Information Security 

1. The Company attaches great importance to maintaining the privacy of Visitors to the Website and to securing the information, with regards to information stored during a visit on the Website. Below are the principles of the information security and privacy protection policy according to which the Company operates, with regards to information stored during a visit on the Website. Any access by a Visitor to the Website and / or any use made of it and its contents means a statement that the Visitor has read and understood these terms and that the Visitor has accepted, agreed and approved their contents. If you do not agree to the aforementioned, do not make use of this Website. 
2. Retention of information –   In order to optimize and improve the services provided by the Company, as part of a visit on the Website, information about the Visitor may be collected. It is clarified that this information is obtained when the Website Visitor provides it of his/her own free will (for example when requesting contact with him/her).
3. Use of  cookie files  – The Company uses cookies technology for the convenience of the Visitor on the Website and to examine the Visitor’s use of the Website. The Company may make such use as aforementioned at its sole discretion. The cookie is an information file that is sent to the Visitor’s personal computer and is stored on it after logging into the Website. Its role is to examine the use of the Website, and to allow quick identification of the Visitor’s details when he/she returns to the Website.
4. Use of information, protection and confidentiality –  the Company invests a lot of effort and resources in order to protect the information it receives from the Website Visitors. The Company uses “secure browsing” technology so that its servers are not directly connected to the Internet but are isolated through several layers of protection aimed at preventing damage to servers that contain information, including personal information of the Website Visitors. In addition, the Company uses TLS technology in order to encrypt the personal information transmitted to the Company from the Website Visitors. The Company undertakes to maintain the confidentiality of the information subject to the provisions of the Protection of Privacy Law, 5741-1981, and other relevant laws. Any information provided by the Website Visitors will constitute consent on the part of the Website Visitor to the Company and / or anyone on its behalf to use the information provided. The Company may, in its sole discretion, use the information stored for the benefit of statistical processing, marketing-related segmentation and targeting, including direct mailing. In some cases the Company may transfer the information to a third party subject to the provisions of the law. It is clarified that despite the identification means that the Company undertakes, as well as precautionary measures, there may be various risks in the use of the Website, which include, among others: viruses, worms, trojan horse malware, software applications, database intrusion, impersonation, errors, discovery and / or alteration of information by unauthorized persons, and the like. The Company and / or anyone on its behalf and / or any of its officers will not be responsible for any damage or loss and / or expense that may be caused as a result of using the Website.
   In any case, the Company or anyone on its behalf will not send you any request for your account and password information and such notification if sent will be fictitious and will constitute a phishing attempt to make adverse use of your information.
   
   

Privacy Policy, Databases, and Direct Mailing

1. The details provided by each Visitor through the Website, insofar as they are provided, including and without derogating from the aforementioned in the framework of filling out the registration form on the Website, will be subject to the Company’s privacy policy as set forth in this document.
2. By providing the details on the Website, each Visitor declares and confirms that he/she knows that the information about him/her will be stored in the Company’s secure databases and / or for the Company by an entity acting on its behalf, and may be used solely in accordance with these conditions, above and below, including for contact with the Visitor and / or management, handling, operation and optimization of services provided or offered for the Visitor by the Company, which may make use of it for statistical analysis and direct mailing to the Visitor on behalf of the Company in offers for various products and / or financial services marketed by the Company by law. The Visitor is aware that at any time after subscribing to the mailing list he/she may withdraw from this agreement and request removal from a particular mailing list or altogether, by contacting the Company’s customer relation center by email Gideon@spikesfund.com / or through the mailing removal mechanism sent to the subscriber.
3. The filling of the details by the Visitor constitutes the Visitor’s consent that his/her details and any data produced on the basis of this data and any information about him/her that became and / or will become known to the Company will be kept in one or more databases of the Company or anyone on its behalf and that this information will be used in accordance with the following purposes: (A) for the purposes of marketing, advertising, sales promotion and sales, for the purpose of contacting the Visitor in any way including by direct mailing in any means of communication deemed appropriate by it, including in writing, print, telephone, facsimile, computerized or other means; (B) for the purposes of mailing management, encouraging loyalty, statistical analysis and research, conducting surveys and any other online use in connection with mailings; (C) For the purposes of mailing marketing and advertising material, including through “cookies”. The use as aforementioned of the Visitor’s details will not be considered an invasion of privacy. It is further agreed that information as aforementioned will be considered the property of the Company and the Visitor hereby waives any claim in respect of the use and / or ownership of such information, including a waiver of any claim under the Protection of Privacy Law, 5741-1981. The Company will not be considered a violator of a commitment to privacy or an infringer of user privacy due to any information as defined in the Computers Law, 5755-1995, which would be used to identify a user or be tracked by another and which results from the use of electronic means of communication in general and computer communications in particular.
4. Each Visitor declares and confirms that he/she is aware that he/she has no legal obligation to provide his/her details and that the provision of information to the Company, including through the Website, insofar as done, is done of his/her own free will and with his/her consent. Any Visitor who provides his/her details as aforementioned hereby expressly agrees to the aforementioned use of his/her details and confirms that their use will not be considered an invasion of privacy and will not entitle him/her to any relief and / or compensation. It is also known to every Visitor that providing incorrect information or failure to provide the full details required may prevent him from receiving the Company’s and / or the Website services and impair the Company’s ability to contact him/her, if necessary. Each Visitor declares that to the extent that he/she submits information of a third party, the Visitor has obtained his/her express consent to the provision of the information to the Company, for the purpose of using this information in accordance with this policy. 
5. The Company will not provide the Visitor’s details to third parties except in each of the cases listed below: (A) if it is required to do so by a court order or by law; (B) If it receives notice of legal proceedings against it and / or any dispute, argument, claim, demand, or legal proceedings, if any, between the Visitor and the Company; (C) If it organizes the mailing activities of the Company within another body – and in the event that it merges with another body provided that that other body accepts with regards to the Visitor the provisions of this privacy policy; In the event of the transfer of the Visitor’s details to another body as aforementioned, the Company will give notice to the Visitor; (D) If and to the extent required for the purpose of operating the mailing list such as to subcontractors and other entities that take part in the Company’s mailing system. The Visitors will have no claim or demand towards the Company in connection with the provision of their personal details as aforementioned and they hereby waive such claim or demand as aforementioned.
6. Visitors who object to the use of their details as aforementioned, are asked not to use the Website, nor to provide their details. Visitors who have registered to the Website and / or the mailing list and wish to remove themselves from the Company’s registered database or wish not to receive contact by direct mailing, will remove themselves through the removal mechanisms found in each mailing.
7. Communication networks, computers, servers, and websites are vulnerable to attacks and attempted hacking by various parties. The Company takes a number of security measures in order to maintain the privacy of the information entered by the Visitors, but every Visitor must know that this cannot be completely guaranteed and there may be security breaches and intrusion into the information. The Company does not guarantee that the services and information on the Website and on the servers that store the information will be completely immune from unauthorized access to the information stored on them. By registering for mailings, the Visitors release the Company and / or anyone on its behalf from liability for any damage caused to them and / or anyone on their behalf due to attacks, attempted hacking and intrusion into information as aforementioned and waive any claim and / or demand from the Company as a result.
8. General – it is clarified that the Company is not responsible for the privacy protection and information security policy of websites the links of which appear on the Website, insofar as they appear. When using the Website, the Website Visitor confirms that he/she is aware that the Company is doing everything in its power to protect personal information, but is unable to guarantee that its precautionary measures will provide complete immunity from intrusion into the Company’s systems. The Company will not bear any responsibility in the event of information being leaked and the Visitor will not have any demand and / or argument and / or claim and / or complaint in the event of an intrusion as aforementioned. The Website Visitor agrees and approves the Company’s privacy protection and information security policy. The Company reserves the right to change and / or update this policy from time to time. Updates as aforementioned will be published on the Website and will take effect on the date of their publication.