Privacy Policy -- Personality Code

Last updated: 30 June 2026

This Privacy Policy explains how The Bederman Group Ltd., an Israeli limited company trading as Personality Code ("Personality Code," "we," "us," or "our"), collects, uses, shares, and protects your personal information when you visit personalitycode.me, take our assessment, contact us, or purchase our coaching programs and materials (together, the "Services").

We are based in Israel and serve clients in Israel, North America, and Europe. This policy is written to meet our obligations under Israel's Protection of Privacy Law, 5741-1981 (as amended, including Amendment 13), the EU and UK General Data Protection Regulation (GDPR), Canadian privacy law (including PIPEDA, Quebec's Law 25, and CASL), and applicable U.S. state privacy laws (including the California Consumer Privacy Act as amended by the CPRA). Region-specific rights are set out in Section 12.

Who is responsible for your data (the "controller"):

The Bederman Group Ltd.
Tel Aviv, Israel
Privacy contact: hello [at] personalitycode [dot] me

1. A quick summary

We collect what you give us (name, contact details, assessment answers, billing info) and some technical data collected automatically (cookies, analytics, ad pixels).
Your assessment answers can touch on your emotions and wellbeing, so we treat them as sensitive data and only process them with your explicit consent.
We never sell your personal information for money.
We use trusted service providers (including AI tools, email/CRM, analytics, advertising, payments, and hosting) to run the business.
You have rights over your data -- including access, correction, deletion, and opting out of marketing -- and they're described in detail below.

This summary is for convenience only; the full policy controls.

2. The information we collect

Information you give us:

Identity and contact details -- your name, email address, and phone number.
Assessment responses -- your answers to the Personality Code assessment, including answers that relate to your emotions and wellbeing, and the personality profile or "type" generated from them. (See Section 4.)
Billing information -- billing name and address, and a record of your transactions. Your payment card details are collected and processed directly by our payment processor; we do not see or store your full card number.
Anything else you choose to share -- for example, in an email, a coaching session, a form, or a message to us.

Information we collect automatically:

Usage and device data -- your IP address, device and browser type, the pages you view, the link or ad that brought you to us, and the dates and times of your visit.
Cookies and similar technologies -- see Section 8.

Information we receive from others:

Advertising and analytics platforms may provide us with aggregated or limited information about how you found us and how our ads perform.

Providing your information is voluntary. However, without certain information (for example, your email and assessment answers) we cannot deliver your results or provide the Services. Where any information is required by law, we will tell you at the point we collect it.

3. How we use your information and our legal basis

We use your personal information to:

Purpose	Legal basis (GDPR / Israeli PPL)
Deliver your assessment results and provide our coaching and materials	Performance of a contract; our legitimate interests in running the Services
Process your assessment answers that relate to emotions/wellbeing	Your explicit consent
Take payment and keep financial records	Performance of a contract; legal obligation
Send you marketing by email, SMS, and WhatsApp	Your consent
Measure and improve our site, and show and retarget ads	Your consent (for non-essential cookies/tracking); our legitimate interests
Keep our Services secure and prevent fraud	Legal obligation; our legitimate interests
Respond to your questions and requests	Our legitimate interests; your consent
Comply with law and enforce our terms	Legal obligation; our legitimate interests

You can withdraw any consent at any time (see Sections 7 and 12). This won't affect anything we did before you withdrew it.

4. Sensitive data and your assessment

Some of your assessment answers can reveal information about your emotional state or wellbeing. Under GDPR this can be special category data, and under Israel's Protection of Privacy Law it may be information of special sensitivity. We give it extra protection:

We process it only with your explicit consent, which you give before completing the assessment.
We use it only to generate your results and to support you within the Services.
You can withdraw consent and ask us to delete this data at any time.

5. Automated processing and AI

Your results are generated using a scoring system and AI tools that analyze your assessment answers (and, where applicable, your messages in chat). This is a form of profiling, but it does not produce legal effects or similarly significant effects on you, and no decision about you is made by automated means alone.

We use third-party AI service providers to help process answers and generate results. Where these providers are located outside your country, we apply the safeguards described in Section 9. You can ask us how your results were produced, or ask a person to review them, by contacting us.

6. How we share your information

We do not sell your personal information for money. We share it only as described here.

Service providers (sub-processors). We use trusted companies to help us run our business. They may access your data only to perform services for us, under contracts that require them to protect it and use it only for us. By category, these include:

Email and customer-relationship management (CRM) -- to manage our contact lists and send communications.
Productivity and cloud storage -- to store and organize information.
Website and marketing analytics -- to understand how our site and ads are used.
Advertising platforms -- to deliver and measure ads, including retargeting.
Payment processing -- to take payment securely (the provider, not us, handles your card details).
Scheduling -- to book calls and sessions.
SMS and messaging providers -- to send the text and WhatsApp messages you've opted into.
AI service providers -- to help process assessment answers and generate your results.
Webinar and video hosting -- to run and deliver our online sessions.
Website hosting and infrastructure -- to operate the site.

We can provide the current list of the specific providers we use on request -- just email us using the details below.

Advertising note: Our use of advertising and analytics technologies may be considered "sharing" of personal information for cross-context behavioral advertising under some U.S. state laws. You can opt out -- see Sections 8 and 12.

Legal and business reasons. We may disclose your information to comply with law or legal process, to enforce our agreements, to protect our rights, safety, or property or those of others, or in connection with a merger, acquisition, or sale of our business.

7. Marketing communications

We send marketing by email, SMS, and WhatsApp only to people who have opted in. You can opt out at any time:

Email: click the unsubscribe link in any message.
SMS / WhatsApp: reply STOP.

We keep a record of your consent and of any opt-out so we can honor your choice. Even after you opt out of marketing, we may still send you service messages directly related to your purchases (for example, payment receipts or program access details).

8. Cookies and tracking technologies

We use cookies and similar technologies to make the site work, to understand how it's used, and to support advertising. We group them as:

Essential -- needed for the site to function. These are always on.
Analytics -- help us understand site usage.
Advertising -- let us measure and retarget ads.

Where required (including for visitors in the EU, UK, and similar regions), we ask for your consent before setting non-essential cookies, and you can change your preferences at any time through our cookie settings.

We honor recognized browser-based opt-out preference signals, such as Global Privacy Control (GPC), where the law requires it.

9. International data transfers

We are based in Israel. The European Union has recognized Israel as providing an adequate level of data protection, so transfers of personal data from the EU and UK to us are permitted on that basis.

Some of our service providers are located outside your country, including in the United States. When we transfer personal data internationally, we use appropriate safeguards, which may include the EU Standard Contractual Clauses, the EU--U.S. / UK--U.S. Data Privacy Framework where a provider is certified, and the transfer requirements under Israel's Protection of Privacy Law. You can ask us for more information using the contact details above.

10. How long we keep your information

We keep your personal information only as long as we need it for the purposes in this policy, and to meet legal, tax, and accounting requirements. After that we delete or anonymize it.

Marketing data -- kept until you opt out, after which we keep a minimal suppression record so we don't contact you again.
Assessment responses -- kept until you ask us to delete them (we may keep a minimal record where the law requires).
Transaction records -- kept for the period required by applicable financial and tax law.

11. How we protect your information

We use reasonable technical and organizational measures to protect your personal information, including access controls and encryption of data in transit. No method of transmission or storage is completely secure, so we cannot guarantee absolute security.

If a data breach affects your rights, we will notify you and the relevant authority where the law requires it.

12. Your rights

Wherever you live, you can ask us to access, correct, or delete your personal information, object to or restrict certain uses, withdraw consent, opt out of marketing, or receive a portable copy of data you gave us. To exercise any right, email hello [at] personalitycode [dot] me. We may need to verify your identity, and we'll respond within the time the law allows. You won't be treated differently for exercising your rights.

If you are in the EU or UK (GDPR). You have all the rights above, and you may lodge a complaint with your local Data Protection Authority. Where we rely on consent, you can withdraw it at any time.

If you are in Israel (Protection of Privacy Law). You have the right to inspect the information we hold about you (we will provide it in Hebrew or English), to ask us to correct it, to request its deletion, and to object to its use for direct marketing. You may complain to the Israeli Privacy Protection Authority (PPA).

If you are in Canada (PIPEDA / Quebec Law 25 / CASL). You have the right to access and correct your information and to withdraw consent. Quebec residents have additional rights, including data portability, de-indexing, and information about automated decisions. You may complain to the Office of the Privacy Commissioner of Canada or, in Quebec, the Commission d'accès à l'information. We send commercial electronic messages only with consent and always include a way to unsubscribe.

If you are in the United States (California and other states). You have the right to know what personal information we collect and how we use it, to access and delete it, to correct it, to opt out of the "sale" or "sharing" of your personal information (we don't sell it for money, but our advertising technologies may count as "sharing" -- you can opt out via our cookie settings, and we honor GPC), and to limit the use of sensitive personal information. Residents of other U.S. states with comprehensive privacy laws have similar rights. We will not discriminate against you for exercising any of these rights.

13. Children

The Services are intended for adults. We do not knowingly collect personal information from anyone under 18 (or under the minimum digital-consent age in your country, which under GDPR may be between 13 and 16). If you believe a minor has provided us with personal information, please contact us and we will delete it.

14. Changes to this policy

We may update this Privacy Policy from time to time. When we do, we'll change the "Last updated" date above, post the new version on the site, and, where the law requires, notify you directly.

15. Governing law

This Privacy Policy is governed by the laws of the State of Israel, and any dispute relating to it will be handled by the competent courts in Israel. Nothing in this section deprives you of any mandatory consumer-protection or data-protection rights under the laws of your country of residence, including your right to complain to your local data protection authority.

16. Contact us

The Bederman Group Ltd.
Tel Aviv, Israel
Email: hello [at] personalitycode [dot] me

If you have any questions about this policy or how we handle your information, please get in touch.