Privacy Policy

Total Capital Bond Ltd., Israel Total Capital Long Ltd. and Israel Total Capital Opportunity Ltd. (collectively, “Total”) respect the privacy of their clients and investors, both existing and prospective, of visitors to Total’s website (the “Website”), and of any other person who provides personal information to Total or whose personal information is collected or received by Total in the course of its activities (collectively, the “Users”).

This privacy policy (the “Privacy Policy”) sets out the manner in which Total collects and processes personal information in the course of its activities, including through the Website, in the course of its engagement with existing or prospective investors and clients, by e-mail, telephone, forms and documents, at meetings and through any other means of communication, as well as the purposes for which such information is used, the manner in which it is retained and the transfer thereof to third parties.

This Privacy Policy applies to personal information provided to Total directly by the data subject and, to the extent relevant and in accordance with applicable law, to personal information about the data subject received by Total from other sources.

The provision of personal information to Total is subject to the User’s free will and consent and is not required by law, unless otherwise stated or unless the provision of such information is required under applicable law. However, without the provision of certain information, Total may be unable to provide a service, respond to an inquiry, engage with the User, or enable the User to subscribe for an investment or to continue his or her investment, as applicable.

The information may be retained in databases under Total’s control and processed for the purposes set out in this Privacy Policy.

This Privacy Policy constitutes, among other things, a notice in accordance with the provisions of the Protection of Privacy Law, 5741-1981, as amended from time to time (the “Law”).

  1. Information Collected

Total may collect and receive personal information in the course of its activities, including through the Website, as part of onboarding and investment processes, in the course of its relationship with existing or prospective investors and clients, as part of identification, know-your-client (KYC), anti-money laundering, counter-terrorist financing and compliance procedures, and through correspondence, calls, meetings, forms, documents and information provided to Total or to anyone acting on its behalf.

Such information may include, among other things:

1.1       Identification and contact details, including full name, identity card or passport number, the company or corporation on whose behalf the User acts, position, telephone number, address and e-mail address;

1.2       Information and documents provided as part of onboarding, investment, identification, KYC, anti-money laundering, counter-terrorist financing and compliance processes;

1.3       Financial and economic information provided to Total in the course of its activities and its relationship with existing or prospective investors;

1.4       Information provided by the User through forms on the Website or in inquiries submitted to Total;

1.5       Information received in the course of calls, meetings or correspondence with Total’s representatives;

1.6       Additional information and documents that the User elects to provide to Total;

1.7       Technical information and information relating to the use of the Website, including IP address, browser and device type, times of access to the Website, pages visited by the User and actions performed on the Website;

1.8       Aggregated, statistical or other data derived from the foregoing information.

Total may also retain and process information collected in the course of its activities in a form that does not personally identify the User.

  1. Purposes of Use

Total may use the information, in whole or in part, among other things, for the purpose of:

2.1       Managing its relationship with existing and prospective investors and clients;

2.2       Evaluating the admission of investors and conducting identification, KYC, anti-money laundering, counter-terrorist financing, compliance and other checks required or customary in the course of Total’s activities;

2.3       Managing investors’ investments, providing services and performing Total’s obligations towards them;

2.4       Responding to inquiries and contacting the User;

2.5       Providing information regarding Total’s activities, the funds managed by it and the services offered by it;

2.6       Operating, managing, maintaining and developing the Website;

2.7       Improving the Website, the user experience and the services provided by Total;

2.8       Analysis and research, compilation of statistical data and monitoring of activity on the Website;

2.9       Sending updates and information, including marketing materials, to the extent the User has consented thereto and in accordance with applicable law;

2.10     Protecting and safeguarding Total’s rights and legitimate interests, preventing misuse or unlawful activity, and defending against claims, demands or legal proceedings;

2.11     Complying with the provisions of any law, regulatory requirement, directive of a competent authority or other obligation applicable to Total.

  1. Transfer of Information to Third Parties

Total will not transfer personal information to third parties other than in accordance with this Privacy Policy and applicable law.

Total may transfer information, or enable access thereto, to the extent required and for the relevant purpose, among other things:

3.1       To suppliers and service providers assisting Total in its activities, including fund managers, administrators, banks and financial institutions, brokers, providers of IT, hosting, information security, information systems, communications, client relationship management, mailing and marketing services, as well as lawyers, accountants, tax advisers and other professional advisers;

3.2       To companies and entities affiliated with Total, to the extent required for the purposes set out in this Privacy Policy;

3.3       For the purpose of conducting identification, KYC, anti-money laundering, counter-terrorist financing and compliance checks;

3.4       Where disclosure of the information is required by law, court order, regulatory requirement or a demand of a competent authority;

3.5       In the context of a dispute, demand, claim or legal proceeding;

3.6       Where there is a concern that the Website or Total’s services have been used unlawfully or in a manner liable to harm Total, anyone acting on its behalf or any third party;

3.7       In the context of a corporate restructuring, merger, sale, transfer of business or assets or a similar transaction, including for the purpose of evaluating such a transaction, subject to applicable law.

Information may also be stored, transferred or processed outside of Israel, including in countries in which the level of protection afforded to personal information may differ from that applicable in Israel, all in accordance with applicable law.

  1. Information Security and Limitation of Liability

Total employs customary and reasonable measures to protect and secure the information in its possession, in accordance with applicable law.

However, information and communication systems, and in particular the transmission and storage of information over the Internet, are not entirely immune to intrusion, unauthorized access, disclosure, loss of information, disruptions, malfunctions or other information security incidents, and Total cannot guarantee the absolute immunity of the Website, its systems or the information stored therein.

Subject to the provisions of any law, Total shall not be liable for any damage, loss or expense incurred by the User or any third party as a result of any such event that is beyond its reasonable control. Nothing in this Privacy Policy shall derogate from any liability or obligation imposed on Total by law that cannot be contracted out of.

  1. Retention Period

Total will retain personal information for the period reasonably required for the purposes for which it was collected or received, for the management of its activities and its relationship with its investors and clients, for the protection of its rights and for compliance with the legal, contractual or regulatory obligations applicable to it, all in accordance with applicable law.

  1. Information Concerning Third Parties

Where a User provides Total with personal information relating to another person, the User must ensure that he or she is authorized to provide such information and that such person has been given the required notices and has provided the consents required by law, to the extent required.

  1. Cookies and Similar Technologies

The Website may use cookies and similar technologies for its proper and ongoing operation, the collection of statistical data, information security, customization of the Website and improvement of the user experience.

Cookies are files stored on the User’s device which may collect, among other things, information regarding the use of the Website, the pages visited by the User, the duration of the visit, the type of device and browser, the operating system and the IP address.

Certain cookies may be operated by third parties that provide Total with analytics, measurement or other technological services.

Browser settings may be adjusted to restrict or block cookies. Blocking certain cookies may affect the availability or proper functioning of certain features of the Website.

  1. Links to External Websites

The Website may contain links to third-party websites or services. Use of such websites and services is subject to their own terms and privacy policies, and Total is not responsible for the manner in which such third parties collect or use information.

  1. Right of Access and Rectification

In accordance with the provisions of the Law, a person is entitled to access, personally or through a person duly authorized for such purpose, personal information about him or her held in a database, subject to the conditions prescribed by law.

Where a User finds that information about him or her is inaccurate, incomplete, unclear or not up to date, the User may contact Total with a request to rectify or delete such information, in accordance with the rights afforded to him or her by law.

  1. Changes to this Privacy Policy

Total may update this Privacy Policy from time to time, including as a result of changes in its activities, the Website, technology or applicable laws and regulations. The updated version will be published on the Website.

  1. Contact Us

For questions, comments or requests regarding this Privacy Policy or the exercise of rights in relation to personal information, Total may be contacted via:

E-mail: [●]

Address: [●]

Last updated: August 2026.