Luach Bracha — Terms of Use and Privacy Policy

Last updated: 8 November 2026 · Version: 2.0-draft

Status of this document. This version (2.0) is a draft prepared for review by qualified Israeli privacy counsel and, where the Service is offered abroad, by counsel in those jurisdictions. Until that review is complete, it describes the Service as it actually works and our commitments, but it should not be relied on as final legal advice. Facts that the operator must still confirm are listed separately for counsel and are not stated here as settled.

What this document contains. Part A — Terms of Use. Part B — Privacy Policy. Part C — Consumer Health Data Privacy Notice. Part D — Notice on Specially Sensitive Information. Part E — Halachic, Medical and Wellness Disclaimer. Part F — Sharing, Questions to a Rav and Attachments. Part G — Storage on Your Device and Cookies. Part H — Retention and Deletion Schedule. Part I — Service Providers and International Transfers. Part J — Age and Eligibility. Part K — Accessibility Statement. Part L — Privacy Requests, Complaints and Security Reports. Schedules.

These Terms of Use (the "Terms") are a binding agreement between you and Kosher Apps Luach Bracha, a private pilot project run from Israel ("we", "us"). If a company later takes over the Service, we will tell you in advance (section 17.4). These Terms govern your use of the Luach Bracha app on the web, on mobile devices and by telephone (together, the "Service").

1. Accepting these Terms

1.1 By creating a luach, by choosing to use it on one phone only, or by otherwise using the Service, you agree to these Terms and acknowledge our Privacy Policy (Part B). If you do not agree, do not use the Service.

1.2 We record the version you accepted and the time you accepted it, inside your encrypted luach.

1.3 Where the law of your country gives you rights that these Terms cannot take away, those rights apply and nothing in these Terms limits them.

2. Who may use the Service

2.1 You must be at least 18 years old, or the age of majority where you live if that is higher.

2.2 You may use the Service only for your own personal, non-commercial use, unless we agree otherwise in writing (for example, an organization that sponsors access for its members).

2.3 The Service is offered worldwide. You may use it only where doing so is lawful, and you are responsible for complying with local law. We may limit or withhold the Service in a country where the law requires it, including under sanctions or export-control laws that apply to us. You confirm that you are not a person with whom we are prohibited by law from dealing.

3. What the Service is

3.1 The Service is a personal calendar (luach) for keeping the laws of taharas hamishpacha. It lets you record dates and events and shows calculations, such as onos, the earliest hefsek tahara, the seven clean days, mikvah night and halachic times (zmanim), according to the ruleset ("shitta") you choose or the rules you enter yourself.

3.2 The Service is offered on the web, as an installable app, and, where available, by telephone.

3.3 We may add, change or remove features. We will not remove your ability to read and export what you have already recorded (see section 10).

3A. The private pilot

3A.1 The Service is currently in a private pilot. It is available by personal invitation only, to a small group of testers.

3A.2 The pilot version is a test version. Features may change, and the calculations have not been approved by a Rav. Do not rely on it alone; see section 4.

3A.3 We may ask you for feedback. Giving feedback is optional, and we will never ask you to share entries from your luach.

3A.4 Optional contributions (section 8.2) are not offered during the pilot.

3A.5 The pilot may end at any time. If it ends without the Service continuing, we will give at least 30 days' notice in the app so that you can export your data, and we will then delete the data we store.

4. Not religious, medical or professional advice

4.1 The Service does not issue halachic rulings. Calculations follow rulesets that, unless marked otherwise in the app, have not been approved by a Rav. Where the app says "ask your Rav", it is because the matter needs a ruling. You remain responsible for asking a competent Rav about your own situation and for following his ruling, including where it differs from what the Service shows.

4.2 The Service is not a medical device and does not give medical advice. It is not intended to diagnose, treat or prevent any condition, or to be used for contraception or for planning or avoiding pregnancy. For medical questions, consult a qualified medical professional.

4.3 Halachic times (zmanim) are calculated astronomically for the location you choose, at sea level, and may differ by a minute or more from a printed luach or local custom. Allow a safety margin.

4.4 You must not rely on the Service as your only record. Keep your own records or backups as the app recommends.

5. Your luach, your keys and your devices

5.1 End-to-end encryption. Your web luach is encrypted on your device before it is stored. We do not hold the keys and cannot read it. This is why we cannot recover it for you.

5.2 Your responsibilities. You are responsible for:

5.3 Loss of access. If you lose every device on which your luach is open and also lose your recovery code, nobody, including us, can recover your luach. We are not responsible for that loss.

5.3A PIN or passphrase. You may protect your luach with a numeric PIN of at least six digits or with a passphrase of at least eight characters that includes letters. After five incorrect attempts the app makes you wait before trying again, and the waiting time increases with further incorrect attempts. Before sensitive actions (such as downloading your data, deleting saved versions, removing or signing out a device, turning on fingerprint or face unlock, or deleting your account) the app asks for your PIN or passphrase again.

5.4 Fingerprint or face unlock is optional and uses your device's own secure hardware. Anyone whose fingerprint or face can unlock your device may be able to open your luach. You choose whether to turn it on.

5.5 Sign-in. If you use an account, we send a one-time code to your email address or phone number. You must provide an address or number you are entitled to use.

6. Using the Service on one phone only

6.1 You may use the Service without an account, with everything stored only on your device ("this phone only").

6.2 In that mode, nothing is copied to us unless you turn on encrypted synchronization. Uninstalling the app, clearing your browser's data, or losing or replacing the device may erase your luach permanently. You are responsible for making and keeping encrypted backups.

6.3 If you later turn on synchronization, your entries are moved into an account under these Terms and the Privacy Policy.

6A. Sharing is always your choice

6A.1 Nothing in your luach is shared with anyone, including your husband, family members, a Rav, a kallah teacher, a mikvah, a healthcare provider or us, unless you yourself choose to share it, see exactly what will be shared, and send it. See Part F.

6A.2 Once you share information with another person, that person can keep, copy or forward it. We cannot control or undo what a recipient does with information you have sent.

7. Acceptable use

You agree not to:

8. Price, optional contributions and future paid features

8.1 The Service is currently free. We do not promise that it will always be free, or that any feature will remain free.

8.2 Optional contributions. You may choose to make a one-time contribution ("Buy us a coffee"). A contribution:

8.3 Future paid features or subscriptions. We may introduce paid features or a subscription. If we do, we will tell you in advance, state the price and terms clearly before you buy, and you will not be charged unless you choose to buy. Subscriptions bought through an app store are billed, renewed and canceled through that store.

8.4 No lock-out of your records. Whether or not you pay, and even if a future subscription ends, you will be able to open, read and export what you have already recorded.

8.5 Taxes. Prices shown include any taxes the law requires to be included, unless stated otherwise.

9. Intellectual property

9.1 The Service, its software, design, text and calculations are owned by us or our licensors and are protected by law.

9.2 We grant you a personal, revocable, non-exclusive, non-transferable license to use the Service under these Terms.

9.3 Your content is yours. We claim no ownership of what you record. Because it is encrypted, we cannot read or use it.

9.4 If you send us suggestions or feedback, we may use them freely, without obligation to you.

10. Your data: export and deletion

10.1 You can, at any time and from inside the app: make an encrypted backup; download all your data in readable form; delete entries; delete earlier versions; and delete your account.

10.2 Deleting your account deletes the data we store for it, as described in the Privacy Policy. Files you have downloaded or printed are under your control, and we cannot delete them.

11. Third-party services

11.1 The Service relies on third parties, such as app stores, hosting, email and SMS providers, push-notification services, payment providers, and, for the telephone line, a telephony provider. Their own terms and privacy policies apply to your use of their services.

11.2 Internet filtering services may block or alter parts of the Service. We are not responsible for a filter's decisions.

12. Availability, changes and ending the Service

12.1 We aim to keep the Service available, but we do not guarantee that it will be uninterrupted, error-free or available in every location or on every device.

12.2 Changes to these Terms. If we change these Terms in a way that matters, we will tell you in the app in advance and ask you to accept the new version. If you do not accept, you may stop using the Service and export or delete your data.

12.3 Ending use. You may stop using the Service and delete your account at any time. We may suspend or end your access if you seriously or repeatedly breach these Terms, if the law requires it, or to protect the Service or other users. Where reasonable, we will tell you first.

12.4 If we discontinue the Service, we will give at least 90 days' notice in the app, so that you can export your data.

13. Disclaimers

13.1 To the extent the law allows, the Service is provided "as is" and "as available". We make no warranty, express or implied, about the accuracy or completeness of any calculation, its fitness for a particular purpose, or its acceptance by any halachic authority.

13.2 Nothing in this section excludes any warranty or guarantee that cannot lawfully be excluded, including under consumer protection law.

14. Limitation of liability

14.1 To the extent the law allows, we are not liable for indirect, incidental, special, consequential or punitive damages, or for loss of data, profits or goodwill, arising from your use of the Service.

14.2 To the extent the law allows, our total liability to you for all claims relating to the Service is limited to the greater of (a) the amount you paid us in the 12 months before the claim and (b) USD 50 (or its equivalent in local currency).

14.3 Nothing in these Terms limits liability for death or personal injury caused by negligence, for fraud, or for any other liability that cannot lawfully be limited.

15. Indemnity

To the extent the law allows, you agree to compensate us for reasonable losses and costs arising from your breach of these Terms or your misuse of the Service. This does not apply where you act as a consumer and local law does not permit such an obligation.

16. Governing law and disputes

16.1 These Terms are governed by the laws of the State of Israel, without regard to conflict-of-laws rules.

16.2 The competent courts of Jerusalem, Israel, have exclusive jurisdiction, except that if you are a consumer you may also bring proceedings in the courts of the country where you live, and you keep the protection of that country's mandatory consumer laws.

16.3 Before starting proceedings, please contact us at luachbracha@gmail.com so that we can try to resolve the matter informally within 30 days. If it cannot be resolved that way, the courts named in 16.2 will decide.

17. General

17.1 Entire agreement. These Terms, the Privacy Policy and any notices in the app are the entire agreement between you and us about the Service.

17.2 Severability. If any part of these Terms is held invalid, the rest remains in force.

17.3 No waiver. Not enforcing a right is not a waiver of it.

17.4 Assignment. You may not transfer your rights under these Terms. We may transfer ours to a successor that agrees to honor these Terms and the Privacy Policy, and we will tell you in advance.

17.5 Force majeure. We are not responsible for failures caused by events beyond our reasonable control.

17.6 Language. If these Terms are translated, the Hebrew version controls for users in Israel and the English version controls everywhere else, to the extent the law allows.

17.7 Contact. Kosher Apps Luach Bracha, Israel, luachbracha@gmail.com.

Last updated: 8 November 2026 · Version: 2.0-draft

We built Luach Bracha so that we cannot read your luach. This policy explains what that means, the limited information we do process, why, for how long, and your rights.

We do not sell anyone's data. Not to advertisers, not to data brokers, not to anyone.

1. Who is responsible

1.1 The controller of personal data processed through the Service is Kosher Apps Luach Bracha, a private pilot project run from Israel ("we", "us").

1.2 Privacy contact: luachbracha@gmail.com. Where the law requires, we appoint a representative in the European Union and the United Kingdom and publish its details here.

1.3 Where the law requires, our databases are registered with the Israeli Privacy Protection Authority.

2. How your luach is protected

2.1 Web and app luach: end-to-end encrypted. Everything you record (dates, onos, hefsek, tevilah, bedikos, notes, special situations, veset kavua, your Rav's rules and your settings) is encrypted on your own device with AES-256-GCM before it is saved. The key that encrypts it never leaves your devices unencrypted. We store only the encrypted copy. We cannot read it, and neither could anyone who obtained our database.

2.2 Your PIN never leaves your device. It opens a key that is also bound to a secret stored only on that device, so a copy of our database cannot be used to guess your PIN.

2.3 Fingerprint or face unlock is handled by your device's secure hardware. We never receive your fingerprint, face or any biometric data.

2.4 "This phone only" stores your encrypted luach only on your device. We receive nothing.

2.5 The telephone line is not end-to-end encrypted. See section 5.

2.6 What we can still see. Encryption protects the content of your luach. It does not hide everything. Our systems necessarily see: your sign-in identifier (email address or phone number); when and from which kind of device you sign in and save; the size and version number of each encrypted save; the devices on your account; security events (section 3); and, only if you turn them on, the times of reminders sent while the app is closed. We describe each of these in section 3 and keep them only as long as stated there.

2.7 Limits of protection. No security measure is perfect. Encryption cannot protect information on a device that is unlocked, infected with malicious software, or in the hands of someone who knows your PIN or passphrase or can unlock your device with a fingerprint or face. Information you share or export leaves the protection of the app.

3. What we process, why and for how long

3.1 Reminder messages show only the word "Reminder" or a code word you choose, never a halachic term. You may also choose a neutral notification title or a notification that shows nothing identifying. Your phone's operating system may still show which app sent it.

3.2 Contribution records are kept in a separate table with no link to your account, your devices or your luach. No name or email address is stored with them.

3.2A The news list and the messages you send are kept in separate tables with no link to your account, your devices or your luach, and only we can read them. Our news is about Luach Bracha only; we never sell, rent or share the list. Please do not include personal or halachic details in a message.

3.3 Problem reports contain only the app version, language, browser type, whether you were online, any technical errors on the page, and the description you type. You see the whole report before sending it, and you send it yourself.

3.3A Everything else you record lives only inside your encrypted luach, where we cannot read it. This includes: periods, hefsek tahara, bedikos and answers about missed bedikos, mikvah nights, notes for your Rav and his answers (including the date an answer concerns, whether it applies generally or only to that case, and when to ask again), your rules history (each change of shitta, your Rav's own rules or your location, with the date it took effect), special situations (pregnancy, nursing, after birth, kallah, menopause), journal entries and favourites, health notes, family dates, contacts, photos for your Rav, mikvah preparation and plans, saved and recently viewed mikva'ot, saved learning pages and what you have read, trip dates, quiet hours and reminder preferences.

3.4 We do not process biometric data. We do not knowingly receive health information in readable form; your luach, which may reveal such information, is encrypted and unreadable to us (see Part C).

4. What we do not do

If we later add privacy-preserving usage statistics, they will contain only counts with no identifiers and no luach content, and we will update this policy first.

5. The telephone line

5.1 To speak your luach to you, the telephone server must read it. It is therefore stored encrypted with a key made from your PIN together with a secret held on our servers, and bound to your caller record.

5.2 This protects it if our database alone is taken, but it is not end-to-end encryption. Someone holding both our database and our server secret could try every possible PIN.

5.3 Your phone number is stored only in hashed (HMAC) form. Your telephone company and our telephony provider can see that a call took place. If you opt in to SMS reminders, our SMS provider sees your number and the neutral message text.

6. Who receives data

6.1 We share data only with service providers that process it for us under written agreements (Schedule 2), with authorities where the law requires, or with a successor if our business is transferred (with notice to you).

6.2 Because your luach is encrypted on your device, none of these recipients can read it.

7. International transfers

7.1 Our database and sign-in servers are located in Singapore (Supabase). Because the Service is used worldwide, data you send to us may be processed outside your country, and some providers may process data in other countries, including the United States.

7.2 Where data is transferred outside Israel, the EEA or the UK, including to Singapore, we rely on an adequacy decision or on standard contractual clauses and supplementary measures, as the law requires. The luach itself reaches the server only encrypted on your device, so it cannot be read there.

No system is perfectly secure. If a personal data breach occurs that affects you, we will notify you and the competent authorities as the law requires, and within the time the law sets.

9. Your rights

9.1 In the app, at any time, you can see your devices, download all your data, delete entries and earlier versions, turn reminders off, and delete your account.

9.2 Under applicable law you may also have the right to access, correct, delete or receive a copy of your personal data; to object to or restrict processing; to withdraw consent at any time (without affecting earlier processing); and to complain to a supervisory authority, such as the Israeli Privacy Protection Authority or your local data protection authority in the EU or UK.

9.3 United States residents may have rights under state laws, including to know, access, correct and delete personal data. We never sell anyone's data, and we do not use it for targeted advertising or profiling, so there is nothing to opt out of. See Part C for consumer health data.

9.3a Where you live. Because the Service is used worldwide, the rights and the authority you can complain to depend on your country. Examples:

Wherever you live, the rights in 9.1 are available to you in the app, and we will consider any request under 9.4.

9.4 To use a right we cannot fulfill in the app, contact luachbracha@gmail.com. We will verify the request without asking you for luach content, and answer within the period the law sets (generally 30 days under Israeli and EU law, 45 days under most US state laws). You may appeal a refusal by writing to luachbracha@gmail.com.

9.5 We cannot give you, correct or delete the content of your encrypted luach on your behalf, because we cannot read it. You can do all of that yourself in the app.

10. Deletion

10.1 Deleting your account removes your account, devices, encrypted luach, earlier versions, reminder registrations and scheduled reminders from our active systems immediately.

10.2 Encrypted copies in server backups are erased when those backups expire, within 7 days.

10.3 Contribution records are not linked to you and are kept for accounting as tax law requires.

10.4 Files you downloaded, printed or backed up are under your control.

11. Children

The Service is intended for adults. We do not knowingly collect personal data from anyone under 18, or under the age of majority where they live if that is higher. If you believe a child has used the Service, contact us and we will delete the account.

12. Changes to this policy

If we make a material change, we will tell you in the app before it takes effect and, where the law requires, ask for your consent again. The version and date appear at the top.

13. Contact

Kosher Apps Luach Bracha · Israel · luachbracha@gmail.com

14. Our commitments

In addition to what the law requires, we commit that:

This notice applies to residents of Washington, Nevada, Connecticut and other US states with consumer health data laws. It supplements the Privacy Policy.

1. What consumer health data could arise

1.1 Entries in your luach, such as the dates of periods, a hefsek tahara, bedikos, mikvah dates, stains, a medical examination, pregnancy, nursing or a birth, may be consumer health data.

1.2 We cannot access this data. It is encrypted on your device before it is stored, and we do not have the key. In "this phone only" mode it never reaches us at all.

1.3 Other data we process may allow an inference about health, for example the fact that you have an account with a family-purity app, or that a reminder is scheduled for a particular time. We treat that information as consumer health data.

2. Categories, sources and purposes

3. Sharing

We share consumer health data only with processors that provide the Service for us (Schedule 2), under contracts that limit their use of it to that purpose. We never sell anyone's data, including consumer health data, and we never share it for advertising.

4. Consent

We collect and share consumer health data only with your consent, which you give when you create your luach, and separately when you turn on reminders while the app is closed or use the telephone line. You may withdraw consent at any time by turning the feature off or deleting your account.

5. Your rights

You may confirm whether we collect or share your consumer health data (we never sell it); access it; receive a list of the third parties and affiliates with which it was shared; withdraw consent; and request deletion. Most of these can be done in the app. Otherwise contact luachbracha@gmail.com. If we decline your request, you may appeal by writing to luachbracha@gmail.com, and, if your appeal is denied, contact your state Attorney General.

6. Geofencing

We do not use geofencing. The app's "Find my location" feature uses your device's position once, on your device, to choose the nearest listed location. The position is not stored or sent to us.

1. Why this notice exists

1.1 A luach for taharas hamishpacha necessarily records information that the law treats with special care: information about menstrual cycles and reproductive health, pregnancy, birth and nursing, intimate life, and religious belief and practice. Under the Israeli Protection of Privacy Law, 5741-1981, as amended (including Amendment 13, in force from 14 August 2025), such information is "information of special sensitivity". Under the EU and UK General Data Protection Regulation it may be "special category data" (Article 9). Under several United States state laws it may be "consumer health data" (Part C).

1.2 This notice explains, in one place, how that information is handled.

2. The design principle

2.1 The Service is built so that this information is not available to us. It is encrypted on your device with a key that we never receive, before anything is stored or synchronized. In "this phone only" mode it never leaves your device at all.

2.2 Because we cannot read this information, we do not use it for any purpose, we cannot disclose it to anyone, and we cannot hand it over in readable form even if legally compelled; we can only hand over encrypted data that we are unable to decrypt.

3. Your choice and your consent

3.1 You decide what to record. Every field is optional except the date you enter for a period, which is what the calculations need.

3.2 Where the law requires your explicit consent to the processing of specially sensitive information, we ask for it separately, at the moment it becomes relevant, and never bundled with unrelated matters. You may withdraw it at any time; withdrawal does not affect processing that took place before it.

3.3 Optional features that involve sending anything outside your device — synchronization between devices, reminders while the app is closed, the telephone line, sharing with a Rav, sending a problem report — are each turned on separately by you, and each can be turned off.

4. What could reveal sensitive facts even without content

4.1 The bare fact that a person has an account with a family-purity app, the times at which reminders are scheduled, or a pattern of activity, could allow someone to infer sensitive facts. We therefore treat that metadata as sensitive too: we keep it to a minimum, never share it except with the service providers that run the Service (Part I), and delete it on the schedule in Part H.

4.2 Notifications show only a neutral word or a code word you choose, never a halachic or medical term, and you may choose a notification that shows nothing identifying.

1. Halachic

1.1 The Service helps you organize your own records, see reminders and view calculations made according to the ruleset you select or the rules you enter on your Rav's instruction. It does not issue halachic rulings and is not a substitute for asking a competent Rav.

1.2 Each calculation shows what it is based on, the rules used and their version, the location and time zone, and whether the rules have been approved by a Rav. Unless the app states that a ruleset has been approved, it has not been.

1.3 Where a situation is uncertain — for example a sighting near sunset, a missed or uncertain bedikah, a stain, a birth, travel across time zones, or any situation the app flags with "ask your Rav" — the app does not decide. It records exactly what you enter and marks the matter for your Rav.

1.4 Learning material in the app is educational. Each item shows its sources and its review status. Material marked "awaiting review" has not yet been reviewed by a Rav, a yoetzet halacha and a women's health professional, and must not be treated as a ruling.

1.5 Halachic times (zmanim) are astronomical calculations for the location you choose and may differ by a minute or more from a printed luach or local custom.

2. Medical and wellness

2.1 The Service is not a medical device and has not been evaluated or authorized as one by any regulator. It does not diagnose, treat, cure or prevent any condition, and does not give personalized medical advice.

2.2 The Service must not be used for contraception or for planning or avoiding pregnancy. Information it shows about ovulation timing or cycle patterns is general, based only on what you entered, and is not a medical prediction.

2.3 Health notes you keep in the app are for your own reference and, if you choose, to show your doctor. If you have a health concern, consult a qualified medical professional. In an emergency, contact your local emergency services.

3. Hotlines and contacts

The telephone numbers and websites of hotlines and organizations shown in the app were checked against the published sources named beside them on the date shown. Hours and numbers change; check them before relying on them. We are not affiliated with these organizations unless we say so.

1. Nothing is shared automatically

1.1 The Service never sends your luach, or any part of it, to anyone automatically. There is no feature that gives a husband, family member, Rav, kallah teacher, mikvah, doctor or anyone else access to your luach.

2. How sharing works

2.1 Questions for your Rav are saved privately in your luach. The app currently does not send questions to a Rav on your behalf. If you choose to share a question, a printout or selected entries, you do so yourself, by printing, by your device's own share feature or by speaking to your Rav, and you see exactly what is included before you do.

2.2 Printing for your Rav includes only the entries you select, and each line states whether it was recorded by you or calculated by the app.

2.3 Neutral words for your husband. The app can prepare a short neutral message (words you choose for each state) that you send yourself. You see the exact words before sending.

2.4 Photos for your Rav are kept encrypted inside your luach for 14 days and then deleted automatically. They are never uploaded anywhere in readable form and are never analyzed automatically, including by any artificial-intelligence system. If you send a photo to someone, it leaves the protection of the app.

2.5 Mikvah calls and directions open your phone's dialer or map application only when you tap them. Nothing about your calendar is sent to a mikvah.

3. After you share

3.1 A recipient can keep, copy or forward what you send. We cannot recall or delete information that has left the app.

3.2 Messaging, email and map applications you use to share are governed by their own terms and privacy policies.

4. Future direct sending

If we later offer sending a question to a verified Rav from within the app, we will show you, before anything is sent: the recipient, the exact text, the dates or entries included, any attachment, how it will be transmitted, and whether that channel is end-to-end encrypted. We will only describe a message as delivered when delivery has been confirmed.

1. No tracking cookies

1.1 The Service does not use advertising, analytics or tracking cookies, and loads nothing from other companies' servers.

2. What is stored on your device

2.1 To work offline, the app stores on your device:

2.2 Display preferences are kept outside the encrypted luach so that the lock screen appears in your language and appearance before you unlock. They do not reveal anything you record.

2.3 Clearing your browser's data, uninstalling the app or resetting your device removes these items. In "this phone only" mode that also erases your luach unless you have a backup.

2.4 Because these items are strictly necessary to provide the Service you request, no consent banner is shown. If we ever add any non-essential storage, we will ask first.

Deleting your account removes your data from our active systems immediately and from backups when they expire. It cannot remove information you have already shared with others or saved yourself.

1. Providers

1.1 We use only the categories of providers listed in Schedule 2, and only when the related feature is in use. None of them can read your luach.

1.2 Register of providers:

1.3 We do not use providers for analytics, advertising, mapping inside the app, or artificial intelligence.

2. International transfers

2.1 Data may be processed outside the country where you live. Where the law requires, we transfer personal data outside Israel, the European Economic Area or the United Kingdom only to countries recognized as providing adequate protection, or under standard contractual clauses or another lawful transfer mechanism, with supplementary measures where needed. We do not claim that all data remains in any single country.

1. The Service is intended for adults. You must be at least 18 years old, or the age of majority where you live if that is higher.

2. We do not ask for identity documents to confirm age, and we do not knowingly collect personal data from minors. If you believe a minor has used the Service, contact us and we will delete the account.

1. We aim to meet the Web Content Accessibility Guidelines (WCAG) 2.2 at level AA, and, for users in Israel, the Equal Rights for Persons with Disabilities (Service Accessibility Adaptations) Regulations, 5773-2013, and Israeli Standard 5568.

2. The app supports screen readers, keyboard use, larger text, a high-contrast appearance, reduced motion and right-to-left and left-to-right languages. The screens are tested automatically for accessibility in all seven languages and in the light, dark, night and high-contrast appearances, and the main screens in all ten design styles.

3. Automated testing does not find every barrier. If something is hard to use, please tell us at luachbracha@gmail.com and we will respond within a reasonable time.

1. Requests

1.1 Most rights can be exercised in the app at any time: see your devices and account activity; download all your data; correct or delete entries; delete saved versions; turn reminders off; delete your account.

1.2 For anything else, write to luachbracha@gmail.com. We will verify your request without asking for the content of your luach, and reply within the period the law sets.

2. Complaints

2.1 If you are not satisfied with our answer, you may complain to the Israeli Privacy Protection Authority or to the data protection authority where you live (see Part B, section 9.3a).

3. Security reports

3.1 If you believe you have found a security weakness, please report it privately to luachbracha@gmail.com with the subject "Security". Please do not access other people's data or disrupt the Service while testing. We will acknowledge reports and will not take action against good-faith research that follows these rules.

4. Incidents

4.1 If a security incident affects your personal data, we will notify you and the competent authorities as and when the applicable law requires. Notification duties differ between jurisdictions; our internal incident response procedure sets out how we assess them.

Schedule 1 — Definitions

Schedule 2 — Categories of service providers

We use the following categories of service providers. Each processes data only on our instructions, under a written agreement. None of them can read your luach, which is encrypted on your device.

A list of our current providers by name, and the countries where they process data, is available on request from luachbracha@gmail.com.