Privacy & Policy

Last Updated: June 2026

Travel Conexion Ltd. (the “Company”, “we”, “us”, or “our”) is a member of the SarEl Group, specializing

in inbound tourism to Israel. We work with foreign travel agents who bring groups and individual

travelers to Israel, providing them with comprehensive ground services including accommodation

coordination, tour guiding, and transportation services. In order to organize tours, coordinate with

hotels and service providers, and meet applicable regulatory requirements, we collect and use personal

information.

This Policy is intended to explain, clearly and transparently, what information we collect, why we collect

it, how we use it, and to whom it may be disclosed.

It applies to all of the Company’s activities, including:

● Browsing and enquiries through our website;

● Managing working relationships with travel agents;

● Operating tours and processing passenger data for operational and regulatory purposes; and

● The use of our information systems and software.

1. Data Controller. The Company is the data controller in respect of the personal information it

holds about the individuals described in Section 3 below. In simple terms, we are the entity

legally responsible for the collection, storage, and use of your information as set out in this

Policy.

However, it is important to clarify that much of our activity is carried out in partnership with

foreign travel agents. Where personal information about end travelers and passengers is passed

on to us by a travel agent for the purpose of executing a tour, we use that information solely to

deliver the required operational service. In such cases, the travel agent bears responsibility as

the data controller in its own right, including the obligation to ensure that the information was

lawfully collected and with the consent of the passengers. In relation to information collected to

meet regulatory and legal obligations, the Company acts as an independent data controller.

If you are a travel agent or any other party providing us with personal information about

another person, you are responsible for ensuring that you have obtained all required consents

and that you are lawfully permitted to share that information with us and to authorize its

processing for the purpose of delivering the service.

2. Personal Information and Consent. In this Policy, “personal information” means any detail by

which you can be identified, directly or indirectly. For example: your name, the name of the

company you represent as well as company ID, your telephone number, address, email address,

bank account details, and any other information you have provided to us or that has been

collected in the course of your engagement with us. Anonymous or aggregated information that

does not allow a specific individual to be identified does not constitute personal information.

You are under no legal obligation to provide us with personal information, and any information

you share with us is provided of your own free will and as a result of your choice to work with us

or to receive our services. However, in order for us to manage the business relationship,

organize tours, meet applicable regulatory requirements, and provide you with the services you

have requested, we require these details. Failure to deliver such information may prevent us

from providing our services.

3. Categories of Data Subjects. In general, the Company collects and processes personal

information about the following categories of individuals:

○ Foreign travel agents and their representatives, who work with us to organize tours to

Israel;

○ Independent tour guides and other service providers who act as suppliers in the context

of the Company’s operations;

○ Tourists and end travelers whose details are passed to us by agents for the purpose of

operating tours; and

○ Visitors and enquirers who contact us through the Company’s website.

4. Categories of Information Collected. Depending on the nature of your relationship with us, we

may collect different types of personal information, as detailed below.

○ Identity and Contact Information. Full name, job title, company name, address,

telephone number, email address, and other contact details, as provided to us when

making contact, managing an ongoing business relationship, or in the course of service

delivery.

○ Commercial and Financial Information. Commercial terms, account identifiers, bank

account details, and payment information relating to suppliers and independent guides.

Without these details, we cannot manage the financial relationship or make payments

as required.

○ Passenger and Traveler Information. Details passed to us by a travel agent for the

purpose of operating a tour, including name, passport number, date of birth, nationality,

and flight details. Free-text fields may also include information relating to a passenger’s

dietary requirements or health-related needs, where the agent chooses to share this

with us. This information is of a particularly sensitive nature and will be used solely for

the purpose of delivering the required operational service. Without this information, we

may not be able to accommodate passengers’ needs during the tour.

We ask that no sensitive information beyond what is strictly necessary be entered in

free-text fields. It is strictly prohibited to provide information about another person

without their authorization.

○ Booking and Operational Data. Data relating to tours and packages booked, tour

destinations, dates, group composition, special requests noted during booking, and the

history of your business dealings with us.

○ Communications Records. Email correspondence and messages exchanged between

you and the Company in the context of the business relationship, including enquiries,

requests, and coordination.

○ Technical and Digital Information. Information collected during use of our website,

including IP address, browsing data, browser type, operating system, pages viewed, and

cookies, for the purposes of website operation, security, and improvement of the user

experience, as further detailed in Section 7.

5. Purposes for Which We Use Your Information. We collect and use personal information only for

specified, explicit, and legitimate purposes, and only to the extent necessary for those purposes.

We do not sell personal information to third parties, nor do we use it for purposes incompatible

with those for which it was originally collected.

The Company uses personal information for the following purposes:

○ Managing ongoing working relationships with travel agents, guides, and service

providers;

○ Operating inbound tours to Israel, including hotel coordination, guiding, transportation,

and related ground services;

○ Processing visas and entry documentation in accordance with the requirements of the

relevant authorities in Israel and destination countries;

○ Meeting regulatory and legal obligations, including documentation for bookkeeping

purposes;

○ Billing, payment processing, accounting, and maintaining financial records;

○ Marketing and direct communications to agents, subject to consent and applicable law;

○ Managing initial enquiries and leads from the website;

○ Legal protection and the pursuit of the Company’s legitimate business interests; and

○ Operating and securing our website and services.

6. Disclosure of Information to Third Parties. The Company will disclose personal information to

the following categories of third parties, and only to the extent necessary to fulfil the purposes

set out above:

○ Vendors and partners who assist us in providing our services, including information

systems, software and IT service providers (for the operation, maintenance, backup, and

security of the Company’s systems), mailing service providers, marketing service

providers, and payment processors;

○ Local and international tourism and ground service providers, including hotels, tour

guides, and tour operators in destination countries, as required to execute the tour;

○ Competent authorities in Israel and destination countries, including for visa processing,

enforcement bodies and courts, to the extent required by law;

○ Third parties in connection with a structural change, merger, acquisition, or transfer of

business activity, provided that the receiving party undertakes to protect the

information in accordance with the terms of this Policy and applicable law;

○ Where there are reasonable and justified grounds to believe that disclosure is

immediately necessary in order to prevent serious harm to a person’s physical safety or

property, or to prevent harm to our infrastructure.

International Transfers. In the course of the Company’s activities, personal information may be

transferred to countries outside Israel, including countries where the level of protection for

personal information may differ from that applicable in Israel. The Company will take reasonable

steps to ensure an adequate level of protection in accordance with applicable law governing

such transfers. Where required, we will put in place appropriate safeguards — such as

contractual arrangements or equivalent protections — to protect the information in transit and

at its destination.

7. Cookies and Analytics Tools. Our website uses cookies and similar digital tools for day-to-day

operation, security, statistical analysis, and improvement of the user experience. Cookies are

small text files stored on the user’s device through their browser. Information collected via

cookies includes, among other things, browsing data, IP address, browser type and operating

system, pages viewed, and time spent on the website.

We may use the following tools, among others:

○ Google Analytics: for statistical analysis of website usage, measuring traffic volumes,

and improving content. This tool uses cookies to collect information about how the

website is used. Its use is subject to Google’s Privacy Policy.

○ Operational cookies: for the day-to-day operation of the website and for retaining the

user’s basic settings during a browsing session.

If additional tools for advertising or analytics purposes are used in the future, this Policy will be

updated accordingly.

You may at any time delete existing cookies or block the saving of new cookies through your

browser settings. Blocking certain cookies may affect the functionality of the website. Cookies

that are not essential to the operation of the website will only be used subject to your consent,

as provided through the consent management interface on the website.

8. Information Security. The Company implements physical, organizational, and technical

information security measures, proportionate to the sensitivity of the information, with the aim

of protecting it against unauthorized access, exposure, loss, or misuse. We regularly review and

update our security practices to address evolving risks.

That said, no information system or website is entirely immune from security risks, and the

Company cannot guarantee absolute protection of information in all circumstances. The

Company does not accept liability for damages resulting from cyber incidents, data breaches, or

security failures that are not within its reasonable control, provided it has taken reasonable

security measures.

9. Your Rights as a Data Subject. We respect the rights of individuals with regard to their personal

information. Depending on your location and the applicable law, the following rights may be

available to you:

○ Access: to request access to the personal information we hold about you;

○ Rectification: to request that inaccurate, incomplete, or outdated information be

corrected;

○ Erasure: to request that your personal information be deleted, where there is no

overriding legal basis for its retention;

○ Objection to direct marketing: to object to receiving promotional communications or

marketing offers from us at any time, whether by contacting us directly or by using the

unsubscribe mechanism included in the communications themselves.

Requests of this kind will be handled in accordance with the provisions of applicable law and will

be subject to verification of the requester’s identity. To make a request regarding your personal

information, please contact us at policy@conexiontravel.com.

If your request concerns personal information in respect of which we are not the data controller

but rather a service provider acting on behalf of another party (for example, information about

tourists and end travelers that was passed to us by the travel agent who organized your tour),

you will need to direct your request to the relevant travel agent.

Please note that responses to requests may be subject to exceptions, restrictions, and retention

obligations imposed on us by law. We reserve the right to continue holding personal

information to the extent required to comply with legal and regulatory obligations, to protect

legitimate legal and business interests, or for the purposes of future defense against claims — all

in accordance with applicable law.

10. Updates to This Policy. The Company may update this Policy from time to time. The date of the

most recent update will appear at the top of this document. In the event of a material change,

the Company will take reasonable steps to notify you, for example by posting a notice on the

website.

11. Governing Law and Jurisdiction. This Privacy Policy, its interpretation, application, and

enforcement shall be governed exclusively by the laws of the State of Israel. Exclusive

jurisdiction over any matter relating to this Policy is vested in the competent courts of the

Jerusalem District.

12. Contact Us. For questions or enquiries regarding this Privacy Policy, please contact the Company

by email at: privacy@conexiontravel.com.