Privacy Policy and Personal Data Protection Under Privacy Protection Law

Introduction

This website and platform is operated by Kidma (hereinafter: 'the Company'). The Company does everything in its power to protect users' privacy. Use of the website, services, and content contained therein indicates your consent as a user to this privacy policy.

Platform Roles and Data Responsibilities

Kidma is a SaaS platform that enables coaches to manage their coaching businesses. It is important to understand the different roles and data responsibilities:

• Kidma (Platform Provider): Kidma provides the technology platform and is the data controller for platform operation data (account information, technical data, billing). Kidma acts as a data processor for client data that coaches store on the platform.
• Coaches (Platform Customers):Coaches are Kidma's customers who use the platform to manage their coaching practice. Coaches are the data controllers for the personal information they collect about their own clients. Coaches are responsible for obtaining appropriate consent from their clients and for the lawful use of that data.
• Clients (End Users): Clients are the customers of coaches who use the platform to participate in coaching programs. Client data is collected and managed by their respective coach, with Kidma providing the technical infrastructure.

Coaches using this platform acknowledge that they are responsible for: obtaining proper consent from their clients for data collection, ensuring their use of client data complies with applicable privacy laws, informing their clients about how their data will be stored and processed, and responding to their clients' data access and deletion requests.

Information Collected

'Personal information' or 'information' is information that can be attributed to a person or entity that the user provided during registration and/or contact. The following information may be collected when using the platform:

• Account Information: Full name, email address, phone number, and login details when creating an account
• Profile Information: Profile picture, professional details, and preferences you provide
• Usage Data: Information about platform usage such as pages viewed, features used, time spent, and usage patterns
• Coaching Program Data: Content you create or upload, such as coaching programs, tasks, documents, notes, and correspondence with clients or coaches
• Communication Data: Messages, chat conversations with AI assistant, interactions between coaches and clients, and inquiries to the company
• Technical Data: IP address, browser type, operating system, device type, and other automatically collected information from computer or phone

Sensitive Information in Coaching Processes

Coaches on this platform may provide coaching services in various fields including but not limited to: business consulting, marketing, health and wellness, personal development, career coaching, and more. Depending on the coaching specialty, different types of sensitive information may be collected by coaches about their clients:

• Coaching Content: Information relating to the specific coaching topic, including goals, progress, challenges, and achievements shared during the coaching process
• Business and Professional Information: For business or marketing coaching: business strategies, financial goals, marketing plans, competitive information, or other professional data
• Health and Wellbeing Information: For health and wellness coaching: information related to physical health, nutrition, fitness, emotional state, or general wellbeing
• Personal Circumstances: Details about personal situation, relationships, career status, or other circumstances relevant to the coaching engagement

Special Protections for Sensitive Information: Kidma implements stringent technical protections for all data stored on the platform:

• Data encryption in transit and at rest
• Access limited only to the authorized coach and their respective clients
• Each coach's data is logically separated from other coaches' data
• Deletion of information upon user request or after termination of engagement
• Client data is not shared with third parties without explicit consent from the coach

Consent for Processing Information:Coaches: By using this platform, you consent to Kidma processing data on your behalf and acknowledge your responsibility as data controller for your clients' information. Clients: By participating in coaching programs on this platform, you consent to your coach collecting and processing your information as described in this policy and any additional terms provided by your coach.

Purposes of Information Collection

Personal information is used for the following purposes:

• Creating a user account and providing access to platform services
• Providing services, follow-up inquiries, and user support
• Sending marketing updates, professional content, and commercial offers (subject to user consent)
• Managing and improving user experience, enhancing services and content
• Enforcing terms of use, complying with legal requirements, and protecting against illegal activity
• Transferring information to authorities as required by law and fulfilling legal requirements or court orders applicable to the Company
• Statistical analysis (not personally identifying) for service improvement

User Rights and Implications of Non-Consent

There is no legal obligation on the user to provide information, and provision of information depends on their will and consent.

• Consent to Provide Information: Provision of information is voluntary but necessary for receiving services
• Non-Provision of Information:If you do not agree to provide the information, in whole or in part, services may not be provided in whole or in part at the Company's discretion
• Legitimate Interest:Processing necessary for the Company's legitimate interests while balancing your rights
• Legal Obligation: Processing necessary to comply with legal obligations, such as reporting to authorities or court orders

Sharing and Transfer of Information

The Company may transfer information to external suppliers and/or subcontractors for the purpose of providing services:

• Supabase: Database hosting, authentication, and file storage
• Vercel: Application hosting and analytics
• Resend: Business email delivery
• Anthropic: AI-powered coaching assistant

Information may be provided to analytical tools such as Google Analytics for website usage analysis. These tools may collect information such as IP address, approximate geographic location, and browsing patterns, but not names or other identifying information. The Company will cooperate with law enforcement authorities or any court order requiring disclosure of user identity or information. Client data stored by coaches will not be accessed by Kidma except as necessary to provide the service, for technical support at the coach's request, or as required by law.

Google User Data

If you choose to connect your Google Calendar to our platform, we access and use certain Google data in accordance with Google API Services User Data Policy.

Google Data We Access: When you authorize Google Calendar integration:

• Your Google account email address (for account linking and identification)
• Your basic profile information (name and profile picture)
• Read and write access to your Google Calendar events (to sync coaching sessions)
• Your Google user ID (for authentication and account management)

How We Use Google Data: We use your Google data solely for the following purposes:

• Linking your Kidma account to your Google account for seamless authentication
• Automatically adding coaching sessions and meetings to your Google Calendar
• Identifying your account when you sign in with Google
• Maintaining calendar sync via secure refresh tokens

Google Data Sharing and Protection: Your Google data is treated with the highest level of security:

• Google tokens are encrypted and stored securely
• Google data is used only for the calendar integration feature
• We never sell, share, or disclose your Google data to third parties

Google Data Storage and Security: We implement security measures to protect your Google data:

• All Google tokens are encrypted at rest in our database
• Access tokens are automatically refreshed as needed
• All communication occurs over encrypted HTTPS connections
• Row Level Security policies ensure your data is only accessible to your account

Google Data Retention and Deletion: You have full control over your Google data:

• We retain Google tokens only as long as the integration is connected
• You can disconnect Google Calendar at any time from account settings
• When you disconnect, we permanently delete all Google tokens
• Deleting your Kidma account will automatically delete all associated Google data

For questions about Google data usage, contact us at info@mentorway.ai or disconnect the integration from account settings.

Cookies

For proper operation of the website, 'cookies' are used for the following purposes:

• Maintaining your logged-in session and saving repeat login details
• Remembering your preferences and settings
• Statistical purposes about website usage
• Information security purposes

These are files that the user's device creates according to commands from the website's computers. Some will be deleted when the device is closed and some will be saved on the user's device. The user can delete or stop saving these files at any time by changing device settings. Disabling may prevent the use of some services and features on the website.

Security and Information Protection

The Company takes reasonable and industry-standard measures to protect the information provided:

• Data encryption in transit (HTTPS) and at rest
• Role-based access control and authentication
• Regular backups and disaster recovery procedures
• Continuous security monitoring and threat detection
• Vetting and monitoring of third-party service providers

However, no transmission or storage methods are completely secure, so the absolute security of information cannot be guaranteed. The Company does not guarantee that the website services will be completely immune from unauthorized access to stored information.

Data Breach Notification

In accordance with Amendment 13 to the Privacy Protection Law, in the event of a security breach affecting your personal information:

• We will notify you within 72 hours of becoming aware of the breach, if the breach is likely to cause significant harm to your privacy
• The notification will include the nature of the breach, the type of information affected, the steps we have taken, and recommended steps for your protection
• We will report to the Registrar of Databases as required by law
• We will immediately take steps to contain the breach and prevent further damage

If you believe your information has been compromised or have questions about data security, please contact us immediately at info@mentorway.ai.

Review, Correction, or Update of Information

The Company allows users to request to review information stored about them, to request its correction or deletion by contacting the email below.

• Right of Access: Request a copy of the personal information we hold about you
• Right to Correction: Request correction of inaccurate or incomplete personal information
• Right to Deletion: Request deletion of your personal information
• Right to Object: Object to the processing of your personal information in certain circumstances
• Right to Portability: Receive your personal information in a structured, readable format
• Right to Withdraw Consent: Withdraw your consent to information processing at any time

The Company may decline a request at its discretion and in accordance with legal provisions, including cases where the action would endanger proper operation of the website, harm other users, require unreasonable investment of resources, or require keeping information for legal defense.

To exercise your rights, please contact us at info@mentorway.ai.

Information Retention Period

Personal information will be retained only for the period necessary to fulfill the purposes of use, and will then be deleted. When you delete your account, we will permanently delete or anonymize your personal information within 90 days, unless we are required to retain it by law.

Where Information is Stored

Information is stored in the Company's database hosted by server hosting and backup providers (which may also be located abroad). Additional information is collected and stored by other companies (such as statistics companies, etc.). They may also store information outside the country. Your consent to this policy also constitutes consent to storing information abroad and transferring it outside the borders of Israel.

Minors' Privacy

The platform is not intended for individuals under the age of 18. We do not knowingly collect personal information from minors. If you believe we have collected information from a minor, please contact us immediately.

Communications and Notifications

The Company may send notifications via email/SMS or other messages about itself or its products and services. By accepting the terms of use (including this privacy policy), the user agrees to receive such commercial messages. The user may remove personal details from the mailing list and stop receiving future messages by using the unsubscribe option in each message or by sending an email to the above email address. The Company reserves the right to send messages related to services purchased or provided, including service and administrative messages without offering the option to cancel their receipt.

Changes to Privacy Policy

The privacy policy may change from time to time. If changes are made to the privacy policy that involve restriction of rights or different use of personal information, the updated policy will be published on the website.

Contact Us

For any question or issue related to this privacy policy or Kidma's data practices:

Email: info@mentorway.ai

Business Name: Kidma

Kidma is the data controller for platform operation data and acts as data processor for client data stored by coaches.

Clients: For questions about how your coach handles your personal information, please contact your coach directly. For questions about Kidma's platform and technical data practices, contact us at the email above.