Privacy Policy of Neuromodulatory Devices & Applications

‍This privacypolicy (“Privacy Policy”) explains how Neuromodulatory Devices &Applications (“NMDA” or the “Company”) and our affiliates (collectively “We”) collect,use, and share personal information from your communications with us and youruse of or interaction with our services, including our website (“Website”), ourdata platform (“Platform”), customer accounts (“Accounts”) and our events,sales, services and marketing activities (collectively, the “Services”). Italso explains how we collect, use, and share personal information if you applyfor a job with us. If you have anyquestions or concerns about this Privacy Policy, or our use of your personalinformation, then please contact us at admin@NDMAhealth.com

‍1. Information You Provide
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‍We collectinformation that you provide to us when you use or interact with our Servicesor apply for a job with us. The amount and type of personal information that Wecollect depends on the nature of the interaction.

‍Your Communications with Us. We may collect information such asyour name, email address, phone number, job title, and company name when yourequest information about our Services, register for our newsletter, requestcustomer or technical support, or otherwise communicate with us.

‍Account. We collect your name and email address to create youraccount on the Platform. We may also collect other information, such as yourtelephone contact, job title and company.

‍Interactive Features. We collect information that yousubmit or make available through our interactive features, such as informationyou choose to provide via the comments feature of the Platform or the commentssection of our Website and social media pages.

‍Surveys. We may contact you to participate in surveys. If youdecide to participate, you may be asked to provide certain information, whichmay include personal information.

‍Conferences, Trade Shows, and Other Events. We may collect personalinformation if you register for or attend one of our conferences, trade shows,or other events, such as your name, company, and marketing preferences.  

‍Job Applications. We may post job openings andopportunities on our Website. If you reply to one of these postings bysubmitting your application, we will collect your name, email address, phonenumber, CV, and cover letter. We use this information to assess yourqualifications and suitability for the job. We may also collect informationsuch as your social media links and demographic information if you choose toprovide this information to us. We may also collect work eligibilityinformation that is required under applicable law or that we need to moveforward for certain positions.

‍2. Information We Collect Automatically

‍Like manybusinesses, We (or our service providers) may automatically collect certaininformation relating to your use of the Services. Some of this information iscollected using cookies, pixel tags, local storage, and similar technologies.

‍Website Visitors. We automatically collect certaininformation if you visit or interact with our Website. This may include deviceor browser information, such as IP address, browser or device type, cookieidentifiers, language preferences, and other unique identifiers. It may alsoinclude information regarding your use of the Website, such as the pagesvisited, the date and time of your visit, the links you click, the types ofcontent you interact with, the frequency and duration of your activities, andother information about how you interact with the Website. We collect thisinformation to better understand how visitors are using the Website anddetermine your general location, for example, to monitor traffic, improvenavigation, fix bugs, and for marketing purposes.

‍Usage Data. If you create an account using the Platform, We alsoautomatically collect certain information relating to your use and interactionwith the Platform as a logged-in user (“Usage Data”). This may include, forexample, IP address, date/time stamps associated with your usage, searches andother actions you take, what portions of the Platform you use, links clicked,information about your computer or device, non-sensitive text entered, mousemovements, and other data and metadata regarding your use of the Platform.

‍3. Information We Collect From Third Parties

‍From time totime, We may also obtain information about you from third party sources, suchas websites and public sources, marketing and business partners, and securityand fraud detection firms. This may include, for example, your name, contactinformation, location information, job title, and information about yourcompany and sector. We use this information to maintain and improve theServices and for our marketing purposes. We may also obtain information aboutjob applicants from third party sources, such as background and screeningchecks, information from referees, and other information about your educationand professional experience that you choose to make publicly available onsocial media sites.

‍4. How We Use Your Information

‍We use yourpersonal information to provide the Services, communicate with you, manage youraccount, send you marketing and offers, or for other business and recruitmentpurposes. In particular, We may use your personal information in order to:

●       Register and manage your account.

●       Send you service-related information, including technicalnotices, updates, security alerts, and other administrative messages.
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●       Ensure the security of the Services, including to monitor andverify access, combat fraud, spam, malware, and other security risks.
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●       Perform debugging, error reporting, and other activities tomaintain the quality of the Services.
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●       Carry out marketing activities, including to send youmarketing and other promotional communications (in accordance with yourmarketing preferences) and assess the effectiveness of our marketing campaigns.
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●       Personalize, target, and deliver advertising for our productsand services on third party websites, apps, and other online services.
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●       Analyze data, including metrics related to your use of theServices to help us understand your needs and improve our products andservices.
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●       Communicate with you about one of our events, includingwebinars and videos.
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●       Assess your suitability for a role with us, verify theinformation you provide to us, and process your job application.
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●       Comply with our legal and regulatory obligations.
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●       Other legitimate business purposes, such as collectingcustomer feedback, identifying usage trends, defending our legal rights, andimproving our products and services.

‍5. How We Share Your Information

‍We may share yourpersonal information with third parties for the purposes of operating ourbusiness and maintaining and improving our Services. In particular, we mayshare your personal information with the following categories of recipients:
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●       Our affiliates or group companies who support data processingservices necessary to provide you with our Services or who otherwise processpersonal information for purposes described in this Privacy Policy.
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●       Third-party business partners, service providers, andauthorized third-party agents that provide services to us (for example, sendingour newsletter, hosting events, and providing customer support and marketingcommunications).
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●       Any buyer (and their agents and advisers) in connection with,or during negotiations of, any merger, sale of company assets, consolidation orrestructuring, financing, or acquisition of all or a portion of our business byor to another company.
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●       Any competent law enforcement body, regulator or governmentagency, court or other third party as necessary to comply with legal process,to protect the rights, property, or safety of (Company), its business partners,you, or others, or as otherwise required by applicable law.
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●       Any other person if we otherwise notify you and you consentto such sharing.We may also share information withother third parties so long as the information has been aggregated and/oranonymized so that it can no longer be used to identify you.

Selling or sharing is defined by selling, renting, releasing, disclosing,disseminating, making available, transferring, or otherwise communicatingorally, in writing, or by electronic or other means, a consumer’s personalinformation by the business to another business or a third party for monetaryor other valuable consideration.

‍6. Data RetentionWe will onlyretain your personal information for as long as necessary to fulfill thepurposes for which it was collected. We will retain and use your personalinformation as necessary to provide the Services, comply with our businessrequirements as well as legal, accounting or reporting obligations, resolvedisputes, protect our assets, and enforce our agreements. To determine theappropriate retention period, we consider the nature and sensitivity of the information,the potential risk of harm from unauthorized use or disclosure, the purposesfor which we process the information, and any applicable legal requirements.    

‍7. Data Transfers

‍Your informationmay be transferred to, and processed in, countries other than the country inwhich you reside and those countries’ laws may be different to the laws of yourcountry. In particular, We are headquartered in the United States and theServices are provided in the United States and other counties where our groupcompanies and third-party business partners and service providers are located.We take appropriate steps to ensure that your personal information is protectedin accordance with applicable laws and this Privacy Policy. This includes, forexample, implementing standard contractual clauses adopted by the EuropeanCommission and UK authorities between our group companies and with our serviceproviders, and implementing additional safeguards where necessary.

‍8. Security

We have implemented technical andorganizational measures to protect the personal information that we collect andprocess about you. These measures have been designed to provide an appropriatelevel of security according to the risk of processing, taking into account thenature of the information and technology available. The safety and security ofyour information also depends on you. Where we have given you (or where youhave chosen) a password for access to the Services, you are responsible forkeeping this password confidential. Please do not share your password withanyone. Although we take reasonable security measures to protect your personalinformation, we cannot guarantee the security of your personal informationtransmitted over the Internet.

We have a team dedicated to keeping your information secure and testing forvulnerabilities. We continue to work to keep your information safe in additionto things like two-factor authentication, encryption of files at rest, andongoing security assessments. We deploy automated technologies to detectabusive behavior and content that may harm our Services, you, or other users.

‍9. Cookies and Similar TechnologiesWe use cookiesand similar tracking technologies, including to ensure the proper functioningof the Services, store your preferences, measure traffic and usage trends,optimize and improve the Services, and deliver advertisements that may be ofinterest to you. A cookie is a small file containing a string of informationthat is sent to your computer or device. You can control or reset your cookiesand similar technologies through your web browser, which allows you tocustomize your cookie preferences and refuse all cookies or to indicate when acookie is being sent. Please note that some features of the Services may notwork properly if cookies are disabled.

‍Analytics. We use analytics tools to collect information aboutyour use of the Services. Some of the third-party tools we use include:

●       AWS Analytics. We use AWS Analytics toenable us to better understand your use of our Services. Like many services, AWSuses first-party cookies to track user interactions, which is used to compileusage reports. The reports disclose trends without identifying individualusers. You can find more information about how AWS collects and uses this dataat aws.amazon.com/privacy/ and can opt-out from AWS supported analytics byvisiting aws.amazon.com/compliance/privacy-features/

‍Advertising and Remarketing. We partner with third partyadvertising services and social media platforms to advertise on the Website andthird party websites (including Google and LinkedIn). This could mean that weadvertise to previous visitors who haven’t completed a task on our Website, forexample using the contact form to make an inquiry. This could be in the form ofan advertisement on the Google search results page or on LinkedIn, a site inthe Google Display Network, or another third-party site. Third-party vendors,including Google and LinkedIn, use cookies to serve ads based on someone’s pastvisits. You can set preferences for how Google and/or LinkedIn advertises toyou using the Google Ad Preferences page or the LinkedIn Ads settings page. Youcan opt-out of interest-based advertising entirely by cookie settings orpermanently using a browser plugin.

‍Do Not Track. Some internet browsers incorporate a“Do Not Track” feature that signals to websites you visit that you do not wantto have your online activity tracked. Given that there is not a uniform waythat browsers communicate the “Do Not Track” signal, we do not currentlyrespond to “Do Not Track” signals.

‍10. Your Privacy RightsYou may havecertain rights and choices with respect to your personal information. Pleasenote that your rights will depend on where you are located and applicableprivacy and data protection laws. These may include, for example, the right toaccess your personal information, request correction or deletion of yourinformation, object or opt-out to our processing of your information, requestthe restriction of the processing of your information, and/or requestportability of your information. Depending on your location and applicable law,you may have the right to appeal the denial of any of these rights. You can exerciseyour rights by emailing us at admin@NDMAhealth.com. We will respondto all requests in accordance with applicable data protection laws. Please notethat we may ask you to verify your request. If you are an authorized agentmaking a request on another's behalf, we may also ask you to provideconfirmation that you have the proper authority to make the request on thatperson's behalf, or we may ask the person to verify their identity with usdirectly. In addition to the rights describedabove, you can opt out from receiving marketing communications from us at anytime by clicking on the "unsubscribe" link in the email or bycontacting us using the methods described below. If you arelocated in the European Economic Area or United Kingdom, and you are not satisfiedwith how we have collected and processed your personal information, you mayalso complain to a data protection authority. Contact details for dataprotection authorities in the European Economic Area are available online.

‍11. Additional Information for EuropeIf you arelocated in the European Economic Area or United Kingdom, we need a legal basisto process your personal information. There are several alternative bases thatwe may rely on, depending on the purpose for processing your personalinformation. We will normally process your personal information because we needto perform a contract with you, the processing is in our legitimate interests,or we have your consent to do so.

●       Performance of a contract. We generally process your personalinformation as necessary to enter into a contract with you or perform ourcontractual obligations, for example to provide our
Services or provide information that you have specifically asked for.

●       Legitimate Interests. We may rely on legitimate interestswhere those interests do not outweigh your fundamental rights, for example topromote our Services, ensure the security of our Services, and improve ourproducts and services.

●       Consent. In certain cases, we may obtain your consent toprocess your personal information, for example in relation to certain marketingactivities or situations where we are required to obtain your consent by law.

●       Legal obligations. In some cases, we may have a legalobligation to collect and process your personal information, for example torespond to lawful requests and orders.

‍12. Additional Information For California And OtherU.S. States

‍This sectioncontains additional information for individuals residing in California andother U.S. states. Depending on yourstate of residence and the way in which you interact with us, some U.S. stateprivacy laws require specific disclosures regarding the personalinformation we collect about you and provide certain rights regarding yourpersonal information. In particular, these state privacy laws include theCalifornia Consumer Privacy Act (“CCPA”), the Virginia Consumer Data ProtectionAct (“VCDPA”), and the Colorado Privacy Act (“CPA”).

‍Notice at Collection. In our capacity as a business orcontroller under U.S. law, we have collected the following categories ofpersonal information in the past 12 months:

‍●       Identifiers, such as name, email address, IP address, andother online identifiers.

●       Commercial information, such as your professional emailaddress, telephone number, etc.

●       Internet or other electronic network activity information,such as IP address, browsing history, interaction with our Services, pageloads, clicks, etc.

●       Geolocation data, such as your city, state, country, etc.

●       Professional/employment information, such as job title,current employer, and (if you apply for a job with us) other information aboutyour professional experience and previous employment.

●       Sensitive personal information as defined under state privacylaws, such as your account log in combined with the log-in password orcredentials and (if you apply for a job with us) information you provide to usduring the recruitment process such as social security, driver's license, stateidentification card, passport number, health information and relatedaccommodations, citizenship/immigration status, and demographic information(such as racial or ethnic origin).

●       Other personal information, such as information you provideto use when you register for webinars or videos, when you contact us forcustomer support, when you attend one of our events, or when you apply for ajob with us.For the sourcesof personal information, please see the sections above titled “Information YouProvide”, “Information We Collect Automatically”, and “Information We CollectFrom Third Parties”. For the business or commercial purposes for which wecollect personal information, please see the section above titled “How We UseYour Information”. For an explanation of how long we retain personalinformation, please see the section above titled “Data Retention”.

‍Your Privacy Rights. Depending on your state of residenceand applicable law, you may have thefollowing rights:

●       The right to know what personal information the Companyhas collected about you.

●       The right to correct your personal information.

●       The right to delete personal information collectedfrom you (with some exceptions).

●       The right to opt-out of the sale or sharing of yourpersonal information.

●       The right to opt-out of the processing of yourinformation for targeted advertising.

●       The right to opt-out of profiling in furtherance ofdecisions that produce legal or processing of personal information for thepurposes of targeted advertising.

●       The right to appeal the denial of any of these rights. To exercise anyof the rights listed above, or appeal denial of a request, please contact us atadmin@NDMAhealth.com.

We will respondto all requests in accordance with applicable U.S. state laws. Please note thatwe may ask you to verify your request. If you are an authorized agent making arequest on another's behalf, we may also ask you to provide confirmation that youhave the proper authority to make the request on that person's behalf, or wemay ask the person to verify their identity with us directly. If we refuse totake demanded action on a request, we will provide instructions on how you mayappeal the decision.

We do not use ordisclose sensitive personal information for purposes other than those purposesunder the CCPA. Additionally, we will not deny goods or services, charge you adifferent price, or provide a different level or quality of goods or servicesbecause you have exercised your rights under the CCPA.

‍Sales & Sharing of Personal Information. As described above, we mayuse cookies and similar technologies to collect personal information from you,including online identifiers, internet/network information, and geolocationdata, and share this information with third party advertising and analyticsproviders. In some U.S. states, including California, sharing digital activityin this manner may be considered a “sale” or “sharing” of personal information.To the extent these practices qualify as “sale” or “sharing” under applicablestate law, or you wish to opt out from targeted advertising, you can accessfurther information about your choices in relation to these practices here.

We do not haveactual knowledge that it “sells” or “shares” personal information of consumersunder 16 years of age.

‍Shine the Light. Under California law, Californiaresidents have the right to request information from companies conductingbusiness in California about the third parties to which the company hasdisclosed their personal information for direct marketing purposes. We do notdisclose personal information obtained through our Services to third partiesfor their direct marketing purposes. Accordingly, we have no obligations underCalifornia Civil Code § 1798.83.

‍13. Children’s Privacy

‍We do notknowingly collect personal information from children under 13 years old (or theapplicable age of consent). If you believe that we may have collected personalinformation from someone under the applicable age of consent, please let usknow by emailing admin@NDMAhealth.com and we will take appropriate measuresto investigate and address the issue.

‍14. Links To Other Sites

‍Our Services maycontain links to other sites or services that are not operated by us. If youclick on any third-party links, you will be directed to that third party’ssite. We strongly advise you to review the privacy policy and terms andconditions of every third-party site that you visit. We have no control over,and assume no responsibility for the content, privacy policies, or practices ofany third-party sites or services.

‍15. Privacy Policy Changes

‍We may changethis Privacy Policy from time to time in response to changing legal,regulatory, technical, or business requirements. We encourage you to frequentlycheck this page for any changes as (Company) will post the most currentversion on our website. When we update this Privacy Policy, we will take appropriate measuresto notify you as required by applicable data protection laws. Your continueduse of the Services after any changes to this Privacy Policy will constituteyour acceptance of such changes. If a revision meaningfully reduces yourrights, we will notify you.

‍16. How to Contact Us

‍If you have anyquestions about this Privacy Policy, wish to report a suspected privacyincident, have a privacy concern, or want to communicate about a complaint, asystem failure, or any other matter please contact us via email admin@NDMAhealth.comand provide sufficient information about the matter on which you arecommunicating so that we may understand and address it. You can also write to us at 501 W.Broadway, Suite 1025, San Diego CA 92101. If you are located in the EuropeanEconomic Area or United Kingdom, NMDA is the controller of your personalinformation.