IRON LOGIC - PRIVACY POLICY
How Iron Logic Ltd. collects, uses, shares and protects personal data
Iron Logic | Version 1.0 | Effective date: 23 September 2026
Summary. Iron Logic . is the controller of the personal data collected through ironlogic.co.il. We collect the data you give us, such as enquiries, bookings, newsletter sign-ups, comments, chatbot messages and job applications, together with technical data collected automatically through cookies and similar technologies. We use it to respond to you, deliver and invoice our services, send marketing only with your consent, and operate, secure and improve the Website. We use only necessary cookies unless you consent to others through our cookie banner. We do not sell personal data for money. Depending on where you are, you have rights of access, correction, deletion, objection and more (Clause 14). Contact: info@ironlogic.co.il.
1 INTRODUCTION AND SCOPE
1.1 This Privacy Policy explains how Iron Logic / Elad Hozainov. (“Iron Logic”, “we”, "us" or “our”) processes personal data in connection with the website at https://ironlogic.co.il (the “Website”). It covers the Website’s contact, booking, payment, newsletter, comment, download, chatbot and careers features, and the related communications, services and social-media and advertising activities.
1.2 This Privacy Policy is issued in accordance with the following laws, to the extent that each applies:
(a) the Israeli Privacy Protection Law, 5741-1981, as amended (including by Amendment No. 13), and the Privacy Protection (Data Security) Regulations, 5777-2017 (together, “Israeli Privacy Law”);
(b) Regulation (EU) 2016/679 (the “GDPR”) and, for the United Kingdom, the UK GDPR and the Data Protection Act 2018;
(c) the German Telecommunications Digital Services Data Protection Act (“TDDDG”) and equivalent EU ePrivacy rules on cookies;
(d) applicable United States state privacy laws, including the California Consumer Privacy Act as amended by the California Privacy Rights Act (“CCPA”); and
(e) the Canadian Personal Information Protection and Electronic Documents Act (“PIPEDA”) and, for Québec, the Act respecting the protection of personal information in the private sector (“Law 25”).
1.3 This Privacy Policy forms an integral part of our Terms and Conditions, available at https://ironlogic.co.il. Capitalised terms not defined in this Privacy Policy have the meaning given in the Terms and Conditions.
1.4 This Privacy Policy does not apply to third-party websites or services linked from, or embedded in, the Website. Those are governed by their operators’ own privacy policies (see Clause 19).
2 CONTROLLER AND PRIVACY CONTACT
2.1 The controller responsible for the processing of your personal data (the “database owner” under Israeli Privacy Law) is:
Controller
Iron Logic Ltd.
Address
Harav Yeshayahu Meshorer 20
Petach Tikva 4931927
Israel
Privacy contact
Elad Hozainov
info@ironlogic.co.il
+972 54 428 7018
2.2 Elad Hozainov is the person responsible for privacy matters at Iron Logic. For the purposes of Québec Law 25, he is the person in charge of the protection of personal information. You may contact him about any matter relating to this Privacy Policy or to your personal data.
3 DEFINITIONS
3.1 In this Privacy Policy, the following definitions apply:
(a) “personal data” means any information relating to an identified or identifiable natural person. It includes “personal information” and “information about a person” as those terms are defined in applicable law;
(b) “processing” means any operation performed on personal data, such as collection, recording, storage, use, disclosure, transfer and deletion; and
(c) “processor” or “service provider” means a third party that processes personal data on our behalf and under our instructions.
4 PERSONAL DATA WE COLLECT
4.1 Data you provide to us. We collect the personal data that you choose to provide, as follows:
Source / Personal data
Contact and enquiry forms
Name, company name, job title, email address, telephone number, country, and the content of your enquiry and any attachments
Bookings and payments
Name, company name, billing address, VAT or company registration number, email, telephone, selected service, date and time, and booking notes. Payment-card data is entered directly into the payment processor’s secure environment. We receive only a transaction confirmation, the payment method type, the last four digits of the card and the transaction reference
Newsletter
Email address, name, company (optional), consent record (date, time, source and confirmation) and subscription preferences
Comments
Display name, email address (not published), comment content and posting date
AI chatbot
Messages you type, and any contact details you choose to share in the conversation
Downloadable Materials
Name, email, company and the material downloaded (where a form precedes a download)
Job applications
Name, contact details, CV, cover letter, employment and education history, qualifications, references, salary expectations and any other information you include
Correspondence
The content of emails, WhatsApp messages, calls and meeting notes, and your communication preferences
4.2 Data collected automatically. When you use the Website, we and our service providers automatically collect the following, subject to your cookie choices (Clause 7):
(a) IP address and approximate location (country or city level);
(b) device type, operating system, browser type and language, and screen resolution;
(c) the pages you visit, time spent, clicks and scrolling, the referring website, and search terms used to reach the Website;
(d) cookie and advertising identifiers, and campaign parameters (UTM); and
(e) the date and time of access, error logs and security events.
4.3 Data from third parties. We may receive personal data about you from the following sources:
(a) payment processors: payment status and transaction data;
(b) advertising and social-media platforms: aggregated campaign reports and, where you interact with our advertisements or lead forms on those platforms, the data you submit there;
(c) professional networking platforms and public sources, such as company websites and business registries: business contact information; and
(d) people who refer you to us, and your employer when it engages us for a project.
4.4 Special categories of data. We do not intentionally collect special categories of personal data. These include data concerning health, racial or ethnic origin, political opinions, religious beliefs, trade-union membership, biometric or genetic data, sex life or sexual orientation, and criminal records. Please do not include such data in any form, comment, chatbot conversation or job application unless it is strictly necessary and we have asked for it.
5 PURPOSES AND LEGAL BASES FOR PROCESSING
5.1 We process personal data for the purposes set out below. Where the GDPR or UK GDPR applies, we rely on the legal bases indicated:
Purpose / Legal basis (GDPR Art. 6(1))
Responding to enquiries and providing requested information
(b) steps prior to entering into a contract; (f) legitimate interest in responding to business enquiries
Processing Bookings, delivering Paid Services and managing the client relationship
(b) performance of a contract
Processing payments, issuing invoices and keeping accounting and tax records
(b) performance of a contract; (c) legal obligation
Sending the Newsletter and other advertising messages
(a) consent
Publishing and moderating comments
(b) performance of the Terms; (f) legitimate interest in maintaining a lawful and respectful platform
Operating the AI chatbot
(f) legitimate interest in providing instant assistance; (b) where the chat leads to an enquiry or Booking
Providing Downloadable Materials
(b) performance of a contract (the download licence)
Evaluating job applications
(b) steps prior to entering into an employment contract; (a) consent for retention in our talent pool
Website analytics and performance measurement
(a) consent
Advertising, remarketing and conversion measurement
(a) consent
Operating the Website, strictly necessary cookies, security, fraud and abuse prevention
(f) legitimate interest in a secure and functional Website; (c) legal obligation (data security)
Establishing, exercising or defending legal claims, and responding to lawful requests from authorities
(c) legal obligation; (f) legitimate interest in protecting our rights
Business administration, and any restructuring, merger or sale of the business
(f) legitimate interest
5.2 Where we rely on legitimate interests, we have balanced them against your interests and fundamental rights. You may ask us for details of that balancing test.
5.3 Where we rely on consent, you may withdraw it at any time, with effect for the future. Withdrawal does not affect the lawfulness of processing carried out before it.
5.4 We will not use personal data for a purpose that is incompatible with the purposes above without first informing you and, where required, obtaining your consent.
6 IS PROVIDING PERSONAL DATA MANDATORY?
6.1 You are under no legal obligation to provide us with personal data. Whether you provide it depends on your free will and consent. However, certain data, marked as mandatory in the relevant form, is required to respond to an enquiry, complete a Booking, issue a tax invoice, subscribe you to the Newsletter or consider a job application. If you do not provide that data, we will not be able to provide the requested feature or service. This statement is made in accordance with Section 11 of the Israeli Privacy Protection Law.
7 COOKIES AND SIMILAR TECHNOLOGIES
7.1 Cookies are small text files stored on your device. Similar technologies include pixels, tags, local storage and software development kits. We use them in the following categories:
Category / Purpose / Providers / Consent?
Strictly necessary
Website operation, security, load balancing, booking and payment functions, and storing your consent choices
Wix, Usercentrics, Google reCAPTCHA, payment processors
No (exempt)
Functional
Remembering preferences, embedded videos and maps, WhatsApp chat, AI chatbot and accessibility settings
Wix, YouTube, Vimeo, Google Maps, WhatsApp, AccessEZ, AI chatbot providers
Yes
Analytics
Measuring traffic and usage, and improving the Website
Google Analytics 4, Wix Analytics
Yes
Marketing
Advertising, remarketing, audience building and conversion measurement
Meta (Facebook and Instagram), LinkedIn, Google Ads, Microsoft Advertising, TikTok, X
Yes
7.2 Consent management. Consent is managed through the Usercentrics consent-management platform (Usercentrics GmbH, Germany). On your first visit, non-essential cookies and technologies are blocked until you give consent. You may accept all, reject all or choose by category or provider. You can change or withdraw your consent at any time through the “Cookie Settings” link in the footer of every page. Where available, we use Google Consent Mode, so that Google tags adjust their behaviour to your consent choices.
7.3 Under Section 25 of the TDDDG and equivalent laws, cookies and similar technologies that are not strictly necessary are used only on the basis of your consent. Any subsequent processing of the data collected is based on the legal bases in Clause 5.
7.4 You can also block or delete cookies through your browser settings. Blocking strictly necessary cookies may prevent parts of the Website, including Bookings and payments, from working properly.
7.5 The Usercentrics banner shows up-to-date details of each cookie and technology used, including its provider, purpose and duration.
8 AI CHATBOT
8.1 You are communicating with an AI. The Website offers an automated chat assistant powered by large language models provided by Google (Gemini), Anthropic (Claude) and OpenAI. It is an artificial-intelligence system, not a human.
8.2 The messages you type are transmitted to the relevant AI provider to generate a response. We use these providers’ business (API) services, not their consumer applications. Where such settings are available, we select settings that restrict the provider’s use of chatbot data for training its models.
8.3 Chatbot answers may be inaccurate or incomplete. They are not professional advice (see Clause 4 of the Terms and Conditions). Do not enter confidential, sensitive or special-category information into the chatbot.
8.4 Chat transcripts may be reviewed by us to answer your enquiry, and to improve the chatbot and our services. They are retained as set out in Clause 12. The chatbot does not make any decision that produces legal or similarly significant effects for you.
9 NEWSLETTER AND DIRECT MARKETING
9.1 We send the Newsletter and other advertising messages by email, SMS or messaging applications only with your express prior consent, in accordance with Section 30A of the Israeli Communications (Telecommunications and Broadcasting) Law, 5742-1982, the GDPR, Section 7 of the German Act against Unfair Competition (UWG), the Canadian Anti-Spam Legislation (CASL) and the US CAN-SPAM Act. We may use a double opt-in procedure, in which you confirm your subscription by clicking a link sent to your email address.
9.2 Newsletters are sent using Mailchimp, ActiveTrail, Rav-Meser or monday.com. These services may record whether a message was delivered and opened, and which links were clicked, so that we can measure the effectiveness of our communications. You can object to this tracking by unsubscribing, or by disabling images in your email client.
9.3 You may unsubscribe at any time, free of charge, by clicking the “unsubscribe” link in any message or by writing to info@ironlogic.co.il. Under Section 17F of the Israeli Privacy Protection Law, you may also request that your data be deleted from any database used for direct mailing. We keep a minimal suppression record (your email address and the date you opted out) solely to ensure that we do not contact you again.
10 DISCLOSURE OF PERSONAL DATA
10.1 We do not sell your personal data for money. We disclose personal data only to the extent necessary, to the following categories of recipients:
Category / Recipients / Purpose / Location
Website platform and hosting
Wix.com Ltd. (including Wix Bookings, Wix Payments, Wix Analytics, Wix comments and forms)
Hosting, forms, bookings, comments, analytics
Israel; servers in the US, EU and other regions
CRM
monday.com Ltd.
Lead, client and project management
Israel; servers in the EU and US
Newsletter and email marketing
Intuit Inc. (Mailchimp); ActiveTrail Ltd.; Rav-Meser; monday.com Ltd.
Sending newsletters and marketing emails
US; Israel
Payment processing
Wix Payments, Stripe, PayPal, Cardcom, Tranzila, Grow (Meshulam), PayPlus
Processing payments, fraud prevention
Israel; EU; US
Analytics
Google (Google Analytics 4); Wix Analytics
Traffic and usage measurement
US; EU
Advertising
Meta Platforms; LinkedIn; Google (Google Ads); Microsoft (Microsoft Advertising); TikTok; X Corp.
Advertising, remarketing and conversion measurement
EU (Ireland); US; other
Embedded content and communication
Google (YouTube, Google Maps, reCAPTCHA); Vimeo Inc.; WhatsApp (Meta)
Videos, maps, spam protection, chat
US; EU
AI chatbot
Google (Gemini); Anthropic PBC (Claude); OpenAI
Generating chatbot responses
US; EU
Consent and accessibility
Usercentrics GmbH; AccessEZ
Consent management; accessibility tools
Germany (EU); other
Professional advisers
Accountants, auditors, lawyers and insurers
Accounting, tax, legal and insurance
Israel; other as needed
Authorities
Courts, tax authorities, regulators and law enforcement
Compliance with law or a binding order
As required
Business transferees
A purchaser, successor or merger partner
Restructuring, merger or sale of the business
As applicable
10.2 Our processors may process personal data only on our documented instructions and under written data-processing terms. These terms include confidentiality and security obligations, as required by Article 28 of the GDPR and by Regulation 15 of the Israeli Data Security Regulations.
10.3 Some recipients, in particular advertising platforms and embedded-content providers, act as independent controllers or joint controllers for part of the processing. Where Iron Logic and Meta Platforms Ireland Limited are joint controllers for data collected by the Meta Pixel, Meta’s Controller Addendum applies, and Meta is responsible for handling your data-subject rights for its own processing. The privacy policies of these providers describe their processing.
10.4 Public information. Comments you post are publicly visible, together with your display name.
10.5 United States: “sharing”. Our use of advertising cookies and pixels may constitute “sharing” for cross-context behavioural advertising, or “targeted advertising”, under certain US state laws. You may opt out as described in Clause 14.5.
11 INTERNATIONAL TRANSFERS
11.1 Iron Logic is established in Israel. The European Commission has recognised Israel as providing an adequate level of data protection, so transfers of personal data from the EU or EEA to Iron Logic in Israel do not require additional safeguards (GDPR Art. 45).
11.2 Some of our service providers process data in countries outside Israel and the EU or EEA, in particular the United States. Where the GDPR or UK GDPR applies, such transfers are made on one of the following bases:
(a) the EU-US Data Privacy Framework and its UK extension, where the recipient is certified;
(b) the European Commission’s Standard Contractual Clauses, or the UK International Data Transfer Addendum, together with supplementary measures where required; or
(c) another lawful transfer mechanism under Chapter V of the GDPR.
11.3 Transfers of personal data from Israel abroad are made in accordance with the Privacy Protection (Transfer of Data to Databases Abroad) Regulations, 5761-2001.
11.4 You may request information about the safeguards that apply to a transfer, and a copy of them, by contacting us under Clause 2.
12 DATA RETENTION
12.1 We keep personal data only for as long as necessary for the purposes for which it was collected, or as required by law. When the relevant period ends, the data is deleted or anonymised. The retention periods are as follows:
Data / Retention period
Enquiries that do not lead to an engagement
24 months from the last contact
Client, Booking, payment and invoicing records
7 years from the end of the tax year concerned, under Israeli tax and bookkeeping requirements, or longer where required by law or for a pending claim
Newsletter subscriber data
Until you unsubscribe or withdraw consent; a suppression record is then kept indefinitely
Comments
For as long as the comment is published, and removed on request or at our discretion
AI chatbot transcripts
12 months from the conversation, unless the conversation becomes part of an enquiry or engagement
Job applications (unsuccessful)
24 months from the end of the recruitment process, or longer with your consent to our talent pool
Job applications (successful)
Transferred to the employee file, and retained under employment-law requirements
Analytics and advertising data
According to the retention settings and policies of the respective provider (for example, Google Analytics 4 and advertising platforms)
Server and security logs
According to the retention policies of Wix and our other service providers
Consent records
For the duration of the consent, plus the applicable limitation period
12.2 We may keep personal data for longer where it is needed to establish, exercise or defend legal claims, until those claims are finally resolved.
13 DATA SECURITY
13.1 We implement appropriate technical and organisational measures to protect personal data against unauthorised access, loss, alteration, disclosure and destruction, in accordance with the Israeli Data Security Regulations and Article 32 of the GDPR. These measures include:
(a) TLS encryption of the Website;
(b) role-based access controls and multi-factor authentication for systems holding personal data;
(c) use of reputable processors with recognised security certifications;
(d) PCI-DSS-compliant payment processing, with no storage of full card data by Iron Logic; and
(e) confidentiality obligations for all persons with access to personal data.
13.2 No method of transmission or storage is completely secure, and we cannot guarantee absolute security. If a data-security incident is likely to result in a risk to your rights, we will notify the competent supervisory authority and, where required, you, within the periods required by law.
14 YOUR RIGHTS
14.1 All users. Subject to applicable law, you may:
(a) access the personal data we hold about you and receive a copy of it;
(b) request correction of inaccurate or incomplete data;
(c) request deletion of your data;
(d) withdraw any consent you have given; and
(e) unsubscribe from marketing at any time.
14.2 Israel. You have the right to inspect information about you held in a database (Section 13 of the Privacy Protection Law), and to request its correction or deletion if it is incorrect, incomplete, unclear or out of date (Section 14). You also have the right to be removed from any database used for direct mailing (Section 17F). If we refuse a request for correction, you may appeal to the competent court as provided by law.
14.3 EU, EEA and UK. In addition to the rights above, you have the right to:
(a) restrict processing (Art. 18);
(b) data portability (Art. 20);
(c) object at any time to processing based on legitimate interests (Art. 21(1)), and to processing for direct marketing (Art. 21(2)); and
(d) not be subject to a decision based solely on automated processing that produces legal or similarly significant effects (Art. 22). We do not carry out such decision-making.
14.4 Right to object. Where we process your data on the basis of legitimate interests, you may object on grounds relating to your particular situation. We will then stop processing unless we demonstrate compelling legitimate grounds, or the processing is needed for legal claims. You may object to direct marketing at any time without giving reasons.
14.5 United States. Depending on your state of residence, you may have the right to:
(a) know and access the categories and specific pieces of personal information we have collected;
(b) request deletion and correction;
(c) opt out of the “sale” or “sharing” of personal information and of targeted advertising;
(d) limit the use of sensitive personal information (which we do not collect intentionally); and
(e) not be discriminated against for exercising your rights.
14.6 To opt out of sharing and targeted advertising, reject marketing cookies in the Usercentrics “Cookie Settings” or email info@ironlogic.co.il. We honour recognised opt-out preference signals, such as Global Privacy Control, where our consent platform supports them. We do not knowingly sell or share the personal information of individuals under 16. You may use an authorised agent to submit a request, subject to verification.
14.7 Canada. You have the right to access and correct your personal information and to withdraw consent, subject to legal and contractual restrictions. Residents of Québec also have the right to data portability, and to be informed of and object to technologies that identify, locate or profile them. These technologies are disabled by default on the Website unless you consent to them.
15 HOW TO EXERCISE YOUR RIGHTS
15.1 To exercise any of your rights, contact us at info@ironlogic.co.il or by post to the address in Clause 2. Please state the right you wish to exercise and provide enough information for us to identify you and locate your data.
15.2 We may ask you to verify your identity before acting on a request, to protect your data from unauthorised access. We will respond within the period required by applicable law. That is generally within one month under the GDPR, which may be extended where permitted, and within the periods set by Israeli Privacy Law and US state law.
15.3 Requests are free of charge. However, we may charge a reasonable fee, or refuse to act, where a request is manifestly unfounded or excessive, as permitted by law.
16 COMPLAINTS
16.1 If you are not satisfied with how we have handled your personal data, please contact us first, so that we can try to resolve the matter. You also have the right to lodge a complaint with a supervisory authority, including:
(a) in Israel: the Privacy Protection Authority (Ministry of Justice);
(b) in the EU or EEA: the data protection supervisory authority of your habitual residence, place of work or place of the alleged infringement;
(c) in the United Kingdom: the Information Commissioner’s Office (ICO);
(d) in Canada: the Office of the Privacy Commissioner of Canada or, in Québec, the Commission d’accès à l’information; and
(e) in the United States: the attorney general or privacy agency of your state, including the California Privacy Protection Agency.
17 CHILDREN
17.1 The Website is directed at Business Users and is not intended for anyone under 18. We do not knowingly collect personal data from anyone under 18. If you believe that a minor has provided us with personal data, please contact us and we will delete it.
18 JOB APPLICANTS
18.1 If you apply for a position through the Website or by email, we use your application data only to assess your suitability, communicate with you and comply with legal obligations. Access is limited to the persons involved in the recruitment process.
18.2 We may contact the references you provide, after first informing you. We will ask for your consent before retaining your application in our talent pool for future opportunities. You may withdraw that consent at any time.
19 THIRD-PARTY WEBSITES AND SERVICES
19.1 The Website contains links to, and embedded content from, third-party websites and services, such as YouTube, Vimeo, Google Maps, WhatsApp and social-media platforms. When you interact with them, the third party may collect data about you under its own privacy policy. We are not responsible for third-party privacy practices, and we encourage you to read their policies.
20 CHANGES TO THIS PRIVACY POLICY
20.1 We may update this Privacy Policy from time to time, for example to reflect changes in our processing, service providers or applicable law. The updated version will be published on the Website with a new effective date. Where changes are material, we will provide additional notice, for example a notice on the Website or an email to Newsletter subscribers, and will obtain your consent where required by law.
21 LANGUAGE AND CONTACT
21.1 This Privacy Policy is drawn up in English. The English version is the only binding version.
21.2 For any question, request or complaint regarding this Privacy Policy or your personal data, please contact:
Commercial Name: Iron Logic.
Privacy contact: Elad Hozainov
Address: Harav Yeshayahu Meshorer 20, Petach Tikva 4931927, Israel
Email: info@ironlogic.co.il
Telephone: +972 54 428 7018
Website: https://ironlogic.co.il
— End of Privacy Policy —