PRIVACY POLICY
 

Brocali Ltd., an Israeli company bearing registration number 516243912, having its business address at 185 HaHistadrut Avenue, Haifa, Israel, together with its affiliates, where applicable (collectively, “Brocali,” “Company,” “Us,” “We,” or “Our”), respects the privacy of individuals who access, browse, register for, purchase, subscribe to, or otherwise use its Platform and Services, as defined below, and is committed to protecting the information that such individuals share with it.
 

Brocali operates an online educational platform accessible through www.brocali.co (the “Platform”), designed to facilitate, enhance, and accelerate the learning experience of medical students, medical graduates, physicians, healthcare professionals, and other eligible learners. The Platform provides access to educational resources and services, including, without limitation, educational videos, recorded lectures, articles, summaries, question banks, flashcards, assessments, practice examinations, self-learning programs, live instructor-led courses, private tutoring sessions, workshops, webinars, and other educational content and services, whether provided on a subscription basis, through a one-time purchase, or otherwise (collectively, the “Services”).
 

For the purposes of this Privacy Policy (the “Policy”), the term “User” or “You” shall refer to any individual who accesses, visits, browses, registers for, or otherwise uses the Platform and/or Services, including any individual who purchases, subscribes to, or participates in any educational program offered by Brocali (a “Student”).

Brocali recognizes the importance of protecting the privacy of its Users and believes that Users are entitled to receive clear information regarding the nature of the information collected, the purposes for which such information is processed, the circumstances under which such information may be disclosed, and the rights available to Users under applicable law.
 

Accordingly, this Policy sets forth Brocali's practices concerning the collection, processing, use, retention, disclosure, and protection of information obtained in connection with the Platform and/or Services.
 

This Policy applies to information collected through the Platform, associated websites, registration forms, educational systems, customer relationship management systems, electronic communications, marketing activities, and other channels through which Brocali interacts with Users.

By accessing and/or using the Platform and/or Services, You acknowledge that You have been provided with this Policy and that Brocali may process information as described herein, subject to applicable law.
 

For the avoidance of doubt, where applicable law requires Your consent for a particular processing activity, such consent shall be obtained separately and shall not be deemed to have been granted merely by accessing or using the Platform.

You are generally under no legal obligation to provide Brocali with Personal Information. However, the provision of certain information may be necessary for the establishment of an Account, completion of a purchase, delivery of educational Services, or performance of other activities requested by You. Failure to provide such information may prevent Brocali from providing certain Services, in whole or in part.
 

1. COLLECTION OF INFORMATION

1.1. General

Brocali may collect, receive, store, and process information concerning Users in connection with their access to and use of the Platform and/or Services.

Such information may include both information that does not identify a particular individual and information relating to an identified or identifiable individual.

For the purposes of this Policy, the following categories of information may be collected:

1.2. Non-Identifiable Information

“Non-Identifiable Information” means information that does not identify, and cannot reasonably be used to identify, a particular individual, whether directly or indirectly.

Such information may include, without limitation, aggregated statistical information, general usage trends, anonymized educational performance data, and other information that has been processed in a manner that does not reasonably permit the identification of an individual.

Brocali may collect and use Non-Identifiable Information for statistical analysis, research, service improvement, business development, quality assurance, and other lawful purposes.

1.3. Personal Information

“Personal Information” means any information relating to an identified or identifiable individual, including information that may identify an individual directly or indirectly, whether independently or in combination with other information reasonably available to Brocali.

Personal Information collected by Brocali may include, without limitation:

(a) Identification and Contact Information: First name, last name, email address, telephone number, mobile number, country of residence, general location, preferred language, and other contact details voluntarily provided by the User.

(b) Academic and Professional Information: Academic institution, university, field of study, academic year, year of admission, graduation year, academic qualifications, professional background, examination preparation interests, intended licensing examinations, educational objectives, and other information relevant to the provision of educational Services.

(c) Account Information: Username, authentication credentials, Account identification details, registration date, Account status, access permissions, login history, and other information necessary for the administration and operation of the User's Account.

(d) Educational Information: Courses purchased or attended, subscription history, educational resources accessed, videos watched, learning progress, questions attempted, answers submitted, assessment results, examination scores, flashcards reviewed, course completion status, tutoring participation, academic feedback, and other information generated through the User's educational activities.

(e) Transactional Information: Products and Services purchased, subscription periods, transaction dates, payment amounts, payment status, billing information, invoices, receipts, installment arrangements, cancellation requests, refund records, and transaction identifiers.

(f) Communication Information: Correspondence and communications exchanged between the User and Brocali, including emails, WhatsApp messages, website inquiries, customer support requests, sales consultations, academic support communications, complaints, feedback, and other information voluntarily disclosed by the User.

(g) Technical and Usage Information: Internet Protocol addresses, device identifiers, operating systems, browser types, language settings, access dates and times, session information, browsing activity, Platform interactions, error logs, and other technical information generated through the use of the Platform.

(h) Marketing Information: Advertisement interactions, campaign sources, webinar registrations, educational product interests, marketing communication preferences, consent records, promotional engagement, and other information relating to the User's interaction with Brocali's marketing activities.

For the avoidance of doubt, information that would otherwise constitute Non-Identifiable Information shall be treated as Personal Information to the extent that it is combined with, linked to, or otherwise reasonably capable of being associated with an identifiable individual.
 

2. INFORMATION COLLECTED UPON REGISTRATION

2.1. Student Accounts

In order to access certain Services offered through the Platform, a User may be required to create an individual student account (the “Account”).

During the registration process, Brocali may request that the Student provide certain Personal Information, including, without limitation, the Student's first name, last name, email address, mobile telephone number, academic institution, academic background, and location.

Upon successful registration, the Student may be provided with authentication credentials enabling access to the Platform and the Services for which the Student is authorized.

2.2. Account Administration

Brocali may collect and process Personal Information for the purpose of establishing, maintaining, administering, authenticating, securing, and managing Accounts.

Such processing may include verification of registration details, management of access permissions, monitoring of subscription periods, identification of purchased Services, and prevention of unauthorized Account access.

2.3. Accuracy of Information

The User undertakes to provide accurate, complete, and current information during registration and throughout the use of the Platform.

The User may request the correction or modification of Personal Information in accordance with the procedures described in this Policy and applicable law.

2.4. Account Security

The User shall be responsible for maintaining the confidentiality of the credentials associated with the Account and for taking reasonable measures to prevent unauthorized access thereto.

Such measures may include maintaining secure passwords, refraining from disclosing authentication credentials to third parties, and signing out of the Account when accessing the Platform through shared devices.

Brocali may process relevant technical and Account information for the purpose of identifying and investigating suspected unauthorized access, fraudulent activity, or violations of applicable contractual terms.
 

3. INFORMATION COLLECTED THROUGH EDUCATIONAL SERVICES

3.1. General

In connection with the provision of educational Services, Brocali may collect and process information concerning the Student's academic background, educational activities, learning progress, and performance.

Such information may be generated automatically through the Platform or provided directly by the Student, an authorized instructor, or another person involved in delivering the relevant Service.

3.2. Subscription-Based Services

Where a Student purchases or subscribes to educational resources for a specified period, Brocali may collect information concerning the subscription, including the subscribed product, activation date, expiration date, access permissions, usage history, and educational activities performed during the subscription period.

Such information may be processed for the purpose of administering the subscription, providing access to purchased resources, maintaining the functionality of the Platform, providing academic support, and evaluating the effectiveness of the Services.

3.3. Self-Learning Courses

Where a Student purchases a self-learning course, Brocali may collect information concerning the purchased course, access duration, educational materials accessed, videos viewed, assessments completed, and other learning activities undertaken by the Student.

Such information may be used to facilitate the provision of the course, monitor educational progress, provide relevant recommendations, and improve the quality of educational materials.

3.4. Live Courses and Workshops

Where a Student participates in a live course, workshop, webinar, or other instructor-led educational activity, Brocali may collect information relating to registration, attendance, participation, communications, academic performance, and other activities associated with the relevant educational program.

Such information may be made available to authorized instructors, tutors, academic coordinators, and other personnel to the extent reasonably necessary for the delivery and administration of the relevant Services.

3.5. Private Tutoring

Where a Student purchases or participates in private tutoring sessions, Brocali may collect information concerning the Student's academic objectives, educational background, tutoring schedule, attendance, learning progress, instructor feedback, and other information reasonably necessary to provide individualized educational assistance.

Such information may be disclosed to the designated Tutor and authorized Brocali personnel for the purpose of delivering, coordinating, and administering the tutoring Services.

3.6. Educational Performance and Personalization

Brocali may process Educational Information for the purpose of evaluating learning progress, identifying academic strengths and weaknesses, providing personalized educational guidance, recommending relevant content, and improving the effectiveness of the Platform.

Brocali may also use automated analytical tools to evaluate educational activities and generate recommendations concerning suitable learning resources or academic preparation strategies.

For the avoidance of doubt, such recommendations are intended solely for educational support and shall not constitute a guarantee of examination success, academic achievement, professional qualification, or licensing eligibility.
 

4. INFORMATION COLLECTED DURING LIVE SESSIONS

4.1. Video Conferencing

Certain Courses, workshops, webinars, and private tutoring sessions may be delivered through third-party video-conferencing or communication platforms, including, without limitation, Zoom or similar services.

By participating in such sessions, the User acknowledges that certain information may be visible or accessible to the instructor, authorized Brocali personnel, and other participants, depending on the applicable platform settings and the User's participation.

Such information may include the User's display name, profile image, video, audio, chat messages, questions, shared documents, and other information voluntarily disclosed during the session.

4.2. Communications Between Participants

The User acknowledges that information shared through public chat functions, audio discussions, video participation, or other collaborative features may be accessible to other participants in the relevant session.

Users are therefore encouraged to refrain from disclosing Personal Information that is unnecessary for participation in the educational activity.

4.3. Recording of Educational Sessions

Brocali may record certain live educational sessions for educational, academic, quality assurance, or other disclosed purposes.

Where such recording takes place, Brocali shall provide appropriate notice and obtain consent where required by applicable law.

Recorded sessions may include presentations delivered by instructors and, depending on the applicable recording configuration, audio, video, chat messages, or other contributions made by participants.

Brocali may make such recordings available to authorized Students, instructors, or personnel where reasonably necessary for the provision of the relevant Services.

Brocali shall take reasonable measures to restrict unauthorized access to recordings containing Personal Information.

For the avoidance of doubt, Brocali shall not use identifiable Student contributions contained in educational recordings for public promotional purposes without an appropriate legal basis and any consent required under applicable law.
 

5. PURPOSES OF COLLECTION AND USE OF INFORMATION

Brocali may collect, process, and use Personal Information for the purposes described herein, including, without limitation:

(a) Establishing, administering, maintaining, and securing User Accounts;

(b) Providing access to educational resources, subscriptions, self-learning courses, live courses, tutoring sessions, and other Services;

(c) Processing purchases, payments, subscription transactions, refunds, and cancellations;

(d) Issuing invoices, receipts, payment confirmations, and other transactional documentation;

(e) Managing educational enrollment, course attendance, academic schedules, and tutoring arrangements;

(f) Monitoring educational progress and providing academic support;

(g) Personalizing the learning experience and recommending educational resources;

(h) Responding to inquiries, requests, complaints, and customer support communications;

(i) Managing relationships with prospective and existing Students;

(j) Delivering operational communications relating to Accounts, purchases, subscriptions, and educational Services;

(k) Conducting marketing and promotional activities, subject to applicable law and any required consent;

(l) Evaluating advertising campaigns and improving marketing effectiveness;

(m) Conducting statistical analysis, research, and service development;

(n) Maintaining, securing, troubleshooting, and improving the Platform;

(o) Preventing fraud, unauthorized access, Account misuse, and other prohibited activities;

(p) Protecting Brocali's legal rights, intellectual property, and legitimate business interests;

(q) Complying with applicable laws, regulations, judicial orders, and lawful requests of competent authorities; and

(r) Carrying out other purposes disclosed to the User at the time of collection or otherwise permitted by applicable law.

Brocali shall process Personal Information only to the extent reasonably necessary for the relevant purposes and in accordance with applicable legal requirements.
 

6. CUSTOMER RELATIONSHIP MANAGEMENT AND COMMUNICATION SYSTEMS

6.1. Customer Relationship Management

Brocali may use customer relationship management systems, including Zoho CRM and associated services, to organize, manage, and administer relationships with prospective and existing Students.

Such systems may contain Personal Information relating to contact details, academic background, educational interests, inquiries, consultations, communication history, purchases, subscriptions, enrollment status, and customer support activities.

Brocali may process such information for the purpose of responding to inquiries, facilitating enrollment, providing requested Services, managing customer relationships, and maintaining appropriate operational records.

6.2. Marketing Automation

Brocali may use marketing automation systems to administer communication workflows, organize prospective Student inquiries, and provide information concerning educational Services.

Such systems may process information relating to the User's educational interests, communications, registration activities, and engagement with the Platform.

Where such systems are used for promotional purposes, Brocali shall comply with applicable legal requirements concerning marketing communications and consent.

6.3. WhatsApp and Electronic Communications

Brocali may communicate with Users through WhatsApp, email, SMS, telephone, and other electronic communication channels.

Such communications may concern course registration, enrollment inquiries, educational guidance, payment confirmations, scheduling, academic support, customer service, and other matters associated with the Services.

Communications may be processed and retained through Brocali's authorized communication and customer relationship management systems.

Where communications are transmitted through third-party platforms, the relevant service providers may independently process certain information in accordance with their own privacy policies and applicable law.
 

7. PROMOTIONAL AND ADMINISTRATIVE COMMUNICATIONS

7.1. Administrative Communications

Brocali may send Users administrative and operational communications relating to the establishment and maintenance of Accounts, purchases, subscriptions, course access, educational schedules, tutoring arrangements, payment confirmations, security notifications, and other matters necessary for the administration of the Services.

Such communications may be delivered through email, WhatsApp, SMS, telephone, or other appropriate communication channels.

7.2. Promotional Communications

Subject to applicable legal requirements and any necessary consent, Brocali may send Users promotional communications concerning educational products, new courses, workshops, webinars, subscription offers, special promotions, and other educational opportunities.

Such communications may be based on information voluntarily provided by the User, including academic background, educational interests, and previous interactions with Brocali.

7.3. Withdrawal of Consent and Opt-Out

Where a User has consented to receive promotional communications, such consent may be withdrawn in accordance with applicable law.

A User may request to discontinue promotional communications by following the unsubscribe instructions included in the relevant message or by contacting Brocali at contact@brocali.co.

Brocali shall process valid opt-out requests in accordance with applicable law.

For the avoidance of doubt, withdrawal of consent to receive promotional communications shall not prevent Brocali from delivering administrative communications reasonably necessary for the provision of existing Services or compliance with applicable legal obligations.

8. PAYMENT INFORMATION AND TRANSACTION PROCESSING

8.1. Payment Processing

Brocali may engage authorized third-party payment service providers for the purpose of processing payments relating to purchases, subscriptions, educational courses, tutoring sessions, and other Services.

In connection therewith, certain Personal Information and transaction-related information may be disclosed to such providers to the extent reasonably necessary for processing the relevant transaction.

8.2. Transaction Information

Brocali may collect and retain information concerning purchases, subscription periods, transaction amounts, payment status, billing details, invoices, receipts, refunds, and related financial records.

Such information may be processed for accounting, taxation, transaction verification, customer support, dispute resolution, fraud prevention, and compliance with applicable legal obligations.

8.3. Third-Party Payment Providers

Where payment transactions are processed by third-party providers, such providers may collect and process payment information independently in accordance with their respective privacy policies and applicable legal requirements.

Brocali may receive payment confirmations, transaction identifiers, and other limited information necessary to administer purchases and provide the Services.

9. SHARING INFORMATION WITH THIRD PARTIES

9.1. General

Brocali shall not sell Personal Information to third parties.

Notwithstanding the aforesaid, Brocali may disclose, transfer, or otherwise make available Personal Information to third parties in the circumstances described herein and to the extent permitted by applicable law.

9.2. Service Providers

Brocali may, from time to time, engage third-party service providers, contractors, and professional advisors for the purpose of operating, maintaining, administering, and improving the Platform and the Services.

Such service providers may include, without limitation, providers of website hosting, cloud infrastructure, database management, learning management systems, customer relationship management systems, marketing automation, electronic communications, video conferencing, payment processing, website analytics, information security, and technical support.

Brocali may disclose Personal Information to such third parties solely to the extent reasonably necessary for the performance of their respective services and subject to applicable legal requirements and appropriate contractual, confidentiality, and information-security safeguards.

9.3. Instructors and Tutors

Brocali may disclose relevant Personal Information to instructors, tutors, academic coordinators, and other authorized educational personnel where reasonably necessary for the delivery, administration, or improvement of the Services.

Such information may include Student identification details, enrollment information, academic background, educational progress, attendance records, assessment results, and other information relevant to the educational services being provided.

9.4. Legal and Regulatory Disclosures

Brocali may disclose Personal Information where such disclosure is reasonably necessary or legally required:

(a) To comply with applicable laws, regulations, judicial orders, subpoenas, or lawful requests of competent governmental authorities;

(b) To enforce applicable contractual terms and policies;

(c) To investigate suspected fraud, unauthorized access, security incidents, or unlawful activities;

(d) To protect the rights, property, or safety of Brocali, its Users, employees, service providers, or the general public;

(e) To establish, exercise, or defend legal claims;

(f) To respond to complaints, disputes, or claims relating to the Platform or Services; or

(g) To comply with any other applicable legal obligation.

9.5. Corporate Transactions

In the event that Brocali undergoes a merger, acquisition, restructuring, investment transaction, transfer of business assets, or other change of control, Personal Information may be disclosed to relevant parties involved in such transaction, subject to applicable law and appropriate confidentiality and data-protection safeguards.

10. THIRD-PARTY SERVICE PROVIDERS AND ANALYTICS

Brocali may engage third-party providers to perform functions necessary for the operation, administration, maintenance, and improvement of the Platform and Services.

Such providers may include technology companies offering analytics, website hosting, customer relationship management, communication services, educational infrastructure, and payment-processing solutions.

Brocali may use website analytics technologies, including Google Analytics where implemented, to collect information concerning Users' interactions with the Platform.

Such information may include IP addresses, device information, browser characteristics, pages visited, session duration, website interactions, and other usage-related information.

Brocali may process such information for the purpose of evaluating Platform performance, understanding usage patterns, identifying technical issues, and improving the Services.

Where analytics or advertising technologies involve the collection or processing of Personal Information, Brocali shall comply with applicable legal requirements, including any applicable notice and consent obligations.

11. COOKIES AND LOCAL STORAGE

11.1. General

When a User accesses or uses the Platform, Brocali may employ cookies, local storage, tracking pixels, and similar technologies for the purpose of enabling the operation of the Platform, improving functionality, maintaining security, and analyzing usage.

Cookies are small data files stored on a User's device that may enable the Platform to recognize the device or browser during subsequent interactions.

11.2. Essential Technologies

Brocali may use essential cookies and similar technologies necessary for authentication, session management, Account security, access to purchased Services, and other core Platform functions.

11.3. Analytics and Performance Technologies

Brocali may use analytics technologies to evaluate website traffic, navigation patterns, Platform performance, and other information relevant to improving the Services.

11.4. Advertising and Marketing Technologies

Subject to applicable legal requirements and any necessary consent, Brocali may use advertising technologies to measure campaign performance, evaluate conversions, and support relevant promotional activities.

11.5. Cookie Preferences

Users may manage certain cookies and similar technologies through their browser settings and, where available, the Platform's cookie-preference mechanisms.

Where applicable law requires consent for the use of non-essential cookies or similar technologies, Brocali shall provide an appropriate mechanism for obtaining and managing such consent.

Disabling certain technologies may affect the functionality or availability of some Platform features.

12. SECURITY OF INFORMATION

Brocali recognizes the importance of protecting Personal Information against unauthorized access, unlawful disclosure, alteration, destruction, misuse, and loss.

Accordingly, Brocali shall implement and maintain technical and organizational security measures appropriate to the nature of the information processed and the risks associated therewith.

Such measures may include, without limitation, authentication mechanisms, access restrictions, secure communication protocols, encryption where appropriate, security monitoring, backup procedures, employee confidentiality obligations, and internal information-security policies.

Access to Personal Information shall be limited, as appropriate, to authorized personnel and service providers who require such access for the performance of their respective duties.

Notwithstanding the foregoing, the User acknowledges that no method of electronic transmission, data storage, or internet-based communication can be guaranteed to be entirely secure.

Brocali shall take appropriate measures to address information-security incidents and shall comply with applicable legal obligations concerning the investigation and notification of such incidents.

13. RETENTION OF INFORMATION

13.1. General

Brocali shall retain Personal Information only for such period as is reasonably necessary to fulfill the purposes described in this Policy or as otherwise required or permitted under applicable law.

The applicable retention period may vary depending on the nature of the information, the Services provided, contractual obligations, legitimate operational requirements, and applicable legal requirements.

13.2. Account and Educational Information

Information associated with a User's Account and educational activities may be retained for the duration of the Account's activity and for such additional period as may reasonably be necessary for the administration of the Services, provision of academic support, resolution of disputes, maintenance of appropriate records, or compliance with applicable law.

13.3. Financial Information

Financial and transactional records may be retained for the periods required under applicable accounting, taxation, and other legal obligations.

13.4. Communication Records

Communications exchanged between Users and Brocali may be retained for customer support, service administration, quality assurance, dispute resolution, and other lawful operational purposes.

13.5. Marketing Information

Information processed for marketing purposes may be retained for as long as reasonably necessary for lawful marketing activities.

Where a User withdraws marketing consent or requests to discontinue promotional communications, Brocali may retain limited information necessary to record and honor such request.

13.6. Deletion and Anonymization

Where Personal Information is no longer required for the purposes for which it was collected, and no applicable legal obligation requires its continued retention, Brocali shall delete, anonymize, or otherwise securely dispose of such information in accordance with applicable law and its internal procedures.

Brocali may retain aggregated or anonymized information that does not reasonably permit the identification of an individual for statistical, research, and service-improvement purposes.

14. MANAGING YOUR PERSONAL INFORMATION

14.1. Access and Correction

Subject to applicable law, Users may request access to Personal Information concerning them that is held by Brocali.

Users may also request the correction of Personal Information that is inaccurate, incomplete, unclear, or outdated, in accordance with applicable law.

14.2. Account Information

Where applicable, Users may review and modify certain Personal Information through their Account settings.

Where such functionality is unavailable, Users may submit a request to Brocali using the contact details provided below.

14.3. Deletion Requests

Users may request the deletion of Personal Information where such right is available under applicable law.

For the avoidance of doubt, Brocali may retain certain information where necessary or permitted for compliance with legal obligations, financial recordkeeping, security, dispute resolution, or other lawful purposes.

14.4. Withdrawal of Consent

Where the processing of Personal Information is based on consent, Users may withdraw such consent in accordance with applicable law.

Such withdrawal shall not necessarily affect processing lawfully undertaken prior to the withdrawal.

14.5. Additional Privacy Rights

Users located in jurisdictions providing additional statutory privacy rights may be entitled to exercise such rights to the extent that the relevant laws apply to Brocali's processing activities.

Such rights may include, where applicable, rights relating to restriction of processing, objection to certain processing activities, data portability, and automated decision-making.

14.6. Submission of Requests

Requests relating to Personal Information may be submitted to:

info@brocali.co

Brocali may request reasonable information necessary to verify the identity of the individual submitting the request.

Brocali shall review and respond to valid requests in accordance with the requirements and timeframes prescribed by applicable law.

15. INTERNATIONAL TRANSFERS OF INFORMATION

Brocali provides educational Services to Users located in Israel and other jurisdictions.

Accordingly, Personal Information may be stored, accessed, transferred, or otherwise processed in countries other than the country in which the User resides.

Such processing may occur through the use of international cloud infrastructure, payment-processing providers, educational technologies, communication systems, and other authorized service providers.

Where international transfers of Personal Information are subject to legal restrictions, Brocali shall implement the safeguards required by applicable law.

Such safeguards may include contractual protections, appropriate information-security measures, and other legally recognized mechanisms.

Where consent is required for a particular international transfer, Brocali shall obtain such consent in accordance with applicable law.

16. THIRD-PARTY WEBSITES AND SERVICES

The Platform may contain links to websites, applications, educational resources, and other services operated by independent third parties (the “Third-Party Services”).

Such Third-Party Services may be subject to separate terms of use, privacy policies, and data-processing practices.

Brocali does not control the privacy practices of independent third parties and shall not be responsible for their collection, use, disclosure, or processing of Personal Information, except to the extent responsibility is imposed upon Brocali under applicable law.

Users are encouraged to review the applicable privacy policies and terms of use before accessing or using Third-Party Services.

17. SOCIAL MEDIA AND EXTERNAL PLATFORMS

Brocali may maintain accounts and communicate with Users through social media platforms, messaging applications, and professional networking services.

Such platforms may include Facebook, Instagram, LinkedIn, WhatsApp, and other communication channels.

Where a User interacts with Brocali through such platforms, certain information may be processed by both Brocali and the relevant platform provider.

The processing activities independently undertaken by the relevant platform provider shall be governed by that provider's applicable privacy policy and legal obligations.

Brocali may process information received through such interactions for the purpose of responding to inquiries, providing customer support, managing educational relationships, and conducting lawful marketing activities.

Users are encouraged not to disclose sensitive or unnecessary Personal Information through publicly accessible social media channels.

18. CHILDREN'S PRIVACY

The Platform and Services are intended for individuals aged eighteen (18) years or older.

Brocali does not knowingly offer Accounts or paid Services directly to individuals under the age of eighteen (18), unless a specific arrangement is expressly authorized by Brocali and complies with applicable law.

If Brocali becomes aware that Personal Information has been collected from a minor in violation of applicable law or this Policy, Brocali shall take appropriate measures to address the matter.

A parent or legal guardian who believes that a minor has provided Personal Information without appropriate authorization may contact Brocali at info@brocali.co.

19. CHANGES TO THIS PRIVACY POLICY

Brocali reserves the right to amend, modify, or update this Policy from time to time, including in order to reflect changes in applicable law, regulatory requirements, the Platform, the Services, technological developments, or Brocali's data-processing practices.

The updated Policy shall be published on the Platform and shall indicate the date of its most recent revision.

Where a material amendment is made, Brocali shall provide appropriate notice through the Platform, electronic communication, or another suitable method, as required by applicable law.

Where a proposed change requires additional consent under applicable law, Brocali shall obtain such consent before undertaking the relevant processing activity.

For the avoidance of doubt, publication of an amended Policy shall not, by itself, constitute consent to processing activities for which separate consent is legally required.

Users are encouraged to review this Policy periodically.

20. APPLICABLE LAW AND DISPUTE RESOLUTION

This Privacy Policy shall be governed by and construed in accordance with the laws of the State of Israel, including the Protection of Privacy Law, 5741-1981, as amended, and the regulations promulgated thereunder.

Nothing contained herein shall be interpreted as excluding, restricting, or waiving any mandatory rights or protections afforded to Users under applicable privacy or data protection laws.

Where the laws of another jurisdiction apply to Brocali's processing of Personal Information, Brocali shall comply with such requirements to the extent applicable.

Any dispute arising out of or in connection with this Policy shall be subject to the jurisdiction of the competent courts of the State of Israel, without prejudice to any mandatory jurisdictional rights available to Users under applicable law.

21. QUESTIONS AND CONTACT INFORMATION

If You have any questions, comments, concerns, complaints, or requests regarding this Privacy Policy or the collection, processing, use, disclosure, or retention of Personal Information, You may contact Brocali using the following details:

BROCALI LTD.

Company Registration Number: 516243912

Business Address: 185 HaHistadrut Avenue, Haifa, Israel

Website: www.brocali.co

General Inquiries: contact@brocali.co

Privacy Inquiries: info@brocali.co

Brocali shall review and respond to privacy-related requests in accordance with applicable legal requirements.

© 2026 BROCALI LTD. All Rights Reserved.