PRIVACY POLICY – TULKKA
Welcome to the website www.tulkka.com ("The Website", "we", "us").
This Privacy Policy describes what personal information we collect, why we collect it, how we use it, with whom we share it, and your rights concerning this information. This policy operates in accordance with the provisions of the Israeli Protection of Privacy Law, 1981 ("The Law") and its regulations (including Amendment 13 to the Law).
Use of the Website is subject to the terms detailed in this Privacy Policy. Please read the Privacy Policy carefully, as browsing the Website and performing actions therein constitutes your consent to the terms contained in this Privacy Policy.
In the event of inconsistency between any terms of this Privacy Policy and any translation into another language, the Hebrew version will control and prevail on any question of interpretation or otherwise.
The terms of this Privacy Policy apply to the use of the Website, and the content contained therein, via any computer or other communication device (such as a mobile phone, tablet computers, etc.). They also apply to the use of the system and the Website, whether through the internet network or through any other network or communication means.
Information actively provided by you:
Upon purchasing and account creation: Full name, contact details (phone, email), residential address, as well as pedagogical and personal information required to tailor the service: language proficiency level, learning goals, interests, and hobbies. Payment details (such as credit card information) are processed by a secure third-party payment processor and are not stored on the Website’s systems.
Information Collected During Learning: Trial lessons and ongoing lessons conducted on video platforms (such as Zoom) may be recorded for quality assurance, teacher training, service improvement, and occasionally for student progress tracking; Progress Data, including information on lesson frequency, study topics, feedback, test results, and educational achievements.
Upon signing up for a mailing list (newsletter): Email address and name.
Upon contacting us: Name, contact details (email or phone), and the content of your inquiry.
Information collected automatically:
Browsing data and technical data: While browsing the Website, we may collect technical information such as IP address, browser type, operating system, entry times, and viewed pages.
Cookies: We use cookies for the current and proper operation of the Website, improving the user experience, collecting statistical data, and tailoring advertisements. Cookies are a small text file that a website, online application, or email may save in the web browser and/or on the hard drive of the computer for use in subsequent visits to the system and/or the Website.
We process your personal information for specific purposes and based on defined legal grounds. Below are a breakdown of the purposes and the corresponding legal basis:
We do not sell or rent your personal information to third parties. We may share your personal information with third parties and service providers acting on our behalf, solely for the purposes detailed in this policy and in accordance with the provisions of the Law. These entities include:
Clearing and Payment Providers: For secure processing of the payment for your purchase. Full payment details are not stored on our systems.
Teaching Staff (Teachers): We transfer to your assigned teachers the information required to conduct the lesson (name, language level, interests, learning history).
Infrastructure and Software Providers: Customer Relationship Management systems (CRM), video platforms for lessons (such as Zoom), and cloud services.
Contractors and Manpower Management Companies: We utilize external companies to manage operations, teachers, sales, technical support personnel and development teams, including companies located outside of Israel.
Mailing Service Providers: For sending newsletters and updates, only if you signed up for this service.
Analytics, Marketing, and Ancillary Service Platforms: We share technical, statistical, and aggregated information (which usually does not personally identify you), as well as relevant personal information, with external services that help us understand how the Website is used, improve services, manage the product review system, and operate our loyalty and benefits program. These services include, but are not limited to:
Google Analytics: For statistical analysis of Website use.
Google Ads: For targeted advertising, remarketing, and measuring the effectiveness of advertising campaigns.
Meta Pixel, Facebook: For ad targeting, marketing campaign analysis, and building targeted audiences.
Law Enforcement Authorities: If required to do so by a judicial order or an instruction from a competent authority.
Professional Advisors: Such as accountants and attorneys, as necessary.
Transfer of Information Outside of Israel: Some of the external services we use (such as Google, Facebook, and mailing service providers) may store and process the information on servers located outside the borders of Israel. The use of these services is subject to their respective terms of use and privacy policies, and we ensure that the transfer of information is conducted in accordance with the law and that adequate safeguards are in place for your information.
The Website operates internationally. You should be aware that your information may be transferred to, stored, and processed in various countries outside of Israel, including the USA, the Philippines, India, and other countries where our teachers or development and support teams are located. We take reasonable measures to ensure your information receives an adequate level of protection when transferred abroad, in accordance with legal requirements.
The services on the Website may also be used by students who are minors. We attach great importance to protecting the privacy of minors and operate in compliance with applicable laws.
Registration for the service, account creation, and provision of personal information for minor users must be performed by a parent or legal guardian, or with their explicit prior consent. By registering a minor for the service, you declare that you are their parent or legal guardian and consent to the collection of their information in accordance with this policy.
Information collected about minors (such as name, age, English proficiency level, and learning progress) is limited strictly to the data necessary for providing the educational services.
Lessons involving minors are recorded for quality control and safety purposes. Access to these recordings is restricted and carefully monitored.
If you are a parent or guardian and believe that information has been provided to us by a minor without your consent, please contact us immediately at info@tulkka.com, and we will take steps to address the issue and delete the information if necessary.
Database Owner: For the purpose of the Law, Amit Binish, who operates the Website, is the "Controller" of the information database in which the data detailed in this policy is collected.
Obligation to Provide Information and its Consequences: You are not legally obligated to provide us with personal information. However, failure to provide certain details may prevent us from providing you with certain services. For example, without providing contact information and basic order details, we will not be able to complete and confirm your order. Without providing an email address, we will not be able to send you an order confirmation or add you to our mailing list, at your request. Information collected automatically is required for the proper and secure operation of the Website.
We maintain administrative, technical and physical safeguards designed to protect the information we collect through the Site against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. However, there is no absolute security in these actions and the Site cannot obligate that the services on the site will be completely immune.
Personal information will be retained for the period necessary to fulfill the purposes for which it was collected, or for a longer period as may be required by law.
According to the Protection of Privacy Law, you have the following rights:
Right of Access (Inspection): You are entitled to request access to the personal information we hold about you.
Right to Rectification: If you discover that the information is incorrect, incomplete, or inaccurate, you may request its rectification.
Right to Erasure (Right to be Forgotten): You may request the erasure of your personal information, subject to legal limitations.
The exercise of this right shall be done by contacting the Website according to the details appearing below.
The exercise of this right is also available to a parent or legal guardian regarding information collected about a minor under their responsibility.
CalOPPA is a California state law that functions as one of the primary data privacy laws in the United States. The law came into effect in July 2004, and is applicable to the operators of commercial websites or online services that collect personally identifiable information about consumers residing in California. Following a 2012 agreement between the California Attorney General and mobile app providers, CalOPPA also applies to mobile apps.
There is wide overlap between CalOPPA and the CCPA, and the majority of requirements of CCPA are applicable to those of CalOPPA.
Under CalOPPA, "Personally Identifiable Information" includes but is not limited to:
First and last names;
Home or physical street addresses;
E-mail address;
Telephone number;
Social Security number;
Any other information that permits a specific individual to be contacted physically or online.
Categories of personal information are collected. The personal information that the Site collects fall into the following categories as established by the California Consumer Privacy Act:
identifiers such as your name, alias, address, phone numbers, or IP address;
personal information, such as a credit card number;
commercial information, such as purchase and content streaming activity;
internet or other electronic network activity information, including content interaction information, such as content downloads, streams, and playback details;
geolocation data, such as the location of your device or computer;
inference data, such as information about your purchase preferences.
Categories of personal information disclosed for a business purpose. The personal information that the Site discloses about consumers for a business purpose fall into the following categories established by the California Consumer Privacy Act:
identifiers such as your name, address, phone numbers, or IP address, for example if we use a third party carrier to deliver your order;
personal information, such as a credit card number, for example if we use a third party payment processor;
your age, gender, or other protected classifications, for example if you choose to participate in a survey distributed by a survey provider;
commercial information;
internet or other electronic network activity information, such as if we use a service provider to help us gather crash reports for analyzing the health of our devices and services.
Right to Request Access to or Deletion of Personal Information: you may have the right under the California Consumer Privacy Act to request information regarding the collection of your personal information by the Site, or access to or deletion of your personal information. If you wish to access this information, please contact us using the contact information provided below.
No sale of personal information. The Site has not sold any personal information of consumers, as those terms are defined under the California Consumer Privacy Act.
No Discrimination. The Site will not discriminate against any consumer for exercising their rights under the California Consumer Privacy Act.
The GDPR is the European Union (“EU”) regulation that harmonizes data privacy and security laws that regulate the use of individuals’ personal data across Europe.
As of May 2018, the GDPR has been applicable in all EU member states, requiring companies to update their privacy and security policies and practices in accordance with the changes introduced by the new Regulation.
The terms of the GDPR apply only to the processing of personal data of persons in the EU, which is defined in Article 4 of the Regulation, as “any information relating to an identified or identifiable natural person”. This includes information such as a person’s name, location data, identification number, and information pertaining the physical, physiological, genetic, mental, economic, cultural or social identifiers of the person.
Naturally, it is likely that the GDPR applies to some of the data gathered through the services offered by the Website. Information entered by the user is kept for bettering the user’s experience.
We are committed to holding our privacy and security policy and practice to the highest standards. See this policy for more information on the measures we have taken to guarantee the responsible use of the data and information gathered by the Website. You can find additional info updates on the GDPR on the official website: https://gdpr-info.eu/
A user who leaves details on the Website, and by their consent authorizes mailings and is added to the Website's mailing list, authorizes the use of their details for receiving marketing information, updates, and advertisements that the Website will send from time to time.
One must not leave details of another person on the Website without their consent and/or without their presence in front of the screen at the time the details are left.
When leaving details, the user will be asked to provide personal details such as: first name, last name, phone, and a valid email address (at the Website's sole discretion). Providing incomplete or incorrect details may prevent the ability to use the service and frustrate contact in case of need. In the event of a change in details, they must be updated on the Website.
It is clarified that there is no legal obligation to provide details on the Website, but without providing them, it will not be possible to receive marketing content and updates from the Website.
Leaving details on the Website and approving the receipt of marketing content includes, among other things, receiving marketing content, information regarding promotions, updates, and discounts offered to registered users.
The aforementioned authorization for mailing (receiving marketing content) constitutes the user's consent to the sending of advertising messages pursuant to the Israeli Communications Law (Telecommunications and Broadcasts) (Amendment No. 40), 2008 ("The Communications Law").
It is clarified that the person leaving the details can remove themselves at any time from the mailing list by clicking on "Unsubscribe" or any similar text that appears at the bottom of every mailing sent, or by contacting the Website via email. As long as the subscriber has not removed themselves from the mailing list as aforesaid, the Website is entitled, subject to the Communications Law, to send direct mailing to the subscriber.
The Website may cancel a user's registration to the mailing list at its absolute discretion.
The Website shall not be responsible for any damage (direct or indirect), loss, distress, and expenses caused to the person leaving the details and/or any third parties as a result of using or relying on any content, information, data, representation, advertisement, product, service, etc., appearing in the mailing. Any such reliance is made at the sole discretion and responsibility of the person leaving the details.
The mailing in its entirety, including all the information appearing therein, is offered "AS IS," and shall be as accurate and correct as possible, however, the information may be incomplete or, alternatively, technical or other errors may have occurred in the information.
The user confirms that they shall have no claim regarding advertisements and/or commercials displayed on the Website, including regarding their placement on the Website. It is clarified that with respect to advertisements displayed under the sponsorship of a third party, the Website has no involvement in the selection of the displayed advertisements, the truthfulness of their content, and their order of appearance.
We reserve the right to modify or update this policy from time to time. The updated version will be published on the Website.
For any question or request regarding this Privacy Policy, please contact us:
Phone: 972(0)4-3033128;
or Email: info@tulkka.com
All rights in this document above reserved to Daniel Bahry law office.
Last Update: December 2025
