Privacy Policy

Zvi Pilzen, CFP Financial Planner and Mortgage Advisor (C.A.M.) (hereinafter: “The advisor“) respects the privacy of its customers and the privacy of its users (hereinafter collectively: “The user"or"The users") on the website https://zvifelsen.com ; On sites that offer the services of a consultant and/or referrer For services as defined below; On landing pages offering the consultant's services and/or referrals For services as defined belowand in the systems used to provide information to the Consultant, as detailed in this Privacy Policy (hereinafter, collectively and separately: “The website“). 

This Privacy Policy (hereinafter: “Privacy Policy") regulates the manner in which the advisor uses the information he collects from and in connection with users.  

The information provided below is intended to help users understand the Advisor's privacy policy. The privacy policy, as detailed below, will clarify the information that the Advisor collects about users, the purposes for which the Advisor collects information, what use the Advisor may make of the information, who the third parties to whom the Advisor transfers information are, and how the Advisor will handle and store information. 

The information that a user provides to the consultant depends on the user's consent and will and does not arise from a legal obligation. The information will be stored in a database for the purposes specified in this privacy policy. The use of the site and/or the services offered by the consultant (hereinafter: “The services"), indicate the user's consent to this privacy policy and that information will be stored and managed in the database as stated. The use of the information in the database will be done in accordance with the provisions of this privacy policy or in accordance with the provisions of any law, for the purposes specified below. Users who do not agree to the above and specified in this privacy policy are asked to refrain from providing any information to the consultant. However, users should be aware that failure to provide information may prevent the consultant from providing all or part of his services.

This privacy policy is written in the masculine gender only for convenience and should be read as referring to the feminine gender as well.

1. What is information?

In this policy, the term “information” means any information collected by the Consultant or provided to him by a User or someone on his behalf, as part of the User’s use of the Site or the Consultant’s services, through which the User can be identified and is protected under the Privacy Protection Law 5741-1981 (“The law“). 

1. The sources through which the advisor collects information about the user 
   1. Information that the user provides to the consultant, in any way, including but not limited to: in digital forms, in a contact form on the website, by email, by telephone (including in applications such as Whatsapp), orally, by mail directly or indirectly;
   2. Information that the user provides to the advisor, through systems used by mortgage advisors, including customer management systems, such as: SMART NPV, and also through forms and digital forms in these systems, for further details see Section 11 below;
   3. Information received by the advisor for the purpose and/or in the context of providing the services, including information received from third parties such as: mortgage advisors and/or financial advisors who use the advisor's services and/or to whom the advisor provides services, banks, insurance companies and any party to whom the advisor contacts in the context of providing the services and at the user's request. Including letters of thanks and/or criticism published on and/or about the provision of the services; 
   4. Information received by the consultant in connection with the use of the site and/or in the context of providing the consultant's services; 

1. The information that the consultant may collect about users 

The consultant may collect the information detailed below (in whole or in part) about users: 

1. Personal identifying information: ID number, contact information including full name, telephone number, address and email, date of birth and age, photo ID, photo driver's license or passport; and personal information: gender, marital status, number of children and their ages, employment status, place of work, position, seniority;
2. Financial and banking information: bank account number, bank name and branch, income information, payslips, confirmation of current account balances, bank account printouts, information on financial obligations (loans, credit lines), information on arrears or unpaid payments, income tax confirmation of withholding tax, confirmation of income, details of existing loans, relevant tax returns, confirmations of eligibility for benefits (e.g., Ministry of Housing eligibility), confirmation of eligibility for an annuity and/or benefit from the National Insurance Institute, pension data (including benefits), credit data report;
3. Property information: property purchase agreement, taboo draft and/or confirmation of rights, real estate appraisals, appraiser valuations, property details: address, area, type of property, lease (if any), approvals from the municipality or local authority, building plans (in the case of purchase from a contractor), building permit, seller/contractor details, warning notes, information on previous mortgages or liens;
4. Employment information: place of work, length of service at the workplace, position, fixed monthly income, additional income (bonuses, commissions), employment status (employee/self-employed), income tax file, VAT file, invoices/profit and loss reports (for the self-employed), CPA certificates on income;
5. Information on legal status: information on foreign citizenship, marriage certificate, confirmation of military/national service, sibling affidavit, immigrant certificate, information on open legal proceedings, information on bank foreclosures or restrictions, information on past bankruptcies or insolvency, signed affidavits, agreements between business partners, relevant insurance policies, pension information, information on an inheritance order, information on an estate distribution order, information on divorce proceedings;
6. Special and specific information: entitlements to benefits at banks, entitlements from welfare/disabled institutions, religious/cultural preferences (if arising in the employment context), medical-health information;
7. Recording of communications: recording of conversations with the user (recording of WhatsApp correspondence, emails and phone calls, recording of meetings (including online meetings), recording of digitally signed agreements);
8. Marketing information: real estate interests, preferred purchase date, willingness to return;
9. Any additional information that a user submits and/or receives from the consultant in connection with the user and the use of the site and/or the consultant's services, including medical information, provided that it is relevant to the services. 

1. The purposes for which the consultant collects the information  

The consultant collects information about the user for the following purposes - all or some of them:

1. For the purpose of and in connection with the provision of the services provided by the consultant, and including for the purpose of combining the information and transferring it to third parties with which the consultant's services are related, such as banks, insurance companies, credit companies, other financing entities, freelancers and contractor employees, and as part of any other service that the consultant has been asked to perform for the user, the user is aware that the third party's privacy policy will apply to information that will be transferred at his request to any of the above entities, and that he is obliged to warn about the provision of information to a third party to which he requests that information on his behalf not be transferred;
2. To comply with the provisions of any law;
3. To contact the user;
4. For analysis, research and compilation of statistics;
5. For the purpose of sending advertising materials, information about products and services, benefits, promotions, discounts and marketing information by electronic means; 
6. For the purpose of defending against claims, demands and allegations against the consultant and anyone on his behalf, as well as against third parties;
7. To enforce the provisions of service agreements and the provisions of this privacy policy;

1. Transfer of information

1. The consultant will not transfer or disclose information to third parties except as specified in this privacy policy. 

1. The transfer of information to third parties will include only relevant information that does not exceed the purposes for which the information is transferred and will be carried out in a manner proportionate to a defined, explicit and legitimate purpose.
2. The consultant may transfer the information or any part of it to third parties in one or more of the following cases: 
   1. Third parties that provide the Consultant with services and/or complementary services in connection with his activities and/or in connection with the services he provides from time to time to his clients and/or in connection with the users and at their request, including, freelancers and contractor employees of the Consultant. These entities may provide the Consultant and/or the user, among other things, appraisal services, website system support services, security systems and information technology (IT) systems, technological maintenance and support services, website operation services, information storage services and/or cloud services, information management services, financial services including advice and presentation of financing terms as well as financing offers and information about financing options, but not limited to, insurance companies and/or insurance agents, companies that provide the Consultant with communication channels with the users, information security services, lawyers and other external professional consultants including an accountant and digital professional services (including document collection and digital signature via an external system of https://app.2sign.co.il/ );
   2. When providing information by law;
   3. If the advisor receives an instruction, including a judicial order, ordering the provision of information in accordance with the provisions of any law;
   4. In any dispute, claim, demand, lawsuit or legal proceedings whatsoever between the user or anyone on his behalf and the consultant or anyone on his behalf;
   5. In the event that the consultant decides to transfer his activities to a corporation he owns;
   6. If a claim is raised or the consultant suspects that a user has committed an act and/or omission that may harm the consultant, anyone on his behalf, or any third parties;
   7. If a claim is raised or the consultant suspects that a user is using the site and/or services to commit an illegal act and/or to enable, facilitate, assist and/or encourage the commission of such an act;
   8. In any case where the consultant believes that providing the information is necessary to prevent harm to the consultant, the user or any third party.
3. In addition to the above, the consultant will be entitled to transfer the information to third parties, as stated above, also outside the State of Israel, including to third parties located in countries whose level of protection of the information does not comply with the provisions of Israeli law and which may provide less protection than that provided under Israeli privacy protection laws. Without derogating from the provisions of this policy, Use of the site indicates the user's consent to this privacy policy, including the transfer of information, its retention and storage with third parties located outside the State of Israel.

1. Information security

The Consultant takes technical and physical measures regarding privacy and information security in accordance with accepted standards. As is known, the storage and transmission of information by electronic means, including via the Internet, can never be completely secure and whenever the User provides information to the Consultant, particularly via the Internet, the User does so with full consent and subject to the risks involved in transmitting information in this way. The Consultant There is no guarantee that the information will be completely immune from unauthorized access. In any case, if the user has reason to believe that transferring information to the consultant is no longer secure, please inform the consultant using the means of contact listed in Section 16 of the Privacy Policy. 

1. Limitation of liability 

The consultant and anyone on his behalf will not bear any liability, and is exempt from any responsibility, in connection with any damage, loss or expense, of any kind and type, whether direct or indirect and/or circumstantial and/or consequential, which has been and/or will be caused to users and/or a third party, in all matters related to and concerning the collection of information, its use, its transfer to third parties, its preservation, its security, etc.

1. Information retention period

The Consultant will retain the User's information for the period of time necessary to ensure the purposes detailed in this Privacy Policy unless a longer retention period is required or permitted by law.

1. Information about other people  

If the User provides personal information to the Consultant regarding other individuals, including family members and other third parties, the User must do so only after: (a) the User has informed the third parties about the contents of this Policy; and – (b) the User has received the necessary consent for the collection, use, disclosure and transfer of personal information about the third party in accordance with this Policy and in accordance with the provisions of the law, to the extent required.

1. Cookies  
   1. Without derogating from what is stated in Section 11 below, the Site may use Cookies and other technologies such as pixels and more (hereinafter collectively: “The cookies“) through which external website operators and the Consultant may collect non-identifying information in connection with users of the Site. Without derogating from the foregoing, if a user chooses to provide identifying information on the Site, that information will be linked to the non-identifying information collected on the Site.
   2. Cookies are small text files that allow information to be collected through users' computers or through the web browser, including, among other things, the following types of information: the pages the user visited on the site, actions taken by the user on the site, the length of time the user spent on the site, information the user viewed on the site, approximate geographic location, the user's age range, the type of device from which the site was accessed, the user's interests, the user's IP address (i.e., the user's computer address on the Internet), number of visits to the site, number of clicks, screen resolution, operating system type and version, web browser type, version and language preference, domain names, and more. 
   3. Cookies are used by the consultant for analysis, statistical analysis and research services of third parties such as Google Analytics. The use of Google Analytics services is subject to the terms of use and privacy policy of Google Analytics. You can learn about the information collected as part of these services, the uses of the information, how to cancel cookies and more in the Google Analytics privacy policy at the link: https://policies.google.com/privacy?hl=iw.
   4. A user who does not want cookies to be collected on his computer can avoid this by changing the settings in his browser. To do this, the user should consult the browser's help file. Disabling cookies may result in some of the services on the site being unavailable or their quality being impaired. Notwithstanding the above, cookies that are essential and necessary for the operation and management of the site cannot be disabled. 

1. Links and hyperlinks 

The Site as defined is not necessarily under the control and/or ownership of the Consultant and the Consultant does not supervise it and does not check the reliability and legality and related to the information security of any site that is not owned by it. In addition, the Site may offer links, hyperlinks or banners to other sites, which the Consultant does not supervise or check, their reliability and legality and everything related to their security and their privacy protection policies. 

The consultant will not be responsible for the use made by users of a site that is not under his control and ownership and/or of the links that appear on the site, on pages that are not on the site or that are on another site, and will not be responsible for the correctness and correctness of the results that may appear in the links, including in linked calculators, and the users undertake to comply with and comply with the instructions and conditions of those sites or web pages and to contact the providers of these sites or pages directly in all matters that may arise in connection with entry, browsing, use, etc. Therefore, the consultant will not bear any responsibility, of any kind, in connection with the other sites, including in all matters related to the collection, use, transfer of information on the other sites, the content that will be published on the pages of the other sites, etc. 

At the user's request, the consultant will direct the user to write a review of the services on an external website. Such external website may allow the user to write an anonymous review, and in any case, writing such a review depends on the user's wishes and there is no legal obligation to write such a review. Similarly, in this case, the consultant does not supervise the external website and has not checked it, its reliability and legality, and everything related to its security and privacy policy. Therefore, the consultant will not be responsible for the user's use of the external website to write the review.

As mentioned above, information can be provided to the advisor Using SMART NPV systems (https://www.snpv.co.il/ ) and system  https://app.2sign.co.il/ (hereinafter: “The systems"), including through forms in systems operated by third parties. It is clarified that everything stated in this policy regarding links, hyperlinks and banners will apply, with the necessary changes, to the use of the systems. Therefore, the consultant will not bear any responsibility, of any kind, in connection with the systems, including with regard to the collection, use or transfer of information through them and/or in connection with the privacy policy of the system operators.

Using Bank Hapoalim's digital payment services – “Bit” (https://www.bitpay.co.il/he (hereinafter: “Billing service provider“) – To the extent possible, the Consultant will allow users to make payment for the Services, via a link from a billing service provider, a credit billing page on behalf of a billing service provider, and directly via the billing services. That is, the payment will be made via the billing service provider, which is a third party, and therefore the credit information or payment details will not be stored in the Consultant’s database. The privacy policy of the billing service provider will apply to information collected by the billing service provider, including information transferred from the billing service provider to the Consultant, including in the event that the Consultant requires verification of the user’s identity in accordance with the information provided by the user to the billing service provider (note: in certain cases, the last 4 digits, billing terms, and more may be transferred and/or displayed to the Consultant). It is clarified that everything stated in this policy with respect to links, hyperlinks, and banners will also apply, with mandatory changes, to the use of the billing services.

1. Right to review and correct information

Users have the right to review the personal information stored about them, to request its correction, updating or even deletion, to the extent that there is no legal impediment to doing so, and the consultant will respond to the aforementioned request in accordance with the provisions of applicable law. If the user wishes to review or correct the information, this can be done by contacting the consultant in accordance with the contact details appearing in Section 16 of this Privacy Policy below.

1. Applicable law and jurisdiction

1. The terms and conditions detailed in this Privacy Policy, as well as any changes or amendments thereto, as well as the use of the Site, will be governed by the laws of the State of Israel without reference to the choice of law provisions applicable therein. 
2. Jurisdiction in connection with any dispute and/or claim that may arise in connection with the use of the website and this privacy policy or related to it is vested exclusively in the Magistrate's Courts in Petah Tikva.

1. Changes and updates 

The Consultant may, at its sole discretion, change the Privacy Policy from time to time without notice or warning. The most recent Privacy Policy published on the Site or together with the Consultant's Services Agreement will be binding on the User. The User's continued use of the Site or Services after the Privacy Policy has been updated will constitute the User's consent to the updated Privacy Policy, including any changes.  

1. variance 

1. The user may not assign his rights and/or obligations under this Privacy Policy to another. The consultant may transfer his rights and/or obligations to another. 
2. This privacy policy does not derogate from any right granted to the consultant and/or anyone on his behalf under any law. 
3. Minor Information: The Consultant does not collect personally identifiable information about minors under the age of 18. Users under the age of 18 must obtain the consent of a parent or guardian to view the Site. If the Consultant becomes aware that a minor under the age of 18 is submitting personally identifiable information to the Site, the Consultant will make reasonable efforts to delete the information and prevent use by minors. The Site and the Consultant's services are not directed to or intended for minors under the age of 18 and the Consultant is not interested in receiving information about minors. If you believe that information has been provided to the Consultant by a minor, please contact the contact details listed in Section 16 of this Privacy Policy below.

1. Contact us

If the user has any questions or comments regarding the privacy policy, the user is invited to contact the advisor via email at:  Zvifelsen@gmail.comOr call: 054-397-6756.    

Updated for October 2025.