Empathy🇮🇱

Key Findings

• Economic: Empathy is a privately held, VC-funded bereavement and estate-logistics software company with a dual New York–Tel Aviv structure, an active Tel Aviv R&D presence, and disclosed funding of $162 million through its May 2025 Series C.^{1, 2, 3}
• Digital: Empathy’s privacy policy states that personal data are maintained in the United States and processed in the United States, Israel, and other locations as reasonably necessary; no dedicated Israeli data-centre infrastructure or Project Nimbus participation was identified.^{4, 5}
• Political: CEO Ron Gura made an October 7, 2023 personal statement condemning the Hamas attack and expressing solidarity with Israeli civilians; no corporate conflict statement was located.^{6, 7}
• Not found: No public evidence identified of Empathy contracts with Israeli military, intelligence, police, or other state-security bodies; of military or surveillance deployment; or of operations in settlements or occupied territories.^{8, 9, 10}

Target Profile

Key Facts:

• Empathy’s stated scale is 50M+ covered policyholders and 9M+ covered employees; the audits treat these as coverage and eligibility figures, not a verified count of active users or records processed in Israel.²
• Its documented locations include New York, Tel Aviv, and Dallas; a circa-2022 staff snapshot of approximately 23 people was not independently re-verified after the 2025 Series C.¹²
• The company’s reviewed material presents Israel as an engineering/R&D location rather than a documented target consumer market.^{2, 13}

Executive Summary

Empathy is a grief-support and estate-logistics software company founded in Tel Aviv in 2020 by Ron Gura and Yonatan Bergman. It operates through a documented dual New York–Tel Aviv structure, with Tel Aviv serving as an engineering and R&D hub and The Empathy Project Ltd remaining an active Israeli entity. Its commercial model is B2B2C: bereavement support is distributed to consumers through insurance-carrier and employer-benefits relationships rather than through physical retail, manufacturing, or agricultural supply chains.^{1, 2, 11, 13}

The strongest documented nexus is economic and operational. Empathy has raised four disclosed funding rounds, including a $72 million Series C in May 2025, bringing stated cumulative funding to $162 million. Its investor base includes Israeli venture firms Aleph and Entrée Capital as well as international venture and strategic insurance investors. The company also maintains a Tel Aviv R&D office. These facts establish an Israeli corporate, employment, and capital nexus, but the audits did not identify verified Israel-sourced revenue, profitability, profit-repatriation flows, Israeli government ownership, state contracts, innovation-authority grants, or a formal Israeli economic-ecosystem designation.^{2, 3, 12, 17}

The governing digital finding is the processing of personal and sensitive user data in Israel, which triggers the rubric’s Data-Exposure / Sovereignty Principle even without a named state contract.⁴ Empathy’s privacy policy states that it and authorised service providers maintain personal data in the United States and process personal data in the United States, Israel, and other locations as reasonably necessary. Careers material identifies a general-purpose engineering stack including React, React Native, TypeScript, Python, AWS, Figma, and SQL. The audits found no public evidence of a named production-cloud provider or region, dedicated Israeli data-centre infrastructure, Project Nimbus participation, Israeli security-vendor relationships, surveillance or biometric tools, or technology supplied to Israeli military, intelligence, police, or state-security bodies.^{4, 5, 18}

The record does not substantiate a military, settlement, or defence-supply nexus. No public evidence identified of defence procurement, military or intelligence contracts, tactical or dual-use variants, security-force deployment, weapons involvement, defence-prime supply relationships, military logistics, export-control matters, or settlement operations. The audits also found no public evidence that Empathy appears in the OHCHR settlement-business database, or that it has been the subject of a company-specific organised boycott, divestment, sanctions, or defence-supply-chain campaign.^{8, 9, 10, 19}

Under the reviewed V6.5 assessment, Empathy receives a BRS of 743, placing it in Tier B (Severe Complicity). The result reflects documented Israeli corporate and data-processing links, no verified military or settlement activity, and limited political evidence centred on a founder’s personal October 2023 statement.^{6, 7}

Timeline of Relevant Events

Corporate Overview

Empathy is a privately held technology company whose stated mission is commercial bereavement and estate-logistics support. Its product is a digital assistant and B2B2C platform intended to help bereaved families manage practical and administrative tasks after a death. Distribution is principally through insurers and employers, including a documented Aflac partnership for on-demand loss support to policyholders.^{13, 26}

The audited corporate structure identifies an Israeli registered entity, The Empathy Project Ltd, and a U.S. entity, The Empathy Project Inc. The company is described in the source record both as Tel Aviv-based and as headquartered in New York and Tel Aviv; the audits resolve this as a genuine dual-hub arrangement, with New York as a commercial/corporate hub and Tel Aviv as the engineering/R&D hub. No parent company, government ownership stake, state-held golden share, or critical-national-infrastructure designation was identified.^{1, 2, 11, 27}

Empathy’s disclosed capital base includes venture firms and strategic insurance-sector participants. Entrée Capital is one investor; Avi Eyal’s percentage ownership in Empathy is not publicly disclosed. A secondary directory lists him as an Empathy director since 2021, while the primary fund biography confirms his Empathy investment and his board role at Lev Echad.^{16, 27} The audits treat these as distinct matters and do not establish that Empathy directed, authorised, or funded Eyal’s external activities.^{17, 27, 28}

No franchise relationships, settlement-based licensees, operational subsidiaries in occupied territory, or corporate integration with a defence-sector parent, sibling, or subsidiary were identified in the reviewed material.^{9, 10}

Domain Summaries

Military: Military

Mechanism of Involvement

No public evidence identified of any Empathy contract, tender, framework agreement, memorandum of understanding, or procurement relationship with the Israeli Ministry of Defence, IDF, Israel Prison Service, Israel Border Police, intelligence agencies, or another Israeli state-security body.^{8, 9}

No public evidence identified of a tactical, ruggedised, mil-spec, defence-grade, dual-use, weapons-related, logistics, construction, or engineering product line. Empathy’s documented product is civilian bereavement and administrative-support software, delivered through consumers, employers, and insurers.^{9, 13}

No public evidence identified of supply relationships with Elbit Systems, Israel Aerospace Industries, Rafael, or Elbit Land; of export licences or end-user certificates involving Israeli security end users; or of military-adjacent operations in the West Bank, East Jerusalem, Golan Heights, or settlements.^{8, 9, 10}

Counter-Arguments and Evidence Limits

The strongest defence is the absence of a documented military nexus. The audited company activity is civilian grief-support SaaS, not defence manufacturing, logistics, construction, surveillance, or security contracting. Searches of procurement, defence-export, press, civil-society, and settlement-monitoring source classes did not identify a demonstrated Empathy military-supply relationship.^{8, 9, 10, 19}

Investor-level activity is not evidence of Empathy military activity. Entrée Capital’s and Avi Eyal’s separately documented defence-tech or emergency-response associations cannot be attributed to Empathy without evidence that the company directed, funded, or operationally participated in them. The audits explicitly distinguish those investor-level facts from an Empathy defence relationship, which was not identified.^{27, 28}

Named Entities and Evidence Map

• Empathy / The Empathy Project Ltd: No public evidence identified of defence, security, weapons, logistics, construction, or settlement activity.^{8, 9}
• Ron Gura and Yonatan Bergman: No public evidence identified that either founder directed defence procurement or defence donations through Empathy.⁹
• Entrée Capital / Avi Eyal: Investor-level material is separately documented; no public evidence identifies activity specifically attributable to or channelled through Empathy.^{27, 28}

Digital: Digital

Mechanism of Involvement

Empathy processes personal data across borders. Its privacy policy states that it and authorised service providers maintain personal data in the United States and process personal data in the United States, Israel, and other locations as reasonably necessary. The policy describes personal and sensitive user data, though the audits do not establish a count of Israeli records or a specific production hosting arrangement.^{4, 18}

The data-processing finding supports I-DIG 5.5. Magnitude 7 reflects an ongoing core service process, without assuming how many records are processed in Israel; Proximity 9 reflects the company’s direct operation. No confirmed tracking, biometric, or Israeli state operational use supports a higher band.⁴

The company separately maintains an Israeli engineering, product, and data footprint, with roles advertised in Tel Aviv. Careers material identifies general commercial tools including React, React Native, TypeScript, Python, AWS, Figma, and SQL. Empathy also markets AI-driven grief-support features as part of its consumer and employer-benefits offering.^{2, 18, 29}

No public evidence identified of any relationship with named Israeli security/defence-adjacent vendors; of facial recognition, biometrics, behavioural analytics, predictive policing, or social-media surveillance; or of technology deployed for military, intelligence, law-enforcement surveillance, offensive cyber, target generation, tracking, or security operations in Israel or the occupied territories.^{5, 9}

Counter-Arguments and Evidence Limits

The relevant documented digital activity is commercial service delivery and R&D, not state-security infrastructure. Although AWS is referenced in careers material, the privacy policy does not name a production cloud provider, hosting region, or legal entity operating production infrastructure. No public evidence identified of dedicated Israeli data centres, sovereign-cloud participation, Project Nimbus involvement, or services supplied to Israeli state institutions or military bodies.^{4, 5}

The scale figures on Empathy’s public materials concern people covered or eligible through insurance and employment partners. They do not verify active-user numbers, records processed in Israel, or the geographic distribution of processing.^{2, 4}

Named Entities and Evidence Map

• The Empathy Project Ltd: Active Israeli entity and Tel Aviv R&D presence.^{2, 11}
• Empathy authorised service providers: Process personal data under the company’s stated cross-border processing disclosure; no named provider is established in the privacy-policy record.⁴
• Ron Gura and Yonatan Bergman: No evidence found connecting either founder to Unit 8200, Talpiot, or other IDF intelligence units.²⁰

Economic: Economic

Mechanism of Involvement

Empathy’s principal documented Israeli economic nexus is corporate formation, investment, and an ongoing R&D footprint. It was founded in Tel Aviv, operates through a dual New York–Tel Aviv structure, and maintains an active Tel Aviv R&D office. The company is privately held and VC-funded rather than government owned.^{1, 2, 11}

The company has disclosed $13 million in seed funding, $30 million in Series A funding, $47 million in Series B funding, and $72 million in Series C funding, for stated cumulative funding of $162 million. Investors include Aleph and Entrée Capital alongside international venture firms and strategic insurer participants.^{3, 17, 22, 23, 24}

No physical-goods supply chain applies to the company’s software business. No public evidence identified of Israeli agricultural sourcing, settlement-origin goods, importer-of-record structures, country-of-origin labelling issues, Israel Bonds participation, Israeli sovereign-bond holdings, settlement-active portfolio holdings, verified Israel-sourced revenue, or profit-repatriation flows.^{13, 19}

Counter-Arguments and Evidence Limits

The company’s commercial revenue model is insurance and employer partnerships, described as principally U.S./North American and later including publicly identified Canadian partnerships. The audited material identifies Israel as an engineering/R&D location, not as a documented consumer-growth market. No public evidence identified of profitability figures, revenue attribution to Israel, or a state-backed economic designation. Accordingly, the record supports an Israeli operational and capital nexus but not a quantified contribution to Israeli state revenue or the settlement economy.^{2, 25}

No public evidence identified of an Israel Innovation Authority grant, Preferred Technological Enterprise tax status, formally branded innovation lab, state contract, government board appointment, or formal economic-ecosystem designation specific to Empathy.^{2, 12}

Named Entities and Evidence Map

• Empathy: Privately held bereavement and estate-logistics SaaS company with New York and Tel Aviv hubs.^{1, 2, 13}
• Aleph and Entrée Capital: Israeli venture investors identified in Empathy’s financing history.^{17, 22, 23}
• Strategic insurers and funds: Series B/C materials identify Allianz, MassMutual, MetLife, New York Life, Securian, Sumitomo, Aflac Ventures, Munich Re, Citi Impact Fund, and TIAA Ventures among strategic participants.^{3, 24}

Political: Political

Mechanism of Involvement

No corporate-level Empathy statement on the Israel–Palestine conflict was located on the official channels reviewed. Those channels describe a commercial grief-tech mission and do not present the company’s Tel Aviv operations as a geopolitical partnership.^{7, 13}

Ron Gura posted a personal LinkedIn statement on October 7, 2023 condemning the Hamas attack and expressing solidarity with Israeli civilians. The audits treat this as a personal statement, not a corporate communication. The political Impact of 2.0 is the rubric’s integration floor; it is not a finding that solidarity with civilians constitutes government advocacy. The isolated statement informs Magnitude 2.5, and founder/CEO attribution supports Proximity 9.0. No further public statements by Gura addressing later phases of the conflict, the July 2024 ICJ advisory opinion, or the November 2024 ICC warrants were identified.^{6, 7}

Both founders’ public biographies record Israeli military service: Gura served as a First Lieutenant in the Israeli Air Force, and Bergman’s profile references an IDF Engineering Manager role. The audits found no public evidence that Empathy used this military background in corporate marketing or PR.^{14, 15}

No public evidence identified of Empathy corporate lobbying, PAC donations, company contributions to military-welfare or settlement-linked organisations, corporate resources directed to Israeli state or military relief efforts, settlement operations, or a corporate partnership with Israeli state institutions.^{7, 10, 27}

Counter-Arguments and Evidence Limits

The strongest defence is that the political record is narrow and largely non-corporate. Gura’s identified October 2023 post was personal; no corporate conflict statement was found. The audits also found no comparable evidence sufficient to establish a pattern of selective corporate political speech across other geopolitical or social issues.^{6, 7}

Avi Eyal’s Lev Echad board role and reported increased defence-tech investment are investor-level facts. Entrée Capital’s investment in Empathy, and a secondary listing of Eyal as an Empathy director, do not by themselves establish corporate authorisation, control, funding, or endorsement by Empathy. His ownership percentage is undisclosed and the primary fund biography does not establish Empathy’s direction of Lev Echad activity.^{27, 16}

Named Entities and Evidence Map

• Ron Gura: Co-founder/CEO; personal October 7 statement and documented prior Israeli Air Force service.^{6, 14}
• Yonatan Bergman: Co-founder/CTO; public profile references prior IDF engineering work; no further conflict statement identified.¹⁵
• Avi Eyal / Entrée Capital: Empathy investor; Eyal’s Lev Echad board role and defence-tech investment activity are documented independently of Empathy.^{27, 28}
• Lev Echad (One Heart): Israeli volunteer emergency-response nonprofit linked in the record to Eyal personally, not to a demonstrated Empathy corporate programme.^{27, 28}

BDS-1000 Score

Method: V6.5.

• V_MAX: 8.50 Avg_OTHERS: 2.07
• BRS Score: 743 Tier: B (Severe Complicity)

The assessment is driven by Economic (8.50) as V_MAX. Tel Aviv founding plus the genuine dual-headquarters structure meet the rubric’s two-condition Israeli-Nexus floor; sustained R&D supports M7 and direct operation P9. The disclosed funding total is company-wide financing, not a quantified amount spent in Israel.^{1, 3, 12} The evidence retains clear limits: the material does not establish military procurement, settlement activity, or state-security deployment. The method assesses evidenced activity, scale and directness. It does not treat unverified allegations, investor proximity, or nationality as proof of a corporate act.

Methodology Note

• Evidence is limited to the four supplied domain audits and their cited source record; claims not supported there are excluded or described as “No public evidence identified.”
• Impact concerns activity type, Magnitude concerns scale, and Proximity concerns directness.
• Entity attribution is specific: investor, founder, director, parent, subsidiary, and company activity are not treated as interchangeable; there is no transitive guilt.
• Investor-level defence-tech or emergency-response activity is retained as context only where documented and is not converted into an Empathy military relationship absent evidence of corporate direction, funding, or operational involvement.
• The temporal rule mitigates divested or exited operations; no such Empathy operation was identified in these audits.
• Settlement operations, where evidenced, may bear on both Economic and Political; no public evidence identified of Empathy operations in settlements, the West Bank, East Jerusalem, or the Golan Heights.^{9, 10}
• “No public evidence identified” reflects the audits’ completed checks, not a claim that evidence cannot exist outside the reviewed record.