Privacy Policy

1. Introduction
This Privacy Policy explains how Medicalix Ltd. / מדיקליקס בע"מ, company number 514891928, with its registered address at 6 HaShfela Street, Kochav Yair 4486400, Israel (“Medicalix”, “the Company”, “we”, “us”), collects, uses, stores and processes personal information in connection with its website at:
https://www.medicalix.com/
This Policy applies to the use of the Medicalix website, information submitted or collected through website inquiries, business inquiries, cookies and analytics tools, and, where relevant, Pharmacovigilance/Vigilance activities as described in Appendix A.
This Policy is intended to address Israeli privacy laws, including the Israeli Protection of Privacy Law, 5741-1981, regulations issued under it, including the Protection of Privacy Regulations (Data Security), and other applicable Israeli legal requirements as amended from time to time.
2. Who we are and our role in relation to personal information
Medicalix provides professional services to companies in the fields of pharmaceuticals, medical devices, cosmetics, food supplements, biocides and other medical or health-related products, including Pharmacovigilance, Vigilance and Medical Information services.
In relation to information collected through the website, such as contact form inquiries, website usage data, cookies and analytics tools, Medicalix generally acts as the controller of the relevant database.
In relation to Pharmacovigilance/Vigilance activities performed for Medicalix clients, Medicalix generally acts as a service provider and information holder/processor on behalf of its clients, while the clients act as the controllers of the relevant information. However, in certain cases Medicalix may also process information in order to comply with legal obligations, regulatory requirements, Ministry of Health procedures, contractual commitments and professional obligations that apply to Medicalix or to its clients.
Medicalix complies with its obligations under Israeli privacy laws, including with respect to database management, data security, appointment of a Data Protection Officer, notices and reports to the competent authority, to the extent such obligations apply to Medicalix under applicable law.
3. What information we collect through the website
When you use the website, Medicalix may collect the following categories of information.
3.1 Information you provide voluntarily
When you submit an inquiry through the website contact form, we may collect:

• Name;

• Phone number;

• Email address;

• The content of your message.

The website does not include a personal account area, user accounts, a customer portal, file upload functionality, online purchase of services, online payments, a careers page, CV submission or newsletter registration.
3.2 Technical and website usage information
When you visit the website, technical and statistical information may be collected, including:

• IP address;

• Browser type;

• Device type;

• Operating system;

• Pages viewed on the website;

• Visit times;

• Actions performed on the website, such as clicks, scrolling and interactions with pages;

• Performance, error and security data;

• Information collected through cookies and similar technologies.

Some of this information is collected through third-party services, including Wix, Google Analytics / GA4, Google Tag Manager, Google Ads, Microsoft Clarity and Wix Analytics, as further described in Appendix B.
4. Are you required to provide information
You are not legally required to provide us with personal information. However, if you choose not to provide certain details, such as your name, email address or phone number in the contact form, we may not be able to handle your inquiry, respond to you or continue the business relationship.
In relation to Pharmacovigilance/Vigilance reports, certain information may be required in order to review, document, assess, report and follow up on a safety event, in accordance with applicable law, Ministry of Health procedures and relevant professional requirements. Further details appear in Appendix A.
5. Purposes of processing
Medicalix may use personal information for the following purposes:

1. Receiving and handling website inquiries;

2. Contacting individuals who submit inquiries and responding to them;

3. Managing business relationships with clients, suppliers, business partners and prospective clients;

4. Operating, maintaining, securing and improving the website;

5. Analyzing website usage and improving user experience;

6. Measuring campaign performance and advertising activity through Google Ads, without remarketing based on the information provided to us;

7. Preventing misuse of the website, identifying technical issues and managing information security risks;

8. Complying with legal requirements, regulatory instructions, orders, procedures and legal obligations;

9. Protecting the rights of Medicalix, its employees, clients, suppliers and third parties;

10. Performing Pharmacovigilance/Vigilance activities, where relevant, as described in Appendix A.

Medicalix does not use the contact details of individuals who contact us through the website for marketing emails, marketing SMS messages or marketing WhatsApp messages. If Medicalix introduces direct marketing activity in the future, it will do so in accordance with applicable law, including obtaining consent where required and providing an opt-out option from any marketing communication.
6. Medical information and sensitive personal information
In the ordinary use of the website, Medicalix does not request users to provide medical information or sensitive personal information through the contact form.
However, as part of Pharmacovigilance/Vigilance activities, Medicalix may process medical information and sensitive personal information, including information about medical condition, medicines, adverse events, medical tests, allergies, pregnancy, details of medical events and reporter details. Such information is processed only to the extent required for Pharmacovigilance/Vigilance purposes, compliance with Ministry of Health procedures, compliance with legal obligations and provision of services to Medicalix clients. Further details appear in Appendix A.
7. To whom we may disclose information
Medicalix does not sell personal information to third parties.
Medicalix may disclose personal information, as necessary and in accordance with applicable law, to the following recipients:

1. Technology, hosting, website operation and email service providers, including Wix and Microsoft 365;

2. Measurement, analytics and advertising providers, including Google, Microsoft Clarity and Wix Analytics;

3. Professional advisers, where required, such as legal, regulatory, accounting or information security advisers;

4. Competent authorities, where required by law, order, regulatory requirement or binding procedure;

5. Medicalix clients, in connection with professional services provided to them, particularly Pharmacovigilance/Vigilance services;

6. The Israeli Ministry of Health, where required or necessary under applicable law, Ministry of Health procedures or the circumstances of the report;

7. Third parties in connection with legal proceedings, investigations, enforcement, merger, restructuring, sale of activity or protection of rights.

Information will be disclosed only to the extent necessary for the relevant purpose and subject to reasonable safeguards intended to protect the information.
8. External service providers, outsourcing and processing
The Medicalix website is hosted and managed through Wix. Contact form inquiries are stored or received through Wix Inbox and Microsoft 365. As of the last update of this Policy, Medicalix does not use an additional CRM system for website inquiries.
The Company may use external providers for website operation, hosting, email, information security, analytics, usage measurement and related services. These providers may process personal information only for the purpose of providing the relevant services to Medicalix and subject to agreements, provider policies and applicable law.
Medicalix acts to regulate its engagements with external providers that process personal information on its behalf in accordance with applicable law, including assessing information security risks, defining the purposes for which information may be used, restricting use of the information to the relevant services, maintaining confidentiality, applying data security measures and restricting further transfers of information to additional parties, to the extent required by law.
9. Transfers of information outside Israel
Medicalix operates in Israel and this Policy is intended to address Israeli law. However, because the Company uses international providers such as Wix, Microsoft, Google and Microsoft Clarity, personal information may be processed or stored outside Israel in accordance with the policies, terms of service and agreements of those providers.
Any transfer of personal information outside Israel, where applicable, will be carried out in accordance with Israeli law, including the Protection of Privacy Regulations relating to the transfer of information to databases outside the borders of Israel, and subject to appropriate commitments by the recipients to protect privacy and data security, to the extent required by law.
In connection with Pharmacovigilance/Vigilance activities, when information from Pharmacovigilance/Vigilance reports is transferred to Medicalix clients outside Israel, Medicalix acts to transfer it after removal of identifying details and de-identification/anonymization, so that the information does not identify the patient or the reporter, including removal of names, contact details and other direct identifiers, to the extent possible and in accordance with applicable law, Ministry of Health procedures and relevant professional requirements.
10. Retention of information
Medicalix retains personal information only for as long as necessary for the purposes for which it was collected, or for a longer period where required by law, regulatory procedures, contractual obligations, reasonable business needs or the protection of legal rights.
In general:

1. Contact form inquiries are retained for as long as required to handle the inquiry, continue the business relationship, maintain reasonable internal records, protect Medicalix’s rights and comply with legal obligations.

2. Pharmacovigilance/Vigilance reports are retained in accordance with Ministry of Health procedures and applicable law.

3. Technical logs and security data are retained in accordance with Wix settings and the settings of relevant providers, and for the period required for website operation, security, misuse prevention and troubleshooting.

4. Cookie data is retained in accordance with the type of cookie, website settings, user choices and the policies of the relevant providers.

11. Information security
Medicalix places great importance on the security of personal information, especially medical information and sensitive personal information.
Medicalix complies with its obligations under the Protection of Privacy Regulations (Data Security), according to the types of information it processes, the sensitivity and scope of such information and the applicable data security level of the relevant databases.
The Company implements technical, organizational and administrative measures intended to protect personal information against unauthorized access, misuse, loss, alteration, disclosure or other compromise. These measures include, among others:

• Access permissions limited by role and need to know;

• Personal passwords;

• Two-factor authentication / MFA in relevant systems;

• Encryption where appropriate;

• Backups;

• Limiting access to information to authorized employees, consultants and service providers only;

• Confidentiality undertakings by employees and consultants exposed to personal or medical information;

• Internal procedures for handling information security incidents or suspected data breaches.

No system is completely immune to information security risks. Therefore, Medicalix cannot guarantee absolute protection, but it applies reasonable and accepted measures to reduce such risks.
12. Your rights regarding personal information
Subject to applicable law, you may have rights regarding personal information about you, including:

1. The right to review personal information about you held by Medicalix;

2. The right to request correction of information that is incorrect, incomplete, unclear or outdated;

3. The right to request deletion, cessation of use or restriction of use of information, where permitted by law;

4. Rights in connection with direct marketing, if such activity is introduced in the future;

5. The right to contact the Israeli Privacy Protection Authority.

Requests to exercise rights may be sent to:
info@medicalix.com
Medicalix will handle requests in accordance with the timelines and requirements set by law. In some cases, Medicalix may not be able to comply with a request, in whole or in part, for example where there is a legal, regulatory or professional obligation to retain the information, including in connection with Pharmacovigilance/Vigilance, or where retention is required to protect legal rights.
13. Minors
The Medicalix website is not specifically directed at minors.
If Medicalix receives a Pharmacovigilance/Vigilance report that includes information about a minor, such information will be processed only to the extent required under applicable law, Ministry of Health procedures, the purposes of the report and the relevant circumstances, as described in Appendix A.
14. Cookies and similar technologies
The website uses cookies and similar technologies for website operation, improving user experience, analyzing website usage and measuring performance. Full details appear in Appendix B.
The website includes a Cookies banner that enables users to manage different categories of cookies, including Essential Cookies, Marketing Cookies, Functional Cookies and Analytics Cookies. Essential Cookies are required for the operation of the website and cannot be disabled through the banner.
15. Changes to this Policy
Medicalix may update this Policy from time to time, including due to changes in law, technologies used, providers, services or website operations.
The last updated date will appear at the top of this Policy. In the event of a material change, Medicalix will take reasonable steps to publish an appropriate notice on the website or by another means, at its discretion and in accordance with applicable law.
16. Contact us
For questions, requests or inquiries regarding privacy and data protection, you may contact the Medicalix Data Protection Officer at:
info@medicalix.com
Appendix A: Pharmacovigilance / Vigilance
1. Purpose of this Appendix
This Appendix explains how Medicalix may process personal information in connection with Pharmacovigilance/Vigilance activities, meaning activities related to the identification, documentation, assessment, review, follow-up and reporting of adverse events, unusual events, undesirable reactions or special situations related to medical and health-related products.
This Appendix applies, as relevant, to medicines, medical devices, cosmetics, food supplements, biocides and other medical or health-related products.
2. How reports are received
Medicalix may receive Pharmacovigilance/Vigilance reports from various sources, including:

• Patients;

• Consumers;

• Healthcare professionals;

• Medicalix clients;

• Pharmaceutical, medical device or health product companies;

• Other parties involved in the report or in the handling of the event.

As of the last update of this Policy, the website does not include a dedicated adverse event reporting form. Reports are received by email, telephone, Medicalix clients or other dedicated reporting channels made available by Medicalix or its clients, depending on the circumstances and applicable procedures.
3. Role of Medicalix
In Pharmacovigilance/Vigilance activities, Medicalix generally acts as a service provider and information holder/processor on behalf of its clients, while the clients act as the controllers of the relevant information.
However, Medicalix may also process information in order to comply with legal obligations, regulatory requirements, Ministry of Health procedures, contractual commitments and professional obligations that apply to Medicalix or its clients.
4. Categories of information that may be collected
In connection with a Pharmacovigilance/Vigilance report, personal information and sensitive personal information may be collected, as necessary and depending on the circumstances of the report.
4.1 Information about the patient or the person to whom the report relates
Such information may include, among other things:

• Name or initials, if provided and required;

• Date of birth, age or age group;

• Gender;

• Weight and height;

• Contact details, where required for review and follow-up;

• Medical information;

• Medical history and clinical condition;

• Description of the adverse event, unusual event or special situation;

• Start date, duration, seriousness and outcome or development of the event;

• Details of the suspected product, including product name, use, dosage, start date, stop date and route of administration;

• Therapeutic indication;

• Other medicines or products used concomitantly;

• Previous reactions to the same product;

• Suspected interaction;

• Test results, diagnoses, clinical information and medical findings;

• Allergies;

• Pregnancy information, where relevant;

• Medical assessment regarding a possible causal relationship between the product and the event;

• Any additional information required for review, documentation, assessment and reporting.

4.2 Information about the reporter
Information about the reporter may include:

• Name;

• Contact details, such as email, phone number or address;

• Profession or role, for example whether the reporter is a healthcare professional;

• The reporter’s relationship to the patient or to the event;

• The content of the report and information provided during follow-up.

5. Purposes of processing
Medicalix may process information in connection with Pharmacovigilance/Vigilance for the following purposes:

1. Receiving, documenting and managing reports;

2. Identifying safety events, adverse events, undesirable reactions and special situations;

3. Reviewing, assessing, analyzing and following up on the event;

4. Contacting the reporter to obtain additional information, where required;

5. Preparing reports for Medicalix clients;

6. Reporting to the Ministry of Health where necessary and in accordance with Ministry of Health procedures and applicable law;

7. Complying with legal requirements, regulatory procedures, contractual commitments and professional obligations;

8. Protecting public health and product safety and quality.

6. Disclosure of information in Pharmacovigilance/Vigilance activities
Personal information in connection with Pharmacovigilance/Vigilance may be disclosed to:

1. Relevant Medicalix clients;

2. The Israeli Ministry of Health, where required or necessary under applicable law, Ministry of Health procedures or the circumstances of the report;

3. Service providers assisting Medicalix with operations, information security, hosting or information systems, where required;

4. Professional advisers or other authorized parties, where required by law or for handling the event;

5. Other competent authorities or bodies where there is a legal obligation or authority to disclose the information.

When information from Pharmacovigilance/Vigilance reports is transferred to Medicalix clients outside Israel, Medicalix acts to transfer it after removal of identifying details and de-identification/anonymization, so that the information does not identify the patient or the reporter, including removal of names, contact details and other direct identifiers, to the extent possible and in accordance with applicable law, Ministry of Health procedures and relevant professional requirements.
7. Retention of Pharmacovigilance/Vigilance information
Information relating to Pharmacovigilance/Vigilance reports is retained in accordance with Ministry of Health procedures, applicable law, contractual commitments and relevant professional obligations.
In some cases, rights such as deletion or restriction of use may be limited due to a regulatory or professional obligation to retain information for product safety, public health, documentation and reporting purposes.
8. Information about minors
If a Pharmacovigilance/Vigilance report includes information about a minor, such information will be processed only to the extent required under applicable law, Ministry of Health procedures, the purposes of the report and the relevant circumstances.
9. Rights of data subjects
Data subjects may contact Medicalix to exercise their rights under applicable law, including requests for access and correction. Medicalix will handle such requests in accordance with the timelines and requirements set by law.
Some rights may be limited where it is necessary to retain the information in order to comply with Pharmacovigilance/Vigilance obligations, Ministry of Health requirements, legal obligations or public health protection requirements.
Appendix B: Cookies Policy
1. What are cookies
Cookies are small files or similar technologies that are stored on a user’s device or browser when visiting a website. Cookies may be used to operate the website, save preferences, analyze website usage, measure performance and improve user experience.
For the purposes of this Appendix, “cookies” also includes similar technologies such as tags, scripts, online identifiers, pixels and measurement tools.
2. Cookie categories on the website
The Medicalix website includes a Cookies banner that allows users to manage different categories of cookies:
2.1 Essential Cookies
Essential Cookies are required for the proper operation of the website, security, page loading, saving basic preferences and operating the cookie consent management mechanism. These cookies cannot be disabled through the banner.
2.2 Functional Cookies
Functional Cookies are used to improve user experience, save preferences and enable certain website features.
2.3 Analytics Cookies
Analytics Cookies are used to understand how the website is used, measure visits, analyze viewed pages, visit duration, clicks, scrolling and interactions with the website.
2.4 Marketing Cookies
Marketing Cookies are used to measure campaign performance and advertising activity. Based on the information provided to us, the website uses Google Ads for conversion and campaign performance measurement, but does not use remarketing.
3. Tools used on the website
The website may use the following tools:

1. Wix and Wix Analytics
   For website operation, website management, basic usage measurement, security and service improvement.

2. Google Analytics / GA4
   For analyzing website usage, measuring visits, viewed pages, traffic sources and interactions on the website.

3. Google Tag Manager
   For managing tags and measurement tools on the website.

4. Google Ads
   For measuring campaign performance and conversions. Based on the information provided to us, remarketing is not used.

5. Microsoft Clarity
   For analyzing user experience, including session recordings, heatmaps, clicks, scrolling and website interactions. This tool is intended to help identify usability issues and improve the website. Microsoft Clarity is not intended to collect the content of medical inquiries, Pharmacovigilance reports or personal medical information.

Based on the information provided to us, the website does not use Meta Pixel / Facebook Pixel, LinkedIn Insight Tag, YouTube/Vimeo, Google Maps, chat tools or external forms.
4. Managing cookie preferences
You can manage cookie preferences through the Cookies banner on the website. Users can choose which cookie categories to approve, except for Essential Cookies that are required for the operation of the website.
You can also block or delete cookies through your browser settings. Blocking certain cookies may affect your website experience or the functionality of certain features.
Non-essential cookies and measurement tools, including Analytics Cookies and Marketing Cookies, will operate in accordance with the user’s choices in the Cookies banner and the technical configuration of the website. Medicalix acts to ensure that non-essential tools are activated only in accordance with the user’s consent or relevant choice, to the extent required under applicable law.
5. Changes to this Cookies Policy
Medicalix may update this Cookies Appendix from time to time, including due to changes in tools, providers, technologies or legal requirements.