Privacy Policy — Deloitte

Last updated: [date]

1. General

This Privacy Policy describes how [Deloitte legal entity name], company number [company number], of [address] ("Deloitte", "we", "the Company") collects, uses, retains and protects your personal information when you use the "Journey Through the Five Lands" service ("the Service"). We are committed to protecting your privacy in accordance with the Israeli Privacy Protection Law, 5741-1981 and its regulations, including Amendment 13.

Use of the Service constitutes consent to this Policy. If you do not agree, please refrain from using the Service.

2. What Information We Collect

Information you provide at registration: full name, nickname, organization, role, phone number, email address and gender.

Questionnaire information: your responses to the 134 statements in the questionnaire, and the personal readiness profile (the report) computed from them for each of the five lands and their components. This is personal information describing patterns of thought, emotion and behaviour that you self-reported.

Technical information (under Amendment 13): IP address, device identifiers and online identifiers, usage data and cookies. See the Cookie Notice.

3. Purposes of Use

• Creating an account, authentication at sign-in and password reset;
• Producing your personal report, analysing it and presenting the results;
• Operating, maintaining and securing the Service;
• Contacting you regarding the Service;
• Improving the model and the Service, wherever possible using aggregated/de-identified information that does not personally identify you.

4. Basis for Processing and Consent

Processing of the information relies on your informed, specific and freely given consent, provided at registration and before completing the questionnaire. Consent may be withdrawn at any time (see Section 8), as easily as it was given.

5. Sharing Information with Third Parties

We do not sell your personal information. We may share information with:

• Service providers (data processors) acting on our behalf and in accordance with our instructions — including hosting and database services ([Supabase]), email delivery and one-time verification codes (OTP), and similar — under appropriate data processing agreements;
• Where required by law, judicial order or a competent authority.

6. Transfer of Information Outside Israel

The information is stored in [storage region — e.g. the European Union]. To the extent information is transferred outside Israel, the transfer will be made only to a country with an adequate level of protection (such as the European Union), or under contractual safeguards, or in reliance on your consent.

7. Information Security

We apply organizational and technical security measures in accordance with the Israeli Privacy Protection Regulations (Information Security), 5777-2017, at the [basic / medium — to be determined by the information classification] security level, including access control, encryption, backup and event logging.

8. Your Rights

Under the Israeli Privacy Protection Law you have the following rights, and we will respond to your request within 30 days:

• Review of information about you (Section 13);
• Correction of information that is incorrect, incomplete, unclear or out of date (Section 14);
• Deletion of the information and the account;
• Withdrawal of consent (Section 8(c) of Amendment 13).

To make a request, contact [privacy officer email / request form in the Service].

9. Automated Decisions and Profiling

The personal report is produced automatically from your questionnaire responses. The report is intended for reflection and guidance only and does not constitute a diagnosis. In accordance with the principles of Amendment 13 and the guidance of the Israeli Privacy Protection Authority on artificial intelligence systems, we act transparently regarding how the report is produced, and you may contact a human representative for clarification.

10. Cookies and Local Storage

See the Cookie Notice, which details which cookies and local storage items are in use (including the storage of your accessibility preferences) and how to manage them.

11. Children's Privacy

The Service is intended for those aged [18] and over. We do not knowingly collect information from minors below this age without the consent of a lawful guardian.

12. Changes to this Policy

We may update this Policy from time to time. A material update will be published in the Service, and the "Last updated" date will change accordingly.

13. Contact / Privacy Officer

For any question or request regarding privacy: [officer name], [email], [address], [phone]. You may also contact the Israeli Privacy Protection Authority.

Draft basis only — requires review and approval by a privacy lawyer and completion of all bracketed details.