TropeTrainer

Privacy Policy

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Hazzan Solutions Legal

The shared legal terms and privacy language for TropeTrainer, iLeyn, and MitzvahManager.

Effective Date: October 2022Hazzan Solutions, LLC

Privacy Policy

Effective Date: October 2022 TropeTrainer, iLeyn, and MitzvahManager are operated by Hazzan Solutions, LLC 4864 Rockaway Beach Road NE Bainbridge Island, WA 98110 United States Email: info@hazzansolutions.com

1. Introduction

TropeTrainer™, iLeyn, and MitzvahManager (“we,” “us,” “our”) is committed to protecting the privacy and security of our users, including children under the age of 13. This Privacy Policy describes how we collect, use, disclose, and safeguard personal information in compliance with:

  • Children’s Online Privacy Protection Act (COPPA)

  • General Data Protection Regulation (GDPR)

  • California Consumer Privacy Act (CCPA/CPRA)

  • California Online Privacy Protection Act (CalOPPA)

  • CAN-SPAM Act

  • Other applicable U.S. and international data protection laws

By using TropeTrainer™, iLeyn and/or MitzvahManager you agree to the practices described in this Privacy Policy.

2. Scope of This Policy

This Privacy Policy applies to:

  • Our website and subdomains

  • Web-based applications

  • APIs and digital services

  • Communications related to our services

3. Information We Collect

We collect only information that is reasonably necessary to provide educational services.

A. Information Provided Directly

Depending on account type, we may collect:

  • Name

  • Email address

  • Parent/guardian email address (for users under 13)

  • Billing information (processed securely via Stripe)

  • Account login credentials

  • Institution or synagogue affiliation (if applicable)

We do not require children under 13 to provide more personal information than is reasonably necessary to participate.

B. Automatically Collected Information

When users access our platform, we may automatically collect:

  • IP address

  • Device type

  • Browser type

  • Operating system

  • Usage activity

  • Session duration

  • Referring URLs

Persistent identifiers are used solely for internal operations such as:

  • Security

  • Fraud prevention

  • System maintenance

  • Performance monitoring

  • Debugging

We do not use persistent identifiers for behavioral advertising directed at children and the following is active

  • IP anonymization is enabled

  • Google Ads features is disabled

  • No cross-device tracking

  • No remarketing audiences

  • No demographic profiling

  • Data retention is minimized

C. Payment Information

All payment information is processed directly by Stripe, a PCI-DSS compliant payment processor. We do not store full credit card numbers on our servers.

4. Children’s Privacy (COPPA Compliance)

TropeTrainer™, iLeyn, and MitzvahManager are wholly or in-part educational service that may be used by children under 13 for Torah and Jewish learning.

We comply with the Children’s Online Privacy Protection Act (COPPA).

When accounts are created through a synagogue or educational institution, the institution represents that it has obtained all required parental notices and consents under applicable law. The Owner reserves the right to request documentation of such consent.

Before collecting personal information from a child under 13, we obtain verifiable parental consent.

Consent may be obtained through:

  • Verified parental email confirmation

  • Payment verification

  • Signed parental consent form

  • Other FTC-approved verification methods

A child account will not become fully active until parental or guardian consent is confirmed.

B. Direct Notice to Parents

Before collecting personal information from a child, parents receive notice that includes:

  • What information is collected

  • How it will be used

  • Whether it will be disclosed to third parties

  • How parents may review or delete information

  • How to revoke consent

C. Parental Rights

Parents have the right to:

  • Review their child’s personal information

  • Request deletion of their child’s personal information

  • Refuse further collection or use

  • Revoke consent at any time

To exercise these rights, contact: Privacy Officer – Hazzan Solutions, LLC

4864 Rockaway Beach Road NE Bainbridge Island, WA 98110 United States

info@hazzansolutions.com

We will respond within a reasonable timeframe as required by law.

D. Data Minimization for Children

We:

  • Do not permit children to publicly post personal information.

  • Do not sell children’s data.

  • Do not use children’s information for behavioral advertising.

  • Retain children’s data only as long as necessary to provide services.

We do not serve targeted advertising to children and do not allow third-party advertising networks to collect information from children for behavioral advertising purposes.

5. How We Use Information

We use collected information to:

  • Provide and maintain our services

  • Process transactions

  • Provide customer support

  • Communicate with users

  • Improve functionality and performance

  • Ensure security and prevent fraud

  • Comply with legal obligations

We do not sell personal information.

If you are located in the European Union or United Kingdom, we process personal data under the following lawful bases:

  • Consent

  • Performance of a contract

  • Legal obligation

  • Legitimate interests (e.g., service improvement, fraud prevention)

You may withdraw consent at any time where processing is based on consent.

7. Data Sharing and Disclosure

We do not serve targeted advertising to children and do not allow third-party advertising networks to collect information from children for behavioral advertising purposes.

We share personal information only with:

A. Service Providers

  • Stripe (payment processing)

  • Google Analytics (usage analytics configured for privacy compliance)

  • Hosting and infrastructure providers

  • Internal communication platforms (e.g., Slack for support management)

All service providers are contractually obligated to:

  • Use data solely to provide services to us

  • Maintain confidentiality

  • Comply with applicable privacy laws

We do not serve targeted advertising to children and do not allow third-party advertising networks to collect information from children for behavioral advertising purposes.

We may disclose information when required by law, court order, or government request.

8. Cookies and Tracking Technologies

We use cookies and similar technologies for:

  • Essential functionality

  • Security

  • Performance analytics

Where required by law (such as in the EU), users may be presented with cookie consent options.

Users may also control cookies through browser settings.

9. Data Retention

We retain personal information only as long as necessary to:

  • Provide services

  • Comply with legal obligations

  • Resolve disputes

  • Enforce agreements

Children’s data is deleted when no longer necessary for educational purposes or upon verified parental request. Inactive student accounts are deleted at the discretion of the administrator/User

Data purged after bar/bat mitzvah completion unless renewed by the Administrator/User

10. Data Security

We implement reasonable administrative, technical, and physical safeguards to protect personal information, including:

  • Encrypted data transmission (HTTPS)

  • Access controls

  • Secure hosting infrastructure

  • Restricted employee access

  • Regular security review procedures

No system can guarantee absolute security; however, we take commercially reasonable measures to protect data.

11. Your Privacy Rights

Depending on your jurisdiction, you may have the right to:

  • Access personal information

  • Correct inaccurate data

  • Request deletion

  • Restrict processing

  • Object to processing

  • Request data portability

California residents may also request:

  • Disclosure of categories of information collected

  • Disclosure of categories of information shared

  • Confirmation that data is not sold

To exercise rights, contact: info@hazzansolutions.com

Identity verification may be required.

12. International Data Transfers

Our servers are located in the United States.

If you access the platform from outside the U.S., your information may be transferred to and processed in the United States, which may have different data protection standards.

Where required, we rely on appropriate safeguards for international data transfers.

Our platform may contain links to third-party websites. We are not responsible for the privacy practices of those external sites.

14. Changes to This Policy

We may update this Privacy Policy from time to time.

If material changes are made, we will provide notice through:

  • Website posting

  • Email notification (if applicable)

Continued use of the platform after changes indicates acceptance.

15. Contact Information

Privacy Officer Hazzan Solutions, LLC 4864 Rockaway Beach Road NE Bainbridge Island, WA 98110 United States Email: info@hazzansolutions.com

16. Global Data Protection and GDPR Compliance

If you access TropeTrainer™, iLeyn, or MitzvahManager (aka B.MitzvahManager) from the European Union (EU), United Kingdom, or other jurisdictions with data protection laws, your data may be transferred to and processed in the United States where our servers and infrastructure reside.

For users located in the EU/EEA under the age of digital consent applicable in their country, parental consent is required before processing personal data.

In accordance with the General Data Protection Regulation (GDPR), we process personal data under the following lawful bases:

  • Your consent, when applicable.
  • When necessary for the performance of a contract.
  • To fulfill legal obligations.
  • Based on our legitimate interests, such as maintaining platform integrity and improving user experience.

For TropeTrainer: We are the Data Controller.

For MitzvahManager (CRM storing synagogue data) and iLeyn: We act as a Data Processor for institutions.

You have the right to access, rectify, erase, restrict processing, or object to our use of your personal data. You may also request a copy of your personal data in a portable format. To exercise these rights, email us at info@hazzansolutions.com.

Data Controller: Hazzan Solutions, LLC, 4864 Rockaway Beach Road NE, Bainbridge Island, WA 98110, United States.

17. Governing Law and Arbitration

These Terms are governed by the laws of the State of Washington, United States, without regard to conflict of law principles.

Any disputes arising out of or relating to these Terms shall be resolved through binding arbitration administered by a mutually agreed-upon arbitration body (e.g., AAA or JAMS), except where small claims court is appropriate. The arbitration shall take place in King County, Washington.

Users may opt out of arbitration by providing written notice within 30 days of agreeing to these Terms. Nothing in this clause shall limit a party’s right to seek equitable relief or enforce intellectual property rights in court.

If you are a consumer in a jurisdiction that does not permit mandatory arbitration, these provisions may not apply to you. In such cases, exclusive jurisdiction shall reside in the courts of Washington State.