Privacy Policy
Last updated: September 23, 2026
This Privacy Policy governs the processing of personal data collected through The Spirit of Sales (https://thespiritofsales.ai/).
The Data Controller responsible for your personal data is Alon Roth (“Website Owner”, “we”, “us”). We operate in strict compliance with the Israeli Privacy Protection Law, 5741-1981, the Protection of Privacy Regulations (Data Security), 5777-2017, and applicable international privacy frameworks, including the California Consumer Privacy Act (CCPA/CPRA) for U.S. residents.
1. Adult Authorization and Supervision of Minors, and Credit Card Verification
The Platform is designed for legal adults (18 years of age or older) and minors supervised by adults. We do not knowingly collect personal data directly from unsupervised minors under the age of 13 or 18 without adult consent.
- All financial transactions are completed via credit card processing. Executing a payment via credit card serves as conclusive legal verification that the transaction is conducted by a legal adult, or under the explicit authorization, supervision, and consent of a parent or legal guardian.
- Any personal data associated with an account used by an authorized minor is deemed collected under valid parental/guardian authorization. If a parent or guardian discovers that a minor has submitted personal data without authorization, they may contact privacy@thespiritofsales.ai to request data deletion.
2. Comprehensive Categories of Information We Collect
We process data directly provided by you, automatically logged by your device, or received via third-party integrations:
- Account & Contact Data: Full name, email address, account password hashes, and profile information provided during direct registration or authenticated via Single Sign-On (SSO) providers (Google Sign-In, Apple ID).
- Financial & Payment Processing Data: Payment method details, transaction amounts, timestamps, and payment status. Full credit card numbers are processed exclusively by PCI-DSS compliant gateways (e.g., Stripe) and are never stored on our servers.
- Online Viewing Access & Usage Logs: Data tracking user dashboard authentication, e-book chapter viewing sessions, audio playback timestamps, and completed learning milestones.
- AI Coach Interaction Data: Text prompts, audio voice inputs, sales simulation responses, and objection-handling exercises submitted to the “Ask Alon” AI Sales Coach.
- Community Chat & Direct Communications: Public posts, replies, comments, direct peer messages, uploaded media, and feedback submitted within the SalesSpirit Community feeds.
- Referral & Gamification Analytics: Unique referral tracking link usage, invitation counters, certification badges earned, and positioning metrics displayed on public leaderboards and ticker-strip marquees.
- Technical & Log Data: IP address, browser type, operating system, device hardware specifications, internet service provider, time zones, referral URLs, and cookie metadata.
3. Lawful Bases and Purposes of Processing
We process personal data under the following legal grounds and business purposes:
- Contract Performance: Enabling user accounts, processing e-book access payments, providing online viewing access, and facilitating core platform functionality.
- Legitimate Business Interests: Maintaining system security, enforcing anti-piracy controls, detecting fraudulent credit card transactions, analyzing usage trends, moderating community chat feeds, operating AI response engines, and updating leaderboard rankings.
- Legal Obligation: Retaining tax records, commercial billing logs, and responding to statutory legal demands or court orders.
- Explicit Consent: Delivering direct marketing updates, promotional notifications, and non-essential cookie tracking (which may be withdrawn at any time).
4. Third-Party Data Disclosures and AI Processing
We do not sell, rent, or trade personal information to third parties for monetary compensation. Data is shared strictly with essential service providers bound by strict confidentiality obligations:
- Third-Party Service Vendors: Data is processed by secure cloud hosting providers, PCI-DSS compliant billing gateways (Stripe), email transmission platforms, and analytics engines (Google Analytics).
- AI Processing Providers: Prompts and audio inputs entered into the “Ask Alon” AI Coach are transmitted securely via API connections to third-party generative AI models (e.g., OpenAI API) solely to output real-time training feedback. AI prompts submitted by users shall not be treated as confidential trade secrets.
- Public Community & Leaderboard Display: User display names, profile avatars, certification tiers, and championship rankings are publicly displayed on the SalesSpirit leaderboard, moving ticker-strip marquee, and community feeds visible to other registered members.
5. International Data Transfers
Personal data collected through the Platform may be stored, processed, or transferred across servers located outside your country of residence (including servers in Israel, the United States, and the European Union). Transfers are executed under appropriate technical safeguards ensuring a level of data protection consistent with Israeli Privacy Protection Law and applicable international privacy standards.
6. Data Security and Technical Safeguards
We maintain administrative, technical, and physical security measures compliant with the Israeli Protection of Privacy Regulations (Data Security), 5777-2017. These controls include SSL/TLS data encryption in transit, tokenized payment handling, restricted database access controls, and firewall monitoring.
Despite robust safeguards, no online system is 100% immune to unauthorized access or cyber intrusions. The Website Owner disclaims liability for data exposure resulting from advanced cyber-attacks, third-party infrastructure failures, or Force Majeure events beyond reasonable control.
7. Data Retention and Erasure Schedules
Personal data is retained only for as long as necessary to fulfill the purposes set out in this Policy:
- Account Data: Retained for the duration of your active platform access and for up to 24 months post-inactivity.
- Billing & Tax Records: Retained for seven (7) years to comply with statutory Israeli and international accounting, tax, and audit obligations.
- Community Posts & AI Interactions: Retained for platform operation, moderation logs, and system optimization.
8. User Data Subject Rights
In accordance with Section 13 and Section 14 of the Israeli Privacy Protection Law, 5741-1981, and applicable U.S. state regulations (CCPA/CPRA), users possess specific privacy rights:
- Right of Inspection & Access: Request confirmation and a copy of the personal data held about you.
- Right of Rectification: Request correction or updating of inaccurate, incomplete, or outdated personal information.
- Right of Deletion: Request the erasure of your personal data, subject to statutory retention exceptions (e.g., tax logs).
- Opt-Out Rights: Opt-out of marketing communications via the “Unsubscribe” link in any promotional email.
To exercise any privacy rights, submit a verifiable request to alonroth11@gmail.com. Requests are processed within 30 days without discrimination.
9. Cookies and Tracking Technologies
The Platform utilizes essential session cookies required for user login authentication and browser-based e-book viewing.
Analytics cookies (e.g., Google Analytics) are used to measure platform traffic and user engagement.
You may manage or block non-essential cookies via your web browser settings, though doing so may impact platform functionality.
10. Governing Law and Exclusive Jurisdiction
This Privacy Policy and all privacy-related claims shall be governed exclusively by the laws of the State of Israel. Any legal dispute arising under this Policy shall be submitted to the exclusive jurisdiction of the competent courts in Israel.