DRAFT prepared for legal review, not a policy.

# Israeli Privacy Protection Law: data handling (draft)

Prepared 2026-09-19 for review by Israeli counsel. Nothing here is legal advice,
and Limud makes no claim of compliance with Israeli law until counsel has
reviewed this draft. No Israeli-law text is published on the site today; this
draft exists so that the gap is visible rather than assumed away.

## 1. Purpose of processing

Limud processes personal data of students, teachers and parents for one purpose:
delivering teaching material, practice and feedback inside an educational
institution that has engaged Limud, or inside a family account an adult has
opened.

## 2. Roles

Where a school or network engages Limud, the school is the owner of the database
and Limud is the holder acting on its instructions. For a family or individual
learner account, Limud is the owner of that database.

## 3. Categories of data

- Identity: name, email, role, class membership.
- Educational content: uploaded material, submissions, scores, teacher feedback,
  and per-student versions of teaching material.
- Audio recordings and photographs of work, where the teacher has enabled them.
- AI tutor conversations.
- Product telemetry limited to open, heartbeat and close events with the
  sections on screen.

## 4. Sensitive data

Wellbeing check-in notes may indicate a child's emotional state. They are
visible to the staff the school designates, are redacted 45 days after the
check-in or 14 days after a flag is resolved, and are excluded from the signals
that shape a personalised version.

## 5. Security and access

- Access to a personalised version or an AI tutor conversation by a member of
  staff writes an audit row naming who read what and when.
- Role separation is enforced at the edge and again in every handler.
- Sessions end after a period of inactivity.

## 6. Data subject rights

Access, correction and deletion requests are answered through the school where
the school is the owner, and directly where Limud is.

## 7. Transfer abroad

Data is processed and stored in the United States. See the data residency draft
in this packet.

## 8. Open items for counsel

1. Confirm the owner and holder designations above for the school channel and
   for the family channel, and whether a database registration obligation
   applies.
2. Confirm the lawful basis and the notice wording required at the point a
   student account is created by a class code.
3. Confirm the transfer-abroad basis under the Privacy Protection Regulations
   and what the notice must say.
4. Confirm the treatment of wellbeing notes, and whether they fall within the
   more sensitive categories and require a separate consent.
5. Confirm the Hebrew wording of every notice. The product's Hebrew copy has not
   been reviewed by a lawyer.