Privacy Policy

Shalom Hebrew Privacy Policy

Updated: OCTOBER  29, 2025

Data Controller:

Shalom Hebrew .
Address: Arlozorov 34, Ramat Gan, Israel
Email: info@shalomhebrew1.com

Data Protection Officer (DPO):

Email: info@shalomhebrew1.com

Representative:

Introduction

Shalom Hebrew is committed to protecting your personal data. This Privacy Policy has been written in clear and accessible language to help you understand how we collect, use, store, and protect your personal information.

Before you provide your personal data or consent to its processing through any form on our website or platform, please read this Privacy Policy carefully to ensure that you fully understand the conditions under which we process and protect your information.

This Privacy Policy applies to your use of the Shalom Hebrew services, as defined in our Terms of Service. It explains when, where, and why we process personal data of users who access the Shalom Hebrew Platform, how we use that data, the circumstances under which we may share it with others, your rights regarding your personal data, and how we keep it secure.

GENERAL

Access to the Shalom Hebrew Platform (including the website, related software, and mobile application) is available with or without the need to create an account. You can browse our website without registering.
However, to use certain features — such as the Shalom Hebrew mobile application, book lessons, or access personalized learning tools — you need to create an account first.

Limited use of the Services is therefore possible without providing personal details (for example, browsing the website, viewing how Shalom Hebrew works, reading the blog, or exploring lesson options).
However, whenever you access the website, we may collect log information and technical data automatically (such as IP address, browser type, and access time) to ensure proper operation and security of our platform.

COOKIES AND DATA COLLECTION

When you access the Shalom Hebrew Platform, we may place cookies on your device to track your activity and improve your experience on the website. You can always choose to opt out of cookies, except for those that are essential for the website to function properly.

When you are a registered user, Shalom Hebrew may collect and process cookie identifiers and the data you specifically provide upon registration, including:

• first name and last name,
• email address,
• phone number,
• social network ID (if you sign in via Facebook or connect Google Calendar),
• time zone, interface language, IP address, and device type.

If you are a tutor, we may also collect and process additional data provided by you, including your postal code, gender, year of birth, city of residence, and educational background.

Registered users may also upload profile pictures and select a preferred currency to perform transactions in accordance with our Refund and Payments Policy.

You can find more details on the specific purposes of data collection and processing in the relevant sections of this Privacy Policy.

Shalom Hebrew may update this Privacy Policy from time to time. Please check this page periodically to ensure you are aware of any changes. Any updates will be posted here with a new modification date at the top of the page. If significant changes are made, we will notify you by email.

We may also occasionally test or introduce new features on the Shalom Hebrew Platform that may affect the way we process personal data. In such cases, we will notify you in advance and, where required by law, obtain your consent.

Any questions about this Policy or our data protection practices should be sent to info@shalomhebrew1.com.

1. What Is Personal Data and the Processing of Personal Data?

Personal data is any information about you that, alone or together with other information, allows someone to identify you as an individual.

Processing of personal data means any operation performed on personal data, whether automated or not — such as collecting, recording, storing, organizing, adapting, using, sharing, restricting, or deleting it.

A data subject is any identified or identifiable person whose data is processed — in this case, you as a user of Shalom Hebrew.

Your consent means a freely given, specific, informed, and clear indication that you agree to the processing of your personal data, either by statement or by clear affirmative action.

2. Shalom Hebrew’s Lawful Bases for Processing

Shalom Hebrew processes your personal data only when there is a lawful basis to do so. Specifically, we process your personal data when:

• The processing is based on your consent — for example, when you subscribe to newsletters, provide feedback or reviews, or allow us to analyze user behavior to improve the learning experience.

(Additional lawful bases are outlined in later sections of this Policy.)

2. Shalom Hebrew’s Lawful Bases for Processing (continued)

Shalom Hebrew processes your personal data only when we have a lawful basis to do so. Specifically, we may process your personal data in the following cases:

• Based on your consent:
  For example, when you subscribe to newsletters, participate in our events, webinars, or contests, accept cookies (other than strictly necessary ones), or when we post sweepstakes winners.
• Contractual necessity:
  When the processing is required to provide you with our Services according to our Terms of Service and any AI Additional Terms of Use that form a contract between you and Shalom Hebrew.
  This includes enhancing the learning experience for tutors and students through AI-powered personalized recommendations, improved lesson planning, and interactive learning tools.
• Biometric consent:
  When you explicitly consent to allow Shalom Hebrew and its online verification provider to process your biometric data (such as face verification) for purposes of identity verification and fraud prevention.
• Legitimate interests:
  Processing may be necessary for the purposes of our legitimate business interests, which may include (but are not limited to):
  • compliance with applicable Israeli financial and accounting laws;
  • assessing business performance by analyzing platform traffic and financial indicators;
  • promoting Shalom Hebrew through social media, media outlets, partners, and affiliates (such as bloggers or influencers);
    in particular, Shalom Hebrew may use a tutor’s name, profile picture, and other professional details for marketing or promotional purposes in accordance with the Terms of Service;
  • fulfilling contracts with Shalom Hebrew Business clients and providing reports on their employees’ learning progress and language assessment results;
  • fraud prevention and session control, ensuring appropriate protection of user data;
  • tutor verification and the continuous development of high-quality Hebrew learning programs;
  • AI data training to improve personalized learning features.
• Legal compliance:
  Where processing is required to comply with applicable laws, such as handling data subject access requests.
• Vital interests and public interest:
  In exceptional cases, processing may occur to protect your vital interests or the vital interests of another individual, or to perform a task carried out in the public interest or under legal authority.

In all cases, Shalom Hebrew will inform you about the legal basis and purpose of any processing before it begins, unless restricted by applicable law.

3. Data We Collect: Scope

(1) Student Accounts

Shalom Hebrew collects and processes the personal data you provide when registering and updating your account.
During registration, you submit your login credentials (username and password), first name, last name, and email address.

You may later edit your account to include additional information, such as syncing your Google Calendar with your Shalom Hebrew calendar.
Providing extra information is optional and designed to improve your experience — for example, to help you coordinate lesson times or manage your schedule more efficiently.

You are not required to provide any additional details beyond what is necessary for registration.

3. Data We Collect: Scope (continued)

(2) Tutor Accounts

Shalom Hebrew collects and processes the personal data you provide when registering and updating your tutor profile.
During registration, you submit your login credentials (username and password), first name, last name, and email address.

We require you to provide proof of qualifications, such as copies of diplomas, certificates, or other evidence of teaching experience.

You may edit your profile at any time to include additional information or to sync your Google Calendar with your Shalom Hebrew Calendar. This optional information helps you coordinate with students and manage your teaching schedule more efficiently.

You are not required to include additional personal information beyond what is necessary for registration. Optional details may include postal code, country, language skills, work experience, and gender information.

Some personal data — such as your name, location, or data derived from your IP address — may be publicly visible to other users or to the public through your profile. Shalom Hebrew may offer a feature that allows you to choose which information is visible to others by adjusting your privacy settings under “Edit My Profile.”

(3) Subscription to the Shalom Hebrew Blog

You may choose to subscribe to the Shalom Hebrew Blog to receive newsletters and updates.
To do this, you must provide your email address and give consent to receive communications.

(4) Posting of Information

Shalom Hebrew processes any personal data you voluntarily provide through the platform.
This may include surveys, feedback forms, Q&A comments, or other messages submitted via the Shalom Hebrew Platform.

By posting or submitting such content, you acknowledge that the information (including identifiable data) may be visible to Shalom Hebrew and other users (students or tutors).

Please note that some of your content may not be fully removable if it is associated with lessons or shared materials used by other users.

Unless you opt out, we may retain this information as long as necessary to resolve disputes, provide customer support, and comply with legal obligations.

Shalom Hebrew reserves the right to suspend or terminate accounts that misuse these interactive features or violate our Terms of Service.

(5) Service Use, Cookies, and Other Similar Technologies

When you use our Services, Shalom Hebrew may monitor and analyze web traffic and track your behavior patterns for legitimate business and security purposes.

Please refer to our Cookie Policy for full details about how we use cookies and similar technologies.

(6) Billing Information

We process transaction details related to your purchases on the Shalom Hebrew Platform, including transaction ID, date, and time.
Payment details are processed securely through third-party payment providers in accordance with applicable data protection laws.

3. Data We Collect: Scope (continued)

(7) Shalom Hebrew for Business

We may collect your name, email address, company name, and phone number to provide you with more information about Shalom Hebrew Business Services, as defined in the Shalom Hebrew Business Terms.

(8) Sensitive Data

Unless you have explicitly consented, Shalom Hebrew does not collect or process your sensitive personal data (such as data revealing race, religion, political opinions, or health information).

(9) Pages on Social Networks

We maintain official Shalom Hebrew pages on social media platforms such as Facebook, Instagram, TikTok, and LinkedIn.
When you interact with our social pages — for example, by following, commenting, or reacting to posts — we may analyze this engagement data to evaluate our marketing performance and improve our social media presence.
This processing is based on our legitimate business interests in understanding and improving our outreach and community engagement.

(10) Tutors Community (for Tutors Only)

We operate a Tutors Community accessible through our website via Single Sign-On (SSO).
To fulfill the purposes defined in this Privacy Policy, we may collect and process interaction data and usage information within this community (such as participation in discussions, shared content, and engagement metrics).

(11) Tutors Academy (for Tutors Only)

As a registered tutor, you may access our Tutors Academy — an online professional development space that offers courses and materials to enhance teaching skills, improve performance, and deepen Hebrew teaching methodologies.
We collect and process your activity data, comments, reviews, and survey responses to improve the courses, monitor effectiveness, and ensure they are engaging and beneficial.

(12) Information Required for Submitting Tax Documentation

To comply with Israeli and international tax and accounting laws, Shalom Hebrew may be required to collect and submit certain tax documentation containing personal data.
This may include your full name, country of citizenship, address, date of birth, taxpayer identification number (TIN) or equivalent, and other relevant details.

If applicable under EU Directive 2021/514 (DAC7), Shalom Hebrew, as a digital platform operator, may collect, verify, and report information about reportable sellers (tutors). This data may include your first and last name, primary address, date of birth, tax ID number, VAT number, and bank account identifier to meet our reporting obligations.

(13) Information Required for Marketing and Promotion

We may collect a tutor’s postal address to promote their Hebrew teaching services through the Shalom Hebrew Platform and help them reach students in specific geographic areas.

(14) Analysis of Speech Activity

When you teach or participate in lessons on the Shalom Hebrew Platform, we may analyze microphone activity to measure speaking time and engagement.
This analysis helps provide you with insights into your speaking participation during lessons and improve your learning or teaching performance.
No voice recordings or speech content are stored or used beyond this analytical purpose.

3. Data We Collect: Scope (continued)

(15) Language Assessment

Shalom Hebrew may process your personal data to assess your Hebrew language proficiency level.
For this purpose, we may collect and process your name, email address, and language assessment results.
Such assessments may occur before or after registration on the Shalom Hebrew Platform.

(16) Video Lessons, Sales Calls, Events, and Webinars

We may process voice recordings, lesson recordings, visual likeness, and interactions when you participate in group or individual lessons, sales calls, webinars, or live events hosted by Shalom Hebrew.
You will always be notified before any recording occurs, and your consent will be requested if required by law.

(17) Information Processed by AI-Powered Tools

Shalom Hebrew integrates AI-powered tools provided by trusted third parties to enhance your learning experience and for AI data training purposes.

We may process certain data such as:

• text prompts,
• voice or audio recordings,
• lesson recordings, and
• lesson transcripts,

to provide:

• personalized learning recommendations,
• automatic lesson plans,
• grammar explanations,
• vocabulary cards and messages,
• suggested exercises and homework,
• assessment of language proficiency levels, and
• AI chatbot-based vocabulary and grammar practice.

All such processing is conducted in accordance with data protection laws, and your data is used only to improve the learning experience and never sold to third parties.

(18) Tutor Verification (for Tutors Only)

We process your facial biometric data (through a secure third-party verification provider) and your identification document to confirm your identity and prevent fraud or impersonation.
This process is based on your explicit consent and is handled securely in compliance with privacy regulations.

(19) Information about Business Clients and Leads

Shalom Hebrew processes the personal data of its business clients and leads (B2B), including:

• name,
• email,
• phone number,
• position, and
• company name.

This data is used for:
(i) Sales and marketing — contacting potential clients, qualifying leads, offering relevant products and services, and managing outreach campaigns.
(ii) Contractual obligations — providing, managing, and fulfilling agreements, including sending documentation, updates, and contract-related communications.

4. Data We Collect: Purposes

(1) Provision of Services

We process your personal data primarily to grant access to the Shalom Hebrew Platform and to fulfill our contractual obligations under the Terms of Service.

Specifically, we use your information to:

• help students and tutors find each other’s profiles,
• schedule lessons,
• facilitate the teaching and learning process, and
• track student progress and performance over time.

4. Data We Collect: Purposes (continued)

(1) Provision of Services (continued)

To use the Shalom Hebrew Services, you must provide payment and billing information (for example, credit card details) through our authorized third-party payment partners, which process your personal data securely and in encrypted form.
Please refer to our Refund and Payment Policy for more information.

We may also ask you to take a Hebrew language assessment to determine your level of proficiency.

For companies using Shalom Hebrew Business Services, we process the personal data of their Authorized Users to:

• create accounts,
• enable access to services,
• conduct language assessments, and
• generate reports on learning progress and results.

Please note that without this information, we will be unable to provide core functionalities of the Shalom Hebrew Platform, connect you with other users, or allow you to communicate and take or give lessons.

(2) Payment Services

Shalom Hebrew uses trusted third-party payment providers (such as Stripe, PayPal, or Braintree) to process payments securely.

• Your payment data is processed only by these providers and is protected using SSL encryption.
• All payment information is stored encrypted and securely by these providers — Shalom Hebrew does not store payment data on its own servers.
• Tutors receive payments for confirmed lessons via the same secure payment channels.

We may also use limited transaction data (e.g., transaction date, amount, and last four digits of your card number) shared by our payment providers to confirm that a specific transaction occurred — for example, to verify your eligibility for a promotional offer.

(3) Referral Programs

Shalom Hebrew may operate referral programs to promote the platform:

• Tell-a-Friend Program:
  You may receive a personal referral link to share with friends. We do not collect your friend’s data unless they follow the link and voluntarily register on the Shalom Hebrew Platform.
• B2B Referral Program:
  You may share a colleague’s name, job title, and email address if you believe they may be interested in Shalom Hebrew Business Services.
  We will notify your colleague at the time of initial contact that their information was shared as part of the referral program.

(4) Communications

We may contact you via email or other communication methods (including in-app or public notifications) for purposes related to the Services, such as:

• welcome messages,
• security or legal notices,
• platform updates,
• reminders, and
• personalized recommendations.

We may also use your data to enable communication between users on the platform — for example, exchanging messages, conducting video calls, or leaving feedback.

You may also receive push notifications through the Shalom Hebrew mobile app. You can adjust or disable these notifications in your smartphone settings.

4. Data We Collect: Purposes (continued)

(5) User Research

We may use your contact information (including your email, phone number, or Zoom/Skype ID) to invite you to participate in user experience research intended to improve Shalom Hebrew’s educational platform.

This research may include:

• Feature development and platform updates,
• Marketing analysis (including potential publication of insights on Shalom Hebrew’s website or social media),
• Customer support improvements, and
• Other service updates aimed at enhancing your learning experience.

Your feedback will never be video- or audio-recorded without your explicit consent. If we wish to record your voice, image, or video during a research session, we will obtain your prior permission.

(6) Marketing and Promotion of Shalom Hebrew

We may process your first name, last name, and email for inclusion in our mailing list or newsletter, and send you informational or promotional updates about Shalom Hebrew Services.

• We will always request your consent first, and you can opt out at any time using the unsubscribe link provided in each message or through your user settings.
• If you have shared your phone number, we may contact you by phone for marketing or promotional purposes.

Affiliate and Influencer Programs:
Shalom Hebrew may allow individuals or organizations to join affiliate or influencer programs to promote our platform. When you apply to participate, we will process your information to register you as an affiliate and monitor your progress in promoting the platform.

We may also use your postal address (with your consent) for search engine marketing and optimization purposes.

Please note that feedback you provide may be used by Shalom Hebrew for marketing or educational purposes without additional compensation, as outlined in our Terms of Service.

(7) Behavioral and Social Media Marketing

We may share your email address or similar identifiers with Google and Meta (Facebook/Instagram) to deliver personalized advertisements and manage social media marketing campaigns.
These activities are conducted based on our legitimate business interests in promoting our services while carefully respecting your privacy and preferences.

(8) Identifying Influencers for Potential Collaborations

We may use third-party analytics tools, such as Captiv8, Inc. and LiveRamp Holdings, Inc., to identify potential influencers or ambassadors among our students or tutors for future collaborations.

This process involves:

• Analyzing your registration data (e.g., name, country, social media presence),
• Matching it with public social media profiles, and
• Receiving limited information (such as your social media handles) from these partners.

If you are identified as a potential influencer, Shalom Hebrew may contact you directly to propose a collaboration and provide you with a specific privacy notice regarding this activity.

4. Data We Collect: Purposes (continued)

(9) Analytics and Development

To continuously improve the Shalom Hebrew Platform, identify user needs, and enhance functionality, we collect and analyze usage data and analytics.
This includes:

• information you provide during registration,
• web traffic and interaction data,
• cookies and similar technologies,
• pages visited, duration and date of visit, device type, approximate location, and related usage data.

For these purposes, Shalom Hebrew may use analytics services such as Google Analytics, Firebase, Hotjar, Amplitude, Branch.io, Braze, or Intercom, all of which comply with privacy and data protection standards.

We may also conduct A/B testing or research activities to compare different platform versions for user engagement and satisfaction.
These tests help us understand how users interact with features, allowing us to improve user experience and develop new ones.

In some cases, we may also run polls or surveys using GDPR-compliant third-party tools. Participation is always voluntary, and you may opt out at any time via your user settings.

We may use cookies and usage data to show you more relevant content and advertising based on your past activity on Shalom Hebrew.
Please refer to our Cookie Policy for more details.

(10) Tutor Verification and Program Development

To maintain the quality and trustworthiness of Hebrew lessons, Shalom Hebrew collects and processes tutor credentials and qualifications to confirm their eligibility to teach the subjects they claim.

Additionally, we collaborate with tutors to develop learning programs and educational materials, using the information they provide.

To verify tutor identities and prevent fraud, we process biometric data (facial recognition) and government-issued ID through secure verification providers.
For analytical purposes, we may also process tutors’ registration data to automate and enhance the verification process.

(11) Improvement of Tutor Ranking Algorithm

To ensure a fair and efficient tutor ranking system, we collect and analyze performance metrics and feedback data provided by both students and tutors.
This helps improve how tutors are displayed and recommended on the platform.

The processing of this data is based on legitimate business interests in providing students with the most relevant and qualified tutors, as explained in Section 3.6 of our Terms of Service.

(12) Managing the Tutors Community

We process emails, interaction data, and usage information of tutors participating in the Shalom Hebrew Tutors Community.
This allows tutors to:

• share best teaching practices,
• receive official updates and resources,
• communicate with one another and with the Shalom Hebrew team.

This processing is based on our legitimate interest in community building, professional development, and engagement among tutors.

All access to personal data shared within the Tutors Community is strictly limited to authorized employees or service providers on a need-to-know basis.

4. Data We Collect: Purposes (continued)

(13) Support and Platform Supervision

In the event of disputes or issues related to the Shalom Hebrew Platform or its Services, we may process relevant data — including communications, account information, and interaction records — to:

• resolve such disputes,
• monitor user activity and compliance with our Terms of Service, and
• respond to user complaints, inquiries, or support requests.

This processing ensures the safety, integrity, and proper functioning of the platform.

(14) Events and Webinars Conducted by Shalom Hebrew

When you register for or attend events or webinars organized by Shalom Hebrew, we process your personal data (such as your name, email address, and company or student affiliation) to:

• provide you with access to the event,
• send you confirmations, reminders, and follow-up materials, and
• deliver related resources or information about our Services that you may have requested.

(15) Competitions and Sweepstakes

Competitions

From time to time, Shalom Hebrew may organize learning-based competitions open to individuals who meet specific eligibility criteria.
Participants must complete a registration form, and their data will be used solely for:

• organizing and conducting the competition,
• determining winners, and
• notifying participants of results and prizes.

Sweepstakes

We may occasionally conduct sweepstakes among registered users who meet entry requirements.
In such cases, we may process your:

• user ID,
• name,
• date of birth,
• country of residence, and
• email address,

for the purposes of verifying eligibility, notifying winners, delivering prizes, and meeting legal and tax obligations.

Winners may be required to submit an affidavit of eligibility and tax documentation (such as national or federal forms).
With your consent, Shalom Hebrew may also publish the winner’s name on its website or social media.

(16) Compliance with Legal Requirements

We process payment-related and transaction information as necessary to comply with applicable financial, tax, and accounting regulations.
Additionally, we may process any data collected through the Shalom Hebrew Platform to respond to legal requests from users or authorities, or to exercise, establish, or defend our legal rights in case of disputes or investigations.

(17) Fraud Prevention

We may monitor certain data, such as login activity, payment patterns, and user behavior, to prevent fraudulent activities, unauthorized access, and misuse of the Shalom Hebrew Platform.
This processing also helps us manage and secure your user sessions effectively.

(18) Platform Adaptation (for Tutors Only)

If you choose to provide gender-related information in your profile, Shalom Hebrew may use that data to improve platform personalization — for example, to enhance the accuracy of profile translations and to make the platform more inclusive and adaptive.

 

(19) Changes to This Privacy Policy

Shalom Hebrew may update or modify this Privacy Policy from time to time.
Any updates will not reduce your privacy rights unless you provide explicit consent to such changes.
The latest version of the Privacy Policy will always be available on this page, and the “Last Updated” date will reflect the most recent revision.

If we make any substantial changes, we will notify you by email or through a prominent notice on our platform.

5. How Is Personal Data Shared?

To provide high-quality services and maintain efficient operations, Shalom Hebrew collaborates with employees, independent contractors, and third-party service providers under Data Processing Agreements (DPAs) or Standard Contractual Clauses (SCCs), in compliance with applicable privacy laws.

For these reasons, some of your personal data may be shared with the third parties listed below.
All third-party partners are carefully vetted, operate under strict confidentiality obligations, and use secure data storage solutions, such as Amazon Web Services (AWS) with servers located in Ireland, Germany, and the United States.

(1) Categories of Third-Party Service Providers

Analytics Services

These providers help us understand user behavior and improve our platform.
Personal data shared may include usage information, cookies, and interaction data, as described in Sections 3(5) and 3(14).

Social Network Platforms and Search Engines

Used for advertising, audience targeting, and visibility improvement.
Shared data may include marketing identifiers as described in Section 4(7) and Section 5(2).

Customer Communication Solutions

Used for managing support requests, feedback, and user communications.
Data may include messages and contact details, as described in Section 3(4).

User Research Tools

Used for surveys, usability studies, and product development research.
Shared data may include contact details and feedback, as described in Section 4(5).

Email and Push Notification Management Services

Used to send transactional emails, reminders, and updates.
Shared data may include contact information and personal identifiers.

SMS Providers for Marketing and Notifications

Used to deliver text message alerts and promotions.
Shared data may include phone numbers and user identifiers.

Payment Service Providers

Used to process payments and refunds.
Shared data may include billing details and transaction information, as described in Section 3(6).

AI-Powered Service Providers

Used to enhance learning experiences, lesson personalization, and AI training.
Shared data may include lesson transcripts, audio samples, and interaction data, as described in Sections 3(16) and 3(17).

Video Conferencing and Speech-to-Text Tools

Used to facilitate online lessons and accessibility features.
Shared data may include audio, video, and session data, as described in Section 3(16).

Influencer Marketing Solution Providers

Used to identify potential brand ambassadors and collaborators.
Shared data may include names, usernames, and public profile links, as described in Sections 3(1) and 3(2).

Language Assessment Tools

Used for evaluating language proficiency and generating reports.
Shared data may include assessment results and contact details, as described in Section 3(15).

Search Engine Optimization (SEO) and Marketing Tools

Used for improving search visibility and digital marketing performance.
Shared data may include advertising identifiers and tracking cookies, as described in Section 3(13).

Tutors Academy Management Services

Used to manage online training materials and courses for tutors.
Shared data may include activity data and feedback, as described in Section 3(11).

Tutors Community Management Services

Used to host and moderate the Shalom Hebrew Tutors Community.
Shared data may include interaction and usage data, as described in Sections 3(10) and 4(10).

Online Verification Providers

Used for secure tutor identity verification and fraud prevention.
Shared data may include biometric data and ID documents, as described in Section 3(18).

Tax and Accounting Compliance Software Providers

Used to meet financial reporting and tax obligations.
Shared data may include personal identification, tax numbers, and payment details, as described in Section 3(12).

5. How Is Personal Data Shared? (continued)

(2) Use of Social Network Platforms

Shalom Hebrew maintains official pages on Facebook, Instagram, LinkedIn, and TikTok to communicate with users, share updates, and promote Hebrew-learning content.

• LinkedIn acts as both a data processor on behalf of Shalom Hebrew and as an independent data controller of user information.
• TikTok and Shalom Hebrew each process personal data independently as separate data controllers.
• For Facebook and Instagram, Meta Platforms, Inc. (“Meta”) and Shalom Hebrew are joint controllers with respect to the collection and processing of data related to:
  • page insights and statistics,
  • user reactions (likes, comments, shares), and
  • information provided when contacting us through Meta’s platforms.

You can find more information about the joint controllership arrangement with Meta here:
👉 https://www.facebook.com/legal/terms/page_controller_addendum.

You may contact Shalom Hebrew at info@shalomhebrew1.com regarding any questions about your personal data or activities on our social media pages.

Additionally, Shalom Hebrew may engage contractors, subsidiaries, and service providers located in various countries, including those outside of the European Economic Area (EEA) and Israel, who may have limited access to your personal data.

Whenever data is transferred internationally, Shalom Hebrew ensures that it is:

• shared only for the purposes defined in this Privacy Policy,
• protected through certified, secure platforms, and
• governed by data protection agreements (including Standard Contractual Clauses approved by the European Commission) and technical safeguards that ensure encryption and secure transfer.

(3) Data Transfer in Case of Change of Control or Asset Disposition

In the event of a merger, acquisition, restructuring, sale of assets, or change of ownership, Shalom Hebrew will:

• continue to protect your personal data’s confidentiality, and
• notify affected users before any transfer of data occurs or if it becomes subject to a different privacy policy.

(4) Companies Using Shalom Hebrew Business Services

If your employer or organization uses Shalom Hebrew Business Services, we may share with them the language learning progress and results of assessments of their authorized users (such as employees or trainees), as agreed in the applicable business contract.

(5) Shalom Hebrew Independent Contractors

We work with independent contractors and freelance professionals who assist in providing our Services.
These contractors may support us in:

• data analytics and software development,
• customer support and communication,
• marketing, user research, and promotions, and
• financial, operational, or legal functions.

All contractors operate under strict confidentiality and data protection agreements, and have access to personal data only on a need-to-know basis.

(6) Other Users of the Shalom Hebrew Platform

Your personal data may be visible to other users or visitors of the Shalom Hebrew Platform, depending on your activity and privacy settings.
For example:

• your name and profile picture may appear to others when you join a group class,
• your reviews or comments on a tutor’s profile may be publicly displayed, and
• your contact information may be shared directly with a tutor or student for lesson coordination, as part of our Services.

 

6. How Long Will Personal Data Be Processed and Stored by Shalom Hebrew?

Shalom Hebrew retains your personal data only for as long as necessary to fulfill the purposes for which it was collected and processed.

Generally, your personal data is kept while your account remains active.
If your account has been inactive for more than 2 years, it will be considered expired, and your personal data will be deleted from our active systems within 90 days or earlier upon request.

For data processed by AI-powered tools, retention may last up to 2 years within the EU (and longer outside the EU) for training and service improvement purposes.

In cases of ongoing disputes or legal obligations, we may retain certain information for longer periods to establish, exercise, or defend legal claims or comply with tax and regulatory requirements.

If you’ve subscribed to our newsletter, your contact details will be stored until you unsubscribe using the link in each email.

If you registered for events or webinars, your details will be merged with your account data or deleted within 30 days after the event if you registered externally.

Lists of participants in sweepstakes will be deleted 30 days after the event closes, and the names of winners will remain public only until consent is withdrawn.

After the expiration of these retention periods, Shalom Hebrew will permanently delete or anonymize your personal data unless otherwise required by law.

7. Your Rights Regarding Your Personal Data

As a user (“data subject”), you have specific rights under data protection laws concerning the personal data Shalom Hebrew processes about you:

(1) Right of Confirmation

You have the right to request confirmation of whether Shalom Hebrew is processing your personal data.

(2) Right of Access

You have the right to access your personal data held by Shalom Hebrew and to receive a copy of it.

(3) Right to Rectification

You may request that Shalom Hebrew correct or complete any inaccurate or incomplete personal data.

7. 
   Your Rights Regarding Your Personal Data (continued)

(4) Right to Erasure (“Right to Be Forgotten”)

You have the right to request that Shalom Hebrew permanently delete your personal data.
In most cases, we will comply with such requests unless the data must be retained to comply with legal obligations (such as tax or accounting laws).

You can delete your personal data by:

• Emailing us at: info@shalomhebrew1.com – we will respond within 30 days and confirm the outcome.
• Deleting specific items (e.g., payment method) via your user account settings.
• Deleting your entire account via the platform’s settings page, following the instructions for permanent removal.

(5) Right to Restriction of Processing

You may request that Shalom Hebrew temporarily restrict the processing of your personal data in specific circumstances, such as:

• when you contest the accuracy of your data;
• when processing is no longer necessary, but you prefer restriction instead of deletion (for example, to establish or defend a legal claim).

(6) Right to Data Portability

You have the right to request that Shalom Hebrew transfer your personal data directly to another controller (for example, another education platform), where technically feasible and without adversely affecting others’ rights and freedoms.

(7) Right to Object to Processing

You may object to the processing of your personal data if it is based on legitimate interests or public interest grounds.
If you object, we will stop processing your data unless we can demonstrate compelling legitimate reasons that override your interests or fundamental rights.

For example, you may object to the use of your data for AI training purposes or automated recommendations directly through your account settings.

7. Your Rights Regarding Your Personal Data (continued)

(8) Right to Withdraw Consent at Any Time

You have the right to withdraw your consent to the processing of your personal data at any time by contacting Shalom Hebrew.

Once we receive your withdrawal request, we will process it promptly and stop processing your data unless required by law to continue doing so.

You can contact us at info@shalomhebrew1.com to submit this request.
All such requests are free of charge.

If you believe that your rights have been violated, you have the right to lodge a complaint with the Israeli Privacy Protection Authority or another competent data protection authority.

When data processing is conducted for direct marketing purposes, you may object at any time, and we will immediately stop using your data for that purpose — no explanation required.

8. Other Privacy Commitments

(1) Cross-Border Data Transfers

Shalom Hebrew may process and store personal data both within Israel and outside of Israel (for example, through third-party hosting or payment providers).
Regardless of location, we ensure that high standards of data protection and security are maintained, including compliance with international privacy frameworks and contractual safeguards.

(2) Response Time to User Requests

Shalom Hebrew will respond to any data-related request within one month of receipt.
In exceptional cases (for example, if the request is complex or we receive an unusually high number of requests), we may extend this period by up to two additional months.
If an extension is required, we will notify you within the first month, explaining the reason for the delay.

(3) Security of Your Data

Shalom Hebrew takes both technical and organizational measures to ensure that personal data is processed securely — protecting it against unauthorized access, alteration, disclosure, loss, or destruction.
We work only with verified and trusted contractors and require them to sign data processing agreements to ensure full compliance with our privacy and security standards.

 

8. Other Privacy Commitments (continued)

(4) Accessing Your Account to Provide Support

In rare and exceptional circumstances, such as for troubleshooting or customer support, Shalom Hebrew’s support specialists may need to access your account.

If this occurs, they may temporarily view information you have submitted, including lesson schedules or connected calendar data (for example, if you’ve synced Google Calendar with the Shalom Hebrew system).

We will always request your explicit permission before accessing your account.
You may also modify your Google Calendar privacy settings to hide personal events before granting permission.

Please note that if you deny access, it may limit our ability to resolve certain technical issues efficiently.

(5) Children’s Privacy

Shalom Hebrew is committed to protecting children’s privacy.
Our services are not intended for use by children under 18 without supervision by a parent or legal guardian.

If you are under 18 (but over 13), a parent or guardian must create and supervise your account.
We do not knowingly collect personal data from children under 13 and actively discourage independent use of our services by minors.

Parents and guardians are encouraged to monitor their children’s online activity and ensure that personal information is not shared on the Shalom Hebrew platform without their consent.

(6) Breach Notifications

If a data breach occurs that may pose a significant risk to your rights or freedoms, Shalom Hebrew will notify you and the Israeli Privacy Protection Authority (or another competent data protection agency) without undue delay.
We will also take all reasonable steps to minimize potential harm.

(7) “Do Not Track” Requests

The Shalom Hebrew platform does not share personal data with third parties for direct marketing purposes.
Please note that our systems currently do not support “Do Not Track” browser requests.

(8) California Privacy Rights

If you are a resident of California, you are entitled to specific rights under the California Consumer Privacy Act (CCPA), including:

• The right to request information about the categories and sources of personal data we collect;
• The right to request deletion of your personal data (subject to legal obligations);
• The right to know whether your data is sold or disclosed, and to whom;
• The right to opt out of the sale of personal data (note: Shalom Hebrew does not sell personal data).

To exercise any of these rights, California residents can contact us at: info@shalomhebrew1.com.

8) California Privacy Rights (continued)

• Right to Know: You have the right to know the categories and specific pieces of personal data that Shalom Hebrew has collected about you and to access a copy of your personal data.
• Right to Correction: You have the right to have inaccurate personal data about you corrected.
• Right to Deletion: You have the right to request deletion of personal data that we have collected, subject to applicable legal exceptions.
• Right to Opt-Out: You have the right to opt out of the sale of your personal data. (For clarity, Shalom Hebrew does not sell personal data.)

Verification of Requests. We may ask you and/or your authorized agent to provide certain information to verify your identity and authority before we fulfill a request. The information requested will depend on your prior interactions with us.

For more information about what personal data we collect and how we collect it, please see Sections 2 and 3 of this Privacy Policy. For the purposes for which your personal data is collected and the categories of service providers who may access it, please see Sections 4 and 5.

Non-Discrimination. Shalom Hebrew will not discriminate against you for exercising any of your rights under the CCPA.

How to Submit a Request. To exercise your rights, please contact us at: info@shalomhebrew1.com.

8.9 Automated Decision-Making and Profiling

As part of the Shalom Hebrew Platform functionality, we may process user data in ways that could be considered profiling.

Specifically, automated systems and algorithms may analyze usage patterns, engagement levels, and other performance metrics to improve the matching process between students and tutors — for example, suggesting suitable tutors to learners or prioritizing lesson recommendations.

This automated processing is necessary for the effective delivery of our services and ensures users receive personalized and relevant learning experiences.

If you wish to request human review, express your opinion, or challenge an automated decision, you may contact us at info@shalomhebrew1.com.

8.10 Sale of Personal Data

Shalom Hebrew does not sell personal data, including that of any user under the age of 16.

9. Data Privacy Framework Program

(1) Participation in International Data Privacy Standards

For data processed under this Privacy Policy, Shalom Hebrew adheres to international privacy principles comparable to the EU–U.S. Data Privacy Framework (DPF) and other global standards.

Our commitment includes:

• Maintaining secure data transfers across borders,
• Ensuring protection of personal information consistent with the EU and Israeli privacy laws,
• Partnering only with third-party providers that meet equivalent privacy and security obligations.

To learn more about the Data Privacy Framework, visit www.dataprivacyframework.gov.

(2) Privacy-Related Complaints

If you have any complaints regarding how Shalom Hebrew handles your personal data, please contact us first at info@shalomhebrew1.com.
We are committed to resolving any privacy-related inquiries quickly and transparently.

If a concern cannot be resolved directly, you may contact the Israeli Privacy Protection Authority or, if applicable, your local data protection authority in your country of residence.

9.3 Dispute Resolution

If you have a concern or complaint regarding the handling of your personal data by Shalom Hebrew, we encourage you to contact us directly first, and we will make every reasonable effort to resolve the matter quickly and fairly.

Please email us at info@shalomhebrew1.com with the subject line “Privacy Dispute Resolution”, and include:

• Your full name and contact information,
• A detailed description of the issue, and
• Any supporting documentation or screenshots that may help clarify the matter.

Upon receiving your email, our Privacy Resolution Team will review the matter and work with you to reach an amicable solution.
If the complaint cannot be resolved internally within a reasonable period, you may choose to pursue independent dispute resolution through the Association of National Advertisers (ANA) at:
👉 https://www.ana.net/content/show/id/accountability-dpf-consumers
These services are provided at no cost to you.

9.4 Binding Arbitration

If you and Shalom Hebrew cannot resolve a privacy-related issue through our internal process or via the independent resolution mechanism described above, you may request that the matter be referred to binding arbitration.

To initiate the arbitration process, please contact us first at info@shalomhebrew1.com, and we will coordinate the process with the appropriate arbitration body and guide you through the next steps.

Arbitration will be conducted in accordance with applicable privacy and consumer protection principles. For reference, you may review the Data Privacy Framework Annex I: Arbitral Model here:
👉 https://www.dataprivacyframework.gov/s/article/ANNEX-I-introduction-dpf

9.5 U.S. Oversight

Shalom Hebrew complies with international privacy and consumer protection standards.
The U.S. Federal Trade Commission (FTC) maintains oversight authority to investigate and enforce privacy compliance obligations where applicable.

9.6 Disclosure to Law Enforcement

Shalom Hebrew may disclose your personal information only when required by law, or when there is a good-faith belief that disclosure is necessary to comply with a lawful investigation, legal process, or order by competent authorities.
Whenever legally possible, we will notify affected individuals of such disclosure.

10. Legal Matters

At Shalom Hebrew, we treat your use of our Services as private and confidential.
However, in limited and legally justified circumstances, we may disclose your personal data in our records if necessary to:

1. Comply with legal obligations or respond to lawful requests, subpoenas, or court orders;
2. Investigate or enforce potential violations of this Privacy Policy or our Terms of Service, including unlawful or abusive use of the Services;
3. Detect, prevent, or investigate fraud, security breaches, or other harmful activities;
4. Protect the rights, property, or safety of Shalom Hebrew, our team members, our users, or the public.

We are committed to handling your personal data responsibly and securely so that you can use our Services with confidence and peace of mind.

If you have any questions or concerns about your privacy or this Policy, please contact us:
📧 info@shalomhebrew1.com
📍 Arlozorov 34, Ramat Gan, Israel

Your Shalom Hebrew Team