This is the English version of the AVOS Privacy Policy. If the English and Hebrew versions differ, the Hebrew version prevails, except where the law of the user’s place of residence requires otherwise.

The AVOS website (the “Site”) offers research, documentation and preservation of family heritage, as well as genealogical and professional research for private, institutional and legal purposes. This includes archival research, locating and documenting historical sources, collecting and preserving family materials, interviews and audio documentation, biographical writing, production of heritage volumes, family trees and digital family archives, eligibility research and locating documents and sources for private clients, lawyers, institutions and communities, and related services (the “Services”).

On the Site you can learn about the different service paths offered by the Site operator, and leave your details to receive information, schedule a consultation or continue a business relationship with the Site operator.

This policy describes how avoslegacy.com handles personal information. Please read it before using the Site. By browsing or using the Site in any way, including viewing content and sending requests for information, you agree to this policy. If you do not agree, please do not use the Site. This policy may be updated from time to time; please check it when you visit the Site.

1. Definitions

1.1. “Site”: the website at avoslegacy.com, including all its pages and any personal area, digital service or self-service offered through it from time to time.

1.2. “Site Operator” or “AVOS”: Noam Efrati, exempt dealer (Israeli VAT-exempt sole proprietor) no. 205405236, trading as AVOS Legacy, address: 2 Ofra Haza St, Rosh HaAyin, Israel; email: hello@avoslegacy.com.

1.3. “Use”: any use of the Site, including visiting, browsing, viewing content, leaving details, making contact, requesting information, ordering services or any other action through the Site.

1.4. “User”: any person who uses the Site or the Services offered through it.

1.5. “Family Materials” or “Research Materials”: any material, information or item provided to AVOS as part of the Services, including documents, certificates, photographs, recordings, videos, personal stories, family information, historical documents and scanned items.

1.6. “Deliverables”: anything produced as part of the Services, including research reports, family trees, heritage volumes, digital archives, edited recordings and documentation.

1.7. “Services”: all services offered by AVOS from time to time, as described above and on the Site.

2. General

2.1. The Site offers archival and genealogical research and the documentation and preservation of family heritage, as described above, including professional research for private, institutional and legal purposes and related services.

2.2. To use some of the Site’s services you may need to provide personal information such as your name, contact details and email address. You are not legally required to provide personal information; doing so is your choice. Without information needed for a particular service, however, we may not be able to provide that service.

2.3. When you provide personal information, you confirm that it is accurate and complete, and you agree to update it if it changes.

2.4. You may not provide information or materials about another person without appropriate authorization. If you provide information about other family members, including photographs, documents, personal stories or contact details, you confirm that you are entitled to do so and that doing so does not breach any law or third-party right.

2.5. Personal information you provide will be kept in AVOS’s databases and used in accordance with this policy and applicable law.

2.6. AVOS may use WhatsApp Business to communicate with you, respond to you and manage the Services (the “Communication Tool”). Information provided through it is processed under this policy. As of the date of this policy, AVOS does not operate an AI chatbot or a dedicated app on the Site.

2.7. As part of the Services, Users may provide content and materials, including Family Materials, documents, photographs, recordings, personal stories and historical information. These are handled in accordance with the law and this policy. Where content is shared in a way that gives access to other users or third parties, such as in a family digital space, this is done according to the service settings and the consents given in the engagement. You are responsible for ensuring you are entitled to provide AVOS with information and content about third parties.

3. What information we collect

The Site collects two main kinds of information: personal details and technical data.

3.1. Personal details are details you provide yourself when you contact us or fill in a form on the Site, such as your first and last name, phone number, email address and the content of your message. During the Services, and depending on the type of research, additional details may be provided, such as an ID number, home address, age and sex, where needed for the research.

If you entered personal details in a digital process on the Site, some of them may be kept and used to contact you (including by WhatsApp) even if you did not complete the process.

In addition, as part of the Services you may provide information and materials about yourself and other people, living or deceased, including family and historical details, names and contact details, identity and official documents, birth, marriage and death certificates, immigration and citizenship documents, inheritance and estate documents, information about family relationships, archival documents, burial information, life stories, photographs, recordings, videos, transcripts, correspondence and genealogical details. What is actually collected depends on the service chosen and the purpose of the research.

Family Materials and Research Materials are provided only to perform the Services, including research, documentation, processing, editing, translation, transcription, locating and verifying sources, preservation and production of the Deliverables ordered. AVOS does not use them for other purposes except as agreed with you, under this policy and as permitted by law.

3.2. As of the date of this policy, AVOS does not use Google Analytics, Microsoft Clarity, Meta Pixel or similar marketing tracking tools on the Site, and does not collect browsing data through them. In the normal technical operation of the Site, hosting, security and communication providers may process essential technical data, such as IP address, browser type, access times and system logs, to run and secure the Site, troubleshoot and prevent misuse.

3.3. The Site may use essential cookies only, as needed for proper operation, security, session management or saving basic preferences. The Site’s cookie banner lets you choose in advance whether to allow statistics and marketing cookies. The only such tool on the Site is AVOS’s own count, and it runs only for users who have allowed measurement: when you arrive through a link AVOS published that carries a tag of its source (a utm tag, for example in a post), one count of the page and the link’s tag is sent to AVOS’s server. The tag and the name of the site you came from are kept in your browser’s temporary storage until you close the tab, and are attached to an inquiry if you send one during that visit, so AVOS knows which post brought it. The count is kept as a daily total only, with no cookies, no IP address and no identifying details. If further tools are activated, they will run only for users who have allowed them, and this policy will be updated to name them.

3.4. AVOS will not activate non-essential tracking, advertising or analytics tools without updating this policy and obtaining consent where required by law.

3.5. Recording interviews and meetings. Interviews, conversations or meetings are recorded only after the interviewee has been informed and has given appropriate consent, or consent has been given by a person legally authorized to consent on their behalf. Recordings, transcripts and documentation are used for the research, documentation, preparation of Deliverables, quality control and handling inquiries, and may be shared with transcription providers or professionals bound by confidentiality. AVOS may use artificial intelligence tools, including for transcription, translation and creating images and video, but is not obliged to do so. Every such output is checked by a person, and personal and family materials are uploaded only to tools that do not use them to train models. An interviewee may ask to access, correct, restrict or delete information about them; such a request will be considered in accordance with the law, the purposes of processing, commitments to the client and the stage of the project. If the interviewee cannot consent themselves, no interview will take place until documented consent is obtained from a person legally authorized to give it.

3.6. Information about minors. Where Family Materials include information or images of minors, the person providing them must ensure they are entitled to do so and that consent of a parent or guardian has been obtained where required. AVOS will process such information only for the service ordered and only as needed, and will not publish it without appropriate authorization.

3.7. Data of special sensitivity. Family research by its nature concerns people’s origin and family relationships, and sometimes also religious belief, health information (such as a cause of death) or information subject to a duty of confidentiality. Under the Israeli Privacy Protection Law this is data of special sensitivity. AVOS processes such information only for the service ordered and only as needed for it, protects it at an appropriate level of security, and shares it only as described in section 6.

4. How information is collected

4.1. Personal details are collected when you enter them yourself on the Site and in the Communication Tool (as defined in section 2.6).

4.2. Essential technical data may be collected automatically by the Site’s infrastructure and its providers, as described in sections 3.2 to 3.4. Details you submit through the Site’s forms (contact, the institutions questionnaire, the fit check and job applications) are kept in AVOS’s own inquiry system, on a server AVOS rents from Hostinger in the European Union, and a copy of the inquiry is emailed to AVOS’s inquiry mailbox on Google Workspace. If the system cannot be reached at the moment of sending, the inquiry is kept in AVOS’s Google Workspace account and sent to the same mailbox. The details are used to answer your inquiry and follow up on it, and only AVOS and the managers acting for it can see them. An inquiry that did not lead to an engagement is deleted from the system 24 months after it was last handled, and you may ask for it to be deleted sooner.

5. How we use information

Information in AVOS’s databases is used only for the following purposes:

5.1. To let you use the Site’s services.

5.2. To identify you on return visits to the Site.

5.3. To contact you when needed.

5.4. To manage our relationship with you and respond to your inquiries, including on return contact.

5.5. To perform the Services you chose, including research, collecting and locating information and documents, contacting archives and sources, documentation, translation and transcription, processing materials, writing, editing, preservation, preparing reports and producing Deliverables according to the project’s purpose.

5.6. To test, maintain and secure the Site and the technology services used to run it.

5.7. To share information with third parties as described in section 6.

5.8. To improve and enrich the Services and content on the Site, including developing new services and changing or discontinuing existing ones. Information used for this will mainly be statistical and will not identify you personally.

5.9. To let you tailor the Site’s services to your preferences.

5.10. To operate the Site properly and securely using essential cookies and essential technical data, as described in this policy.

5.11. For analysis, monitoring and sharing statistical information with third parties, provided such information does not identify you personally.

5.12. To send you, from time to time and subject to your express consent, email about AVOS’s services and products. Such email will be sent only under the express consent you gave when signing up on the Site or at any other time. You may withdraw your consent at any time and stop receiving marketing communications from AVOS.

5.13. For any other purpose set out in this policy or in the Site’s Terms of Use.

5.14. AVOS keeps personal information for as long as needed for the purposes for which it was collected, to provide the Services, to comply with the law, to protect its rights or to conduct legal proceedings, and then deletes it or makes it non-identifying where possible and in accordance with the law.

5.15. Information about purchases, payments and invoices may be kept by AVOS, by the payment provider and by AVOS’s bookkeeping providers or accountant, as needed for operational, accounting and legal purposes and in accordance with the law.

6. Sharing information with third parties

AVOS will not share information in its databases with third parties except as follows:

6.1. A successor to AVOS: if the AVOS business is transferred to another entity, for example on the formation of a company, information will be transferred to it only to continue the same services, provided it uses the information in accordance with this policy and the law.

6.2. Business partners: personal information and Family Materials will not be shared with advertisers or business partners who are not needed to perform the Services without express consent or another appropriate legal basis. Sharing with such parties for analysis, marketing or business development is limited to anonymous, aggregate and statistical information that does not allow identification of any person or family. This does not limit sharing with providers and professionals needed to perform the Services, as described in the next section, subject to confidentiality and information security.

6.3. Staff and professional service providers: AVOS may give access to information to its employees, researchers, genealogists, translators, transcribers, documentation staff, writers, editors, designers, production staff, consultants, subcontractors and providers in Israel and abroad, as needed to perform the Services. They receive access only to the extent their role requires and are bound by confidentiality, information security and applicable law, according to the nature of the engagement.

6.4. Where required by law: AVOS may share information with, or give access to, any body to which disclosure is required by law or by order of a competent authority, including courts and law enforcement.

6.5. To operate the Site and provide the Services, AVOS may use third-party services and systems, including website and sales platforms, payment processing, invoicing, hosting and infrastructure, mailing, email and other services needed to run the Services.

6.6. AVOS may use, among others, external systems for website management, hosting, communication, documentation, customer management and other digital services, as updated from time to time. Use of these systems may be subject to the privacy policies and terms of those third parties.

6.7. This list is not exhaustive. AVOS may share information with additional service providers or third parties where needed to provide the Services, operate the Site, secure information, comply with the law or protect its rights, always in accordance with this policy and the law.

6.8. Transfers outside Israel: in operating the Site and providing the Services, personal information may be stored or processed outside Israel, including through Google Workspace, Hostinger and other hosting and cloud providers, communication, transcription, translation and customer-management services, researchers and subcontractors. Such transfers or access are made in accordance with applicable law, using agreements, confidentiality undertakings and appropriate safeguards as relevant. AVOS does not undertake that information will be stored only in Israel.

7. Information security

7.1. AVOS takes reasonable and accepted technical security measures, appropriate to the nature of the Services and the law that applies to it, to protect the personal information in its possession.

7.2. AVOS takes reasonable security measures suited to the nature of the information, the scope of its activity and the risks. These may include access controls, permissions, backups and technical and organizational safeguards.

7.3. While these measures reduce the risk of unauthorized access, they do not provide absolute security. AVOS therefore does not and cannot guarantee that the Site’s services will be completely immune from unauthorized access to the information stored in them, and will not be liable to you for any damage caused by disclosure or use of information resulting from unauthorized intrusion by others, as long as AVOS took reasonable security measures.

To improve security, you should also take appropriate measures, including protecting your access credentials, using secure devices, taking care when sending personal and family materials, and using common protections on your devices, such as active and up-to-date antivirus software.

8. Links on the Site

8.1. The Site may include links to websites owned by others (“Linked Sites”).

8.2. Linked Sites are not under AVOS’s control, and AVOS is not responsible for them or their content.

8.3. Including a link does not mean that AVOS endorses or is responsible for the content of the Linked Site, or guarantees its reliability, accuracy, legality or privacy practices.

8.4. Linked Sites may place their own cookies and tracking tools on your device. Their use of these tools is governed by their own privacy policies, not by this policy. Linked Sites have no access to AVOS’s cookies, and AVOS has no access to theirs.

8.5. AVOS is not responsible for any consequence of using or relying on Linked Sites, and recommends that you read their terms of use and privacy policies.

9. Your rights

9.1. You may ask to review the personal information held about you in the Site’s databases, and to correct or delete it if you believe it is incomplete, incorrect, unclear or out of date, by writing to hello@avoslegacy.com.

9.2. AVOS may ask for additional details or documents to verify your identity and ensure that information is disclosed only to the person it concerns.

9.3. AVOS cannot undertake to delete all information provided to it, to the extent it is reasonably needed to provide the Services, manage the relationship, keep business records, comply with the law or protect AVOS’s rights. Information may also be disclosed to bodies with legal authority to require it, without additional consent from the person concerned.

9.4. AVOS may keep information reasonably needed for its business, including records required by law and evidence relating to Users, in accordance with this policy or as required by law or contract.

9.5. AVOS will handle requests to review, correct or delete personal information in accordance with the Israeli Protection of Privacy Law and applicable law.

9.6. You may stop receiving marketing communications at any time by using the unsubscribe link in each message or by contacting AVOS.

10. Governing law and jurisdiction

10.1. This policy is governed exclusively by the laws of the State of Israel.

10.2. Disputes about this policy will be heard by the courts competent under the law.

11. Contact

For any question about this policy, write to hello@avoslegacy.com.

12. Changes to this policy

AVOS may change this policy at any time, subject to the law. We will post the updated policy on the Site with a new “last updated” date. If we make a material change to how we use personal information, we will also make reasonable efforts to notify affected users, for example by a notice on the Site or by email.

Last updated: November 2026.

Appendix A: Notice for users in the European Union and EEA (GDPR)

A.1. Scope. This appendix applies only to users, visitors and clients in the European Union or the European Economic Area, and supplements this policy. Where they conflict, this appendix prevails for data subjects in Europe.

A.2. Lawful bases. AVOS processes personal information and Family Materials on these bases under Article 6 GDPR:

• Contract: processing is necessary to provide the Services, manage the family project and produce the Deliverables you ordered.
• Consent: marketing email, non-essential cookies and tracking tools are used only with your active, express consent (opt-in). You may withdraw consent at any time.
• Legitimate interest: maintaining the Site, information security, fraud prevention and improving services, provided your fundamental rights do not override these interests.
• Legal obligation: keeping accounting and transaction records and information required by law and tax authorities.

A.3. Your rights under the GDPR: access; rectification; erasure (except information we must or may keep by law, such as accounting records or completed transactions); restriction of processing; data portability; and objection to processing based on legitimate interest or for direct marketing.

A.4. International transfers. Personal information and Family Materials may be stored and processed in Israel, the European Union, the United States and other countries where AVOS’s service providers operate, including Google Workspace and Hostinger. Where European law applies, transfers to countries without an adequacy decision are made using an appropriate legal mechanism, such as Standard Contractual Clauses (SCCs), with additional safeguards as needed. Information may also be accessed or processed by researchers, subcontractors, archives, institutions and service providers outside Israel; where the GDPR applies, this is done in accordance with European law and its transfer mechanisms.

A.5. Complaints. To exercise your rights, write to hello@avoslegacy.com. You also have the right to lodge a complaint with the Israeli Privacy Protection Authority or with the supervisory authority in your EU country of residence.

Appendix B: Notice for users in the United States

B.1. Scope. This appendix supplements this policy for users in the United States, including the disclosures required by the California Online Privacy Protection Act (CalOPPA).

B.2. Categories of personal information we collect. Identifiers and contact details (name, email address, phone number); the content of messages you send us; information and Family Materials you provide during the Services, as described in section 3.1; payment and invoicing details (card details are entered on the payment provider’s page and are not received by AVOS); and essential technical data (IP address, browser type, access times and logs).

B.3. Categories of third parties. We share personal information only with the categories of recipients described in section 6: service providers that help us run the Site and the Services (such as hosting, email, form-processing, payment and invoicing providers), professionals who work on your project, affiliated entities, and authorities where the law requires it. We do not sell personal information, and we do not share it for cross-context behavioral advertising.

B.4. Tracking by others. As of the date of this policy, we do not allow third parties to collect personal information about your online activities over time and across websites through the Site.

B.5. “Do Not Track” signals. Because the Site does not track users across websites, it does not change its behavior in response to “Do Not Track” browser signals. If we activate any statistics or marketing tools in the future, they will run only for users who have allowed them in the cookie banner.

B.6. Changes. We will notify users of material changes as described in section 12. The “last updated” date shows when this policy was last changed.

B.7. Reviewing and correcting your information. You can ask to review or correct the personal information you provided by writing to hello@avoslegacy.com, as described in section 9.

B.8. Marketing email. Each marketing email from AVOS identifies AVOS as the sender, includes our postal address and a working unsubscribe link, and we honor unsubscribe requests promptly and in any case within 10 business days.

B.9. Children. The Site is not directed to children under 13, and we do not knowingly collect personal information online from children under 13. Information about minors provided by family members as part of a project is handled as described in section 3.6.

B.10. State privacy laws. Where a U.S. state privacy law applies to AVOS, you may have additional rights, such as to know, correct or delete your personal information. You may exercise any applicable right by writing to hello@avoslegacy.com, and we will not discriminate against you for doing so.