Sar-El Tours and Conferences Ltd. (the “Company”, “we”, “us”, or “our”) is a member of the SarEl Group.

Since 1993, the Company has served churches, Christian ministries, tour agents, tour leaders, and

individual travelers, arranging pilgrimage tours, conferences, and events in Israel and neighboring

countries, together with related ground services – including accommodation coordination, tour guiding,

transportation, and, where applicable, conference, event, media production, and education program

support. In order to organize tours, conferences, events, 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, including newsletter sign-up;

● Managing working relationships with travel agents, tour leaders, and church or ministry

organizers;

● Organizing and operating tours, conferences, and events for groups and individual travelers, and

processing related participant and attendee data for operational and regulatory purposes;

● Providing ground transportation, media and event production, and education training services;

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 with whom it has a direct relationship – described as Group A in

Section 3 below –, including information collected directly through the website, or from

individual travelers and families who book with us without going through a travel agent or group

organizer. In simple terms, we are the entity legally responsible for the collection, storage, and

use of your information as set out in this Policy.

Much of our activity, however, is carried out at the request of, and in partnership with, a travel

agent, tour leader, church or ministry, conference or event host, or other client (each, and

“Organizing Party”). Where an Organizing Party engages us to arrange a group tour, conference,

convention, event, production, or program, and, in doing so, provides us with personal

information about other individuals – for example, members of a travel group, conference

attendees, or persons appearing in a production, described as Group B in Section 3 below – we

process that information solely to deliver the specific service the Organizing Party has

requested, and at its instruction. In such cases, the Organizing Party bears responsibility as the

data controller of that information, including the obligation to ensure that it was lawfully collected and with the consent of the individuals concerned; our role is closer to that of a service

provider engaged to carry out a defined task on their behalf.

In relation to information collected to meet the Company’s own regulatory and legal obligations

– for example, visa and entry processing or bookkeeping – the Company acts as an independent

data controller regardless of the channel through which the information reached it.

If you are a travel agent, tour leader, church or ministry representative, conference or event host

or organizer, or a client of our media, production, or education services, and you provide 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

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

address, passport details, 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, conferences, and events, 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. We collect and process personal information about two broad

groups of individuals: those with whom we have a direct business or operational relationship

(Group A), and those whose information is provided to us by one of those parties solely so that

we can deliver a specific tour, conference, event, production, or program (Group B). Our role in

relation to each group, and the purposes for which we may use their information, are further

explained in Section 1 and 5.

Group A – Individuals with whom we have a direct relationship

● Travel agents and their representatives, who work with us to organize tours to

Israel and neighboring countries;

● Tour leaders, pastors, and church or ministry representatives who engage us to arrange a group tour;

● Hosts and organizers of conferences, conventions, or events who engage us to help

produce their event in Israel;

● Clients who commission out media and event production services;

● Travel partners and organizations who engage our education and training division

(Sar-El Academy);

● Individual traveler and families who contact or book with us directly, without a

travel agent or group organizer;

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

context of the Company’s operations; and

● Visitors and enquirers who contact us or subscribe to updates through the

Company’s website.

Group B – Individuals whose information is provided to us by one of the parties above, solely to

deliver a specific tour, conference, event, production, or program.

● Members of a church, ministry, or other group travelling on a tour arranged on

their behalf by a tour leader, agent, or organizer;

● Attendees and delegates of a conference, convention, or event, whose details are

provided to us by the hosting organization;

● Individuals who appear in, or attend, a media or event production commissioned by

one of our clients;

● Group members participating in an education, lecture, or encounter program

arranged for their group through a travel partner.

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.

○ Contact Information. Full name, job title, organization 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,

and where applicable, to travelers, organizers, hosts, or clients who transact with us

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

and receive payments as required.

○ Passenger and Traveler Information. Details relating to individuals participating in a

tour, including name, passport number, date of birth, nationality, and flight details. This

may be collected directly from a traveler or family who books with us, or provided to us

by a travel agent, tour leader, church, or ministry for members of a group or tour. Free-

text fields may also include information relating to a passenger’s dietary requirements

or health-related needs. 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 passenger’s needs during the tour.

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

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

without their authorization.

○ Conference and Event Information. Registration details, itinerary and session

preferences, dietary or accessibility needs, and other information relating to attendees

or delegates, as provided to us by the hosting organization in connection with the

conference or event we help produce.

○ Media and Event Production Information. Where the Company provides media or

event production services, this may include photography, video, or audio recordings

taken during a production, which may capture the images or voices of individuals

attending or features in that production, as provided to us or authorized for capture by

the client who commissioned the production.

○ 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.

○ Marketing and Newsletter Information. Name and email address ad provided when

subscribing to our newsletter or updates through the website.

○ 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.

Where information described as Group B in Section 3 is provided to us by an Organizing Party,

we use it solely to deliver the relevant services, at that party’s request, and not for any

independent purpose of our own – except to the extent needed to meet the Company’s own regulatory and legal obligations, as described in Section 1. Subject to that, the Company uses

personal information for the following purposes:

○ Managing ongoing working relationships with travel agents, tour leaders, church and

ministry organizers, conference and event hosts, production clients, travel partners,

guides, and service providers;

○ Organizing and operating tours, conferences, events, and productions in Israel and

neighboring countries, including hotel coordination, guiding, transportation, and related

ground services;

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

relevant authorities;

○ Meeting regulatory and legal obligations, including documentation for bookkeeping

purposes;

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

○ Marketing and direct communications to agents, organizers, and individual subscribers,

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,

conference, or event;

○ Competent authorities, 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:

○ Analytics tools: including Google Analytics and similar tools, for statistical analysis or

website usage, measuring traffic volumes, understanding how visitors navigate the

website, and improving content. The tools use cookies to collect information about how

the website is used. Their use is subject to the relevant provider’s privacy policy.

○ Advertising and social media tools: such as the Meta (Facebook) pixel and Google Ads,

which help us measure the effectiveness of our marketing and, subject to your consent,

may be used to show more relevant advertising about the Company on those platforms.

○ 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.

Such 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. will be handled in accordance with

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 sarel@sareltours.com, using the

subject line "Privacy Policy Request from Client" (or similar wording that clearly indicates you

are exercising your rights as a data subject).

If your request concerns personal information described as Group B in Section 3, you will need

to direct your request to the relevant Organizing Party.

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: sarel@sareltours.com.