Privacy Policy, Terms of Use & Disclaimer

2.1 Types of Data Collected

When using the website, certain information may be collected, including:

• Name and email address voluntarily provided, for example when subscribing to a newsletter
• Name or nickname, email address, and content provided when posting a comment
• IP address
• Browser, operating system, and device type data
• Usage data and browsing statistics
• Cookies and similar digital identifiers

2.2 Provision of Data and Consent

Providing information to the website owner is entirely voluntary. Users are under no legal obligation to provide any information, and declining to do so will not prevent them from browsing the website and reading its content.

Providing a name and email address in order to subscribe to the newsletter is based on the user’s explicit consent, given through an affirmative action in the subscription form. Consent may be withdrawn at any time.

A user who posts a comment does so voluntarily and with the knowledge that the comment, including the name or nickname provided alongside it, will be displayed publicly and visible to all.

2.3 Purposes of Data Use

Collected data will be used solely for the following purposes:

• Sending updates and content to subscribers who signed up voluntarily
• Displaying, managing, and moderating comments
• Operating, maintaining, and improving the website
• Statistical analysis of activity and user traffic
• Information security and protection against unauthorized use

The data will not be used for any purpose not listed above, except with the user’s separate consent or as required by law.

2.4 Transfer of Data to Third Parties

The website relies on external service providers for hosting, mailing, data analysis, and technical operation. As of the date this document was updated, these are the following services:

• Hosting and content delivery: GitHub Pages, operated by GitHub, Inc.
• Domain management and basic traffic measurement: Cloudflare, Inc. (DNS services and Cloudflare Web Analytics)
• Traffic measurement and analytics: Google Analytics, operated by Google LLC
• Content-page interaction measurement: Carried out on the website owner’s own servers (Cloudflare Workers), with no data passed to a third party
• Mailing and distribution list: Resend, operated by Resend, Inc.
• Bot verification on the signup form: Cloudflare Turnstile, operated by Cloudflare, Inc.
• Comments system: Disqus, operated by Disqus, Inc.

The comments system is operated by an external provider, which collects and processes the information submitted through it as an independent controller and in accordance with its own privacy policy. A user wishing to post a comment may be required to hold an account with that provider. The website owner has no control over how the provider collects, stores, or uses this information.

These providers may process and store data outside the borders of the State of Israel, including in countries whose level of protection for personal data differs from that applied in Israel. Their processing of the data is subject to their own privacy policies and to the laws applicable to them.

Data will be transferred to additional parties only where there is a legal obligation to do so, or in order to protect the website owner’s rights in legal proceedings.

The website owner does not sell, rent, or trade in personal data.

In the event of a transfer of ownership of the website or its operations to another party, the website owner may transfer the collected data to that party, provided that the recipient assumes the obligations set out in this document toward users. Notice of such a transfer will be published on the website.

2.5 Data Retention and Security

Data will be retained for as long as necessary for the purposes for which it was collected or as required by law. Newsletter subscriber data will be deleted within a reasonable time after an unsubscribe request. Published comments will be retained for as long as they are displayed on the website, subject to the right of deletion under section 2.6.

The website owner applies reasonable security measures appropriate to the nature and scope of the data. However, complete immunity from intrusion, technical failure, or unauthorized use cannot be guaranteed.

In the event of a severe security incident as defined in the Protection of Privacy Regulations (Data Security), 5777-2017, the website owner will act to address and report it in accordance with the applicable legal requirements.

2.6 User Rights

Under the Protection of Privacy Law, 5741-1981, users have the following rights:

• Unsubscribing from the mailing list - via the unsubscribe link included in every mailing, or by contacting the email address in section 1
• Reviewing the personal data held about them
• Correcting data that is inaccurate, incomplete, unclear, or out of date
• Deleting personal data to the extent permitted by law
• Deleting a comment they posted, by contacting the email address in section 1

Requests on these matters should be sent to the email address in section 1. A response will be provided within a reasonable time and in accordance with the periods prescribed by law.

A user who believes their rights under the Protection of Privacy Law have been infringed may file a complaint with the Privacy Protection Authority at the Ministry of Justice.

2.7 Minors

The website is not intended for minors and does not knowingly collect personal data about anyone under the age of 18. If the website owner becomes aware that such data has been collected, it will be deleted.

2.8 Cookies

The website uses cookies and similar technologies. Types of cookies:

• Essential - required for the basic functioning and security of the website. These do not require consent.
• Measurement and analytics - used to understand usage patterns in aggregate form (Google Analytics).
• Comments - placed by the comments system provider in order to identify the user and display comments.

Non-essential cookies are placed on the basis of user consent. Consent may be changed or withdrawn at any time.

Basic traffic measurement on the website is carried out using a tool that does not place cookies, does not store information on the user’s device, and does not identify users over time. This measurement does not require consent. More detailed measurement, which is cookie-based, is carried out only subject to consent as stated above.

In addition, the website independently measures basic interactions on content pages, such as scroll depth within a post, clicks on outbound links, copying a code snippet, and use of the share buttons. This measurement is carried out on the website owner’s own servers, places no cookies, stores no information on the user’s device, creates no user or visit identifier, and does not retain the IP address. The data is kept in aggregate form only and is deleted automatically after 90 days. This measurement does not require consent.

The comments system is not loaded at all without an action by the user. It can be activated in two ways: by granting consent to non-essential cookies, which is saved for future visits, or by loading the comments once for that visit only, which is not saved and does not constitute ongoing consent. Withdrawing consent stops the system from loading.

Cookies can also be blocked or deleted through browser settings. Blocking them may affect the functioning of the website.

3.1 Permitted Use

Use of the website is permitted for personal and lawful purposes only. Users undertake not to use the website in any manner that violates any law, infringes third-party rights, or disrupts the operation of the website.

3.2 Comments and User Content

General. The website allows users to post comments on the content published on it. Posting a comment constitutes agreement to the terms set out in this section.

Poster responsibility. Full responsibility for the content of a comment, including its substance, accuracy, and legal implications, rests solely with the user who posted it. Comments do not reflect the position of the website owner, and their publication does not constitute agreement, approval, or verification on their part.

Prohibited content. Comments must not include, among other things:

• Defamation, slander, or harm to reputation
• Incitement, threats, harassment, or hate speech
• Content that infringes a person’s privacy, including identifying details of a third party
• Content that infringes intellectual property rights
• Commercial or promotional content, or spam links
• Recommendations, solicitation, or advice regarding the merits of investing in a specific financial asset
• Any content that violates a legal provision

Right to edit and delete. The website owner may, at their sole discretion and without any obligation to give reasons or prior notice, decline to publish a comment, edit it, delete it, close a comment thread, or block a user. This does not impose on the website owner any obligation to monitor, review, or filter comments in advance.

No monitoring obligation. The website owner does not routinely monitor comments and does not review them before publication. They are not responsible for any damage caused as a result of content posted by a user. A user who believes a comment harms them or breaches the terms above is invited to contact the email address in section 1, and the website owner will review the request and act at their discretion and in accordance with the law.

License to use. A user who posts a comment grants the website owner a non-exclusive, royalty-free, and unlimited-in-time license to display the comment on the website, store it, and use it as required for the operation of the website. Rights in the content of the comment remain with the user. This does not derogate from the website owner’s right to delete the comment as stated above.

Public publication. A comment, including the name or nickname provided alongside it, is displayed publicly and may be indexed by search engines. Users should not include in a comment any personal information they do not wish to disclose.

3.3 Automated Collection and Model Training

The use of automated means to scan, copy, mine, or retrieve content from the website is prohibited without prior written permission.

The website owner expressly reserves all rights with respect to text and data mining and to the use of website content for training, calibrating, or improving computational models, including artificial intelligence models. Such use is prohibited without prior written permission.

3.4 Intellectual Property

All rights in the content appearing on the website, including texts, designs, graphics, code, logos, and other content, are reserved to Nitay Neeman unless expressly stated otherwise.

The content may not be copied, reproduced, distributed, published, translated, or used commercially in any way without prior written permission from the website owner.

3.5 Links to External Websites

The website may include links to external websites. These links are provided for user convenience only. The website owner has no control over the content of external websites and is not responsible for their content, policies, or operation.

3.6 No Commitment to Accuracy or Currency

Content on the website is written at a particular point in time and based on information available at the time of publication. Some information, including regulatory, tax, or financial information, may change over time and may not be current, complete, or accurate.

The website owner makes no commitment as to the correctness, completeness, reliability, or currency of the content, and is under no obligation to update it.

3.7 Changes to Terms

The website owner may update, change, or amend this document at any time. The updated version will be published on the website and will take effect from the date of its publication. The date of the last update is stated at the top of the document.