PRIVACY POLICY

Effective date: September 30, 2026
Last updated: September 30, 2026

1. WHO WE ARE AND WHAT THIS POLICY COVERS

This Privacy Policy explains how ALLA MARGULIS ("we", "us" or "our") collects, uses, stores and discloses personal information through the website on which this Policy appears, its registration and checkout processes, and our online courses and related customer support.

Business owner: ALLA MARGULIS
Business status: Sole proprietor registered in Israel as an Osek Patur
Israeli business registration number: 342844420
Business address: Sokolov 77, Holon, Israel
Privacy contact: zeffaaschool@gmail.com

We determine the purposes and means of processing personal information associated with our business. Our courses are intended for adults aged 18 and over in the United States.

We handle personal information in accordance with applicable law, including the Israeli Protection of Privacy Law, 5741-1981, as amended, including Amendment No. 13, the Protection of Privacy Regulations (Data Security), 5777-2017, and applicable United States privacy requirements.

2. PERSONAL INFORMATION WE COLLECT

We collect the following categories of information:

- Contact information: your name, email address and telephone number, which you provide when registering, purchasing a course or contacting us.
- Purchase and access records: the course purchased, purchase date, amount and currency, payment status, transaction identifiers, refunds where applicable, and records needed to provide and manage course access. Depending on the payment method, payment providers may also make limited payment metadata available, such as the last four digits of a payment card.
- Communications: information contained in messages you send us and our responses.
- Technical and usage information: information processed by our website and connected services, such as IP address, browser and device characteristics, approximate location derived from IP address, referring pages, pages visited, interaction events and cookie or similar identifiers. The information collected depends on the service, its settings and your privacy choices.
- Privacy preferences: your cookie choices, marketing preferences and information needed to record and respect those choices.

The contact details we request directly are your name, email address and telephone number. Payment providers may request additional information through their own payment interfaces. Technical information and purchase records are processed as described above.

We do not ask you to submit homework, photographs or other learner-created content.

You are generally not legally required to provide personal information to us. Providing it is voluntary. However, without information needed to identify your purchase, create or maintain access, or respond to your request, we may be unable to provide the relevant service. Required fields are identified in the relevant form. Consent to optional analytics, advertising or marketing emails is not a condition of purchasing or accessing a course.

3. HOW WE USE PERSONAL INFORMATION

We use personal information for the following purposes:

- Registering customers and providing and managing access to purchased courses.
- Processing purchases and refunds, confirming payments, issuing receipts and maintaining transaction records.
- Answering questions and providing customer support.
- Sending service communications about purchases, access, security or material changes affecting a purchased course.
- Operating and protecting the website, detecting fraud and abuse, and resolving technical problems.
- Understanding website use and measuring or improving advertising through optional tools, subject to your consent and privacy choices.
- Sending promotional emails where you have opted in.
- Meeting legal, tax and accounting obligations, and establishing, exercising or defending legal claims where permitted by law.

We process information for these disclosed purposes, with your consent where required, or as otherwise permitted or required by applicable law.

4. PAYMENTS

Payments are processed through Allpay or PayPal, depending on the payment method you select. Payment method details are entered through the payment provider's interface and handled by that provider and its payment-processing partners.

We receive transaction information needed to confirm the payment, provide course access, keep accounting records and handle support or refunds. We do not store full payment card numbers or card security codes.

Allpay and PayPal may process information for their own payment, security, fraud-prevention and legal compliance purposes under their respective privacy policies.

5. WHO RECEIVES PERSONAL INFORMATION

We disclose information to the following providers to the extent needed for their relevant functions and, for optional tracking, subject to your consent and privacy choices:

- Tilda: hosting the website, collecting registration and order information, and operating the customer account and course access functions.
- Vimeo: hosting and delivering course videos. Its embedded player may process technical information and use cookies or similar technologies.
- Allpay and PayPal: processing payments and related transaction information.
- Google: providing Google Analytics and processing communications handled through our Gmail address.
- Meta: receiving website event and technical information through Meta Pixel for advertising measurement and, where enabled, targeted advertising.

We may also disclose relevant information to professional advisers, such as accountants or legal advisers, where necessary and subject to appropriate confidentiality protections; to authorities where required or otherwise permitted by law; or where reasonably necessary and lawful to investigate fraud, protect security or defend legal claims.

If our business or course operations are transferred, information may be disclosed as necessary for that transaction, subject to applicable law and appropriate privacy protections. We will provide notice where required.

Where a provider processes information on our behalf, we use appropriate contractual arrangements required by applicable law. Some providers also process information for their own purposes and are responsible for those activities under their own policies.

Provider privacy information is available here:

Tilda: https://tilda.cc/privacy/
Vimeo: https://vimeo.com/privacy
Allpay: https://www.allpay.co.il/en/terms/privacy-policy
PayPal: https://www.paypal.com/us/legalhub/paypal/privacy-full
Google: https://policies.google.com/privacy
Meta: https://www.facebook.com/privacy/policy/

6. COOKIES, ANALYTICS AND ADVERTISING

We use cookies and similar technologies, including pixels and local storage, for the purposes described below.

Strictly necessary technologies support website security, authentication, checkout, access to requested services and storage of privacy choices. They do not require consent through our cookie banner where applicable law permits their use without that consent.

Optional preference technologies remember choices that are not essential to providing a requested service.

Analytics technologies, including Google Analytics, help us understand website visits and interactions and improve the website.

Advertising technologies, including Meta Pixel, measure advertising results and may support targeted advertising. They may send information such as page URLs, event timestamps, cookie identifiers, browser or device information, and purchase events and related transaction metadata to the relevant provider. Meta may associate information received from the Pixel with information it already holds and use it as described in its privacy policy.

We activate optional preference, analytics and advertising technologies only after you consent to the relevant category. You can accept or reject non-essential categories, choose categories separately, and later change or withdraw your consent through the cookie settings control on the website.

Rejecting analytics or advertising cookies does not prevent purchasing or accessing a course. Disabling strictly necessary technologies through your browser may affect login, checkout or video playback.

Vimeo processes technical information needed to deliver requested videos. Its player may also use optional analytics or preference technologies, depending on its configuration and your choices. Optional video tracking is subject to the consent controls described above.

Disclosures to advertising providers can constitute "sharing" for cross-context behavioral advertising or a "sale" under some United States privacy laws, even when no money is paid for the information. You can decline advertising tracking through the website's cookie settings and exercise applicable legal rights as described below.

Legacy browser Do Not Track (DNT) signals do not automatically change our cookie settings. Tracking choices are managed through the website's consent controls. Where applicable law requires us to recognize an opt-out preference signal, including Global Privacy Control (GPC), we honor it for the processing covered by that law.

Withdrawing consent stops future optional tracking covered by that choice. Information previously disclosed may remain subject to the provider's applicable retention rules and your legal rights. Browser controls can be used to remove previously stored cookies.

7. PROMOTIONAL EMAILS

We send promotional emails only where you have opted in through a separate consent mechanism. You can unsubscribe using the link in an email or by contacting zeffaaschool@gmail.com.

Unsubscribing from promotional emails does not affect course access. We may continue sending necessary service messages, such as payment confirmations, access instructions and security notices.

8. CHILDREN AND MINORS

Our courses and services are intended for adults aged 18 and over. We do not knowingly collect personal information from individuals under 18.

If you believe a minor has provided us with personal information, please contact zeffaaschool@gmail.com. We will investigate and take appropriate steps to address the information and account, subject to applicable legal requirements.

9. HOW LONG WE KEEP INFORMATION

Course access lasts five years. We retain the account, contact and purchase information needed to provide access and support during the applicable five-year access period.

After access expires or an account is closed, we retain information only for as long as reasonably necessary to meet legal, tax and accounting obligations, resolve disputes, prevent fraud, or establish, exercise or defend legal claims. An account deletion request may affect our ability to provide continuing access; we will explain any relevant consequences when handling the request.

Support communications are retained for as long as necessary to address the request and related operational or legal needs. Analytics, advertising and cookie information is subject to separate retention settings and purposes. We retain consent and opt-out records where needed to respect your choices and demonstrate compliance.

When information is no longer needed, we delete it or anonymize it. Copies in backups may remain for a limited period under the applicable backup retention cycle, with access restricted.

10. INTERNATIONAL PROCESSING

We operate in Israel and use providers that may process information in the United States and other countries where they and their service providers operate. Your information may therefore be processed outside your state or country of residence.

Transfers of personal information from Israel are made on a basis permitted by the Protection of Privacy Regulations (Transfer of Data to Databases Outside the State Borders), 5761-2001, and subject to required safeguards, including applicable contractual commitments. Privacy laws and available protections can differ between countries.

11. INFORMATION SECURITY

We use reasonable technical and organizational safeguards appropriate to the information and our operations, and comply with applicable Israeli data security requirements. These measures are intended to protect against unauthorized access, use, alteration, loss and disclosure.

No transmission or storage system can guarantee absolute security. Please protect your login credentials and do not send full payment card details or card security codes by email.

12. YOUR PRIVACY RIGHTS

Subject to applicable requirements and exceptions, Israeli law gives you rights to access personal information about you held in a database and request correction of information that is inaccurate, incomplete, unclear or outdated. You may also request deletion where the law provides that right, including applicable rights concerning direct marketing.

If a United States state privacy law applies to our business and your information, you may have additional rights, including rights to:

- Confirm whether we process your information and obtain access or a copy.
- Correct inaccurate information.
- Request deletion, subject to legal exceptions.
- Opt out of applicable sales, sharing or targeted advertising.
- Limit certain uses of sensitive personal information, where applicable.
- Appeal a denial of a request, where the law provides an appeal right.

To submit a request, contact zeffaaschool@gmail.com. Please describe your request and provide enough information for us to locate the relevant records. We may request limited additional information to verify identity where necessary, but will not require identity verification for an advertising opt-out where the law prohibits it.

We respond within the time limits required by applicable law. If we cannot fulfill a request, we will explain the reason and provide any applicable appeal instructions. Where the law permits authorized agents, an agent may submit a request with appropriate evidence of authority.

We do not discriminate against you for exercising applicable privacy rights. Some information may need to be retained for legal obligations or to provide a service you continue to request.

13. EXTERNAL WEBSITES

The website may link to external websites or services. Their collection and use of information are governed by their own privacy policies. This does not affect our responsibility for information we process or disclose.

14. CHANGES AND CONTACT

We may update this Policy to reflect changes in our services, practices or applicable law. The current version and its effective date will be published on the website.

For material changes, we will provide appropriate notice, for example through a prominent website notice or email. Where a change requires renewed consent or another legal step, we will take that step before applying the change to the affected processing.

For privacy questions, requests or complaints, contact ALLA MARGULIS at zeffaaschool@gmail.com or write to Sokolov 77, Holon, Israel.