This Privacy Policy (hereinafter referred to as the “Policy”) describes the procedure for processing and protecting personal data of users on the website hebrewerry.com (hereinafter referred to as the “Website”). This Policy is prepared in accordance with the requirements of Federal Law of the Russian Federation No. 152-FZ “On Personal Data” and other applicable laws. We strive to ensure the confidentiality and security of any information received from you. By using our Website, you express your consent to the terms of this Policy.
The processing of personal data of the Website's users is carried out by Early Stage LTD (registered at: House of Francis, Room 303, Ile Du Port, Mahé, Seychelles) – hereinafter referred to as the “Operator” or the “Company.” Contact email for personal data inquiries:support@hebrewerry.com.
This Policy applies to all information about users that the Operator may receive in the course of your use of the Website, including data collected during account registration, submitting comments, subscribing to newsletters, as well as during simple visits to Website pages.
For the purposes of this Policy, “personal data” means any information relating directly or indirectly to an identified or identifiable natural person (user of the Website). Other terms (operator, processing, provision of data, etc.) are used in the meanings specified in personal data legislation.
We collect only the personal data necessary to provide Website services and communicate with users.
When registering on the Website, leaving comments, or filling out feedback forms, you may provide us with your personal data. As a rule, this is the minimum necessary information:
Contact information: name (or pseudonym) and email address. For example, an email address is requested during account registration or newsletter subscription; your name or nickname may be requested for display in comments.
Registration data: when creating an account, you create a password, which is stored in encrypted form. A login or user identifier may also be recorded.
Additional information: at your discretion, you may fill out your profile or leave information in comments—for example, a link to your social media profile, a photo, your city of residence, etc. Such data is collected only if you choose to provide it.
When visiting the Website, certain data is automatically collected through technical means:
Our Website may allow registration or authorization through accounts of third-party services. If you choose to use this option, we will receive certain personal data from the corresponding third-party service—usually your name and email address associated with that account. This data is provided to us by the third-party service based on your consent, and we process it in accordance with this Policy.
Note: we do not gain access to your social media accounts or other information except that which you permit to be transferred.
We do not collect or process special categories of personal data, such as information about racial or ethnic origin, political views, health status, biometric data, etc., except when you voluntarily make such information publicly available on the Website (for example, by publishing it in comments).
We process users’ personal data strictly for specific purposes and on legal grounds. Below are the purposes of processing and the corresponding legal bases:
Your data is used to create and manage your account and ensure the operation of the basic functions of the Website (e.g., publishing your comments, saving your list of studied words, etc.).
Legal basis: the necessity of concluding and performing an agreement with you for the provision of Website services. When you register and accept the user agreement, a contract for the use of the service is effectively concluded between you and the Operator, and the processing of your data for these purposes is permissible without additional consent.
We use contact information (e.g., email) to communicate with you regarding the operation of the service: sending notifications about important functional updates, responding to your support requests, informing you of rule changes.
Legal basis: your consent expressed when you contact us or provide your contact details for feedback. In some cases, the basis may be contract performance (e.g., notification of changes in service terms).
By registering on the Website, including registration through social network accounts, the User confirms and provides their consent to receive informational and marketing email newsletters related to the operation of the Website, its services, news, special offers, and other materials. By checking the box “I agree to the Privacy Policy and the User Agreement” during registration, the User consents to such communications. The User may unsubscribe from these newsletters at any time by using the corresponding link in the email or by sending an unsubscribe request to the Website’s email address:support@hebrewerry.com
Personal data in aggregated form (including automatically collected technical data and Website behavior information) is used for analytics—studying how users interact with our resource. This helps identify errors, optimize content, improve user experience, and develop new features.
Legal basis: the Operator’s legitimate interest in improving its service. When consent is required (e.g., for analytics cookies), we request it separately (via a banner or browser settings).
If advertising materials appear on the Website (such as ads from Yandex.Direct or other networks), personal data (mainly cookies and data about your visits) may be used to show relevant ads.
Legal basis: user consent.
Before enabling personalized advertising, we ensure that consent is obtained. Users may change settings or refuse personalized advertising at any time.
In some cases, we process and store personal data to fulfill legal obligations—for example, in response to requests from courts or government bodies, or for accounting and tax purposes (if you purchase paid services).
Legal basis: fulfillment of the Operator’s legal obligations.
We may request your separate consent for the use of personal data for additional purposes not covered above. In this case, we clearly inform you which data we want to process and why, and begin processing only after receiving your consent. You may refuse or withdraw consent at any time without negative consequences (except that you may not receive an additional service tied to that consent).
We do not use personal data for purposes incompatible with those originally stated. Specifically, we do not sell or transfer your personal data to third parties for independent use without your consent. Data may be transferred only as described in Section 5 below.
Our Website uses cookies to ensure its functionality, personalize user experience, and provide analytics. Cookies are small text files stored on your device when you visit a site. With cookies, we remember, for example, your settings and preferences (interface language, saved dictionary words, etc.) to simplify future visits. Cookies also help you remain logged in without entering your login and password each time.
You may change your browser settings at any time to disable cookies or delete saved files. Note that disabling all cookies may limit the functionality of certain Website features (e.g., automatic login or the ability to post comments).
Some cookies are necessary for the proper functioning of the Website and for providing the services you request. For example, authentication cookies identify a registered user, and preference cookies store interface language selection. These files are classified as essential and functional; without them, some Website features may not be available. Such cookies are used based on our legitimate interest and do not require separate consent. However, you may disable them in your browser settings (though some functions may not work properly).
We do not disclose or transfer your personal data to third-party organizations or individuals except when necessary for Website operation or required by law. Some services supporting the operation of our Website are provided by external companies under contract with us; in such cases, they act as our partners–“operators on assignment” (processors). For example:
In all such cases, the following principles apply: we transfer only the minimum data necessary for the processor’s functions; they may not use the data for other purposes; all processors must ensure data security and comply with the law.
The Operator may disclose or transfer your personal data to third parties only with your explicit consent. For example, if you wish to integrate with a third-party service and authorize us to transfer data, we will do so only after confirming your approval.
We may provide personal data upon lawful request from government authorities as required by legislation. For example, at the request of a court, law enforcement, or regulatory bodies (with proper documentation), we must provide the requested information. We may also disclose data if necessary to protect our legal interests or prevent fraud or other unlawful activities—but only within legal limits.
If our company (the Website operator) participates in a merger, acquisition, asset sale, or other business reorganization, personal data of users may be transferred to the successor (new Website owner). In such a situation, we ensure the new owner accepts the obligations of this Policy. Users will be notified in advance and may stop using the Website and request deletion of their data before the transfer.
We store personal data only for the time necessary to achieve the purposes for which they were collected.
After the expiration of retention periods or achievement of processing goals, we delete or irreversibly anonymize personal data.
In accordance with Russian law, we ensure the recording, systematization, accumulation, and storage of personal data of citizens of the Russian Federation on servers located within the Russian Federation. If you are a Russian citizen, your personal data collected via the Website will initially be stored on servers in Russia. If further processing is required (e.g., by our foreign office or cloud services), data may be transferred abroad with compliance to cross-border transfer rules (see Section 6.4).
We take necessary organizational and technical measures to protect your personal data from unlawful or accidental access, destruction, alteration, blocking, copying, distribution, and other unlawful actions. In particular:
Despite these measures, no method of data transmission over the Internet or electronic storage can be 100% secure. We constantly improve security systems but cannot completely exclude unforeseen events (e.g., hacking). In case of data leakage or unauthorized access, we promptly notify users and competent authorities (if required by law) and take necessary steps to minimize consequences.
Our Website may be used by users from different countries; therefore, data may sometimes be transferred to servers outside your country of residence. The main Operator is located outside Russia, and some partners (analytics, email services) may also be abroad.
For transfers outside Russia, we ensure the receiving country provides adequate legal protection. If the country is not recognized as providing sufficient protection, we transfer data only with written consent or based on other legal grounds (e.g., contract performance).
By using the Website and providing data, you agree to possible cross-border transfers for the purposes outlined in this Policy, with required safeguards. We ensure foreign recipients adhere to the same confidentiality and security requirements as in Russia.
Our Website is not intended for persons under 18, and we do not knowingly collect personal data of children. If you are under 14, you must not provide personal data without parental or guardian consent. Parents are strongly encouraged to monitor their children’s online activity. If we discover that a child under 14 has provided personal data without confirmed parental consent, we will delete it.
If you are a parent or guardian and you know your child has provided data to us, please contact us using the details in Section 9 so we can delete such data.
Each user whose personal data is processed under this Policy has the rights granted by personal data legislation and by our Company. We respect these rights and strive to ensure their exercise.
You may request confirmation of whether your personal data is being processed, as well as information about which data we hold, on what basis and for what purpose they are processed, to whom (if anyone) such data has been disclosed, and other information required by Article 14 of Federal Law 152-FZ. We will provide a clear report within a reasonable period (no later than 30 days from receipt of the request unless otherwise required by law).
If you find that your personal data is outdated, incomplete, or inaccurate, you may request correction or supplementation. You may edit profile data in your account settings or request support assistance (with identity verification to prevent unauthorized changes).
If processing is based on your consent (e.g., newsletters or analytical/advertising cookies), you may withdraw your consent at any time. You may also request deletion of your personal data if they are no longer needed for stated purposes or if processing violates the law.
Note: the right to deletion is not absolute—e.g., we cannot delete financial transaction data required by law, but such data will be blocked from other uses.
You may demand temporary restriction of processing (except storage) if you dispute data accuracy or legality until verification is complete.
You may object to personal data processing when we lack legal grounds to continue. For example, you may demand termination of marketing communications. Each email contains an unsubscribe link. You may also disable cookies used for personalized ads via Website or browser settings.
If you believe we violate data processing rules, you may file a complaint with us—we will promptly investigate. You may also contact the Russian data protection authority (Roskomnadzor) or the courts.
To exercise your rights, you may send us an official request (see Section 9). The request must include identifying information (e.g., full name and account email). We will fulfill or lawfully reject your request within statutory deadlines.
We regularly review this Policy and may update it to reflect changes in Website functionality or legal requirements. When updated, we change the “last updated” date at the beginning. In case of significant changes (e.g., types of collected data or processing purposes), we will notify registered users via email and/or a notice on the Website before changes take effect.
We recommend periodically reviewing this page to stay informed of how we protect your information. Continued use of the Website after the new version takes effect constitutes your acceptance. If you disagree, you may stop using the Website and request data deletion per Section 8.
If you have questions, comments, or complaints regarding this Policy or personal data processing, you may contact us:
Email: support@hebrewerry.com
Postal address: Early Stage LTD, House of Francis, Room 303, Ile Du Port, Mahé, Seychelles
Feedback form: https://hebrewerry.com/feedback
We review all inquiries and are ready to assist within our competence. Upon request, we will provide information about stored data, correct inaccuracies, or delete data if you exercise your right to erasure, subject to legal requirements.
Thank you for taking the time to read our Privacy Policy. We value your trust and do everything possible to ensure your personal data is protected. Use the Website with confidence—your privacy is important to us!
Last updated: July 17, 2025