eNeura Inc. (“eNeura”, “We”, “Us”) understands the sensitivity of information about your health and the importance of protecting your privacy. Your confidence in our ability to protect your information is paramount.
This policy (together with our terms of website use and any other documents referred to on it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. We may collect personal data from you through our site (www.eNeura.com) (our site) and other online resources (such as email and the sTMS mini Online Migraine Diary).
We treat your personal data:
For the purpose of the Act, the data controllers are:
Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
EU-US PRIVACY SHIELD
eNeura complies with the EU-US Privacy Shield as set forth by the U.S. Department of Commerce and the Federal Trade Commission regarding the collection, use, and retention of personal information from European Union member countries. We are subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission.
INFORMATION WE MAY COLLECT FROM YOU
You can access most of the pages on our site without giving us your personal information and we only collect personal data about you if you choose to give it to us. We may collect and process the following data about you:
IP ADDRESSES AND COOKIES
We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual.
For the same reason, we may obtain information about your general internet usage by using a cookie file which is stored on the hard drive of your computer. Cookies contain information that is transferred to your computer’s hard drive. They help us to improve our site and to deliver a better and more personalised service. They enable us:
WHERE WE STORE YOUR PERSONAL DATA
All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
USES MADE OF THE INFORMATION
We use information held about you in the following ways:
DISCLOSURE OF YOUR INFORMATION
We may disclose your personal information to any member of our group from time to time, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006, as well as our Representative.
Your name, mailing address. phone number and email address, if required, will be disclosed to our shipping vendors if you elect to fill a prescription for an sTMS device. You cannot opt-out of this disclosure to our shipping vendors.
We may disclose your personal information to other third parties only with your prior consent as indicated by your signature on an authorization/consent form when you submit the personal information to us in writing, or if you actively opt-in if the information is provided via an online program. Instances where your personal information may be disclosed to third parties include:
We may disclose your de-identified sensitive information to third parties:
We will provide an individual opt-out or opt-in choice before we share your data with third parties other than our agents, or before we use it for a purpose other than that for which it was originally collected or subsequently authorized.
To limit the use and disclosure of your personal information, please submit a written request to firstname.lastname@example.org.
You have the right to ask us not to: disclose your sensitive information with third-parties; use your sensitive information for a purpose other than those for which it was originally collected or subsequently authorized by you through the exercise of opt-in choice; process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes.
Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
You may opt-in/out of these marketing programs by checking the appropriate box(es) on the patient registration form, or when you create your sTMS mini Online Migraine Diary account. You may also exercise the right to Opt-In or Opt-out of these programs at any time by contacting us via email at email@example.com.
ACCESS TO INFORMATION
The Act gives you the right to access, correct or delete information held about you. Your right of access can be exercised in accordance with the Act. To access the detailed information we hold about you, contact Customer Care at e-mail customercare@eNeura.com. We will provide you a copy of the information we hold about you within 30 days.
We will take reasonable steps to permit individuals to correct, amend, or delete information that is inaccurate, incomplete, or has been processed in violation of the Privacy Shield Principles (except when the burden or expense of providing access, correction, amendment or deletion would be disproportionate to the risks to the individual’s privacy, or where the rights of the persons other than the individual requesting the data would be violated.)
PRIVACY COMPLAINTS BY EUROPEAN UNION CITIZENS:
Attn: Customer Care
715 North Pastoria Avenue
Sunnyvale, CA 94085 USA
Or email: firstname.lastname@example.org
We have further committed to refer unresolved privacy complaints under the EU-US Privacy Shield Principles to BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus.
Privacy Shield organizations must respond with 45 days of receiving a complaint. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed by us, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint.
As a last resort, and in limited situations, EU individuals may seek binding arbitration before the Privacy Shield Panel to be created by the U.S. Department of Commerce and the European Commission.
LIMITATION ON APPLICATION OF PRINCIPLES
Adherence by us to these Privacy Principles may be limited (a) to the extent required to respond to a legal or ethical obligation; and (b) to the extent expressly permitted by an applicable law, rule or regulation.
Our site is intended for use by adults. We will not collect any personal data from a person we know to be under the age of 18 without the prior, written consent of that person’s parent or adult legal representative, who will have the right to request access to, or deletion of, the information provided by the child.
Attn: Customer Care
715 North Pastoria Avenue
Sunnyvale, CA 94085 USA