Privacy Notice Last updated: 27.7.26 

BEN YEHUDA 98 TLVLtd., an Israeli company, company number _515533065_, with its  address at ___GORDON 17___ (the "Hotel,” “we,” or “us”), respects your right to privacy.  Your ability to make informed decisions regarding the use of your Personal Data (as defined below) is important to us. The purpose of this Privacy Notice (the “Privacy Notice”) is to  explain the Hotel’s practices regarding the Personal Data collected when you use our Site  (as defined below) and how the Hotel collects, uses, transfers, and secures the Personal  Data it collects. Our Site (the “Site”) is intended to provide a convenient and secure  platform for booking and purchasing accommodation and vacation packages at the Hotel.  Your use of the Site of any kind, including leaving your details to contact the Hotel,  constitutes your consent and approval of the terms of this Privacy Notice.). The terms  “you” or “your” in this document refer to any user of the Site. For any questions or issues  regarding this Privacy Notice, please contact: [HELLO@SCARLET-HOTEL.COM].  

“Personal Data” means information relating to an individual, such as name, address, phone  number, or email address, or as defined by law. You are not legally required to provide us  with Personal Data; any provision of Personal Data is made solely with your consent. If you  do not agree to provide some or all of the Personal Data, some or all of the Site and its  Services may not be available to you. 

1. Personal Data We Collect  

1.1.Communications: When you contact us (e.g., via our “Contact Us” form, by email, or otherwise), request information, we collect the data you provide, such as your  name, company (if applicable), contact details (phone, email), dates (e.g., date of  birth, anniversary if you choose to provide them), postal address, and the content of  your message or question. Additionally, if you upload User Content to the Site, we  will also receive such Personal Data. 

1.2.Registration for Newsletter and/or for our Loyalty Program: If you register to receive our publications (including newsletters), join our loyalty program, we may collect  your first and last name, email address, postal address, date of birth, and  anniversary date.  

1.3.Activity and System Data: When you use the Site, we may automatically gather  certain information about your device, such as your browser, operating system, IP  address, device ID, mobile device identifiers, and/or data about your usage of the  Site.  

1. How We Use Your Personal Data. You agree and acknowledge that the Hotel may  store the information you provide, as well as any additional Personal Data that may be  collected about you, in its databases. The Hotel shall be entitled to manage such  databases in accordance with applicable law as the database controller and to use the  Personal Data in the manner described in this Privacy Notice, including for the purposes  detailed therein. 

1.1. Services and Adaptations. We and our third-party service providers use the Personal Data we collect for the following purposes: (1) to provide you with access to the Site  and provision of Services at the Hotel; (2) granting rights and benefits related to 

participation in our loyalty program; (3) providing support and assistance in resolving issues you or other users may encounter; (4) contacting you if necessary; (5)  addressing inquiries, including those submitted via the Site, and responding  accordingly; (6) preventing fraud attempts and safeguarding the security of the Site,  as well as addressing any issues related to the Site; (7) managing the Hotel and its  business operations, including customer retention, analyzing usage patterns on the  Site, forecasting customer needs (including potential cancellations), and identifying  market and customer trends and preferences; and (8) creating Lookalike Audiences  that enable us to identify new potential customers with characteristics similar to our  existing customers.  

1.2. Internal Needs. We may use your Personal Data for internal purposes, including for  the development of new Services and/or content and/or for the offering of new  products, improving the Site or our Services and adapting them to our needs and/or  those of the users, developing new products or Services, analyzing activity volumes,  performing financial assessments and forecasts, evaluating customer usage  potential, using certain Personal Data for research, development and testing  purposes, and adjusting server capacity to anticipated workloads. 

1.3. Statistical Information and Analytics We and/or our service providers use analytics  tools to collect and analyze information about the use of the Site, such as the  frequency of user visits, the pages viewed, and the websites or applications used  before visiting the Site. By analyzing the information we collect, we may compile  statistical data across various platforms and users, which helps us improve the Site or our Services, understand customer trends and needs, consider new products and  Services, create Lookalike Audiences to identify and advertise the Hotel’s Services to  potential customers, and adapt existing products and Services to customer  preferences. Such analytics tools include, among others, “Google Analytics.”  Additional information about how Google collects data and how you can control  such use can be found in Google’s policy:  

https://policies.google.com/technologies/partner-sites. 

1.4. Marketing. Subject to your consent, we may use your Personal Data to send  newsletters. If you no longer wish to receive such emails, you may request to be  removed from our mailing list by clicking the unsubscribe link included in the  message and/or by following any other instructions provided in the communication.  We may also use your Personal Data to provide you with targeted offers and/or  advertisements from third parties, in accordance with your personal preferences.  

1. Sharing the Personal Data We Collect  

1.1. Access-Holders at Hotel: Access-holders are Hotel personnel who are allowed  access to Personal Data. As of the date of this Privacy Notice, typical access-holders  include (without limitation): reservations managers, front-desk staff and managers,  housekeeping staff, food and beverages staff. The identity and/or type of access holders may change over time according to our business needs. If there is a material  change, we will use commercially reasonable efforts to update you.  

1.2. Affiliates: We share information, including your Personal Data, with our parent  and/or subsidiaries and affiliated companies where necessary to provide you with  the Services, Site, and/or to manage our business. They may be located in countries  other than the State of Israel.

1.3.Service Providers and Subcontractors:  

1.3.1.We may share information, including Personal Data, with service providers  and other third parties (“Third-Party Providers”), who may use the information  to: (1) assist us in operating the Site and/or provide the Services; (2) help us  understand the use of the Site; and (3) provide you with direct marketing based  on your personal preferences on our Site and on other sites and/or applications  you choose to visit. 

1.1. 

1.1.1.Third-Party Providers may be located in countries other than the State of  Israel. All authorized third parties will be subject to confidentiality obligations  and restrictions on the use of Personal Data. Nevertheless, some of these  countries may provide levels of protection for Personal Data or other information that are not equivalent to the level of protection in the State of Israel, and you  hereby consent to the transfer of your Personal Data to such countries.  

1.2. Business Transfers. Our databases (which include your Personal Data) may be  disclosed and/or transferred as part of, or during negotiations of, any merger, sale of  the Hotel's assets, or acquisition (including in cases of liquidation), including after  the consummation of any of the above. In such case, your Personal Data shall  continue being subject to the provisions of this Privacy Notice. 

1.3. Advertisers. When you click on an ad, whether or not it's on our Site or on another  website, the relevant advertiser will be alerted that someone has visited the page on which the relevant advertisement was displayed, and may be able to identify that it  was you by using certain mechanisms, like cookies (as detailed in Section 7 below).  

1.4. Transfer of Personal Data for Law Enforcement Purposes. We will cooperate with  law enforcement authorities or any judicial order requiring or instructing us to  disclose the identity, behavior, digital content, or any other Personal Data of any user suspected of engaging in actions that appear to be unlawful or in violation of the 

law. In addition, we may share your Personal Data with third parties if we believe in  good faith that such disclosure is appropriate and intended to protect our rights,  property, or safety (including the enforcement of this Privacy Notice and/or the  Terms), or to protect the rights, property, or safety of third parties. 

1.5. Additional Disclosures. We will transfer your Personal Data to relevant third parties  in cases where: (1) the Hotel determines that any of your actions on the Site violate  the Terms or were carried out in order to commit fraud of any kind; or (2) the Hotel  is subject to legal proceedings (administrative, criminal, or civil) as a result of actions  

you performed through the Site. 

1. How We Protect Personal Data. We follow industry-standard practices to protect  Personal Data, both during its transmission and once it is received. However, the  transmission of Personal Data over the internet or its electronic storage can never be  fully secure. Accordingly, we cannot guarantee the absolute security of your Personal  Data. To help ensure the best possible protection of your Personal Data,  please safeguard your passwords and control access to your computer  through appropriate measures. 
2. Inspection and Correction Rights. You may request to review the Personal Data processed by the Hotel about you, in accordance with Section 13 of the Privacy Protection Law, 5741–1981 (the “Privacy Protection Law”). If you find that such Personal Data is incorrect, incomplete, unclear, or not up to date, you may request that we correct or delete it, in accordance with Section 14 of the Privacy Protection Law. The Hotel will act within a reasonable time to respond to your request, subject to the provisions of the law. In addition, in certain cases, you may request the deletion of your Personal Data from the Hotel’s databases in accordance with Section 3 of the Privacy Protection Regulations (Provisions Regarding Data Transferred to Israel from the European Economic Area), 5783–2023. If we decide, at our discretion, to deny your request, we will notify you in the manner and form prescribed in the regulations. You may appeal our decision to the Magistrates’ Court in the manner and form prescribed in the regulations. 
3. Retention of Personal Data. We will retain your Personal Data for as long as necessary to: (1) fulfill the purposes of use of the Personal Data described above; (2) comply with our legal obligations; (3) resolve disputes; (4) enforce our agreements; or (5) for a longer period as required under applicable law. We may delete your Personal Data without notifying you if we determine that it is no longer necessary to retain it for the purposes described above. 
4. Cookies and Similar Technologies. Cookies are small text files that are sent to your device through your browser. We use cookies and similar technologies (such as beacons or pixels – small graphic files typically designed to identify users and/or their activity) (collectively, “Cookies”). A “session cookie” remains on your device only until you leave the Site. We may also use a “persistent cookie” to store your settings and personal preferences from visit to visit, which will remain on your device for longer periods. For example, if you log in to the Site, a cookie will be used to recognize you as a current user. We use both our own cookies and cookies from third parties. Most web browsers and end devices are initially set to accept cookies, but you can change this setting to block certain cookies. You can also delete existing cookies at any time. Please

note that some features of the Site may not function properly if you disable or remove cookies. 

The cookies we use may change from time to time. The types of cookies we generally use fall into the following categories: 

1. Third-Party Applications and Services. Part of the Site includes the use of third party services. All use of such services is at your own risk and subject to such third party's terms and privacy policies.  
2. Children. We do not knowingly collect Personal Data from children under the age of eighteen (18). In the event that you become aware that an individual under the age of eighteen (18) is using the Site without parental permission, please advise us immediately.  
3. Communications. We reserve the right to send you communications related to the Site via email and/or any other communication channel known to us, including service messages and administrative messages related to your account, without offering you the option to opt out, except if you terminate your membership in the club and remove yourself from our mailing list.  
4. Changes to the Privacy Notice. We may update this Privacy Notice from time to If we make material changes to this Privacy Notice, we will seek to inform you by notice on our Site.  
5. Contact. You can contact us by sending an email to ____HELLO@SCARLET HOTEL.COM__ or by completing the dedicated form on the “Contact Us” page of the Site.