PRIVACY POLICY

NeuraMetrix, Inc. (“NeuraMetrix”) has implemented a privacy policy (“Privacy Policy”) to protect any personally identifiable information (“Personally Identifiable Information”) and individually identifiable health information (“Protected Health Information”) you share with us. This Privacy Policy is designed to inform users how we gather and use personal information collected by us via our website (www.neurametrix.com), application (“NeuraMetrix TC”), and web portal (portal.neurametrix.com). We will take reasonable steps to protect user privacy consistent with the guidelines set forth in this Privacy Policy and with applicable U.S. laws.

Personally Identifiable Information

What Personally Identifiable Information do we collect?

Website: We accept unsolicited inquiries via our website in which email and name are collected.

Application/Web Portal: To install our application and access our web portal, we ask you to provide us with your email address. At present, we do not collect other Personally Identifiable Information such as name, address, phone number, birth date, social security number, driver’s license number, medical record number, health plan or insurance number, or other identifying information.

It is our intention to charge a monthly user fee for our services. For users responsible for payment of such fee, we will collect information required to facilitate payment including name, address and credit card information.

How do we use your Personally Identifiable Information?
Website: We use your email address to respond to your questions and comments. In the future, we may send you a newsletter or other materials relevant to your inquiry and our service. You will be able to choose to stop receiving emails by following the unsubscribe instructions included in such emails.

Application/Web Portal: We use your email address to send you a link to enable you to install NeuraMetrix TC on your personal computer. Upon registration, you are assigned a unique user name (“User ID”) and emailed a link to install the application. Following installation, the application runs in background and does not require logging in or turning on or off the application. You access your online personal record of collected and analyzed cadence data (“Dashboard”) via a web portal using your User ID (not your email address) and personally selected password. We use your email address to identify you if you have lost your password. In addition, we will use your email to contact you if it appears NeuraMetrix TC has been inadvertently uninstalled from your computer or to notify you of a software update. We will use name, address and credit card information ONLY in connection with collecting payment for our services. We do not share your Personally Identifiable Information except as described below in Research and Third Party Disclosure.

How do we protect your Personally Identifiable Information?
Your Personally Identifiable Information is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems and are required to keep the information confidential.

Application/Web Portal: Your user account is established using a system-generated unique User ID and is protected by a password for your privacy and security. Your assigned User ID, not your email address, is used to access the web portal containing your Dashboard. After accessing your Dashboard, you should log off the web portal. You must prevent unauthorized access to your Dashboard by selecting and protecting your password appropriately and limiting access to your computer or device and browser.

Protected Health Information

What Protected Health Information do we collect?
During the registration process, we request (but do not require) certain Protected Health Information regarding your brain health including age, gender, primary diagnosis, year of diagnosis, and brief family history. As we collect and analyze the metadata associated with your typing cadence, we develop and record a history of your typing cadence and various scores and their trends. Additions to the Protected Health Information will also include inputs by you, any person authorized by you, or your physician via chart notes added to the Dashboard.

 

How do we use your Protected Health Information?
We use your Protected Health Information in our research efforts to correlate specific typing cadence patterns with different brain diseases and disorders. We may share de-identified health information with our partners, researchers and other interested parties.  In addition, we may share de-identified health information publicly to show trends about the use of our services.

 

How do we protect your Protected Health Information?
The Protected Health Information provided in the registration process is not displayed on your Dashboard or otherwise accessible via the web portal. It is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems and are required to keep the information confidential. If it is provided to researchers, it will not be associated with any Personally Identifiable Information; it will only be associated with the User ID assigned at registration. If your physician or health care provider has access to your Dashboard, your Protected Health Information will be associated with other Personally Identifiable Information and electronic medical record only within the secure operating system of your physician health care provider.

Research

Application/Web Portal: We may use and disclose your Protected Health Information for research purposes. No Personally Identifiable Information will be included with any the Protected Health Information that may be disclosed. All research projects are subject to a special approval process by us and shall be at our sole discretion. This process evaluates a proposed research project and its use of Protected Health Information, trying to balance the research needs with subjects’ need for privacy of their Protected Health Information. Before we use or disclose Protected Health Information for research, the project will have been approved through this research approval process. In the event a researcher requests any Personally Identifiable Information, we will always seek your pre-approval and ask for your specific permission. You will have the right to decline to participate in such medical research or share such Personally Identifiable Information with the researcher.

Tracking Technologies

We use cookies, which are small files that a site or its service provider transfers to your computer’s hard drive through your web browser (if you allow) that enable the site’s or service provider’s systems to recognize your browser and capture and remember certain information. We use cookies to help us compile aggregate data about service use and website traffic so that we can improve service experiences. We may use trusted third-party services that track this information on our behalf. You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. If you disable cookies, it will not affect your experience visiting our site.

Third Party Disclosure

We do not sell, trade, or otherwise transfer to outside parties your Personally Identifiable Information or Protected Health Information. However, website hosting partners and other parties who assist us in operating our services, website, or conducting our business, will have access to Personally Identifiable Information and Protected Health Information so long as such parties agree to keep such information confidential. We may release your Personally Identifiable Information when we believe release is required to comply with the law, enforce our site policies, or protect ours or others’ rights, property, or safety.

Communications

We may use your email to respond to your requests or inquiries and to improve our services. We may also use your email address to contact you with updates and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send.

International Transfer

The Personally Identifiable Information and Protected Health Information provided during registration as well as typing cadence data collected may be transferred to, analyzed, and maintained on computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction. If you are located outside United States and choose to provide information to us, please note that we transfer the information to the United States for analysis and storage. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to such transfer.

Your Security

We take reasonable steps to ensure that your Personally Identifiable Information and Protected Health Information is kept safe from loss, unauthorized access, modification or disclosure. However, due to the nature of wireless technology and potential security breaches, we cannot ensure the security or privacy of information you submit electronically, including Personally Identifiable Information and Protected Health Information. Please remember that you control what Personally Identifiable Information and Protected Health Information you provide while using NeuraMetrix TC. Ultimately, you are responsible for maintaining the secrecy of your Personally Identifiable Information and Protected Health Information in your possession. Always be careful and responsible regarding your Personally Identifiable Information and Protected Health Information. We are not responsible for, and cannot control, the use by others of any information which you provide to them or make public in any way and you should use caution in selecting the Personally Identifiable Information and Protected Health Information you provide to others.

Consent

By providing Personally Identifiable Information and Protected Health Information to us, and installing and using NeuraMetrix TC you voluntarily consent to the collection, use and disclosure of Personally Identifiable Information and Protected Health Information as specified in this Privacy Policy. Without limiting the foregoing, we may on occasion ask you to consent when we collect, use, or disclose your Personally Identifiable Information and Protected Health Information in specific circumstances. Sometimes we may imply your consent through your conduct with us, and rely on that, if the purpose of the collection, use or disclosure is obvious and you voluntarily provide the information.

You may revoke any and/or all consents you have given to us; in order to revoke such consent(s), please contact our Privacy Officer in writing at the address listed at the end of these terms and allow 30 days for such revocation to be effective. Please note, however, that revocation of any consent does not have retroactive effect.

Changes to This Privacy Policy

This Privacy Policy is effective as of July 18, 2017 and will remain in effect except with respect to any changes in its provisions in the future, which will be in effect immediately after being posted on this page. We reserve the right to update or change our Privacy Policy at any time and you should check this Privacy Policy periodically. Your continued use of NeuraMetrix TC after we post any modifications to the Privacy Policy on this page will constitute your acknowledgment of the modifications and your consent to abide and be bound by the modified Privacy Policy. If we make any material changes to this Privacy Policy, we will notify you either by email, by in-application message, by placing a prominent notice on our website, and/or by some other means.

Feedback and Complaints

You can contact us about this Privacy Policy in writing or by email to us at the address below. If you believe that there has been a third-party violation of this Privacy Policy, we request that you contact us immediately with the details of the violation.

NeuraMetrix, Inc.
1117 S. California Avenue, PH 275
Palo Alto, CA 94304 USA
email: privacy@neurametrix.com