NeuroRPM Inc. (the “Company” or the terms “we”, “our”, “us”) is committed to protecting your personal information and ensuring you understand how we collect, use, and share it. We take your privacy seriously, and this Privacy Policy (“Policy”) describes how the Company collects, gathers and uses information that we come to possess about you through your use of our technology and services.
 

This Policy applies to the programs, systems, services, websites, and apps we own or operate, including the NeuroRPM program (“Program”), NeuroRPM’s website www.neurorpm.com (“Site”) and mobile applications (the “App”), and all of our services (“Services”).
 

By using our Program, Site, App, or accessing any of our Services, you consent to our use and processing of your personal information in accordance with this Policy.

We collect and process your personal information to best provide the requested products and services, respond to your requests or your sponsor's requests (i.e., the entity paying for your use of our Services), and for other purposes set forth in this Policy.

Please read this Policy carefully and contact us if you have any questions or concerns.

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1. WHAT THE PRIVACY POLICY COVERS
 
This Privacy Policy covers the personally identifiable information that our Company collects, uses, and discloses from you when you access our Site, our App, or use our Services. Personally identifiable information includes any information that can be used to identify or contact you, such as your name (first and last name), your personal profile, your email address, or other contact information (collectively referred to as your "Personal Information"), as well as information on your use or potential use of our Program, Site, App, or Services. We are committed to securely and carefully managing your Personal Information related to the Services that we provide. However, please note that this policy does not apply to the practices of companies, websites, or other third-party services that we do not own or control. It also does not apply to individuals or groups that we do not employ or oversee.

Protected Health Information ("PHI")

We understand that it is imperative to maintain the privacy and integrity of protected health information ("PHI") that we receive as you use our Program, Site, App, or Services. PHI is personal information that we receive as part of your use of our Program, Site, App, or Services that relates to your past, present, or future health or physical, medical or mental health or condition, the provision of health care to you, or your past, present, or future payment for the provision of health care, which is created, received, transmitted, or maintained by the Company.

This Privacy Policy describes how we protect your privacy as a user of our Program, Site, App, and Services. You should also be aware that federal and state laws provide you with additional rights related to the access to, use, and disclosure of Personal Information that constitutes PHI.
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2. PERSONAL INFORMATION WE COLLECT
 
We collect information directly from you, computer devices and third-party services that you connect to, as well as automatically through your use of our Program, Site, App, and/or Services. The information we collect enables us to manage your account, administer our Program, and provide you with our Services. We also use your information to respond to your questions and inquiries, send you communications regarding the Services and your access to and use of the same, obtain your feedback on our Program, Site, App, and Services, analyze your user activity, personalize and improve our Services, conduct research activities, and contact you about our Company. We may enhance or augment the Personal Information we have about you with information obtained from a third-party.
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We receive and store any information you enter on our Program, Site, App, or provide to us through the Services, including any third-party services that you connect with our Services (e.g., Apple, Google, or Amazon). Personal Information that we collect may include your full name, gender, age, mobile phone number, credit card or payment information, email address, the email addresses of your contacts, home and business addresses, IP address, browser information, username, password, and health information such as weight, height, pre-existing medical conditions, medications, tracking of movement activity and insurance information, and any other information or data that you provide when using our Site, App, and/or Services. You may choose not to provide us with certain information, but doing so may result in us being unable to provide you with the full functionality of our Program, Site, App, or Services. Our goal is to use the Personal Information directly for your benefit.
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When you use our Program and interact with devices such as your phone, tablet, or wearable device, we collect your raw movement and motion data (i.e., inertial motion unit data) along with other health and wellness information, which may include, but not limited to, heart rate, sleep, physical activity (e.g., steps, flights walked, stability), location, and time when data is being collected. In addition, we collect device model and operating system, the device ID, the device language, activities performed, and how long the Program is actively collecting data.
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When you use third-party services and if you choose to connect your App to a compatible third-party service, such as those administered by Apple or Google, we will collect, with your permission, additional information such as username and email address, step count, heart rate, distance and floors traveled, active and resting energy levels, sleep analysis, blood pressure readings, glucose and oxygen saturation levels, and workout history.

When you contact us electronically, such as through customer support, we receive the information you send us in your message and any additional information you choose to provide. Our ability to incorporate your data into our Program and Services enables us to best meet your needs as a technology provider. 

3. HOW WE USE YOUR INFORMATION
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We collect, process, and analyze your information, including your Personal Information and/or Protected Health Information for the following purposes:
 

• To provide our Program, Site, App and/or Service to you in a personalized manner.

• To communicate with you about your use of our Program, Site, App and/or Service.

• To answer questions you may have about our Program, Site, App and/or Service.

• To research and develop new features and future products and services.

• To understand how you and other users utilize our Program, Site, App, and/or Service, both on an individualized and aggregated basis, in order to improve our Program, Site, App, and/or Service by enhancing and adding features and capabilities.

• To understand if collected information is your personal information.

• To offer location customization to provide you a more personalized and relevant user experience.

• To gather feedback through surveys and questionnaires.

• To comply with any and all legal obligations.

• To prevent or take action regarding illegal activities, potential fraud, or situations involving threats or risks to the safety of any person or violations of our Terms of Service or this Privacy Policy.
   

By using our Program, Site, App, and/or Service, you expressly acknowledge and consent to the collection and use of your data for potential clinical research purposes. Any data utilized for these purposes will be processed in a de-identified manner, ensuring the removal of personally identifiable information to protect your privacy. Further, to enhance public health and safety, your data may be used in support of regulatory filings and communications with health oversight agencies. For these regulatory purposes, the data will remain de-identified unless explicit consent is provided to do otherwise.
 

4. HOW WE SHARE YOUR INFORMATION
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We will not rent, sell, or share your identifiable information with other people or non-affiliated companies except to provide the Program, Site, App, and/or Services, or when we have your permission or when required under this Privacy Policy. We may share your information, including your Personal Information and/or Protected Health Information, with outside parties and partners only with your prior consent. These parties may include healthcare providers, family members, and caregivers. We may also share de-identified profile information and aggregated data collected from you with healthcare researchers, our partners, and other research organizations. We will not share any information that could specifically identify you, such as your name.
 

We may disclose the information we collect from you to comply with the law, a judicial proceeding, court order, or other legal process, such as in response to a court order or subpoena. We may also share your information to prevent or take action related to illegal activities, potential fraud, or situations involving threats or risks to the safety of any person or violations of our Terms of Service or this Privacy Policy.
 

We take great efforts to protect your privacy. However, we cannot control whether or how users will subsequently use or disclose previously disclosed information, and expressly disclaim any responsibility for such actions. If you do not consent to the disclosure of this information, please do not access or use the Program, Site, App, or our Services.

As indicated in our terms and conditions, we may use de-identified data for ongoing research and development, as well as for regulatory filings or communications with health oversight agencies. Any use of identifiable information will only be carried out with your explicit consent.

5. HOW WE SECURE YOUR PERSONAL INFORMATION
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We take the security of your information very seriously and utilize industry standard measures to safeguard and protect your information from unauthorized access, use, and disclosure. We use systems, procedures, and processes consistent with information privacy and security requirements under applicable federal and state laws, including the Health Insurance Portability and Accountability Act of 1996 (HIPAA).
 

To protect the Program, Site, App, and our Services, including its device, system servers, and the data on those servers, we use industry-standard instructions such as access enforced firewalls and SSH secure communications. We also regularly maintain security patches for applications and modules used. Your user account is protected by a password for your safety, privacy, and security. We have incorporated safeguards in assigning and maintaining your password to ensure that there is no unauthorized access to your account. However, it is your responsibility to protect your user ID and password. We strongly recommend that you diligently protect your account password and strictly limit access to your account by signing off after you have finished accessing your account.
 

We also have internal controls to monitor and limit access to your information to only those employees or contractors who have a business need to know. Our employees and contractors are trained on information security best practices and are required to maintain the confidentiality of your information. In the event of a data breach, we will take immediate action to investigate and mitigate the impact of the breach. We will also notify affected individuals and relevant authorities in accordance with applicable laws and regulations. However, we cannot guarantee that our security measures will prevent all unauthorized access, use, or disclosure of your information.

By using our Program, Site, App, or Services, you acknowledge and accept the risks associated with the transmission of your information over the internet and agree that we are not liable for any unauthorized access, use, or disclosure of your information beyond our reasonable control.
 
6. CHANGES TO THIS PRIVACY POLICY
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By using the Program, Site, App and Services, you agree to the current Privacy Policy and our Terms of Service, on which this Privacy Policy is incorporated. We reserve the right, in our sole discretion, to change, modify, discontinue, or terminate the Program, Site, App, and/or Services or to modify this Privacy Policy at any time. Use of information we collect is subject to the Privacy Policy in effect at the time such information is used or disclosed. If we change the way we use Personal Information, we will notify you by sending you an email and providing an announcement on our Site and/or App. By continuing to access or use the Program, Site, App or Services after we have posted a change to our Privacy Policy or have provided you with notice of a change, you are indicating that you agree to be bound by the modified Privacy Policy. If the modified Privacy Policy is not acceptable to you, your only recourse is to cease accessing the Program, Site or Mobile App and using the Services.
 
7. QUESTIONS
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If you have any questions, suggestions, concerns or complaints regarding our Privacy Policy on our Site, App, or Services please contact NeuroRPM’s Privacy Officer at:
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By email: help@neurorpm.com
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Address:
Privacy Officer
NeuroRPM Inc.
3124 Dumbarton Street NW
Washington, DC 20007
 
Updated October 2023