PRIVACY POLICY

Effective Date: 22nd of February, 2026

This Privacy Policy describes how Chaim Apsan (“Company,” “we,” “our,” or “us”) collects, uses, stores, protects, and discloses personal information through chaimapsan.com (“Website”) and in connection with the SEAM™ methodology and related services (“Services”).

By using this Website or engaging in Services, you consent to the practices described below.


1. Information We Collect

We collect information in the following ways:

1.1 Information You Provide Voluntarily

This may include:

  • Full name

  • Email address

  • Phone number

  • Business name

  • Financial or business context shared during application or consultation

  • Health-related information voluntarily disclosed

  • Written communications

  • Scheduling information

  • Payment details (processed via third-party providers)

If you apply for Services, you may provide sensitive personal, business, or health-related information. Submission of such information is voluntary.


1.2 Automatically Collected Information

When you access the Website, we may automatically collect:

  • IP address

  • Browser type

  • Device type

  • Operating system

  • Referring URLs

  • Pages viewed

  • Time spent on pages

  • Cookies and tracking data

This data helps improve Website functionality and user experience.


1.3 Payment Information

We do not store full credit card numbers or banking credentials.

Payments are processed through secure third-party payment processors. Their privacy policies govern handling of financial information.


2. How We Use Information

We may use collected information to:

  • Respond to inquiries

  • Evaluate applications for Services

  • Deliver sessions and programs

  • Communicate with Clients

  • Process payments

  • Improve Website functionality

  • Maintain internal records

  • Comply with legal obligations

  • Protect against fraud or misuse

We do not sell personal information.


3. Confidential Information

Due to the executive-level nature of Services, Clients may disclose:

  • Proprietary business information

  • Investment plans

  • Financial data

  • Health information

  • Strategic documents

Such information is treated as confidential and will not be disclosed except:

  • With Client’s written consent

  • If required by law

  • If necessary to prevent imminent harm

However, no system can guarantee absolute security.


4. Legal Basis for Processing (If Applicable – GDPR)

If you are located in the European Economic Area (EEA), we process personal data under the following legal bases:

  • Consent

  • Contractual necessity

  • Legal compliance

  • Legitimate business interests

You may withdraw consent at any time.


5. Data Retention

We retain personal data only as long as necessary to:

  • Provide Services

  • Maintain records

  • Comply with legal obligations

  • Resolve disputes

We may retain anonymized data indefinitely.


6. Cookies and Tracking Technologies

We may use:

  • Cookies

  • Analytics tools

  • Website performance tools

You may disable cookies in your browser settings, though this may affect Website functionality.


7. Data Sharing

We may share data with:

  • Payment processors

  • Scheduling software providers

  • Email service providers

  • Website hosting providers

  • Legal or regulatory authorities if required

All service providers are expected to maintain reasonable security standards.

We do not sell or rent personal data to third parties.


8. Data Security

We implement reasonable administrative, technical, and physical safeguards to protect personal information.

However:

  • No transmission over the Internet is completely secure.

  • We cannot guarantee absolute security.

You transmit information at your own risk.


9. International Data Transfers

If you are located outside the country in which Company operates, your information may be transferred and processed in other jurisdictions.

By using the Website or Services, you consent to such transfers.


10. Your Rights

Depending on your jurisdiction, you may have the right to:

  • Access personal data

  • Correct inaccurate data

  • Request deletion

  • Restrict processing

  • Object to processing

  • Request data portability

Requests may be submitted via:
info@chaimapsan.com

We may require verification of identity before responding.


11. California Privacy Rights (CCPA – If Applicable)

If you are a California resident, you may have rights under the California Consumer Privacy Act, including:

  • Right to know what data is collected

  • Right to request deletion

  • Right to opt-out of sale (we do not sell data)

Requests may be submitted via:
info@chaimapsan.com


12. Children’s Privacy

This Website and Services are not intended for individuals under 18 years of age.

We do not knowingly collect data from minors.


13. Third-Party Links

The Website may contain links to third-party websites.
We are not responsible for their privacy practices.


14. Professional Boundaries

While Services may involve personal or health-related discussion, this Website and Services:

  • Do not create a doctor-patient relationship

  • Do not create a therapist-client relationship

  • Do not constitute medical advice

Health information shared voluntarily is handled as confidential personal data but not as protected health information under HIPAA unless explicitly stated.


15. Methodology Protection

SEAM™ and related frameworks are proprietary intellectual property.

Personal data collected in connection with Services may not be used by Clients to:

  • Replicate

  • Teach

  • Commercialize

  • Reverse engineer

the methodology.

Unauthorized use may result in legal action.


16. Changes to This Policy

We may update this Privacy Policy at any time.

The updated version will be posted with a revised effective date.

Continued use of the Website constitutes acceptance of changes.


17. Contact Information

For privacy-related inquiries:

Chaim Apsan
Apsan Creative Works
HaTzvi 15 – Jerusalem
Email: info@chaimapsan.com