Privacy Policy – "Hallelujah" Program

1. Introduction and Purpose

This Privacy Policy details how PZC Hagshama Association (hereinafter: "The Association" or "We"), operating in Israel under the Netaim Organization and running the "Hallelujah" program, collects, uses, retains, discloses, and protects the personal data of program participants, their parents, and website visitors. This is done in accordance with the requirements of the EU General Data Protection Regulation (GDPR) and the Israeli Protection of Privacy Law.

• Data Controller: The Association determines the purposes and means of processing personal data.
• Target Audience: The program is intended for youth (ages 12-18) from Israel and abroad participating in summer camps and journeys.

2. Types of Data Collected

We collect two types of information: Information collected via the website and information collected during the registration process for the program.

2.1. Information Collected via the Website

• Technical Usage Details: IP address, data regarding site usage, browser type (via cookies and tracking technologies).
• Voluntary Inquiries: Free text (via "Contact Us" forms or newsletter registration) arriving at the Association's systems.

2.2. Information Collected via the "Hallelujah" Program (Data Subjects – Parents and Children)

• Identification and Contact Details (Parent and Child): Full name (of the child and both parents), gender, grade/age, residential address, phone numbers (of both parents), email addresses (of both parents).
• Identification Documents: Photocopy of the participant's passport (for booking hotels, flights, and border crossings).
• Special Categories of Personal Data (Sensitive Data - Art. 9):
  • Medical Information: Health declaration, sensitivities, allergies, and medication.
  • Beliefs/Religion: Dietary requirements (such as Kosher food) indicating a religious lifestyle.
  • Media: Photographs and video footage of participants during the journey.

3. Method of Data Collection and Processing

Information is collected when Data Subjects (or their parents):

1. Browse the site (via Cookies and IP).
2. Register for the newsletter or contact us via the "Contact Us" form.
3. Fill out program registration forms and provide full details and documents.

The information is entered and processed in the Association's management systems.

4. Purposes of Use

• Program Execution: Managing registration, booking flights, accommodation, insurance, and group assignment.
• Safety and Medical: Maintaining the health and security of participants during the journey.
• Communication: Updates for parents, responding to inquiries, and maintaining contact before and during the journey.
• Future Programs: Maintaining contact with participants and their parents to offer continuation programs and additional activities of the Netaim Organization.
• Reporting and Supervision: Transferring information to funding bodies and partners (Summer Camp Israel, The Kibbutz Movement).
• Marketing and Documentation (Subject to Consent): Using photos from the journeys for advertising and activity documentation purposes.
• Legal Compliance: Meeting legal and judicial obligations applicable to the Association.

5. Legal Basis for Processing

Data processing by the Association is performed based on one or more of the grounds detailed in the GDPR regulations:

Special Note – Processing Sensitive Data (Art. 9): We rely on the Explicit Consent of the parents for medical and religious data. In medical emergencies, processing may be based on Vital Interests to protect the participant's life.

6. Sharing Data with Third Parties (Processors and Recipients)

The Association shares personal data with the following parties:

7. International Data Transfers

• Transfer to Israel: The Association relies on the fact that parents voluntarily contact and choose to transfer the information to Israel.
• Legal Basis for Transfer (Art. 49(1)): Contract Performance and Explicit Consent of the parents.
• Cloud Services: Providers like Google or Monday.com may store data on servers in the USA.

8. Data Retention

1. Sensitive Information and ID Documents (Medical, Religion, Passport): This information is deleted or fully anonymized a reasonable time after the program ends (usually within a few months), unless there is a legal obligation to keep it for a longer period.
2. Contact Details and General Information: Kept in the Netaim Organization's databases to allow the organization to offer participants and alumni continuation programs and future activities.
3. Right to Erasure: You reserve the right to request the deletion of contact details from our databases at any time.

9. Data Subject Rights (GDPR Rights)

Data subjects have the following rights:

• Right of Access & Rectification: To request a copy or correct your personal data.
• Right to be Forgotten (Erasure): To request the deletion of data (subject to legal retention obligations).
• Right to Restriction & Object: To restrict use or object to processing for marketing or continuation programs.
• Data Portability: To receive the information in a readable format.

10. Children's Privacy

We collect and process information about minors solely based on the Explicit Consent of the Parents/Legal Guardians. All requests to exercise rights will be made by the authorizing parent.

11. Cookies and Tracking Technologies

Our site uses Cookies (Google Analytics, Facebook Pixel, YouTube) for operation, user experience, security, and traffic analysis. Use of marketing cookies is subject to your consent via the site's Cookie Banner.

12. Data Security

We implement technical and organizational security measures (SSL encryption, access control) to protect your personal data. However, data transmission over the Internet is not absolutely secure (100%) against all breaches.

14. Updates to the Policy

We reserve the right to update this policy. Notice of changes will be published on the website.