Privacy Policy

1. Introduction

פרונטרה 1 בע"מ (Fronterra 1 Ltd.), company number 516593167, trading as Fronterra Investments (“Fronterra”, “we”, “our”, or “us”), is committed to protecting the privacy of all individuals who interact with our website at www.fronterra-inv.com (the “Site”). This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information in accordance with the Israeli Protection of Privacy Law, 5741-1981 (as amended) and all applicable regulations thereunder, as well as other relevant data protection frameworks where applicable.

By accessing or using this Site, you acknowledge that you have read, understood, and agree to the practices described in this Privacy Policy.

2. Information We Collect

We may collect the following categories of personal information:

• Contact information — name, email address, phone number, and company or organization name, provided voluntarily through our inquiry forms.
• Professional information — your role, investor classification (e.g., institutional investor, limited partner, business owner), and nature of your inquiry.
• Technical data — IP address, browser type, operating system, referring URLs, pages visited, and time spent on the Site, collected automatically via cookies and similar technologies.
• Correspondence — any messages or documents you send to us.

We do not knowingly collect personal data from individuals under the age of 18. The Site is intended for professional and institutional audiences.

3. How We Use Your Information

We use the personal information we collect for the following purposes:

• To respond to investor inquiries and partnership requests.
• To evaluate potential investment opportunities and conduct due diligence.
• To communicate updates, fund-related information, or relevant developments to existing or prospective investors and partners (where consent has been obtained).
• To maintain records as required by applicable Israeli securities and financial regulations.
• To improve the functionality and content of our Site.
• To comply with our legal obligations, including anti-money laundering (AML) and know-your-customer (KYC) requirements under Israeli law.

4. Legal Basis for Processing

We process personal information where: (a) you have given your consent; (b) processing is necessary to respond to your inquiry or fulfill a contractual obligation; (c) we have a legitimate interest in processing (e.g., managing investor relations or improving our Site); or (d) we are required to do so by law. Where we rely on consent, you may withdraw it at any time by contacting us.

5. Disclosure of Information

We do not sell, rent, or trade personal information. We may share information with:

• Professional advisors — legal counsel, auditors, tax advisors, and compliance consultants, subject to strict confidentiality obligations.
• Service providers — third-party technology and infrastructure providers that support our operations, who are contractually bound to protect your data.
• Regulatory authorities — the Israel Securities Authority (ISA), the Israeli Tax Authority, or other competent authorities, when required by law.
• Prospective acquirers — in the event of a merger, acquisition, or restructuring of Fronterra, subject to confidentiality undertakings.

6. Cookies and Tracking Technologies

Our Site uses cookies and similar tracking technologies to understand how visitors engage with our content and to improve Site performance. You may configure your browser to refuse cookies; however, certain features of the Site may not function correctly if you do so. We do not use cookies for targeted advertising purposes.

7. Data Retention

We retain personal information for as long as necessary to fulfill the purposes for which it was collected, including compliance with legal, accounting, and regulatory requirements. Inquiry data is typically retained for a period of seven (7) years in accordance with Israeli record-keeping obligations under the Companies Law and tax regulations, unless a longer period is required.

8. Data Security

We implement appropriate technical and organizational measures to protect personal information against unauthorized access, loss, destruction, or alteration. However, no method of transmission over the internet is entirely secure, and we cannot guarantee absolute security.

9. Your Rights

Under the Israeli Protection of Privacy Law, you have the right to:

• Request access to personal information we hold about you.
• Request correction of inaccurate or incomplete information.
• Request deletion of your personal information, subject to legal retention obligations.
• Withdraw consent where processing is based on consent.
• Object to processing for direct marketing purposes.

To exercise any of these rights, please contact us at the details below.

10. International Transfers

Where personal data is transferred outside of Israel, we ensure that adequate safeguards are in place in accordance with applicable law, including transfers to jurisdictions recognised by the Israeli Privacy Protection Authority as providing an adequate level of protection.

11. Changes to This Policy

We may update this Privacy Policy from time to time. Any material changes will be posted on this page with an updated effective date. Continued use of the Site following such changes constitutes acceptance of the revised policy.

12. Contact Us

If you have any questions about this Privacy Policy or wish to exercise your rights, please contact us at: