Privacy Policy

Version 2.1 - Effective 2026-10-15 - WIZDOM Circles

Who Controls Your Data

The data controller for this site and for WIZDOM Circles is:

Gil Luxenbourg
Israeli sole trader (עוסק מורשה)
HaGilboa 8, Ra'anana
Israel

Gil Luxenbourg is the named contact for every privacy question, access request and deletion request, and acts as the designated privacy contact for the purposes of Israel’s Protection of Privacy Law and Quebec’s Law 25. Reach him through the WIZDOM contact form with “Privacy Request” in the subject line.

Introduction

WIZDOM Circles 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: none. We run no Google Analytics, no advertising pixel, no retargeting tag and no visitor-level analytics product of any kind. Our host, Cloudflare, keeps ordinary server logs in order to deliver and protect the site; we do not use them to build a picture of you.

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 submitting a request via the contact form with "Withdraw Consent" in the subject line.

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 delivery and security is provided by Cloudflare under Cloudflare’s privacy terms.
• Video is served by YouTube in privacy-enhanced mode (youtube-nocookie.com), which does not set tracking cookies unless you press play.
• 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, and our email delivery provider) strictly to operate the service. Recordings and intake responses are never shared with anyone other than you.

Cookies and Analytics

This site sets no advertising, analytics or tracking cookies. There is no cookie banner because there is nothing to ask you to consent to. That is a deliberate design choice, not an oversight.

Three third parties can set a cookie, and only when you choose to involve them:

• Video. Videos are embedded through youtube-nocookie.com, which sets nothing until you press play. If you never press play, nothing is set.
• Payment. If you go to checkout, PayPal sets what it needs to process your payment and prevent fraud. That is strictly necessary to the transaction you asked for.
• Security. Cloudflare may set a security cookie to tell a human visitor from an attack. This is strictly necessary to keep the site up.

If we ever add analytics, we will ask for your consent first, through a banner that blocks the script until you actively accept, with rejecting made exactly as easy as accepting. Until that day this section will keep saying what it says now.

Do Not Track and Global Privacy Control

We honour the Global Privacy Control (GPC) signal. Since we do not sell or share personal data for advertising and run no targeted advertising, there is in practice nothing for the signal to switch off - but if that ever changes, GPC will be treated as a valid opt-out request in every jurisdiction that recognises it, including California, Colorado, Connecticut, Oregon, Delaware and Montana.

If You Are Outside Israel

European Union, EEA and United Kingdom. Where the GDPR or UK GDPR applies, you hold the rights listed above plus the right to data portability, the right to object to processing based on legitimate interests, and the right to lodge a complaint with your national supervisory authority. Our lawful bases are your consent for marketing email and for health information, performance of a contract for anything you have bought, and our legitimate interest in running and securing the service. Consent is as easy to withdraw as it was to give.

United States. Depending on your state you may have the right to know what we hold, to correct it, to delete it, to obtain a portable copy, and to opt out of sale, sharing and targeted advertising. We do not sell or share personal data and do not advertise to you based on it. We do not discriminate against anyone who exercises a privacy right.

Canada. PIPEDA applies to our handling of Canadian residents’ data. If you are in Quebec, Law 25 applies: you may ask for your data to be de-indexed, anonymised or deleted, and you may ask for a copy in a portable format. Our designated privacy contact is named under Contact below.

Marketing email, everywhere. We only send marketing email to people who actively ticked a box asking for it. We keep a record of when, from which page, and the exact wording shown at the time. Every marketing email identifies the sender, carries a postal address, and unsubscribes you in one click. We never re-add an address that has unsubscribed without fresh, explicit consent.

Contact

For privacy questions, data access requests, correction or deletion requests, use the WIZDOM contact form with "Privacy Request" in the subject line. Every submission is read by Gil personally, and we respond to verified requests within 30 calendar days.

Gil Luxenbourg
Israeli sole trader (עוסק מורשה)
HaGilboa 8, Ra'anana
Israel

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 - submit a request through the WIZDOM contact form 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.