Privacy Policy

Version 1.1 — Effective 2026-04-30 — WIZDOM AI / gil@gilluxenbourg.com

Introduction

WIZDOM AI is a patient education service operated by Gil Luxenbourg from Israel, serving patients globally. This policy describes what personal data we collect, why we collect it, where it is stored, how long it is kept, and the rights you have over it. We treat health-related information with the level of care it deserves. We do not sell data to third parties, ever.

Data We Collect

We collect the following categories of information:

• Identifying information you provide: name, email address, country of residence.
• Health intake information: your responses to the 24-question WIZDOM intake, which includes a medical baseline relevant to designing a cannabis education protocol.
• Call recordings and transcripts, only when you consent to recording at the start of a call.
• Payment receipts and transaction metadata via PayPal. WIZDOM does not store full payment-card details.
• Website analytics: aggregate usage data through Cloudflare Web Analytics (privacy-friendly, no cookies) and Google Analytics 4 (uses cookies for event tracking).

Lawful Basis for Processing

We process health-related information on the basis of your explicit consent, given at the time of intake, combined with our legitimate interest in providing the patient-education service you have requested. You may withdraw consent at any time by emailing gil@gilluxenbourg.com.

Pseudonymization — Two-Zone Architecture

We apply pseudonymization (a technical measure recognized under GDPR Article 32 and equivalent privacy frameworks) to limit the impact of any potential data exposure. In practice this means we operate two zones:

• An identity zone that links your name, email, and payment receipt to a unique patient identifier of the form `WZ-YYYY-NNNN`.
• A medical zone that stores your intake responses, personalized program documents, and notes — referenced only by the patient identifier, never by your name.

The mapping between identifier and identity is held in a single restricted location. A breach of the medical zone alone would yield pseudonymous data, not full health records linked to identifiable individuals. This does not eliminate all risk — patient-facing email correspondence by its nature links identity and content — but it materially reduces the exposure surface of the practice's largest data assets.

Where Data Is Stored

• Intake responses, email correspondence, calendar bookings, and call recordings are stored within Google Workspace, on Google's Israel and European Union infrastructure. Standard Contractual Clauses (SCCs) apply to any cross-border transfer.
• Payment data is held by PayPal under PayPal's privacy terms and applicable Data Processing Agreement.
• Website CDN and analytics data is processed by Cloudflare under Cloudflare's privacy terms.
• Google Analytics 4 data is processed by Google under Google's privacy terms.
• The patient-identifier mapping (see Pseudonymization above) is held within Google Workspace under access controls limited to the sole operator.

How Long We Keep It

• Intake data is retained for five (5) years after the end of your engagement, so that we can support follow-up questions and protocol iteration. You may request earlier deletion.
• Call recordings and transcripts are retained for thirty (30) days unless you request a longer retention period in writing.
• Payment receipts are retained for the period required by Israeli tax law (currently seven years).
• Email correspondence is retained for the duration of the business relationship plus two years.

Your Rights

Patients in any jurisdiction are granted the following rights, modeled on the GDPR standard:

• The right to access the personal data we hold about you.
• The right to correct inaccurate information.
• The right to request deletion of your data, subject to retention requirements imposed by Israeli tax law for payment records.
• The right to receive a copy of your data in a portable format.
• The right to withdraw consent for processing at any time.

We respond to verified requests within thirty (30) calendar days.

Data Sharing

We do not sell, rent, or trade personal data to any third party. Data is shared only with the service providers listed above (Google Workspace, PayPal, Cloudflare, Google Analytics) strictly to operate the service. Recordings and intake responses are never shared with anyone other than you.

Cookies and Analytics

Cloudflare Web Analytics is privacy-first and does not set cookies or fingerprint visitors. Google Analytics 4 uses cookies to measure aggregate site usage and event flow. You can disable analytics cookies through your browser settings or by using a tracking-protection extension without losing access to any WIZDOM service.

Contact

For privacy questions, data access requests, or deletion requests:

gil@gilluxenbourg.com

Security Measures

We apply the following safeguards:

• Two-factor authentication on every system that holds patient data (Google Workspace, PayPal, Streak, Cloudflare).
• Pseudonymization of medical-zone data as described above.
• Encryption of data at rest (Google Workspace default) and in transit (TLS).
• Sole-operator access — no shared logins or contractor access in V1.
• Strong unique passwords managed via password manager.
• Verbal recording-consent reaffirmation at the start of every call.

A more detailed internal record of our processing activities and risk assessment is maintained in a Data Protection Impact Assessment document, available on request to a relevant supervisory authority.

How to Make a Privacy Request

To exercise any of the rights listed above — access, correction, deletion, portability, or withdrawal of consent — email gil@gilluxenbourg.com with "Privacy Request" in the subject line. We respond within thirty (30) calendar days. Where verification of identity is required, we will ask for it before disclosing or modifying records.

Jurisdiction

This policy is governed by the laws of the State of Israel. Where local law in your country grants stronger rights, those local rights apply. Patients may also lodge a complaint with their national supervisory authority — for example the Israeli Privacy Protection Authority, an EU member-state Data Protection Authority, the UK Information Commissioner's Office, the Office of the Privacy Commissioner of Canada, or the Australian Office of the Australian Information Commissioner.