Empathy - Digital Audit

Enterprise Technology Stack & Vendor Relationships

No public evidence identified of any licensing, subscription, or integration relationship between Empathy (empathy.com) and Israeli security/defence-adjacent vendors such as Check Point, Wiz, SentinelOne, CyberArk, Nice, Verint, Claroty, or Palo Alto Networks; this was checked against the company’s privacy policy, careers/engineering listings, and general trade press, none of which surfaced such vendors¹²³. Empathy’s disclosed engineering stack, drawn from its careers pages, consists of React, React Native, TypeScript, Python, AWS, Figma, and SQL - general-purpose commercial cloud and development tooling rather than Israeli-origin security software²³. No public evidence identified regarding named systems integrators or IT outsourcing partners for Empathy, or whether any such integrator mandated Israeli-origin technology.

Surveillance, Biometrics & Retail Technology

No public evidence identified of Empathy using facial recognition, biometric identification, behavioural analytics, or gait-analysis technology of the kind associated with vendors such as Trigo, BriefCam, AnyVision/Oosto, or Trax; Empathy’s product is a consumer grief-support and estate-logistics application, not a retail or loss-prevention platform⁴⁵⁶. No public evidence identified of Israeli-origin predictive-policing, sentiment-analysis, social-media-monitoring, or workforce-surveillance tools in use by Empathy. No public evidence identified of indirect delivery of such technologies to Empathy via third-party platforms.

Cloud Infrastructure, Data Residency & Sovereign Cloud Participation

Empathy’s own privacy policy states that the company and its “authorized Service Providers maintain and store personal data in the United States, and process personal data in the United States, Israel and in other locations as reasonably necessary” - a primary-source admission that sensitive personal data is processed in Israeli jurisdiction¹. This is material given the sensitivity of the data at issue: Empathy’s platform handles bereavement, estate, financial/insurance-claim, and identity data covering a claimed 40–50 million individuals across North America and the UK, delivered through partnerships disclosed in its 2025 Series C and “Empathy Alliance” announcement⁶⁷. Empathy is legally constituted in Israel as “The Empathy Project Ltd,” company number 516223187, incorporated 2020-07-14, with a registered address in Tel Aviv and an “Active” status⁸. No specific cloud provider (AWS, GCP, or Azure) is named in Empathy’s privacy policy, which references only generic “hosting and server co-location services”¹; careers listings reference “Amazon AWS” as an engineering tool but do not confirm which regions or legal entities host production data². No public evidence identified that Empathy operates or leases dedicated data-centre infrastructure in Israel, as distinct from processing personal data via its Israel-based operations and staff. No public evidence identified of Empathy participation in Project Nimbus or any comparable Israeli government-backed cloud initiative⁹. No public evidence identified of Empathy providing data-sovereignty, data-residency, or infrastructure-resilience services to Israeli state institutions or military bodies - its role is that of a data processor and infrastructure consumer, not an infrastructure vendor to the Israeli state.

Defence, Intelligence & Security Sector Technology Relationships

No public evidence identified of any contract, partnership, or service agreement between Empathy and the Israeli Ministry of Defence, IDF, Israeli intelligence agencies, or other state security bodies, based on review of funding announcements, press releases, and general trade coverage⁴¹⁰⁶¹¹. No public evidence identified of Empathy’s commercial technology being deployed for military, intelligence, or law-enforcement surveillance in Israel or the occupied territories. No public evidence identified of Empathy developing, selling, licensing, or maintaining offensive cyber capabilities, zero-day tools, or digital weapons systems.

AI, Algorithmic & Autonomous Systems

Empathy markets AI-driven features, including an AI grief-support capability referenced in its own site content, as part of a consumer and employer-benefits product rather than a state-security application¹²⁶. No public evidence identified naming the underlying AI model vendor (e.g., OpenAI) with sourced confirmation. No public evidence identified of Empathy providing AI/ML, computer-vision, or decision-support systems to Israeli state, military, or security bodies. No public evidence identified that Empathy’s AI models are trained on, or given access to, civilian population data, intercepted communications, or surveillance-derived datasets from Israel or the occupied territories. No public evidence identified of Empathy providing autonomous target-generation, threat-detection, or tracking systems to any military or security force; the domain does not appear applicable to Empathy’s business at all.

Technology Ecosystem & R&D Footprint

Empathy maintains a confirmed Israeli R&D presence: the company is headquartered jointly in New York and Tel Aviv, with an active Tel Aviv engineering, product, and data office advertising roles including Senior Full-Stack Developer, React Native Developer, and BI Developer²³⁵¹³. Its Israeli legal entity, The Empathy Project Ltd, has been active since 2020⁸. The company was founded by Ron Gura (CEO) and Yonatan Bergman (CTO), Israeli entrepreneurs who previously co-founded The Gifts Project (sold to eBay in 2011) and held roles at eBay, PayPal, and WeWork⁴¹⁴¹⁵. No evidence was found connecting either founder to Unit 8200, Talpiot, or other IDF intelligence units, despite specific searches on this point¹⁵¹⁶. Empathy’s investor base includes Israeli venture firms Aleph and Entrée Capital, the latter having led its Series A¹⁰¹⁷, alongside General Catalyst, Index Ventures, LocalGlobe, Primetime Partners, and Adams Street Partners, which led the 2025 Series C⁶¹⁸¹⁹. The Series C also introduced the “Empathy Alliance,” bringing in strategic investors including MassMutual Ventures, Allianz, MetLife, New York Life, Sumitomo, Aflac Ventures, Munich Re, Citi Impact Fund, Securian, and TIAA Ventures⁶²⁰²¹. Individual angel investors include Shai Wininger (Lemonade), Sir Ronald Cohen, John Kim, and Micha Kaufman (Fiverr)¹⁴¹⁰; specific searches for Sir Ronald Cohen’s ties to Israeli defence or cyber firms surfaced only his Portland Trust and Apax Partners/Social Finance roles, with no defence or cyber investment link found. No public evidence identified of any acquisitions of Israeli-origin technology companies by Empathy. No public evidence identified of patent portfolios, licensing, or co-development arrangements between Empathy and Technion, Hebrew University, Weizmann Institute, or other Israeli research institutions. Empathy has been named a sample vendor in Gartner’s Hype Cycle for Life Insurance, indicating enterprise/insurance-sector market recognition rather than defence-sector positioning⁷.

Civil Society Scrutiny & Regulatory History

No public evidence identified of Empathy being named in the UN OHCHR settlement-business database, UN A/HRC/59/23 (Albanese, 2025), Who Profits, AFSC Investigate, Al-Haq, B’Tselem, SOMO, or Don’t Buy Into Occupation lists, based on direct searches against these source classes²². No public evidence identified of any organised boycott, divestment, or sanctions campaign targeting Empathy specifically, based on searches of BDS Movement, Ethical Consumer, and general boycott-app coverage. No public evidence identified of regulatory inquiries, legal challenges, export-control actions, or sanctions investigations involving Empathy’s technology sales or services to Israeli state entities.

End Notes