1. Scope & Acceptance
      
        - This Privacy Policy explains how we collect, use, share, secure, retain, and transfer personal information when you visit our Site or purchase our digital products (the Services).
 
        - By using the Services, you agree to this Policy; if you do not agree, discontinue use.
 
        - This Policy is incorporated into our Terms of Service.
 
      
      2. Roles & Definitions
      
        - Controller: ThriveSerene (Israel) for personal information we collect directly.
 
        - Personal Information means information relating to an identified or identifiable individual.
 
        - Processing means any operation on personal information (collection, storage, use, disclosure, deletion, etc.).
 
        - We act as controller for data we collect, and independent or joint controller with certain third parties where their tools collect directly (e.g., payment providers).
 
      
      3. Information We Collect
      
        - You provide: name (or alias), email, billing details, purchase information, support messages, and any content you send us.
 
        - Automatic: device data, IP address, general location (city/region), pages viewed, timestamps, error logs, and anti-fraud indicators (e.g., unusual download patterns).
 
        - From third parties: payment/checkout providers, email service providers, security/anti-fraud vendors, and dispute/chargeback platforms (e.g., transaction confirmations, risk scores, dispute outcomes).
 
        - Cookies & similar tech: we use strictly necessary cookies (operation, security, licensing). If/when enabled, we also use functional/analytics cookies. We will request consent for non-essential cookies where required by law and provide controls to manage choices.
 
      
      4. How We Use Data & Legal Bases (GDPR/UK GDPR)
      
        - Contract: to take and fulfill orders, deliver digital content, manage access links, and provide support.
 
        - Legitimate interests: to secure the Services, prevent fraud/piracy (including download/device limits), improve performance, and maintain accurate records.
 
        - Legal obligations: tax, accounting, compliance, and responding to lawful requests.
 
        - Consent (where required): email marketing, non-essential cookies, and certain international transfers when consent is the chosen basis.
 
      
      5. Sharing & Disclosure
      
        - Service providers/Processors: hosting, email delivery, analytics (if enabled), customer support tools, and logistics for digital deliverybound by contracts to handle data lawfully and securely.
 
        - Payment providers: (e.g., Shopify Payments/PayPal or equivalent) typically act as independent controllers; we do not receive full card data.
 
        - Security/anti-fraud: limited sharing to investigate abuse, piracy, or chargeback fraud and to protect users and our platform.
 
        - Legal: disclosures to comply with law, court orders, or to protect our rights, security, users, or the public.
 
        - No sale/share: we do not sell or share personal information for cross-context behavioral advertising as defined by the CPRA. If this changes, we will update this Policy and honor applicable opt-out rights.
 
      
      6. International Transfers
      
        - We operate from Israel and may process data in other countries using reputable vendors.
 
        - For EEA/UK users, where required, we rely on appropriate safeguards such as EU Standard Contractual Clauses (SCCs) and, for the UK, the IDTA or UK Addendum.
 
        - Note: The EU recognises Israel as providing an adequate level of protection, permitting transfers from the EEA to Israel without additional transfer tools.
 
      
      7. Security
      
        - We implement administrative, technical, and organizational measures to protect personal information against unauthorized access, disclosure, alteration, or destruction.
 
        - Access to personal information is limited to authorized personnel and vetted vendors with a need-to-know.
 
        - We monitor for suspicious activity and may restrict access temporarily (e.g., link/device limits) to protect users and the platform.
 
        - Where required by law, we will notify authorities and/or affected individuals of certain security incidents.
 
      
      8. Retention
      
        - We keep personal information only as long as reasonably necessary for the purposes described (including legal/accounting obligations) and then delete or de-identify it.
 
        - Examples:
          
            - Purchases/invoices: kept for statutory accounting/tax periods;
 
            - Security/access logs: kept for a limited period to detect and investigate abuse;
 
            - Marketing records: kept until you opt out or withdraw consent.
 
          
         
      
      9. Your Rights & How to Exercise Them
      
        - EEA/UK (GDPR/UK GDPR): right of access, rectification, erasure, restriction, portability, and objection; right to withdraw consent where applicable. We aim to respond within one month (may extend by up to two months for complex/volume requests and will notify you within the first month if extended).
 
        - US State Privacy Laws (e.g., CA/CO/CT/VA/UT/OR/TX/DE, etc.): rights to know/access, delete, correct, and to opt-out of sale/share or targeted advertising (where applicable). We typically respond within 45 days (may extend once by 45 days with notice). If we deny a request, you may appeal by emailing us with Appeal in the subject.
 
        - Israel (PPL, incl. Amendment 13): rights include access and correction of data in a registered database; the law and guidance continue to evolve following Amendment 13 (in force Aug 14, 2025).
 
        - Submitting requests: email support@thriveserene.com with the right youre invoking and your jurisdiction; we may verify your identity (e.g., order ID, email confirmation). We do not discriminate for exercising rights.
 
      
      10. Preference Signals (GPC) & Cookies
      
        - Where legally required (e.g., California), we honor the Global Privacy Control (GPC) opt-out signal for sale/share or targeted advertising. We may choose to honor it more broadly as a good-faith practice.
 
        - Non-essential cookies/analytics (if enabled) are used only with your consent in jurisdictions that require it; consent can be withdrawn at any time via the banner or browser settings.
 
      
      11. Children
      
        - Our Services are not directed to children under 13 and we do not knowingly collect their data.
 
        - Purchases are restricted to adults (18+) or 1617-year-olds with parental/guardian consent (see Terms of Service).
 
        - EEA/UK note: child consent thresholds vary by country (often 1316, default 16); where consent is relied upon for information-society services, parental authorization may be required below the set age.
 
      
      12. Automated Decision-Making
      
        - We do not make decisions with legal or similarly significant effects based solely on automated processing.
 
        - We may use automated anti-fraud signals to flag suspicious behavior; any access-limitation decision can be reviewed upon request.
 
      
      13. Data Integrity & Minimization
      
        - We collect only what we need for stated purposes and take steps to keep data accurate and up to date.
 
        - You are responsible for providing accurate contact and order information.
 
      
      14. International Representatives & Complaints
      
        - EU/UK representatives: If we are required to appoint an EU/UK representative under GDPR Art. 27/UK GDPR, we will publish their details here; designation does not limit our responsibilities.
 
        - Supervisory authorities: You may lodge a complaint with your local data-protection authority. We encourage contacting us first so we can try to resolve your concern promptly.
 
      
      15. Changes to this Policy
      
        - We may update this Policy from time to time; the Last Updated date shows the current version.
 
        - Material changes will be posted on the Site. Continued use after changes constitutes acceptance.
 
      
      16. Contact
      
        - Email: yoavman997@gmail.com
 
        - Postal/Registered address: will be published once available; until then, contact us by email for privacy requests or complaints.