suppliers, for the purpose of providing the Services made available through the App.
    4. Cookies may be disabled. By way of example, most internet browsers permit Users to delete Cookies from the Device, block the receipt of Cookies, or receive alerts before Cookies are stored. It is, however, clarified that deletion of Cookies from the browser or from the memory of the User's platform shall not result in the deletion of information or content already transmitted to the Company or to third parties by means thereof. In addition, Users should note that deletion of Cookies or refusal to permit their storage may adversely affect the user experience in the App, including with respect to the ability to provide the Services offered therein. Users are advised to review the instructions available in their browser in order to obtain further information regarding these functions.
  6. Marketing
    1. To the extent Users have expressed interest in the Services offered through the App and have provided their details for the purpose of receiving updates, and/or have otherwise consented to receive direct marketing, the Company and/or any person acting on its behalf shall be entitled to transmit to such Users marketing and advertising materials, including updates, offers, benefits, and the like, by various digital means, including email and instant messaging applications (such as chat and WhatsApp). To the extent Users no longer wish to receive such communications, they may withdraw their consent at any time through the relevant mailing itself or by requesting removal from the mailing list via email sent to: contact@mytowerapp.com.
  7. Other Platforms
    1. The App and the Services offered therein may include links to various online platforms, including pages, websites, applications, and similar services, which are not operated or managed by the Company, including for activities and services made available by such third parties. The Company neither controls nor supervises the operation of such platforms, and any link thereto appearing in the App shall not be construed as the Company's approval of their content, nor as any representation or warranty regarding their reliability, currency, or legality. Any use made of such platforms shall be at the sole risk and responsibility of the Users. Use of such platforms shall be subject solely to the terms of use and privacy policy appearing thereon, if any, and Users are therefore advised to review such documents prior to making any use thereof.
  8. Data Subject Rights
    1. Subject to applicable law, Users shall have the right to review identifiable personal information relating to them that is held and stored in the Company's databases, and to request the correction or deletion thereof if such information is found to be inaccurate, incomplete, or outdated. Users wishing to exercise such rights may contact the Company in writing in the manner prescribed by law or via email at: contact@mytowerapp.com, and the Company shall use reasonable efforts to comply with such requests in accordance with applicable law.
  9. Information Security
    1. The Company has invested commercially reasonable efforts in implementing information security measures within the App, including mechanisms and technological systems intended to assist in protecting against information leakage, unauthorized access and use, and the transfer, disclosure, copying, or deletion of information. Notwithstanding the foregoing, while such efforts are intended to mitigate existing risks, the Company does not guarantee that the App shall be wholly immune from such events, and the Company shall not be liable for any damage caused to Users or any person on their behalf as a result thereof.
    2. Users acknowledge that services involving information processing, particularly where information is transmitted via the internet, inherently involve a certain degree of risk, and Users consent to the provision and collection of information in accordance with the terms of this Privacy Policy and applicable law and assume the risk of security incidents affecting the confidentiality, integrity, or availability of such information.
  10. Contact
    1. The provisions of this Privacy Policy may be amended from time to time, inter alia, in order to reflect technological, business, legal, or regulatory developments. It is hereby clarified that, if material changes are made to the provisions concerning the use of personal information provided by, and/or collected in relation to, Users through the App, notice thereof shall be published on the appropriate platform within the App and/or in this Privacy Policy. Continued use of the App following the implementation of such changes shall constitute the Users' consent thereto, and Users are therefore advised to review this Privacy Policy periodically.
    2. If a User has any questions concerning this Privacy Policy, such User may contact the Company by email at: contact@mytowerapp.com.
Last updated: 08/2026