Privacy Policy & Legal Notice
Last updated: September 26, 2026
Privacy Policy
1. Controller
1.1. The controller of the personal data described in this Privacy Policy is Present Training and Guidance, a licensed sole proprietorship (osek murshe) owned by Ben Friedman, trading as viter.io, HaRishonim 100, Haifa, Israel (“we”, “us”). Contact for all privacy matters: hello@viter.io.
1.2. This Privacy Policy applies to the website at viter.io, including its JAMEs product pages (the “Website”), and to enquiries submitted through it. The JAMEs application is governed by its own Privacy Policy, published within the application. Personal data processed in the course of consulting or development engagements is governed by the agreement for the relevant engagement.
2. Personal Data We Process
- Server logs: IP address and request data, recorded by our hosting provider when the Website is accessed.
- Analytics: aggregated usage statistics collected by Umami, which does not use cookies and does not identify individual visitors.
- Advertising: if, and only if, you select “Accept” in the cookie banner, Google Ads cookies and similar identifiers, and information about your visit such as pages viewed and conversion events.
- Contact form: your name, email address and the content of your message.
3. Purposes and Legal Bases
| Purpose | Legal basis (GDPR) |
|---|---|
| Operating and securing the Website (server logs) | Legitimate interests (Art. 6(1)(f)) |
| Aggregated, cookieless analytics | Legitimate interests (Art. 6(1)(f)) |
| Advertising measurement through Google Ads | Consent (Art. 6(1)(a)) |
| Responding to contact-form enquiries | Legitimate interests (Art. 6(1)(f)); steps prior to entering into a contract (Art. 6(1)(b)) |
| Compliance with legal obligations | Legal obligation (Art. 6(1)(c)) |
4. Retention
4.1. Contact-form messages are retained by Web3Forms for up to three (3) years. Copies received in our mailbox are retained for as long as necessary to respond to the enquiry, to conduct any resulting business relationship and to keep records of business correspondence, and are deleted when no longer required for those purposes or upon a valid erasure request.
4.2. IP addresses in server logs are retained by our hosting provider, Google, for a few months.
4.3. Analytics data is retained by Umami for three (3) months.
4.4. Google Ads cookies are retained for the periods set by Google, unless you withdraw consent or delete them earlier.
5. Recipients
| Recipient | Function | Location |
|---|---|---|
| Website hosting (Firebase Hosting); Google Ads, subject to consent | United States and other countries | |
| Web3Forms | Delivery of contact-form messages | European Union |
| Umami | Cookieless, aggregated analytics | United States and European Union |
5.1. We may also disclose personal data where required by law or by a binding order of a competent authority.
6. International Transfers
6.1. We are established in Israel, which is recognized by the European Commission as providing an adequate level of protection for personal data. Where personal data is transferred to a recipient in a country without an adequacy decision, including the United States, the transfer is made under the Standard Contractual Clauses adopted by the European Commission or another transfer mechanism recognized under applicable data protection law.
7. Cookies
7.1. Website analytics (Umami) do not use cookies. Google Ads cookies are set only after you select “Accept” in the cookie banner. Your choice is saved in your browser’s local storage so that the banner is not shown again; this is strictly necessary to respect your choice and is not used for tracking. You may withdraw or change your consent at any time through the “Cookie settings” link in the Website footer. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.
8. Your Rights
8.1. Subject to applicable law, including the GDPR and the Israeli Protection of Privacy Law, 5741-1981, you have the right to: access your personal data; rectify inaccurate data; erase your data; restrict processing; object to processing based on legitimate interests; receive your data in a portable format; and withdraw consent at any time where processing is based on consent.
8.2. To exercise these rights, email hello@viter.io. We may verify your identity before responding. We respond within one month of receipt; where permitted by law, this period may be extended by up to two further months, in which case we will inform you of the extension and its reasons.
8.3. You have the right to lodge a complaint with a data protection supervisory authority, in particular in the EU Member State of your habitual residence, place of work or place of the alleged infringement, or with the Israeli Privacy Protection Authority.
9. Children
9.1. The Website is not directed to persons under 18 years of age, and we do not knowingly collect their personal data.
10. Changes to this Privacy Policy
10.1. We may amend this Privacy Policy. The current version is published on this page with its date of last update.
Legal Notice (Impressum)
Service provider: Present Training and Guidance, licensed sole proprietorship (osek murshe) registered with the Israel Tax Authority, trading as viter.io
Owner and person responsible for content: Ben Friedman
Address: HaRishonim 100, Haifa, Israel
Email: hello@viter.io
Further contact: contact form on this Website
VAT identification number: the Provider does not hold an EU VAT identification number.