Privacy Notice

Last updated: 3 June 2026

1. Who we are

Smart-Technology, owned by Malki Pessach, based in Israel, operates the BrightOwl learning platform and acts as the data controller for personal data collected through the Service. Contact: malki.smarttech@gmail.com.

2. Personal data we collect

• Account data: name, email, password (hashed), grade level, language preference.
• Profile / progress data: courses enrolled, lesson progress, quiz results.
• Support communications: messages you send us via email or in-app chat.
• Usage & device data: IP address, browser type, pages viewed, device identifiers, log timestamps.
• Cookies: essential cookies for authentication and basic analytics cookies.

Payment data (card number, billing address, tax info) is collected directly by our payment provider Paddle and is not stored on our servers.

3. Why we use your data and our legal basis

• Provide the Service (account creation, lesson access) — performance of contract.
• Process orders via Paddle — performance of contract.
• Customer support — performance of contract / legitimate interests.
• Security & fraud prevention — legitimate interests and legal obligation.
• Product improvement & analytics — legitimate interests.
• Marketing emails — only with your consent; you can unsubscribe at any time.
• Legal compliance — legal obligation.

4. Who we share data with

• Paddle.com Market Limited — our Merchant of Record, which processes payments, manages subscriptions, handles tax compliance, issues invoices, and provides refund/customer service support.
• Hosting & infrastructure providers (cloud hosting, email delivery, analytics) acting as our data processors under appropriate agreements.
• Professional advisers (legal, accounting) where necessary.
• Authorities when required by law or to protect our rights.

We do not sell your personal data.

5. International transfers

Some of our service providers (including Paddle and our hosting provider) may process data outside Israel, including in the EEA, the UK and the US. Where required, transfers are protected by adequacy decisions or Standard Contractual Clauses.

6. Data retention

We keep account and progress data for as long as your account is active and for a reasonable period afterwards (typically up to 24 months) to support reactivation, dispute resolution, and legal obligations. Billing records are retained for the period required by tax law (typically 7 years). After these periods, data is deleted or anonymised.

7. Your rights

You have the right to:

• Access the personal data we hold about you.
• Request correction of inaccurate data.
• Request deletion ("right to be forgotten") where applicable.
• Restrict or object to processing based on legitimate interests.
• Request data portability.
• Withdraw consent at any time (for marketing).
• Lodge a complaint with the Israeli Privacy Protection Authority or, if you are in the EEA/UK, with your local supervisory authority.

To exercise these rights, email malki.smarttech@gmail.com. We will respond within one month.

8. Security

We use appropriate technical and organisational measures — including TLS encryption in transit, hashed passwords, access controls, and role-based permissions — to protect your data.

9. Cookies

We use essential cookies needed for authentication and session management, and limited analytics cookies to understand how the Service is used. You can control cookies via your browser settings; disabling essential cookies may prevent the Service from working.

10. Children

BrightOwl is intended for students in grades 3–12. Where the user is a minor, a parent or legal guardian must create the account and consent to this Privacy Notice on the child's behalf.

11. Changes

We will update this Notice from time to time. Material changes will be announced in-app or by email.

12. Contact

Smart-Technology (Malki Pessach), Israel — malki.smarttech@gmail.com