Privacy Policy
Effective date: 11/08/2021
This privacy policy describes how NeuraLace Medical Inc. (“NeuraLace Medical,” “we,” and “us”) collects, uses and discloses personal information we collect when you use our websites, mobile applications, or our other online products and services (collectively, the “Services”), contact our customer service team, engage with us on social media or otherwise interact with us. By purchasing our products or using our Services, you consent to the collection, use and disclosure of your personal information in accordance with the following privacy policy.
Collection and Use of Personal Information
Categories and Types of Personal Information We Collect
The types of personal information relating to you that we may “process” (such as collect, use and store) depends on your interaction with us. The key categories and types of personal information that we may collect and process are set out below.
· Contact Information: name, email address, mailing address, phone number
· Financial Information: financial condition, income, debts, assets, ability to pay for treatment, financial or economic hardship status
· Employment Information: current and prior employment status, employer, and job title, job
· Education Information: education level, schools attended, degrees obtained
· Medical Information: medical history, pain level, diagnosis, treatment history, physician information, responses to treatment, medical records, lab and test results, clinic-created records, and treatment and progress notes
· Identifiers: IP address, user name, account number, password and other security information for authentication and access
· Geolocation Data: the general region or area from which you access our site
· Internet or other electronic activity (“internet activity data): email, browsing and click history, including information about how you navigate the Internet;
· Commercial Information: records of products or services purchased, obtained or considered, or other purchasing or consuming histories;
· Audio, electronic, visual or similar information (“audio/visual data”): videos, photographs, or audio recordings
· Inferences: we may use information from the categories described above in order to create a profile about you, to reflect your preferences, characters, behavior and attitude.
Use of Personal Information
We use your personal information for the following purposes:
· Axon Care: We use your contact information, financial information, identifiers, employment information, education information, medical information, commercial information, audio/visual data, and inferences to:
o Evaluate whether you qualify for treatment
o Assist you in locating a clinic or provider
o Communicate with and assist your medical provider
o Communicate with you
o Monitor the status of your treatment
o Provide requested information, products or services
o Send care updates
o Respond to customer service requests and inquiries
o Administer an online account
o Administer a financial hardship program
· Axon Therapy. We use your contact information, financial information, identifiers, employment information, education information, medical information, commercial information, audio/visual data, and inferences to help us track treatment progress and outcomes, improve our Axon Therapy device, revise treatment protocols, and conduct research or clinical trials.
· Analytical Purposes: We use your identifiers, internet activity data, geolocation data, commercial information, audio/visual data, and inferences to analyze preferences, trends and statistics.
· Marketing and Promotional Purposes: We use your contact information, identifiers, commercial information, internet activity data, geolocation data, and audio/visual data, and inferences to send you a newsletter or blog post, improve our marketing efforts, create social media posts or advertisements, and provide you with information about us, including personalized marketing communications.
· Maintenance and Improvement of Services: We use your contact information, commercial information, identifiers, employment information, education information, medical information, geolocation data, and internet activity data to answer your questions and respond to your requests, improve our Services, provide and maintain functionality on our websites, and help us diagnose technical and service problems and administer our websites.
· Security and Fraud Prevention: We use your contact information, identifiers, commercial information, financial information, medical information, geolocation data, internet activity data, inferences, and audio/visual data to protect our websites, our stores and nurseries, our company and others, and to prevent fraud, theft and misconduct.
· Legal: We use your contact information, identifiers, financial information, employment information, education information, medical information geolocation data, internet or other electronic activity, audio and visual information and inferences to comply with our legal obligations, including reporting requirements, and defend Altman Plants in and protect Altman Plants, property, employees, and others through legal proceedings.
Sources of Personal Information
We collect information from the following sources:
· Directly from you: We collect contact information, financial information, identifiers, commercial information, and audio/visual data that you provide directly to us.
· Automatically: When you access our Services, we collect identifiers, geolocation data, and internet activity data using tools like browser cookies. This activity is further described below in the Cookies and Other Tracking Technologies section.
· From third parties: We may collect contact information, identifiers, commercial information, audio/ visual data, and inferences from third parties, including health care providers, clinics, healthcare clearinghouses, and organizations, universities, and private clinics that are conducting research studies or clinical trials.
· From social media platforms and networks. We may collect contact information, identifiers, geolocation data, internet activity data, commercial information, and audio/visual data from social media platforms and networks that you use in connection with our websites or mobile applications, or that share or allow you to share information with us, such as Facebook, Twitter, Pinterest, and Instagram. For example, if you use functionalities, plugins, widgets, or tools from social media platforms or networks in connection with our websites (e.g., to log into an account, or to share purchases, and other content with your friends and followers on social media), we will collect the information that you share with us, or that those social media platforms or networks share with us.
· Combined Information: We combine information we obtain from different sources with publicly available information, including to create inferences about you.
Information Sharing
We will share personal information in the following circumstances or as otherwise described in this Privacy Policy:
Service Providers: We may share information with vendors and service providers who support the operation of the Services and business and who need access to such information to carry out their work for us (including, for example, web hosting, analytics, payment processing, order fulfillment, email delivery, marketing, insurance, storage and warehouse services, shipping, and customer support services). In some cases, the vendor or service provider may directly collect the information from you on our behalf.
Medical Providers, Clinics and Researchers: We may share personal information with HIPAA-covered entities such as health plans, health insurance companies, health care providers and healthcare clearinghouses;. We may also share information with organizations, universities, and private clinics that are conducting research studies or clinical trials.
Marketing/Analytics/Advertising Partners: We may share personal information with third party marketing, analytics or advertising partners, including social media platforms and networks, for commercial purposes such as sending you marketing emails and advertisements.
Professional Advisors: We may share information with professional advisors, such as lawyers, bankers, auditors, and insurers, where necessary in the course of the professional services that they render to us.
Responding to Legal Requests: We share information if we think we should in order to comply with any applicable law, regulation, legal process or other legal obligation. This includes cooperating with law enforcement when we think it is appropriate, obtaining legal remedies or limiting our damages, and to enforcing or protecting our contracts, legal rights or the rights of others, including by responding to claims asserted against us.
Corporate Transactions. We may share information in the event we: (i) sell or transfer, or are considering selling or transferring, all or a portion of our business or assets; or (ii) are considering or engaging in any reorganization, conversion, merger, sale, joint venture, assignment, transfer or disposition of all or any portion of our ownership interest, business or operations.
With Your Consent or At Your Direction. We may share information with third parties whenever you consent to or direct such sharing.
Cookies and Other Tracking Technologies
We want you to be aware that certain online tools exist to help us serve and recognize you when you visit one of our websites. We receive and store certain types of information when you visit our website. You may be familiar with the term “cookies.” When you access the Services, we (including companies we work with) may place small data files on your computer or other device. These data files may be web beacons, cookies, clear gifs, pixel tags, e-tags, flash cookies, or other local storage provided by your browser or associated applications (collectively called cookies). Cookies allow us to understand how users navigate to and around our website, view product pages, access content and make purchases. We may use cookies, for example, to keep track of your preferences and profile information. Cookies are also used to collect general usage and volume statistical information. If you want to remove or block cookies, you may be able to update your browser settings. You can also find instructions on how to manage cookies on different types of web browsers at www.allaboutcookies.org.
Do Not Track Signals
Some browsers have a “do not track” feature. It lets you tell websites you visit that you do not want them to track your online activity. These features are not yet uniform across browsers. Our sites are thus not currently set up to respond to these signals. For more information on Do Not Track signals, please visit https://allaboutdnt.com/.
Third Party Analytics and Advertising
We allow others to provide analytics services and serve advertisements on our behalf across the Internet and in mobile applications. These entities may use cookies, web beacons, device identifiers and other technologies to collect information about your use of the Services and other websites and applications, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in mobile apps, links clicked and conversion information. We use this information to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests, and better understand your online activity.
Google Analytics. We use analytics services provided by Google Analytics. If you would like more information on how Google uses data when you use our Services, please visit www.google.com/policies/privacy/partners. If you would like to opt-out, Google provides a an opt-out tool which is available at https://tools.google.com/dlpage/gaoptout.
Links to Other Websites
Our website includes links to other websites whose privacy practices may differ from those of Altman Plants. If you submit personal information to any of those sites, your information is governed by their privacy statements. We encourage you to carefully read the privacy statement of any website you visit.
Security
We follow generally accepted industry standards to protect the personal information submitted to us. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security and encourage you to use websites and share information with caution.
Children
We do not knowingly collect or store any personal information from anyone under the age of 13. If we become aware that we have collected or stored personal information from an individual under age 13, we will remove his or her personal information from our files. If you are a parent or guardian and believe we may have inadvertently collected personal information from your child, please notify us immediately by sending an email to hello@neuralacemedical.com
Choices/Opt-out
We strive to offer you choices about how personal information is used and shared. Your choices include:
Online Advertising. You can manage third-party advertising preferences for some of the third parties we work with to serve advertising across the Internet by using the choices available at http://www.networkadvertising.org/managing/opt_out.asp and www.aboutads.info/choices. We do not guarantee that all of the third parties we work with will honor the elections you make using those options, but we try to work with third parties that do.
Social Media Platforms and Networks. We encourage you to review your privacy options and settings with the social media platforms and networks you use to understand what choices you have about sharing information from those platforms and networks with us.
Email Choices. You can opt out of marketing or advertising emails and newsletters by using the “unsubscribe” link or mechanism noted in communications you receive from us. You may also request to opt out of marketing or advertising emails by contacting us through one of the methods specified in the Contact Us section below.
Contact Us
You can contact us about this Privacy Policy by writing or emailing us at the address below:
NeuraLace Medical, Inc.
Attn: Privacy
3770 Tansy Street, Ste. 101
San Diego, CA 92121
Email: hello@neuralacemedical.com
Updates to this Privacy Policy
We may update this policy from time to time. The updated policy will be posted on our website. Your continued use of the website after we post a revised policy signifies your acceptance of the revised policy.
