Privacy Policy
1. General
1.1 We at SKcure Ltd., Company No. 517152179, located at 94 Yigal Alon St., Alon Tower 2, 19th Floor, P.O. Box 146, Tel-Aviv 6789139 (the "Company"), attach great importance to the protection of the privacy of users of this platform (the "Platform").
1.2 This Privacy Policy applies to your use of the Platform, regardless of how you access or use it, including:
1.2.1 when you use the Platform, whether via your computer, mobile device, or any other device, and whether you connect to the services through a website and/or any application;
1.2.2 telephone calls, emails, other electronic messages including SMS, internet chats, audio and/or video calls conducted via the Platform, browsing the website/portal, and any other form of communication between you and the Company in connection with the Platform and/or its related services.
1.3 We implement advanced security measures to protect the information on the Platform. These security measures are intended to mitigate the risks of breaches, data leaks, and misuse of information stored on the Platform and to ensure the level of privacy protection required by law and in accordance with best practices.
1.4 Considering the sensitivity of the information stored on the Platform, including users’ medical information, we exercise heightened caution to comply with international privacy standards, including the U.S. HIPAA standard, which establishes a uniform framework for the management, storage, and transfer of medical information.
1.5 It is hereby clarified that this Privacy Policy may be updated from time to time at the Company’s sole discretion, as the privacy policy is dynamic and may change as new content and services are added to the Platform, which may also affect the policy. Therefore, we recommend reviewing this Privacy Policy periodically. In the event of material changes regarding the use of personal information, a notice will be published on the Platform.
1.6 This document has been drafted based on the relevant law at the time of writing, and we have made every effort to adapt the policy to legislative changes in the field. It is clarified that nothing in this Privacy Policy is intended to permit the Company to engage in actions prohibited by law.
2. Information Collected
2.1 We collect the following types of information:
2.1.1 Personal Information – information that identifies you as an individual or can be attributed to an identifiable person. Such information may include, but is not limited to, general information such as your name, telephone number, date of birth, gender, location, IP address, email address, and similar data, as well as information related to your health, including information about your medical conditions, symptoms and possible causes, medical history, test results, and any other personal health information.
2.1.2 Non-Personal (Anonymous) Information – information that does not identify and cannot be used to identify users who use the Platform anonymously, as well as information regarding users who have created an account, and anonymous statistical data generated during regular use of the Platform. This information primarily includes technical and aggregated data on usage patterns, such as cumulative statistical analyses of Platform operations, browsing activities, browser information, app usage data, information collected via cookies, pixel tags, and other technologies.
3. Collection of Information Based on Explicit and Informed Consent
3.1 It is clarified that you are not obligated to provide any personal information to the Platform, and the request to provide such information does not constitute a requirement by the Company. The decision whether to provide any information to the Platform is solely yours. However, it is clarified that the Platform’s questionnaires are designed to enable the Platform and the physicians and compounding pharmacies providing their services through it (the “Suppliers”) to offer you services optimally tailored to your personal needs. Failure to provide such information may impair the ability of the Platform and the Suppliers to do so and may negatively affect the medical solution offered to you by an authorized provider. All personal information provided to the Platform will be stored and used solely in accordance with the provisions of this Privacy Policy.
3.2 You may be explicitly requested to share certain information with us. For example, when you create an account on the Platform or contact us through forms and questionnaires on the Platform, email, or by any other means. This information may include, among other things, sensitive personal information regarding your health. The decision to share this information is entirely at your discretion; however, note that the Platform and/or the Suppliers may not be able to provide their services, in whole or in part, without receiving certain information necessary for that purpose. Additionally, the absence of non-essential information that was requested may naturally affect the efficiency of the services or their personal suitability to your specific needs and/or condition.
3.3 In order to verify data or improve the efficiency of the services provided to you by the Platform or the Suppliers, as applicable, it may be necessary to obtain additional data, including medical and/or mental health information about you from authorized third parties, in particular from medical institutions or your healthcare provider, or to share personal information you provided with such third parties. It is clarified that any provision or receipt of such information is subject to your prior consent before the information is transferred. It is clarified that the information transferred pursuant to this section will be used solely for the purposes specified in section 5.1 below.
3.4 If you provide us with personal information regarding other individuals, you represent that you have the authority to do so and that you permit us to use such information in accordance with this Privacy Policy.
4. Automatic Information Collection
4.1 Upon accessing the Platform, you may choose among different levels of anonymous and aggregated information collection through cookies, according to the options presented by the Platform. You may change or withdraw your consent at any time through your browser settings or on the Platform itself. Please note that access to the Platform is conditional upon your consent to the collection of certain anonymous and aggregated information via cookies, as determined by the Company. Without this consent, you will not be able to use the Platform.
4.2 In addition to the information you provide to us voluntarily, in response to explicit requests, or information you allow the Suppliers to share with us, we automatically collect certain anonymous and aggregated information when you visit the Platform. We do this ourselves or with the assistance of third-party services, including through the use of cookies and other tracking technologies, as detailed below.
4.3 The information collected as described in section 4.2 may include your IP address (which may also be associated with your domain name or your Internet service provider’s domain), data related to your use and navigation of the Platform, unique identifiers associated with your mobile device or our application, and your estimated geographic location. We may collect this information in various ways, for example:
4.3.1 Certain information is automatically collected by most browsers or via your device, such as MAC address (Media Access Control), computer type (Mac or Windows), screen resolution, operating system name and version, device manufacturer and model, system language, browser type and version, and the name and version of the Platform software you are using. We use this information to ensure proper functioning of the Platform.
4.3.2 When you download and use the Platform as a mobile application, we may track app usage data, such as the date and time of app access from your device to the Platform servers, and which files or information were downloaded to the app based on your device number.
4.3.3 Certain information is collected via cookies. Cookies are small pieces of information stored directly on the device you are using. Cookies allow us to collect information such as browser type, duration of use of services, pages viewed, language preferences, and other traffic data. We use this information for security purposes, to facilitate navigation, to present information more efficiently, and to personalize the user experience. We also collect statistical information about service usage to continuously improve design and functionality, understand usage patterns, and assist in troubleshooting. If you do not wish to have information collected via cookies, most browsers allow you to automatically reject cookies or choose to accept or reject a particular cookie (or multiple cookies) from a specific site. Please note that doing so may prevent you from fully enjoying the services or receiving service at all, depending on the Company’s determination.
4.3.4 We may use Pixel Tags (also known as Web Beacons) and Clear GIFs to track user actions within the services (including email recipients), measure the effectiveness of marketing campaigns, and compile statistics on service usage and response rates.
4.3.5 We may use third-party analytics services, such as Google Analytics, which employ cookies and similar technologies to collect and analyze information about service usage and report on activity and trends. These services may also collect information about usage of websites, applications, and other online resources.
4.4 To the extent that the Platform enables audio and/or video calls between users and healthcare service providers, such calls are not recorded, documented or stored by the Platform. For the avoidance of doubt, the Platform serves solely as a technological means for conducting such calls and does not retain the content of the calls or any recording or documentation thereof.
5. Permitted Uses of Collected Information
5.1 Your medical information is collected solely for the following medical and operational purposes:
5.1.1 Processing your personal information on the Platform in order to generate information, reports, and personalized feedback tailored specifically for you, based on your personal information, in accordance with the dedicated functionality of the Platform, solely for the purpose of transferring them to qualified healthcare service providers.
5.1.2 Sharing your personal information with the Suppliers to receive the medical solution you ordered from them, to provide medical care for the relevant medical condition, along with the personalized information, reports, and feedback generated by the Platform based on your personal information, which the Supplier who is a physician may consider, at their sole discretion, when providing medical advice. It is clarified that sharing your medical information with the Suppliers (such as physicians and pharmacies) will be done solely for the purpose of the service you ordered and/or offered to you personally on the Platform, in compliance with applicable law. Sensitive medical information (such as data that could harm you if disclosed) will only be provided to authorized physicians, in accordance with the Patient Rights Law, 1996.
5.2 Your personal information that is not medical information is collected solely for the purposes stated above, and additionally for the following purposes:
5.2.1 Providing the Platform functionality for you, such as account access arrangements and customer support, provided that we may limit your access to the information, reports, and personalized feedback generated by the Platform. Such limited information will be accessible to the authorized staff of the Supplier providing the medical solution you ordered.
5.2.2 Responding to your inquiries and fulfilling your requests when you contact us via one of the contact forms on the Platform, by email, or by any other means – for example, when you send us questions, suggestions, feedback, or complaints, or when you request additional information about our services or the services of the Suppliers.
5.2.3 Verifying your details and providing related customer support.
5.2.4 Complying with any legal or regulatory requirements, including for the purpose of defending legal proceedings, to the extent reasonably required.
5.2.5 Sending you administrative information, such as changes to our terms, conditions, and policies.
5.2.6 Providing you with information, via email or otherwise, about our Company, the Platform, products, and services, and sending you related marketing materials. This information may be general or tailored to your individual needs and preferences. If you no longer wish to receive marketing emails from us, you may unsubscribe from our mailing list by clicking the “unsubscribe” link included in every marketing message we send.
5.3 Except where the law requires otherwise, we may use non-personal information for any purpose, without restriction, as it does not identify you or any other person and cannot be traced back to you. Without limiting the foregoing, we may use non-personal information for the purposes stated above, and additionally for the following purposes:
5.3.1 Analyzing your non-personal information to improve the Platform’s models, including through artificial intelligence software.
5.3.2 Conducting security monitoring to detect and prevent fraudulent activity.
5.3.3 Developing new products and services.
5.3.4 Improving, correcting, maintaining, upgrading, and modifying existing products, services, and safety measures.
5.3.5 Identifying usage trends – for example, understanding which parts of our services are most interesting to users.
5.3.6 Determining the effectiveness of our marketing campaigns so that we can tailor them to the needs and preferences of users.
6. Transfer of Information Outside the Platform
6.1 We may share all of your data with companies related to us, so that they may use it under the same terms as we use it, in accordance with this Privacy Policy. We will be responsible for any violation of the terms of this Privacy Policy by such related companies to the same extent as we are responsible for our own actions or omissions. For the purposes of this Privacy Policy, the term “related company” (or “related party”) means a company that directly or indirectly (through intermediaries) owns, controls, is owned or controlled by, or is under joint control with the Company.
6.2 In the course of the Platform’s ordinary business operations, we may share your personal information with third parties as detailed below and in the following cases:
6.2.1 We may share all of your data, without limitation, with the Supplier who is a physician and/or the medical institution where you receive, or wish to receive, the medical solution ordered from such Supplier via the Platform.
6.2.2 We may share your relevant data with external service providers, whether in Israel or abroad, whose services and solutions complement, assist, or improve our services, including but not limited to pharmaceutical compounding centers, pharmacies, storage and server services, network and content delivery services, information security and cybersecurity services, performance measurement services, data optimization and marketing services, content providers, as well as our legal and financial advisors. These service providers may access your personal information only according to their role and for the purpose of its use.
6.2.3 The Company engages only with service providers that have undertaken to implement appropriate information security measures in accordance with the Israeli Protection of Privacy Law, the Protection of Privacy Regulations (Data Security), the procedures and guidelines of the Ministry of Health, and generally accepted industry standards. Among other things, the service providers undertake to manage access permissions, encrypt sensitive information, maintain access logs, restrict access to authorized personnel only, and notify the Company without undue delay of any information security incident.
6.2.4 A service provider that becomes aware of an information security incident or of a concern regarding the compromise of information provided to it shall notify the Company without undue delay and shall fully cooperate in order to mitigate the damage, investigate the incident, and comply with applicable legal requirements. A service provider may not use the information for research, development, training of artificial intelligence systems, marketing, statistical purposes, or any other purpose unrelated to the provision of the services, unless expressly authorized by the Company and permitted by applicable law.
6.3 In addition to the above, in certain cases as detailed below, we may share your personal information with third parties when required or appropriate, particularly when there is a legal obligation to do so:
6.3.1 We may share personal information to comply with applicable laws and regulations, including laws that apply outside your country of residence.
6.3.2 We may share personal information with third parties in connection with a transaction, such as a merger, sale of assets or shares of the Company, reorganization, financing, change of control, or acquisition of any of our operations or part thereof, or in the event of bankruptcy or similar or related proceedings.
6.3.3 To the extent permitted or required under privacy laws, we may disclose your personal information in response to a legal request or to comply with applicable law, if we in good faith believe that the law requires us to do so, with or without prior notice to you.
6.3.4 To the extent permitted or required by law, we may share your personal information with others if we in good faith believe it will help protect the rights, property, or personal safety of the Company, any Platform users, or the general public, with or without prior notice to you.
6.4 Any third party that receives information from the Platform as part of a service ordered via the Platform (physician, pharmacy, technology provider) must sign a binding confidentiality agreement with the Company as a condition for receiving such information.
6.5 Any sharing of medical information by the Platform will be conducted in accordance with Israeli law (including the Privacy Protection Law, 1981, the Patient Rights Law, 1996, Ministry of Health regulations, etc.), even if the Supplier receiving the information operates outside the jurisdiction of Israel.
6.6 Except where the law requires otherwise, we may share your non-personal information with any party, for any purpose, without limitation or liability.
6.7 The Company expressly clarifies that the information, results, and reports generated by the diagnostic tools on the Platform, including questionnaires and AI models, are not based on clinical research or Ministry of Health approval (AMAR), and are provided solely as an auxiliary tool for the healthcare service providers to support their medical decision-making. The use of information generated by the Platform is solely for the purpose of supporting and guiding a physician or other qualified professional, and the user hereby acknowledges and accepts full exclusive responsibility for any medical, therapeutic, or other decisions made based on such information. The Company and/or its representatives shall bear no liability, express or implied, for any damage or loss resulting from reliance on this information.
6.8 The Company may verify that its service providers comply with information security and privacy requirements through declarations, documentation, audits or other control measures, to the extent required by applicable law.
6.1.1 Any service provider receiving personal Information or medical Information from the Company shall undertake to process such information solely for the purpose of providing the services for which the information was provided and in accordance with the Company's instructions, applicable law and the agreement entered into with such service provider. The service provider may not independently use the information, disclose or transfer it to any third party, or use it for any other purpose without the Company's or the data subject's express authorization, to the extent required by applicable law.
6.5.1 The Platform will transfer medical Information solely to authorized healthcare service providers and not to any other party. It is hereby clarified that healthcare providers may retain medical Information in separate databases in accordance with such healthcare providers' privacy policies and subject to applicable law, including the provisions of the Public Health Regulations (Retention of Medical Records), 1976. The Company has no control over or oversight of such databases maintained by healthcare providers and shall not be liable for any damage or loss arising from any act and/or omission by the relevant database owner.
7. Right of Access to Your Personal Information
7.1 At any time, you are entitled to request to review your personal information collected and stored by the Platform. Such a request shall be submitted by completing an online form or by sending an email to:info@skcure.com. Upon receipt of your request, we shall provide you, without unreasonable delay, with a printed or electronic copy of the personal information collected and stored by the Platform, subject to our right to restrict your access to any information that we may be required to restrict in accordance with applicable law.
7.2 Following its transfer to the healthcare service provider, medical Information is deleted and is not retained on the Platform. If you wish to review medical Information retained in the healthcare service provider's databases, you may contact the relevant Supplier directly. Upon your request, we will be happy to provide you with the contact details of the person responsible for privacy protection at such Supplier. You may submit your request for such contact details to us through an online form or by email at info@skcure.com.
7.3 It is hereby clarified that if we refuse to comply with your request to review and/or correct your personal information, we are obligated to notify you of such refusal in accordance with the law. You shall be entitled to appeal such refusal before the Magistrates’ Court, in the manner and procedure prescribed by the Privacy Protection Regulations (Conditions for Reviewing Information and Procedures for Appeals against Refusal to a Request for Review), 1981.
8. Accuracy of the Information You Choose to Provide to the Platform
8.1 It is hereby clarified that you are obligated to ensure that all information you provide to the Platform, to the extent that you choose to provide any information, shall be true, complete, and accurate as of the date it is provided, including all information regarding your health condition, medical history, background illnesses, and medications you are taking. You undertake to immediately inform the physician and/or the medical institution from which you receive, or wish to receive, the medical solution ordered from him/it via the Platform of any change in your health condition and/or in any medical treatment or medication that is unrelated to the treatment prescribed by the aforesaid physician.
8.2 You undertake not to provide the Platform with any incorrect or incomplete information. It is hereby clarified that any medical treatment you receive from the Supplier who is a physician shall be based on the information you provide to the Platform, and that the attending physician and the Suppliers acting in accordance with such physician’s decisions shall rely on the accuracy of this information when making decisions regarding your treatment.
8.3 It is hereby clarified that providing information that is inaccurate or incomplete may lead to various adverse consequences, including impairing the ability of the authorized provider to provide you with an appropriate medical solution and even endangering your health, and that any damage or loss incurred by you as a result of any inaccuracy or incompleteness of the information you have provided shall be your sole responsibility.
9. Your Right to Update Your Personal Information
9.1 If the functionality of the Platform allows it, you are entitled to modify, update, or supplement your personal information stored on the Platform by yourself and at any time. If the functionality of the Platform does not permit you to modify certain personal information, you are entitled to request that we correct such personal information by submitting an online form or by email to: info@skcure.com.
9.2 Under no circumstances shall we reject or disregard such a request on unreasonable grounds. Unless there are substantial reasons to deny your request, we shall make the correction, update, or addition to your personal information in accordance with your request, and shall notify the Supplier who is a physician and/or the medical institution from which you receive, or wish to receive, the medical solution ordered via the Platform – without undue delay. If there are substantial reasons for denying your request, we shall notify you of such denial and provide a reasonable explanation for it.
9.3 For the avoidance of doubt, our refusal to fulfill your request shall not prevent you from submitting the same request directly to the Supplier who is a physician and/or to the medical institution from which you receive, or wish to receive, the medical solution ordered from him/it via the Platform, and you shall be entitled to do so at any time and at your sole discretion. Upon your request, we will be happy to provide you with the contact details of the person responsible for privacy protection at such Supplier. You may submit your request for such contact details to us through an online form or by email at info@skcure.com.
10. Your Right to Delete Your Personal Information
10.1 We will retain your personal information, except the medical information, for as long as your user account remains active, in order to provide you with access to your information and to deliver the Platform’s services. Your medical information will be deleted from the Platform immediately after it is provided to the healthcare service provider and will not be retained on the Platform.
10.2 We may continue to retain your personal information even after your user account has been deactivated or you have ceased using the Platform, to the extent reasonably necessary for compliance with our legal obligations, for the resolution of disputes involving our users, for the enforcement of our agreements, or for the protection of our legitimate interests, and all in accordance with applicable law. When your personal information is no longer required, we will ensure that it is deleted. In any event, personal information stored on the Platform shall not be retained for longer than the period permitted by law.
10.3 You are entitled to request that we delete your personal information by submitting an online form or by email toinfo@skcure.com. Please note that upon submitting such a request, and in the absence of your personal information, the Platform will not be able to provide you with personalized services. We will verify and respond to your request in accordance with applicable law, taking into account the type of personal information concerned and its level of sensitivity.
10.4 It is hereby clarified that we will not approve a request for deletion of personal information if such deletion would conflict with the provisions of any applicable law. Upon deletion of the information from the Company's databases, a corresponding request will also be sent to the service providers processing the information on the Company's behalf to delete such information, subject to Section 6.5 above and in accordance with applicable law.
10.5 For the avoidance of doubt, and notwithstanding any provision to the contrary, we shall be entitled to retain non-personal (anonymous) information, provided that such information does not identify you or any other person and cannot be linked to you.
11. Third-Party Services
11.1 This Privacy Policy does not address, and we are not responsible for, the privacy practices, information, or any other conduct of third parties, including the conduct of Suppliers outside the Platform. Our Company has conducted a thorough review and selected the best Suppliers in order to provide our customers with the highest level of service. However, it is hereby clarified that we have no control over such third parties, including the Suppliers, and they are not subject to our Company’s authority in their activities. The presence of specific Suppliers on the Platform does not constitute a recommendation or endorsement by us of such Suppliers.
11.2 Furthermore, we are not responsible for the policies or practices regarding the collection, use, disclosure, or protection of information by other organizations, such as Facebook, Apple, Google, Microsoft, RIM, or any application developer, application provider, social media platform provider, operating system provider, mobile network service provider, or any other device manufacturer – including with respect to any personal information you disclose to such organizations through or in connection with the Platform. You are advised to exercise caution and review the relevant privacy policies of such third-party organizations.
11.3 Although we will take advanced precautionary measures to protect your personal information, applying efforts and safeguards no less stringent than those required by law for the types of information collected through the Platform, including medical information – such as entering into confidentiality agreements, implementing advanced electronic security systems within the Platform, and limiting disclosure of personal information to the minimum required by law, where applicable – we shall not be responsible for any failure by third parties, including Suppliers, to implement appropriate security measures, nor for any unauthorized use of your personal information by any third party, unless otherwise required by law without exception.
12. Security
12.1 We are committed to implementing appropriate safeguards corresponding to the types of information collected through the Platform, including suitable measures for the collection of sensitive information, in order to ensure that your information is kept secure. To prevent unauthorized access or disclosure, we have implemented – and will continue to maintain and regularly update – appropriate physical, electronic, and administrative procedures designed to protect and secure the personal information collected and stored by the Platform.
12.2 Nevertheless, unfortunately, it is not possible to guarantee that any data transmission or storage system will be completely secure against unauthorized access or disclosure for various reasons, including circumstances beyond our reasonable control, such as, without limitation: natural disasters, wars, acts of terrorism, riots, civil unrest, failures of communication or power infrastructure, cyberattacks, disruptions in cloud or hosting services, government directives, or any other event beyond our reasonable control and not resulting from our acts or omissions. If you have reason to believe that your interaction with us is no longer secure, please notify us immediately by submitting an online form or by email toinfo@skcure.com.
12.3 It is hereby clarified that we shall not be liable for any direct or indirect damage caused to the user as a result of an incident involving data leakage or unauthorized access, unless such incident was caused by our gross negligence or willful misconduct. Without derogating from the foregoing, we shall not bear any responsibility for cases of misuse of personal information resulting from actions or omissions of the user, third parties, or circumstances beyond our reasonable control, including, without limitation: cyberattacks, force majeure events, security failures of third parties, or improper use of the Platform.
13. Security of Your Access Credentials to the Platform
13.1 We may, from time to time, establish additional and/or alternative identification methods, and we ask that you keep your username and password confidential to prevent any misuse. We recommend that you change your password periodically. We also ask that you protect your privacy and prevent any leakage of your personal information from the Platform by refraining from granting access to your personal account and/or your personal devices, including your mobile phone, computer, tablet, etc., and/or by refraining from sharing your password and/or any verification code sent to your phone or email.
14. Data Protection Officer
14.1 These are the contact details of our Data Protection Officer:
14.2 Name: Dan Adi, adv.
14.3 Email: info@skcure.com
14.4 Phone: 077-977-6572
14.5 For any matter relating to privacy, you may contact our Data Protection Officer by submitting an online form or by abovementioned email. For any privacy-related matter, you may contact the Data Protection Officer by submitting an online form or by using the email address specified above.