PRIVACY POLICY

Online course "Israel's Political Compass: How to Make an Informed Choice for the Knesset"
Last updated: 18 August 2026


1. GENERAL PROVISIONS

The purpose of this policy is to explain our practices regarding the privacy of users of the website and participants of the Course, and how an Osek Patur (sole businessperson) Artiom Svirshchik, business ID 342522612, of Sderot HaNassi HaShishi 20, Jerusalem, Israel (hereinafter: "the Company") uses the information provided to it by users or collected by it when they use the website and the Course.

Some of the information collected identifies you personally — for example your name, e-mail address, telephone number, the tier you purchased and the means of payment used. This is information you knowingly provide, for example when registering for the free webinar or purchasing the Course. Some information does not personally identify you: this is statistical and aggregate information, such as the pages you viewed and the offers that interested you.

Certain technical data and online identifiers may be considered "Personal Information" under applicable law, including IP address, device identifiers, advertising identifiers, and identifiers stored in cookies or similar technologies, as described below.

This Policy is intended to comply with applicable Israeli privacy and data protection laws, including the Protection of Privacy Law, 5741-1981 (including Amendment No. 13), and the Protection of Privacy Regulations (Data Security), 5777-2017, as may be amended from time to time. Where we transfer Personal Information outside Israel, we will do so in accordance with the Protection of Privacy Regulations (Transfer of Data to Databases Outside the State Borders), 5761-2001, and any other applicable requirements.


2. INFORMATION WE COLLECT

Registration for the free webinar — name, e-mail address; Telegram username where you join the webinar group.

Purchase of the Course — name, e-mail address, telephone number, ID number where required by law for issuing an invoice, tier purchased, transaction details and receipt records.

Payment — payment is processed by our payment provider. The Company does NOT collect or store full credit card numbers or account details.

Participation in the Course — attendance in live sessions, questions submitted, messages in the closed Telegram group, and (for the individual tier) scheduling details.

Use of the website — IP address, device and browser type, pages viewed, referral source, campaign parameters (UTM), and cookie identifiers as described in Section 9.

To the extent that personal information is required when registering for the services of the Company or when purchasing from it, the Company will only ask you for the information that is directly necessary for the provision of the services.


3. USE OF THE INFORMATION

The use of the information collected will be made in accordance with this Privacy Policy or in accordance with the provisions of any law, in order to:
— allow you to use the various services the Company offers, and to deliver the Course you purchased;
— issue receipts and comply with tax, accounting and record-keeping obligations under Israeli law;
— send you operational communications regarding the Course — access links, schedule changes, materials and reminders;
— improve the services and content offered;
— for monitoring and statistics;
— modify or cancel existing services and content;
— handle enquiries, cancellation requests and refunds;
— send marketing communications about the Company's future products, subject to your consent and your right to unsubscribe at any time.


4. LIVE SESSIONS AND RECORDINGS

Live sessions of the Course are recorded, and the recordings are made available to all participants. If you turn on your camera or microphone, or ask a question aloud or in the chat, your image, voice, display name and question may be captured in the recording and become visible to other participants.

If you prefer not to appear in a recording, you may keep your camera and microphone switched off and submit questions in writing, including anonymously by request to the Company.

Participants are prohibited from recording, copying or distributing the sessions.


5. POLITICAL OPINIONS AND SENSITIVE DATA

The Company does not require, request or profile the political opinions of participants. You are not obliged to disclose your political views, voting intention or party preference at any stage, and the Company does not maintain any record of participants' political preferences.

Where a participant voluntarily expresses opinions during a session or in the closed Telegram group, such content is not collected into any database for the purpose of political profiling, and is not transferred to any party, candidate, political body, or other third party for any purpose.


6. PROVIDING INFORMATION TO A THIRD PARTY

The Company will not pass on to third parties your personal details and the information collected about your activity on the website, except in the cases listed below:
— to service providers who process data on the Company's behalf in order to deliver the Course, as listed in Section 7, and only to the extent necessary;
— in the event of a legal dispute between you and the Company that requires disclosure of your details;
— if your actions on the website are against the law;
— if a court ruling orders the Company to provide your details or information about you to a third party;
— where required for compliance with tax or accounting obligations;
— if the Company sells or transfers the operation of the website or the business to any corporation in any way, or merges with another entity, provided that this corporation accepts the provisions of this Privacy Policy towards you.

The Company does not sell personal information, and does not transfer it to political parties, candidates, campaign organisations or political consultancies under any circumstances.


7. OUR SERVICE PROVIDERS

The Company uses the following categories of service providers, which may process Personal Information on its behalf:
— AllPay — processing payments and issuing receipts;
— Tilda — hosting the website and processing registration forms;
— Google Meet — delivering and recording the live sessions;
— Telegram — operating the closed group of the Course;
— analytics providers — measuring website usage, subject to your cookie consent.

Each such provider processes the information under its own terms and privacy policy, and the Company acts to engage providers that maintain appropriate security standards.


8. INTERNATIONAL TRANSFERS

Some of the service providers listed above store or process data on servers located outside the State of Israel. Where we transfer Personal Information outside Israel, we do so in accordance with the Protection of Privacy Regulations (Transfer of Data to Databases Outside the State Borders), 5761-2001, and any other applicable requirements, including by relying on transfers to jurisdictions offering adequate protection or on appropriate contractual undertakings.


9. COOKIES

The Company uses cookies and similar technologies (such as pixels, tags and local storage) on the website to enable core functionality, enhance user experience, provide security, analyse performance, and (where applicable) support marketing activities.

Cookie categories:
— Essentials (strictly necessary). Required for the website to function and for security and fraud prevention. These cookies are always active.
— Preferences / personalisation. Used to remember choices and preferences (for example, language selection).
— Analytics. Used to understand how the website is used and to improve it.
— Marketing. Used to measure and optimise marketing campaigns and deliver advertising (for example, via advertising pixels).

Essentials examples (always active). Examples of Essentials may include: (i) security cookies and tokens used to detect fraud, abuse or automated traffic; (ii) cookies required to enable and secure form submissions and protect them from bots (including CAPTCHA / reCAPTCHA-related cookies where applicable); (iii) session and load-balancing cookies used to maintain stability and performance; (iv) cookies used to store your cookie-consent status and preferences; and (v) cookies required to provide a feature you explicitly requested.

Consent and controls. Except for Essentials, we will place and use cookies only if and after you provide your consent (where required) via our cookie consent mechanism. You can consent to all categories or choose specific categories. You can withdraw or change your consent at any time via the cookie settings link on the website (e.g. "Manage cookies"). We may retain a record of your cookie preferences (including the date/time and categories chosen) to demonstrate compliance and to respect your choices.

Impact of refusal. If you reject non-essential cookies (or certain categories), some parts of the website may not function as intended.

Third-party cookies and embedded content. The website may include third-party services and embedded content (for example, video players) and third-party scripts. These third parties may set their own cookies and collect data for their own purposes, subject to their own policies, and may act as independent controllers. Where possible, we use privacy-enhanced embedding options (for example, YouTube "privacy-enhanced mode") to reduce cookie usage until you interact with the embedded content.

Browser settings. You can also control cookies through your browser settings. However, disabling cookies may affect the functionality of the website.


10. RETENTION PERIODS

The Company retains Personal Information only for as long as necessary for the purposes described in this Policy:
— transaction and receipt records — for the period required under Israeli tax and accounting law;
— Course access and participation data — for the period during which recordings remain available to you, and thereafter as required to handle any claim;
— marketing contact details — until you unsubscribe or request deletion;
— webinar registration data of persons who did not purchase — 24 months from registration, unless you request deletion earlier.


11. DATA SECURITY

The Company implements up-to-date information security systems and procedures at its website, and acts in accordance with applicable requirements under Israeli law, including the Protection of Privacy Regulations (Data Security), 5777-2017 (as amended). While these systems and procedures reduce the risks of unauthorised intrusion, they do not provide complete security. Therefore, the Company does not warrant that its services will be completely immune from unauthorised access to the information stored therein.


12. YOUR RIGHTS (DATABASES)

Under the Protection of Privacy Law, 5741-1981 (including Amendment No. 13), and other applicable law, you may be entitled to request access to Personal Information we hold about you, and to request that such information be corrected, updated or deleted (as applicable).

Requests on this subject should be directed to: infoddubov@gmail.com. We will respond within the period prescribed by law. We may request reasonable verification of your identity before acting on a request.


13. DIRECT MARKETING

Where we use your Personal Information for direct marketing, you may be entitled to object and/or request deletion of such information from our databases, in accordance with applicable law, including Amendment No. 40 to the Communications Law (Bezeq and Broadcasts), 5742-1982. Every marketing message includes a simple means of unsubscribing, and you may also unsubscribe at any time by writing to infoddubov@gmail.com.


14. MINORS

The website and the Course are intended for persons aged 18 and over. The Company does not knowingly collect Personal Information from minors. If you believe that a minor has provided us with Personal Information, please contact us and we will act to delete it.


15. MISCELLANEOUS

In the event of sufficient changes to this Privacy Policy in regard to the use of personal information that you have provided, a notice will be published on the home page of the website.

The Company's website may contain links to external websites, which offer a variety of services, owned and operated by third parties. These services are not part of this Privacy Policy, and those interested should check the privacy terms of these third parties. It is hereby clarified that the Company will not be responsible for the interaction between its users and the third parties as stated above.


CONTACT FOR PRIVACY MATTERS

Artiom Svirshchik
E-mail: infoddubov@gmail.com
Address: Sderot HaNassi HaShishi 20, Jerusalem, Israel

© 2026 Artiom Svirshchik. All rights reserved.

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