Privacy Policy

Goch Capital LTD
Effective Date: August 2025

1. Introduction

Goch Capital LTD (“we,” “our,” or “us”) values your privacy and is committed to protecting your personal information in compliance with:

Israeli Protection of Privacy Law, 1981 (including Section 13 and Amendment 13), and the Privacy Protection Regulations (Data Security), 2017.
The EU General Data Protection Regulation (GDPR).
Applicable U.S. laws, including the California Consumer Privacy Act (CCPA/CPRA).

This Privacy Policy explains how we collect, use, disclose, transfer, and safeguard your personal data when you visit our website www.gochcapital.com or use our services.

By using our services, you agree to this Policy. If you do not agree, please stop using our services.

2. Information We Collect

We collect the following categories of information:

Personal Data: Name, email, phone number, mailing address, demographics (e.g., age, gender, location, interests).
Financial Data: Payment details (credit/debit card, billing address) when processing purchases or transactions.
Technical/Usage Data: IP address, device type, browser, operating system, access times, pages visited, cookies, and analytics data.
Third-Party Data: Data received from linked services (e.g., social networks, identity providers), only if you authorize such sharing.
Sensitive Data: We generally do not collect sensitive data (e.g., biometric, health, or religious data). If required, we will obtain explicit consent.

3. Legal Basis for Processing

We process personal data only where lawful. Depending on your jurisdiction, our bases include:

Consent: Where you explicitly agree (e.g., to receive newsletters).
Contractual necessity: To provide requested services or fulfill transactions.
Legal obligation: To comply with tax, financial, or regulatory duties.
Legitimate interest: To improve our services, secure our systems, prevent fraud, and communicate with customers—provided these interests do not override your rights.

For California residents, processing may also be defined as a “business purpose” or “sale/share” of personal information, as per the CCPA.

4. How We Use Your Information

We may use your information to:

Provide, maintain, and improve our services.
Process and complete transactions.
Communicate about your account, purchases, or updates.
Send promotional offers (with opt-out options).
Personalize your experience and improve our website.
Comply with legal obligations.
Detect and prevent fraud or unauthorized access.

5. Data Sharing & International Transfers

We may share your personal information with:

Service providers (payment processors, hosting, analytics, customer support, IT, and marketing).
Affiliates or business partners (where necessary for providing services).
Legal authorities (when required by law or to protect rights, property, or safety).
Corporate transactions (in case of a merger, acquisition, or restructuring).

International Transfers

If we transfer personal data outside Israel, the EU, or your jurisdiction, we ensure safeguards such as:

Countries deemed to provide adequate protection,
Standard Contractual Clauses (GDPR),
Binding corporate rules, or
Your explicit consent.

6. Data Retention

We retain personal data only as long as necessary for the purposes stated in this Policy, or as required by law. Afterward, we securely delete, anonymize, or archive it.

7. Your Rights

Under Israeli Law (Section 13 & Amendment 13)

You have the right to:

Access your data held by us (directly, or via an authorized representative/guardian), in a language you understand (Hebrew, Arabic, or English).
Correction or Deletion of inaccurate or outdated data.
Refusal & Appeal: If your request is refused, we will notify you, and you may appeal to court under Section 15 of the law.

Under GDPR (EU Residents)

You also have the rights to:

Portability: Receive a copy of your data in a structured, machine-readable format.
Restrict Processing: Request limited use of your data.
Object to processing based on legitimate interests or direct marketing.
Withdraw Consent at any time.

Under CCPA (California Residents)

You may request:

Access: Disclosure of categories and specific pieces of personal data collected.
Deletion: Removal of your personal data (subject to exceptions).
Opt-Out: Choice to prevent “sale” or “sharing” of your data.
Non-Discrimination: You will not be discriminated against for exercising these rights.

How to Exercise Your Rights

To make a request, please contact us (see Section 10). We will respond within applicable legal timeframes.

8. Children’s Privacy

Under Israeli law: we do not knowingly collect data from individuals under 18 without parental consent.
Under U.S. COPPA: we do not knowingly collect data from children under 13.
If we learn we have collected such data, we will delete it promptly.

9. Cookies & Tracking

We use cookies and similar technologies to:

Enable website functionality,
Analyze site usage,
Deliver personalized content,
Support advertising.

You can manage cookie preferences through your browser or opt-out of targeted ads (e.g., via the Network Advertising Initiative).

10. Data Security

We implement technical, organizational, and physical safeguards to protect personal data, as required by:

Israeli Data Security Regulations (2017),
GDPR requirements, and
Industry best practices.

However, no system is 100% secure, and we cannot guarantee absolute protection.

11. Supervisory Authorities & Contact

Israeli Authority

Privacy Protection Authority (PPA)
https://www.gov.il/he/departments/the_israeli_privacy_protection_authority

EU Residents

You may contact your local Data Protection Authority (DPA).

U.S. Residents

You may contact your state’s Attorney General or relevant regulator.

Contact Goch Capital LTD

Email: Investor.relations@gochcapital.com
Address: Ehad Haam 9, Tel Aviv, Israel

12. Changes to This Privacy Policy

We may update this Policy from time to time for legal, operational, or technical reasons. Updates will be posted on this page, and material changes will be notified to you when required by law.