1. Introduction

ZmanLive ("we", "our" or "us") operates the synagogue website creation and management platform, as well as a WhatsApp assistance service. This Privacy Policy explains how we collect, use, disclose and protect your information when you use our services. This policy complies with the Israeli Privacy Protection Law of 1981 and the Privacy Protection Regulations (Data Security) of 2017, as well as the European Union General Data Protection Regulation (GDPR)

2. Information we collect

Personal information: • Name, email address, phone number • Synagogue information (name, address, denomination) • Payment information (securely processed via iCount, Google Play or the Apple App Store) • Website customization preferences • Photos and content you upload Information related to the WhatsApp service: • Your WhatsApp phone number • The content of the messages you send to our assistant • The voice notes you send to it • The images you send to it (logo, gallery photos, posters) • The technical identifier of your synagogue's WhatsApp group • Message timestamps and delivery status Automatically collected information: • IP address and browser information • Usage patterns and website interactions • Device and operating system information • Cookies and similar tracking technologies Third-party information: • Hebrew calendar data from HebCal API • Payment processing data from iCount • In-app purchase identifiers from Google Play and the Apple App Store • Website hosting data from Netlify

3. How we use your information

We use your information to: • Provide and maintain our website creation services • Process payments and manage subscriptions • Generate automated prayer times and Hebrew calendar features • Operate our WhatsApp assistant and answer your requests • Publish prayer times and announcements in your synagogue's WhatsApp group • Provide customer support and respond to requests • Send important service updates and notifications • Improve our services and develop new features • Comply with legal obligations Legal basis (GDPR compliance): • Performance of contract for service delivery • Legitimate interests for service improvement • Legal compliance for regulatory requirements • Consent for marketing communications

4. WhatsApp service

ZmanLive offers a conversational assistant reachable through WhatsApp, as well as automated publishing of prayer times in your synagogue's WhatsApp group. What goes through WhatsApp: • The messages you send to our assistant, and its replies • The voice notes and images you send to it • The prayer times, announcements and posters published in your synagogue's group How we identify a user: Your WhatsApp phone number is matched against the ZmanLive account it belongs to. A number that matches no account receives a refusal message, and its content is not processed beyond that check. Meta's role: WhatsApp is a service operated by Meta Platforms. Message delivery is handled by Meta, whose terms and privacy policy apply to that transport. We only have access to messages exchanged with our own business number and to your synagogue's group, never to your other conversations. Retention: Conversation content is kept for 90 days for support and troubleshooting purposes, then deleted. Technical delivery logs (date, send status, recipient) are kept for 12 months. How to opt out: You may at any time request disconnection from the WhatsApp group from your dashboard, remove our number from your contacts, or write to us at privacy@zman.live.

5. Artificial intelligence processing

Our WhatsApp assistant and some dashboard features rely on artificial intelligence models provided by third parties. What is sent, and to whom: • The text of your messages is sent to OpenAI to understand your request and compose a reply • Your voice notes are sent to Google (Gemini) to be transcribed into text • Images used for generating prayer time posters are sent to Google (Gemini) • The text you ask to translate (announcements, content) is sent to Anthropic (Claude) when you use automatic translation • The synagogue name is sent to Google (Gemini) to suggest a web address during sign-up • Posts on the Suggestions board are sent to DeepL to be translated into the other languages Purpose and legal basis: These operations serve solely to deliver the service you requested (performance of contract). No data is used for advertising purposes. Model training: We use these services through their business interfaces, in which submitted content is not used to train our providers' models. Automated decision-making: The assistant makes no decision producing legal effects concerning you. Any change it makes to your site follows an instruction you gave it, and remains editable from your dashboard. If you would rather your content not be processed by these providers, do not use the WhatsApp assistant or automatic translation: prayer times, announcements and your site remain fully editable by hand from the dashboard.

6. Congregant and third-party data

Some of the data we process concerns not our customers but third parties, in particular: • Members of the synagogue's WhatsApp group, who receive the published times and announcements • People who submit a hall rental request from a synagogue's public website (name, email, phone, requested dates) • Names appearing in memorial messages published by the synagogue Allocation of responsibilities: The customer synagogue is the data controller for the data it publishes and for the composition of its WhatsApp group. ZmanLive acts as a processor for these operations. It is the synagogue's responsibility to inform its members of the automated publishing of prayer times and, where applicable, to obtain their consent. If you are affected by one of these processing activities and wish to exercise your rights, write to privacy@zman.live: we will forward your request to the synagogue concerned and act on it within the statutory deadlines.

7. Your GDPR Rights

In accordance with GDPR, you have the following rights: Right of access: You can request a copy of your personal data. Right to rectification: You can correct inaccurate data. Right to erasure: You can request deletion of your data. Right to portability: You can receive your data in a structured format. Right to object: You can object to the processing of your data. Right to restriction: You can restrict the processing of your data. To exercise these rights, contact us at privacy@zman.live

8. Data Retention

We retain your personal data only for as long as necessary for the purposes for which it was collected: • Account data: As long as your account is active • Payment data: According to legal requirements (7 years) • WhatsApp conversations: 90 days • WhatsApp technical delivery logs: 12 months • Browsing data: 2 years maximum • Cookies: According to the cookie policy After your account is deleted, some data may be retained for legal or security reasons.

9. Data Security

We implement appropriate security measures to protect your data: • Encryption of data in transit and at rest • Restricted access to personal data • Continuous system monitoring • Secure backups • Staff training on data protection Data breach notification: In the event of a data breach affecting your personal information, we commit to: 1. Notify affected users within 72 hours 2. Report the incident to the relevant supervisory authorities 3. Provide details of the breach and the corrective measures taken 4. Zman administrators will provide updates within the following 72 hours

10. Data Transfers and Processors

Your data may be transferred to the following providers, acting as processors: Infrastructure and hosting: • Supabase (database, authentication) - European Union • Netlify (website hosting) - United States • Backblaze B2 (image storage) - United States • Coolify / private server (n8n automations) - European Union Messaging: • Meta Platforms — WhatsApp Business Platform (message delivery) - United States Artificial intelligence: • OpenAI (understanding and composing the assistant's replies) - United States • Google — Gemini (voice note transcription, poster generation) - United States • Anthropic — Claude (automatic translation of content) - United States • DeepL (translation of Suggestions board posts) - Germany Payments: • iCount (web billing and payment) - Israel • Google Play Billing (Android in-app purchases) - United States • Apple App Store (iOS in-app purchases) - United States Other services: • HebCal (Hebrew calendar) - United States • Google (analytics) - United States All transfers to third countries are carried out with appropriate safeguards in accordance with GDPR (standard contractual clauses, adequacy decisions). This list is updated whenever a provider changes.

11. Cookies and Tracking Technologies

We use cookies and similar technologies to: • Ensure the website functions properly • Analyze site usage • Personalize the user experience • Improve our services You can control the use of cookies through your browser settings. Consent to non-essential cookies can be withdrawn at any time.

12. Consent and Withdrawal

Your consent is required for the processing of certain personal data. You can withdraw your consent at any time by: • Changing your privacy settings in your account • Contacting us directly at privacy@zman.live • Using the unsubscribe links in our emails • Requesting disconnection from your synagogue's WhatsApp group Withdrawing consent does not affect the lawfulness of processing carried out before the withdrawal.

13. Deleting your account and your data

You may request the deletion of your account and associated data at any time. From your account: Sign in, open "My personal data", then request deletion of your account. Without signing in: Send an email to privacy@zman.live from your account's email address, with the subject "Delete my data". We may ask you for a confirmation in order to verify your identity. Timeframe: your request is processed within 30 days. What is deleted: your account, your website content, your images, your prayer times, your WhatsApp conversations and the connection to your synagogue's group. What is retained, and why: invoices and payment records are kept for 7 years under Israeli accounting and tax obligations. A public page detailing this procedure is available at zman.live/data-deletion

14. Changes to this Policy

We may update this privacy policy from time to time. Significant changes will be notified by: • Email to the address associated with your account • Notification on our website • Updating the "Last updated" date We encourage you to review this policy regularly.

15. Contact and Complaints

For any questions regarding this policy or your GDPR rights: Data Controller: ZmanLive Ltd. Email: privacy@zman.live Phone: +972-54-545-4367 Data Protection Officer: Email: admin@zman.live DPO Contact: admin@zman.live Supervisory Authority: For complaints regarding data processing, you may contact the Israeli Privacy Protection Authority: Website: www.gov.il/privacy Phone: *3071