PRIVACY POLICY (EN)

Introduction

Welcome to pumpkinulpan.com, operated by IVRIT ONLINE Ltd., Reg. No. 516832607, Yereh Av 13/14, Modiin, Israel (“Website Management”).

This Privacy Policy (“Policy”) explains how Pumpkin Ulpan (“we,” “us,” or “our”) collects, uses, shares, and protects your personal information when you visit or use our website at https://pumpkinulpan.com (the “Website”) or any related services, including our courses, membership areas, and subscription plans (collectively, the “Services”).

By accessing or using our Services, you agree to the terms of this Policy. If you do not agree, please do not use our Services.

1. Information We Collect

A. Personal Information You Provide Directly

• Name, email address, and username when you create an account.

• Payment-related information when purchasing subscriptions or services (note: we do not process or store payment card details directly — see Section 4).

• Information provided in communications with us, such as customer support inquiries.

B. Automatically Collected Information

• Usage Data: course progress, exercise performance, AI tutor interactions, time spent on the Website.

• Device Information: IP address, browser type, operating system, device identifiers.

• Cookies and Tracking Technologies: preferences, session data, analytics (see Section 9).

C. Data from Third Parties

• Wix (our website host) may collect technical and access-related data.

• Payment processors (e.g., https://grow.business/) collect billing details for transactions.

2. Legal Basis for Processing (GDPR & UK GDPR)

For users in the EEA and the UK, we process personal data based on:

• Contract performance

• Legitimate interests (analytics, service improvement, security)

• Consent (for marketing communications and optional tracking)

• Legal obligation

3. How We Use Your Information

We use your information to:

• Provide access to our Services, including course materials, AI tools, and user accounts.

• Personalize learning experiences and recommendations.

• Send service-related emails, updates, reminders, and promotional communications only to users who have explicitly opted in, with the ability to opt out at any time.

• Analyze user activity to improve our Services.

• Prevent fraud and ensure security.

• Comply with legal and regulatory obligations.

3A. Email Communications and Anti-Spam Policy

We do not promote or advertise our website using unsolicited email messages. We do not purchase, rent, or use third-party mailing lists, and we do not permit affiliates, partners, or third parties to advertise our services via email on our behalf.

Emails mentioning our domain are limited to:

• Transactional emails initiated by the user (such as account creation, access or subscription activation, and required service instructions);

• Security-related notifications (for example, login alerts, which can be managed in user settings);

• Explicit opt-in communications, sent only to individuals who have voluntarily provided their contact details through our website and requested to receive such information.

Any use of unsolicited email to promote our website is strictly prohibited and is not authorized by us.

4. How We Handle Payments & Financial Data

We do not process or store payment card details directly. All transactions are securely handled by https://grow.business/ in accordance with their Privacy Policy.

We retain only transaction records (such as receipts) as required for legal and accounting purposes.

5. How We Share Your Information

We do not sell personal data.

A. Service Providers

• Wix — website hosting and infrastructure

• Google Analytics — website analytics

• https://grow.business/ — payment processing

• Email delivery services — for transactional and opt-in communications only

B. Legal Compliance & Business Transfers

We may disclose information if required by law or in the event of a business transfer.

6. Data Security

We use industry-standard security measures, including encryption, access controls, and secure cloud infrastructure. No system is 100% secure, but we take reasonable steps to protect your data.

7. Data Retention

• Accounts: retained while active

• Payment records: retained for legal obligations

• Inactive accounts: may be deleted after two years

• Marketing data: retained until you opt out

To request account deletion, contact admin@pumpkinulpan.com.

8. Your Rights (GDPR, CCPA & Other Laws)

You have the right to access, correct, delete your data, opt out of marketing communications, and withdraw consent where applicable.

Data requests:
Email: admin@pumpkinulpan.com
Subject: “Data Request”

9. Cookies & Tracking Technologies

We use essential, analytics, and (with consent) marketing cookies. You can disable cookies in your browser settings.

Contact Information

Email: admin@pumpkinulpan.com
Phone / WhatsApp: +972 (58) 763 9398
Address: Yereh Av 13, Modiin, 7176364, Israel