NEURELIS CONSUMER HEALTH DATA PRIVACY POLICY
This Consumer Health Data Privacy Policy (“Health Data Policy”) describes how Neurelis, Inc. (“Neurelis”, “we,” “us” or “our”) processes “Consumer Health Data,” as that term is defined under applicable state privacy law, about consumers who reside in the states of Nevada, Washington, and any other applicable U.S. jurisdiction who visit the Neurelis websites (including but not limited to neurelis.com, valtoco.com, myneurelis.com, letstalkseizures.com, valtocoprograms.com, neurelismedicalaffairs.com, valtocowebinars.com and other Neurelis-owned websites that link to this Health Data Policy) (the “Sites”), as well as clinical trials, products, and services (collectively, the Sites and other Neurelis services are referred to as the “Services”). Please carefully read this Health Data Policy as it contains important information concerning your Consumer Health Data and how we use it.
This Health Data Policy relates only to Consumer Health Data. It does not describe how Neurelis processes your personal information. For more information about our information practices with respect to personal data, please refer to our Privacy Policy
Categories. We collect the following categories of Consumer Health Data:
- Individual health conditions, treatment, diseases, or diagnoses;
- Information that could identify your attempt to seek health care services, including our prescription products;
- Use or purchase of prescribed medication, including our prescription products;
- Diagnoses or diagnostic testing, treatment or medication;
- Bodily functions, vital signs, symptoms, or measurements; and
- Any inferences of the above categories of consumer health data derived or extrapolated from non-health information, such as cookies and other tracking technologies on our Sites if you provide your express permission for our collection.
Sources of Collection. We collect Consumer Health Data from the following categories of sources:
- Directly from you when you share it with us and from your interactions with our Services, including our patient support or similar programs that we may offer;
- With your permission, we and our third-party providers and business partners may collect your health data over time and across different internet websites or online services when you use any internet website or online service of the regulated entity; and
- From third parties and business partners, including our third-party providers and business partners that are involved or operate the patient support or similar programs that we may offer.
Purposes of Collection. We collect, processes, and disclose Consumer Health Data for the following business purposes:
- Operate, maintain, and enhance the features of the Sites, including monitoring and analyzing the effectiveness of the content on the Sites, monitor aggregate site usage data and track other usage of the Sites.
- Provide you with the Services and any related features or functions.
- Provide you with a tailored and user-friendly experience as you navigate our website and other Services.
- Promote and market the Services to you, including through personalized advertising.
- Communicate with you for administrative and other business purposes, including providing you information that you have requested.
- Conduct research on users’ demographics, interests, and behavior based upon information you provide during use of our Sites.
- Anonymize and aggregate information for analytics and reporting.
- Carry out our legal and contractual obligations and enforcing our rights.
- Comply with any applicable legal obligations.
- Authenticate use, detecting potential fraudulent use, and otherwise maintain the security of the Services.
- Develop, test, improve, and demonstrate the Services.
- Protect and ensure the safety and security of our Services and users.
- Short-term transient use.
- Any other purpose with your consent.
Disclosures.
We disclose some or all of the above categories of Consumer Health Data for the purposes described above with the following third parties and affiliates:
- To our wholly owned subsidiary, Aegis Therapeutics Inc.;
- As legally required in relevant legal proceedings and otherwise to the extent required or explicitly authorized by applicable law;
- To other companies we collaborate with for research and development activities related to products and services jointly offered or developed by us and that company; and
- To data analytics and advertising and marketing providers.
Your Privacy Rights
Depending on your place of residency, you may have the right to submit some or all of the following requests regarding your Consumer Health Data, subject to applicable law and certain exceptions:
- Right to confirm and access your Consumer Health Data, including a list of all third parties and affiliates with whom we have shared the Consumer Health Data. You may request that we provide you with a copy of the Consumer Health Data that we maintain about you.
- Right to correct your Consumer Health Data. If your Consumer Health Data we maintain is inaccurate and you would like us to rectify it, you may request that we make changes to it.
- Right to withdraw consent from collection or sharing of your Consumer Health Data at any time. This includes withdrawing your authorization to “sell” your Consumer Health Data if you provided it to us.
- Right to delete your Consumer Health Data.
- Right to appeal a decision by us regarding your request to exercise any of the above rights.
Policy Updates
This Health Data Policy may be updated periodically to reflect changes in our privacy practices. We will post changes on this page and identify the date the privacy notice was last updated. If you have provided an email address, you also may be notified by email at the last email address you provided us, by posting notice of such changes on the Services, or by other means, consistent with applicable law. If a material change will apply to Personal Information we already have collected, we will additionally seek your consent in accordance with applicable law. It is your responsibility to review the Health Data Policy from time to time to view any such changes. IF YOU DO NOT ACCEPT AND AGREE TO THIS HEALTH DATA POLICY, INCLUDING ANY CHANGES, THEN YOU MAY NOT ACCESS OR USE THE SERVICES.
Contact
Should you have any questions about our privacy practices or this Health Data Policy or wish to submit a request concerning your Consumer Health Data, please email us at privacy@neurelis.com or contact us at 3430 Carmel Mountain Road, Suite 300, San Diego, CA 92121 and/or our toll-free number 1-858-251-2100. You may also submit requests by filling out a request form online Here. Please note that we may take steps to verify your identity before we fulfill your request in accordance with applicable law.