Last Revised: [October __ 2023]
 

Brocali Ltd. and/or its affiliates (“Brocali”, “Us” or “We”) respects the privacy of the Users of its Platform as defined below and is committed to protect the information that its Users share with it.

We operate an online platform at http://www.brocali.co (the “Platform”) offering a training platform designed to accelerate the learning experience of medical students and doctors by providing a comprehensive library of articles, videos, flashcards, and questions, live courses and sessions designated for medical students and graduates for preparation for the Usmle step 1 board exams (and other courses as may be updated from time to time (the “Courses”) and providing other features and services in connection with the Courses, including course materials, questions, and content (together with the Courses, the “Services”).

The term “You” or “User” refers to a person subscribing for one of the Courses available on the Platform (the “Student”); or any person who views, uses, accesses or browses the Platform (defined below).

We believe that You have a right to know our practices regarding the information We may collect when You use the Platform and/or use the Services offered thereon, whether by a Student or just a visitor of the Platform. The guidelines contained herein apply to Your visit or use of the Platform and/or Services.

BY ENTERING TO AND/OR USING THE PLATFORM AND/OR VIEWING OR USING ANY OF THE SERVICES, YOU AGREE TO THIS PRIVACY POLICY, INCLUDING TO THE COLLECTION AND PROCESSING OF YOUR PERSONAL INFORMATION (DEFINED BELOW). IF YOU DISAGREE TO ANY TERM UNDER THIS POLICY, YOU MAY NOT USE THE PLATFORM OR THE SERVICES. YOUR CONTINUED USE OF THE PLATFORM AND/OR THE SERVICES SHALL BE DEEMED AN ACCEPTANCE BY YOU OF THE TERMS OF THIS POLICY.

Note that You have no legal obligation to provide Brocali with any information, and therefore providing information while using the Platform and/or the Services depends solely on Your voluntarily approval; however, the provision of certain information is necessary for Brocali to provide You some or all of the Services.

1. Collection of Information

We may collect two types of data and information through Your use of any of the Services and/or while You are viewing or otherwise using the Platform, as follows:

1. 1. Non-Identifiable Information (“Non-identifiable Information”). To put it simply, when collecting or using Non-identifiable Information, We have no idea what is the identity of the User from which We have collected such Information. The Non-identifiable Information We gather consists of technical information and behavioral information, including, among others, the following:

Technical Information: Type of operating system; type of browser; screen resolution; browser, device and keyboard language; type of mobile device and mobile device version.

Behavioral Information: User surfing patterns; the purchased “course”; learning/video watch progress; ‘reviews’ provided by You as a ‘Student’.

Statistical Information: Amount and type of Services used per Student and Feedbacks.

1. 1. Individually identifiable information (“Personal Information”) - to put it simply, this information may identify an individual or is of a private and/or sensitive nature. The Personal Information gathered may contain, among other things, Your name, email address, and phone number, and any other identifiable information You have provided Brocali and/or any of the tutors providing the Courses (the “Tutor”) voluntarily during the process of creating the student account (as stated in Section 2) or during the use of certain Services (including, while attending the Course) and/or visiting the Platform.

For avoidance of doubt, any Non-identifiable Information connected or linked to any Personal Information is deemed a Personal Information as long as such connection or linkage exists.

1. Information Collected Upon Registration

   1. In order for a Student to be able to use any of the Services on the Platform, the Student must create a ‘student account’ (the “Account”) during which he/she shall provide his/her personal details as follows:

      1. A Student must provide his/her first name, last name, email address and mobile number, academic institution in which he/she is admitted, year of admission to academic institution as well as his/her location.

      2. Upon creating the Account, the Student will be granted a username and a password which grants them a permission to log into the Platform.

2. 1. The Users hereby agree that Brocali will collect the Personal Information upon creation of the respective Account to use such Personal Information as stated in this Policy.

   2. The User may, at any time, submit to Us a request a username and/ or password change. All personal information of the User which were collected by Us during the registration process as previously stated are used as indicated in Section 4. Access to the Services on the Platform is only possible through using the username and a password.

   3. Students should take steps to protect against unauthorized access to their password, phone, and computer by, among other things, keeping log-in and password credentials private, signing off after using a shared computer, and choosing a robust password that nobody else can easily guess.

3. Information Used During Course Sessions

You understand that the Course sessions will be delivered through a video conference tool used by Us (eg. Zoom). To this effect, You understand that when participating in a Course session, You may be visible to other attendees of such session as well as by representatives of Brocali including the Tutor, all depending on Your Account settings. In addition, while participating in a Course session, You will be heard by such other attendees of that session if You decide to speak using the microphone through the video conference tool.

You also understand that while attending a Course session, any participant in such session, including, the host as well as other Students enrolled in the Course may be able to see Your display name and profile picture, and can also see and (depending on Your Account settings) record or save meeting content, audio transcripts, messages sent to participant(s) during such session, and any information shared during the session.

Attendees of a Course session can also see text messages sent via the Video conference tool, as well as sender and receiver information, along with the content of messages sent to and from attendees participating in that session, including, messages sent to all attendees in a Course session; and direct messages sent to a specific attendee of that Course session.

1. Usage of Information

The Non-identifiable Information We collect is used mainly to learn about general trends of usage of the Platform and the Services, perform statistical analysis of the Services, enhance the user experience on our Platform and the Services, and in order to improve the Services, including for training and quality assurance purposes, and other lawful purposes. For example, We are using the Non-identifiable Information to determine which Users like or don't like based on traffic to those areas on the Platform or the Services, as well as their Feedbacks. This may assist Us in building a better Platform and offering better Services to You.

The Personal Information is used to enable the overall operation of the Services, to create an Account for You on the Platform and give You access to the Services, to personalize User's experience, thus improving and enhancing such User's experience, learn more about Your preferences and suggest relevant content to You, and pursuant to Your consent, deliver You with notifications regarding Courses which We believe that You might be interested in. We will also use the Personal Information for identification purposes (when logging in to Your Account on the Platform).

From time to time We may engage third party service providers to perform certain functions and provide services to Us, such as hosting and maintaining our servers and the Platform, database storage and management, e-mail management etc. We may share your Personal Information and some technical information with these third parties to enable them to perform such services.

If a User or any person visiting the Platform decides to contact Us through a "Contact Us" form on the Platform, for any inquiry and/or a problem in the Platform We will collect the User's person’s full name, telephone number, and email address, as well as the User's/person’s message. We will use this information only for the purpose of handling the User’s/such person’s inquiry.

1. Sharing the Information with Third Parties

We will not share Personal Information with any third party other than as stated in this Policy. Notwithstanding the aforesaid, We may disclose Personal Information in the following cases: (a) to satisfy any applicable law, regulation, legal process, subpoena or governmental request; (b) to enforce this Privacy Policy, including investigation of potential violations of any of the provisions of the Privacy Policy; (c) to detect, prevent, or otherwise address fraud, security or technical issues; (d) to respond to Users' support requests; (e) to respond to claims that any content violates the rights of third-parties; (f) to respond to claims that contact information (e.g. name, email address, etc.) of a third-party has been posted or transmitted without their consent or as a form of harassment; (g) to protect the rights, property, or personal safety of Us, Our users, or the general public; (h) when We are undergoing any change in control, including by means of merger, acquisition or purchase of all or substantially all of Our assets; (i) to enable Tutors to render the Services to Students, and to adjust the Services to the Students’ requirements and needs; (j) to handle and process payments of fees by the Students in connection with Courses subscribed for through the Platform; and (k) pursuant to Your explicit approval, in order to settle a dispute and/or review a claim submitted to Us by a Student with respect to a certain Tutor and/or certain Service.

You hereby acknowledge and agree that the Platform may collect and process Personal Information and Non-Personal Information in accordance with Sections 2, 3, 4 and 5.

1. Managing Your Information

If You have an Account with us, You may access such Account and correct or modify any or all of the personal information You provided in your account settings. You may request that we terminate Your Account by sending Us a request to the following email: Info@brocali.co.

1. Promotion and Administrative Emails

Brocali may from time to time send You email communications detailing new features or services on the Platform and/or updates regarding existing Services. You may choose to stop receiving such emails by following the unsubscribe instructions included in these emails or by contacting Us at support@brocali.co. We will still send You email messages about the status of Your Account or any notices as required by law as long as Your Account remains active.

1. Cookies & Local Storage

When You use our Platform and/or the Services, We may use industry-standard technologies such as session "cookies" (or similar technologies), which store certain information on Your computer (“Local Storage”) and which will allow Us to enable automatic sign-in to the Platform and/or Services and make the User's browsing more convenient and effortless. It is easy to prohibit the Local Storage option. Most browsers will allow the User to erase cookies from their computer hard drive, block acceptance of cookies, or receive a warning before a cookie is stored. In order to erase or disable the Local Storage option You should use the settings option according to the specific instructions provided by the technology provider. However, if You block or erase, cookies, Your online experience may be limited.

1. Security & Retention of Data

We take a great care in maintaining the security of Your information and in preventing unauthorized access to it through the use of appropriate technology and internal procedures, including by using firewall software and using a Standard Secure Socket Layer (SSL) certified encryption-based security of information on its website. However, Brocali does not guarantee that unauthorized access will never occur.

Brocali will retain your Personal Information only for as long as it is necessary for the purposes set out in this Privacy Policy including, for the purpose of allowing the provision of the Services. We will retain and use Your Personal Information to the extent necessary to comply with our legal obligations (eg. if We are required to retain Your data to comply with applicable laws), resolve disputes, and enforce agreements and policies. Data that is no longer retained (including, following the termination of your Account on the Platform) may be anonymized or deleted. We may store aggregated Non-personal Information without time limit.

1. Third Party Service Providers

We may engage third party service providers to provide certain services to Us, among others, third party services as may be necessary to help us operate the Platform and/or provide technical support to Brocali and/or the Users, as well as services necessary for hosting and maintaining our servers and the Platform, database storage and management, e-mail management etc. We may share Your Personal Information or other technical information with such third parties to enable them to perform such Services to Us. We may also share Your Personal Information with such service providers for business purposes such as to verify transactions, to process online payments made by You, and to prevent, detect and investigate fraud or other prohibited activities, facilitate dispute resolution such as chargebacks or refunds, subject to obligations consistent with this Privacy Policy and other confidentiality and security measures. .

We use Google Analytics (“Analytics”) to collect analytical information about the User's use of the Platform. This tool collects the User's IP address, device type, language of use, duration of activation, content the User has visited in the Platform, user interface clicks, frequency and extent of use of the Platform. We process Analytics' aggregate information to understand how Users interact with the Platform so We can develop and improve it. We will share the Analytics data with service providers, who assist us in the internal operation of the Platform. These companies are only allowed to use the Personal Information of the Users as needed to provide Us with these services and not for their purposes. The Analytics information We collect using a third-party tool is only used to support the internal operation of the Platform, i.e. to maintain and develop the Platform. The Analytics information We process is aggregate information that We ourselves cannot attribute to a specific User. We do not combine information collected using Google Analytics with personally identifiable information.

1. Third Party Sites

While using the Platform You may encounter links to third party sites and/or third party content (such as, information, applications and other services)(the “Third Party Services”). Please be advised that the Third Party Services are independent sites, and Brocali assumes no responsibility or liability whatsoever for them with regard to privacy matters or any other legal matter, including, without limitation, the accuracy or completeness of their content. If You decide to use such Third Party Services, including, if You decide to click on a link (on our Platform) to any third party site, You do this at your own risk and responsibility. We encourage You to carefully read the privacy policies and terms and conditions of such third-party sites before using any of the features available on such sites. Such Third Party Services may use their own cookies or other methods to collect information about You.

1. Social Media Plugins

We may use several plugins of or links to social media platforms, such as Facebook, Linkedin, Twitter, etc. (the “Social Media Platform”). You are allowed to “like” Our content using such plugins, and/or share Our content with friends and family through such plugins. Clicking on the plugin will establish a direct connection between Your browser and the server of the Social Media Platform. If You “like”/share Our content through the Social Media Platform You will do that on Your own will and responsibility, and in such case, Brocali have no knowledge of the content of the data transmitted to the Social Media Platform or how it is used by the Social Media Platform and We recommend that You read the privacy policy of such Social Media Platform.

1. Children’s Privacy

The Platform is not meant to be used by or for persons under 18. Therefore, Brocali does not knowingly collect or process personal data from or with respect to children under the age of 18, and You must be 18 years of age or older in order to use the Platform. If You are a parent or legal guardian and believe that Your child under the age of 18 has submitted his or her personal data or other data without your consent, permission, or authorization – please let us know immediately, and we will take steps to remove that information from our servers promptly. We cannot and will not take responsibility for misrepresentation by persons as to their age.

1. Changes to Privacy Policy

The terms of this Privacy Policy will govern the use of the Platform and Services and any information collected therein. Brocali reserves the right to change this Privacy Policy at any time, so please re-visit this page as often as You wish. In case of any material change, Brocali will post a clear notice on the Platform. Changes to this Privacy Policy are effective as of the stated "Last Update” and Your continued use of the Platform and/or Services on or after the Last Update date will constitute acceptance of, and agreement to be bound by, those changes.

If a User is located in a jurisdiction where transfer of its Personal Information to another jurisdiction requires its consent, then the User hereby provides us his/her express consent to such transfer or the storage, processing or maintenance of the Personal Information in other jurisdictions (including, to third parties with whom we share the Personal Information) by using the Platform and/or Services.

1. Applicable Law and Dispute Resolution

This Privacy Policy shall be governed by and construed in accordance with the laws of the State of Israel without regard to its conflict of law provisions. The courts of the Tel Aviv-Jaffa district shall have exclusive jurisdiction in all disputes and proceedings arising from this Privacy Policy.

1. Questions

If you have any questions or comments about this Privacy Policy, please feel free to send us an email to or write to us at: contact@brocali.co