NeuroPace Privacy Statement

Effective Date: October 31, 2016


This Statement explains how NeuroPace, Inc. (“NeuroPace”, “we” or “us”) collects, uses, and discloses personal information and what we do to keep it safe.

We may update this Statement from time to time, and by using the website, you are agreeing to the most recent version of it.  Additional privacy conditions may apply based on the options you choose on our website, for example, if you use our electronic patient diary or decide to participate in our patient ambassador program.

Some features of the website are only for use by medical professionals who can prescribe or use NeuroPace’s products, and we therefore limit access to those features to individuals who meet certain requirements, for example, those for whom we have approved a registration form.  This Statementcovers all users of our website.

INFORMATION WE COLLECT AND USE

We may collect both non-personal and personal data about you.

Non-personal information does not identify you, so we use and share that information freely without restriction, for example, to make the website more useful to visitors and for other business purposes, such as to create reports for internal use, provide (including by selling) aggregated information to third parties about how people use our website.

Personal information that we can use to identify you and that we may collect includes your:

  • name
  • contact information (such as telephone number, email address, physical address)
  • medical device serial number
  • date of birth
  • other demographic information such as your age, education, gender, interests and where you are located (or where the device you are using to access the website is located based on its Internet Protocol (IP) address)
  • health information, such as about your health status or medical condition, health care provided to you (including dates of surgery or doctor’s appointments), or payment for health care
  • for healthcare providers in the United States, a National Provider Identifier (NPI #) or a state license number

NeuroPace only collects personal information from you that you choose to share with us.  We may collect your information:

  • by virtue of your choice to have and use our products
  • through personal contact with our employees, for example, at an epilepsy event
  • over the telephone
  • via our website
  • through correspondence (email or regular mail)
  • through third parties who have your permission to disclose your information to us (such as when you leave a message with our telephone answering service)
  • when you submit a resume to us in order to be considered for a job opportunity, and
  • if you are a medical professional, registering for access to those parts of our website intended exclusively for you.

More specifically, and by way of example, some features of our website invite you to send us information about yourself (for example, a patient testimonial) or to have us send you particular information (for example, about our educational offerings), or to participate in an activity (such as a survey or a contest).  We may offer to send you educational material about our products and therapies after you fill out a form or you enter certain information or answer certain questions.  We also may offer you ways to customize your website experience by providing us with some personal information.  We can combine this personal information with non-personal information we collect through “cookies” (described below) about your prior use of the website to let you know about new products or events that we think may be of interest.  So we may use your personal information for any or all of the following:

  • Generally:
    • to answer your questions
    • to provide you with information about our programs for patients, clinical trials, and research
    • to send you information you ask for about products, programs, resources, events, or services of NeuroPace, or those of others, that we think might be of interest to you
    • to send you product updates
    • to conduct market research or analysis or for our other marketing efforts and campaigns
    • to send you a NeuroPace newsletter
    • to send you marketing communications
    • to improve our website or to customize content for you, based on your preferences or apparent interests
    • in responding to subpoenas or other requests by a court or regulatory body for information
    • to safeguard your interests, such as to notify you in the event of a breach of privacy or other security incident, as may be appropriate
    • to protect our interests, such as our rights and property in case of fraud, unauthorized uses of the product, or other legal injury or harm
    • to manage and administer our business, including in providing and supporting our products or services with third party contractors or service providers who are obligated to maintain confidentiality, such as a telephone answering service or a  business and travel expense management service
    • in connection with a proposed or actual financing, sale, securitization, assignment, or other disposition of our business or assets (including accounts) for the purposes of evaluating or undertaking the proposed transaction including satisfying any auditing or reporting requirements with respect to the transaction
    • other business and legal purposes including complying with statutes, regulations, guidances, and best practices
  • If you are a patient with one of our products:
    • To provide and support the product
    • For product registration and medical device tracking
    • Reporting any adverse events
    • Creating, receiving, maintaining and transmitting your data to enable use of the product and to allow your doctors to adjust and manage your therapy
    • To communicate with the epilepsy center, medical practice, hospital, doctors and other medical practitioners involved with your care and insurers who may pay for all or some of it
  • If you are a medical professional
    • to provide education and training for our products
    • to provide samples or demo devices and other educational aids
    • to notify you about or to invite you to webinars, symposia, conferences , congresses, and other professional meetings that NeuroPace is involved with or believes may be of interest to you
  • If you are a medical professional  with a NeuroPace account, for example, for the Patient Data Management Database (PDMS) or one who provides services to NeuroPace:
    • to manage and administer your account
    • to provide you with clinical and technical support for our products
    • to meet our compliance obligations, such as for reporting transfers of value under the Sunshine Act
  • If you are interested in employment at NeuroPace:
    • to allow you to search our “Careers” feature for job postings, to upload a resume, and to ask to be contacted by us or one of our recruiters about an employment opportunity
    • to contact you about opportunities
    • to process a job application

HOW WE TAKE CARE OF YOUR PERSONAL INFORMATION

NeuroPace takes its responsibility to protect your personal information seriously, and we use reasonable safeguards to avoid unauthorized use or disclosure of it, and inadvertent loss or impermissible alteration of it.

If you are a patient with a NeuroPace product, we maintain any personal information we have in the product in accordance with the requirements of the HIPAA Security Rule.  We also maintain our customer files securely, and limit access to them to only personnel who need to use the information to carry out their job responsibilities, such as for customer service.

We may ask you to answer certain questions to verify your identity if you call us for customer service.

We may require that you establish a user name and password for access to certain areas of our website or to set up an account.  It is up to you to keep your user name and password information secure.  If you think your logon credentials have been comprised, let us know by contacting our privacy officer at privacy@neuropace.com.

We cannot ensure or guarantee that information you provide to us via our website or via email will be 100% secure, because it is not possible for us to make the internet 100% secure.  So please consider this when sending any information to us via the website or via email.

COOKIES AND SIMILAR TECHNOLOGIES

A cookie is a small data (text) file that is sent to your browser and may be stored on your computer or mobile device when you visit a website.  NeuroPace uses cookies, both temporary and permanent to enhance your ability to use and navigate on our website, and to help us manage and improve the website, including by providing us with information on how people find and use our website, and to assess how well the website is working for its intended purposes, such as by analyzing trends and statistics.  NeuroPace may use third party providers to collect information for us for analysis.  If you do not allow cookies, not all the features of our website may be available to you.

You may find social media buttons on our website you can use to share information or otherwise interact with social media (such as Facebook, Twittter and LinkedIn).  These features may involve the use of web beacons or clear GIFs, tiny graphics placed on a website, to track which pages were viewed and what information is collected.  They can be used to measure traffic and assess behavior.

LINKS TO THIRD PARTY SITES

NeuroPace may link to a third party website from its website.  If we do this, the links are provided for information only, and NeuroPace is in no way endorsing the website or the website providers to which the links take you.  We are not responsible for the content of the website or the privacy practices of those websites.

OPTING OUT

You have the right not to receive marketing materials from NeuroPace.  You can ask us not to use your personal information for marketing purposes.  You can “unsubscribe” from any email communications we send you.  If you are receiving materials from us that you do not want, or you believe we are using your personal information without your permission, please contact our privacy officer at privacy@neuropace.com.

CHILDREN/MINORS

NeuroPace’s website is not intended for use by children under the age of 18.  NeuroPace does not intentionally collect personal information from minors.  If we discover that a child has provided us with personal information on line, we will take steps to delete the information.  If you believe we have received personal information from a minor, please contact our privacy officer at privacy@neuropace.com.

CALIFORNIA “DO NOT TRACK” DISCLOSURES

California law requires NeuroPace to let you know how we respond to web browser “Do Not Track” or “DNT” signals.  NeuroPace does not presently honor Do Not Track requests.

REVISIONS TO THIS PRIVACY STATEMENT

NeuroPace reserves the right to change this Statement at any time.  If we make a significant change to it, we will post a notice on our homepage for a reasonable period of time after the change to let you know to review the privacy statement again because the change has been implemented.

COMPLAINTS/CONCERNS

Please contact the NeuroPace Privacy Officer if you believe NeuroPace has violated this Statement or any applicable law:  privacy@neuropace.com.