Privacy Policy

1. GUARIP (“GUARIP”, “we”, “us” or “our”) may collect and process personal information about users of the Website and purchasers or users of the courses (“Personal Information”). For purposes of Israeli law, “Personal Information” means information relating to an identified or reasonably identifiable individual. Personal Information may include, depending on the interaction with the Website, your name, telephone number, email address, date of birth or age-related information, account and login details, purchase and transaction details, course access and progress information, correspondence with GUARIP, technical identifiers (such as IP address, device and browser information), cookie and usage data, and any other information you choose to provide. GUARIP will act as the controller of the Personal Information held in its databases, unless otherwise expressly stated. GUARIP’s full legal name, company/registration number and privacy contact details: Guarip (R.N. 324860246), [email protected].

2. When GUARIP requests Personal Information directly from you for inclusion or use in a database, the provision of such information is generally voluntary unless a legal requirement is expressly stated. However, certain information is necessary to create an account, process a purchase, provide access to a course, respond to a request, provide customer support, comply with legal obligations, prevent fraud or maintain Website security. If you do not provide information identified as necessary, GUARIP may be unable to complete the purchase, create or maintain your account, provide access to the relevant course or service, or respond to your request. Where consent is required by applicable law for a particular processing activity, GUARIP will request consent in an appropriate manner. Acceptance of this Privacy Policy does not, by itself, constitute consent for every processing activity where a separate consent is legally required.

3. GUARIP processes Personal Information only for defined and legitimate purposes, including: (a) registration and account administration; (b) processing purchases, payments, refunds and transaction records; (c) providing and administering access to courses and digital content; (d) user authentication, customer support and responding to inquiries; (e) maintaining, securing and improving the Website and services; (f) analytics, service measurement and troubleshooting; (g) fraud prevention and enforcement of the Terms of Use; (h) complying with legal, accounting, tax, consumer-protection and regulatory obligations; and (i) sending marketing or promotional communications where permitted by law and, where required, subject to consent. GUARIP will not use Personal Information for a purpose incompatible with the purpose for which it was collected, except as permitted by applicable law.

4. Payment information may be processed by third-party payment service providers, such as PayPal, Stripe, Google Pay, Apple Pay, Kajabi Payments or other providers used by GUARIP from time to time. GUARIP may receive limited transaction information, such as transaction identifiers, payment status, amount, date and limited card information, but does not intend to store full payment-card details unless expressly stated. Such service providers process information under their own terms and privacy policies and may also process information on GUARIP’s behalf. GUARIP will use reasonable measures to select and engage service providers in a manner consistent with applicable privacy and information-security requirements; however, nothing in this Privacy Policy excludes any responsibility that cannot lawfully be excluded.

5. GUARIP may disclose Personal Information only to the extent reasonably necessary for the purposes described in this Privacy Policy, including to: hosting, cloud, website-platform and course-platform providers; payment processors; email, customer-support and communications providers; analytics and security providers; professional advisers; affiliated entities where relevant to the services; competent authorities where disclosure is required or permitted by law; and a purchaser, investor or successor in connection with a corporate transaction, subject to applicable law and appropriate safeguards. GUARIP does not sell Personal Information merely by operating the Website. If GUARIP conducts direct-marketing activities or transfers information for direct-marketing purposes, it will do so subject to the requirements of applicable Israeli law.

6. Subject to the Israeli Privacy Protection Law, 5741-1981, as amended (including Amendment No. 13), you may have the right to review Personal Information relating to you that is held in a database controlled by GUARIP, in accordance with Section 13 of the Law. A request may be submitted to [email protected]. GUARIP may request information reasonably necessary to verify your identity before responding and will handle the request within the period and in the manner required by applicable law. Nothing in this Privacy Policy creates a shorter mandatory response period than that prescribed by law.

7. If Personal Information relating to you is incorrect, incomplete, unclear or not up to date, you may request that it be corrected, and where applicable under law, deleted, in accordance with Section 14 of the Israeli Privacy Protection Law and other applicable law. A request should be submitted to [email protected]. A general request for deletion does not necessarily require GUARIP to delete information that GUARIP is permitted or required to retain, including for legal, tax, accounting, fraud-prevention, security, dispute-resolution or enforcement purposes.

8. GUARIP retains Personal Information only for the period reasonably necessary for the purposes for which it was collected and processed, and as required or permitted by applicable law. Retention periods may differ according to the category and purpose of the information. GUARIP will periodically review retained information and, when it is no longer required, will delete, anonymize or restrict access to it, subject to applicable legal retention requirements. Without limiting the foregoing:

(a) account, registration, course-access and course-administration information may be retained while the account or course relationship remains active and for a reasonable period thereafter for service administration, support, legal compliance, security and dispute handling;

(b) purchase records, invoices, refunds and transaction-related documentation may be retained for the periods required or permitted under applicable tax, accounting, consumer-protection and commercial laws;

(c) full payment-card details are generally processed by third-party payment providers. GUARIP may retain limited transaction references and payment confirmations reasonably necessary for accounting, support, fraud prevention and legal compliance;

(d) marketing and communications information may be retained until consent is withdrawn, an unsubscribe request is made, an objection is accepted, or the information is no longer reasonably required for the relevant purpose, subject to records GUARIP may retain to document an opt-out or legal compliance;

(e) technical, security, usage, log and cookie-related information may be retained for periods reasonably necessary for operation, security, analytics, troubleshooting, fraud prevention and legal compliance. Where the Privacy Protection Regulations (Data Security), 5777-2017 require particular security logs or documentation to be retained for a specified period, GUARIP will retain them accordingly; and

(f) anonymized or aggregated information that no longer identifies an individual may be retained and used for analytics, research, service improvement and business purposes, provided that it is maintained in a form that does not identify an individual.

GUARIP will periodically review the Personal Information it holds and will delete, anonymize or restrict access to information that is no longer required, except where continued retention is required or permitted by applicable law.

9. Israeli privacy law applies to GUARIP’s processing activities to the extent applicable. If GUARIP offers services to individuals in the European Economic Area or otherwise engages in processing activities subject to the EU General Data Protection Regulation (GDPR), GUARIP will comply with the GDPR to the extent it applies. Any previous reference to Directive 95/46/EC should not be relied upon, as that Directive has been replaced by the GDPR. Information transferred from the European Economic Area to Israel may also be subject to the Israeli Privacy Protection Regulations (Instructions for Data Transferred to Israel from the European Economic Area), 5783-2023, where applicable.

10. Personal Information may be stored or processed in Israel and in other countries in which GUARIP or its service providers operate. A transfer of Personal Information from Israel to a database outside Israel will be carried out in accordance with the Privacy Protection Regulations (Transfer of Data to Databases Outside the State Borders), 5761-2001 and any other applicable law, including by relying on an applicable legal ground and, where required, obtaining appropriate written undertakings concerning protection of the information. GUARIP does not represent that every destination country has privacy laws identical to Israeli law.

11. GUARIP implements reasonable administrative, technical and physical safeguards designed to protect Personal Information, taking into account the nature of the information, the scope of processing and the risks involved. GUARIP will operate its databases in accordance with the Israeli Privacy Protection Regulations (Data Security), 5777-2017, to the extent applicable, including appropriate database documentation, access controls, authentication, security procedures, incident management, security of communications, oversight of external service providers and other measures required for the applicable security level. No information system can be guaranteed to be completely secure, and GUARIP therefore cannot guarantee absolute security; however, this does not derogate from duties imposed on GUARIP by applicable law.

12. Users are also responsible for taking reasonable steps to protect their accounts and devices. In particular, users should:

a. do not share your user ID, password or code with anyone else;

b. do not post unauthorized commercial communications (such as spam) on Website;

c. do not upload viruses or other malicious code;

d. log off the Website when you are finished;

e. take customary precautions to guard against “malware” (viruses, Trojan horses, bots, etc.), for example by installing and updating suitable anti-virus software;

f. do not facilitate or encourage any violations of our policies.

13. If you have reason to believe that your interaction with the Website is no longer secure, that your account has been compromised, or that there may have been unauthorized access to Personal Information, please contact GUARIP immediately at [email protected]. GUARIP will assess and handle security incidents in accordance with applicable law, including any applicable duties under the Privacy Protection Regulations (Data Security), 5777-2017.

14. GUARIP may use cookies and similar technologies, including pixels, web beacons, scripts and local-storage technologies, for purposes such as operating the Website, authentication and access control, security, remembering preferences, analytics, service improvement and, where permitted, advertising or remarketing. Where applicable law requires prior consent for a particular non-essential technology or processing activity, GUARIP will seek such consent before activating it. Essential technologies that are reasonably necessary to provide a service requested by the user, secure the Website, process a transaction or maintain account access may be used as permitted by law. The cookie banner and consent settings, where used, should accurately reflect the technologies actually deployed on the Website and should not be relied upon as a substitute for this Privacy Policy.

15. You may be able to manage non-essential cookies and similar technologies through the Website’s cookie-consent tool and/or through your browser or device settings. Disabling certain technologies may affect Website functionality, personalization or analytics. Where consent is the legal basis for a particular processing activity, you may withdraw that consent for future processing through the mechanism made available by GUARIP, without affecting processing lawfully carried out before withdrawal.

Cookies and similar technologies do not, by themselves, give GUARIP unrestricted access to your computer or device. They may, however, collect online identifiers, device data, usage information and other data that may constitute Personal Information under Israeli law where it relates to an identified or reasonably identifiable individual.

16. GUARIP may amend this Privacy Policy from time to time. The updated policy will be posted on the Website with an updated effective date. Where a change is material and applicable law requires additional notice or consent, GUARIP will provide such notice and/or obtain such consent as required. Changes will not retroactively legitimize a processing activity that was unlawful when carried out.

17. You should keep your login credentials confidential, use reasonable security precautions, log out of shared devices and keep your device and security software appropriately updated. This user responsibility does not derogate from GUARIP’s own information-security obligations under applicable law.

18. The Website and courses are intended for users aged sixteen (16) or older, as described in the Terms of Use. GUARIP does not knowingly seek to collect Personal Information from children below the applicable age threshold in violation of law. Where parental or guardian consent is required by applicable law or by the Terms of Use, GUARIP may require appropriate confirmation. If GUARIP becomes aware that information was collected in breach of applicable requirements, it will take reasonable steps to delete, restrict or otherwise handle the information in accordance with law.

19. Your use of the Website is subject to this Privacy Policy. Where GUARIP relies on your consent for a specific processing activity, that consent will be requested separately where required and may be withdrawn in accordance with applicable law. Continued use of the Website does not constitute blanket consent to any collection, use or disclosure of Personal Information beyond what is permitted by law and described in this Privacy Policy.

20. DATA CONTROLLER AND PRIVACY CONTACT. The identity and contact details of the controller: Guarip, company/registration no. 324860246, email [email protected]. If GUARIP is required under Section 17B1 of the Israeli Privacy Protection Law to appoint a Data Protection Officer (DPO), the DPO’s contact details will be made available as required by law.

21. DATABASE REGISTRATION / NOTICE. Amendment No. 13 narrowed the categories of databases that must be registered. GUARIP will register a database or provide notice to the Israeli Privacy Protection Authority only where the statutory conditions for registration or notice apply. The absence of a registration requirement does not exempt GUARIP from the substantive obligations of the Privacy Protection Law and regulations.

22. GOVERNING PRIVACY LAW. This Privacy Policy is intended to be read together with the Website Terms of Use. Nothing in this Privacy Policy limits rights or obligations that cannot be waived under the Israeli Privacy Protection Law, 5741-1981, the Privacy Protection Regulations (Data Security), 5777-2017, the Privacy Protection Regulations (Transfer of Data to Databases Outside the State Borders), 5761-2001, the Privacy Protection Regulations (Instructions for Data Transferred to Israel from the European Economic Area), 5783-2023, or other applicable mandatory law.