Neurologx Privacy Policy

In this Privacy Policy (“Policy”), we describe how Neurologx (“Company”, “Neurologx”, “we”, or “us”) collects, uses, and discloses information that we obtain about visitors to our website https://www.neurologx.io (the “Site”) or users of our services (collectively, the “Services”).

By visiting the Site or using any of our Services, you agree that your personal information will be handled as described in this Policy. Your use of our Site or Services, and any dispute over privacy, is subject to this Policy and our Terms of Service including its applicable limitations on damages and the resolution of disputes. The Terms of Service are incorporated by reference into this Policy. Please note: if you disagree with any term provided herein, please refrain from using our Services.

The Information We Collect About You

We collect information about you from your voluntary contact submissions via our Site, and automatically through your use of our Services.

Protected health information.

In certain circumstances, we may collect or use your information through our Sites and Services while acting as a Business Associate under the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”), which may constitute “Protected Health Information.” A “Business Associate” includes an entity that provides services to a HIPAA Covered Entity that involves the use or disclosure of Protected health information. If your health care provider or health insurance company qualifies as a Covered Entity, and we provide services to them or on their behalf, we may qualify as their Business Associate. “Protected Health Information” or “PHI” as defined under HIPAA, generally means information about you that identifies you and that relates to your physical or mental health or condition, the provision of health care to you, or payment for health care provided to you. To the extent your PHI is collected while operating as Business Associate under HIPAA, we will only use and disclose your information as permitted by HIPAA, which may include, but not be limited to, fulfilling our service obligations, our internal management and administration, to carry out our legal responsibilities, to de-identify or aggregate data and use such de-identified data for any lawful purpose, or as otherwise required by law. If you continue to receive Services from us and sign a separate HIPAA authorization form to release your health information to us, then such health information shall no longer be subject to HIPAA and shall be subject to the terms of such authorization form.

Information We Collect Directly From You.

The information we collect from you depends on how you use our Services. To the extent we collect PHI from you in any of the categories set forth below, then such PHI is subject to HIPAA, as set forth above.

• Communications and interactions.
  When you communicate with Neurologx, which we do in accordance with your healthcare provider, we collect personal information limited to your phone number, state of residency, and year of birth.

Information We Collect Directly From Covered Entities or Business Associates.

We may collect your response details as it relates to the service lines we support, such as medication adherence and disease management campaigns, but never any personal identifiable information.

How We Use Your Information

We use your information for the following purposes:

• Services.
  To provide our Services; to communicate with you about your use of our Services, to respond to your inquiries, and for other customer service purposes; and to tailor the content and information that we may send or display to you, to offer location customization, to provide you with relevant information and/or reminders related to a medical condition and/or particular treatment, and to otherwise personalize your experiences while using our Services.

  
  

• Communications.
  To send you text messages or other messages whether general or personal (e.g., appointment reminders; care management services; etc.), related to our Services, and to provide information about updates to our Terms of Use.

  
  

• Security and Protection of Rights.
  To protect our Services and business operations; to protect our rights or those of our stakeholders; to prevent and detect fraud, unauthorized activities and access, and other misuse; where we believe necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety or legal rights of any person or third party, or violations of our Terms of Service.

  
  

• General Business and Operational Support.
  To consider and implement mergers, acquisitions, reorganizations, bankruptcies, and other business transactions such as financings, and related to the administration of our general business, accounting, auditing, compliance, recordkeeping, and legal functions.

  
  

• Compliance and Legal Process.
  To comply with the law and our legal obligations, to respond to legal processes and related to legal proceedings.

  
  

• Other Purposes.
  For any other purposes for which we obtain your consent.

  
  

How We Share Your Information

We may share the data that we collect for the purposes described above, in order to provide our Services to you, to respond to and fulfill your requests, as otherwise directed or consented to by you, and as follows:

• Caregivers.
  ‍If, at your request, you are assisted by caregivers while using our Services, you may allow them to communicate on your behalf. By doing so, you provide your consent to share your Personal Information and PHI with them. The caregivers' access to your Personal Information and PHI is subject to this Policy and our Terms of Service.

  
  

• Service Providers.
  We disclose the information we collect from you to service providers, contractors or agents who perform functions on our behalf. These may include, for example, IT service providers, cloud storage providers, customer support, security monitoring, marketing providers, analytics providers, and others.

  
  

• Medical Provider Partners.
  Our Services primarily serve as a platform to ease your communication with applicable Medical Providers or your insurance company.

We also disclose information in the following circumstances:

• Business Transfers.
  If (i) we or our affiliates are or may be acquired by, merged with, or invested in by another company, or (ii) if any of our assets are or may be transferred to another company, whether as part of a bankruptcy or insolvency proceeding or otherwise, we may transfer the information we have collected from you to the other company. As part of the business transfer process, we may share certain of your personal information with lenders, auditors, and third-party advisors, including attorneys and consultants.

  
  

• In Response to Legal Process.
  We disclose your information to comply with the law, a judicial proceeding, court order, or other legal process, such as in response to a court order or a subpoena.

  
  

• To Protect Us and Others.
  We disclose your information when we believe it is appropriate to do so to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms of Service or this Policy, or as evidence in litigation in which we are involved.

  
  

• Aggregate and De-Identified Information.
  We may share aggregate, anonymized, or de-identified information about users with third parties for marketing, advertising, our business purposes, research or similar purposes.

Transfers of Personal Information

We take steps to ensure that any international transfer of personal information is carefully managed to protect your rights and interests and that such transfers comply with applicable data protection laws. In this regard, we only transfer your personal information outside of the country in which it was originally collected to countries which provide an adequate level of data protection similar to that of the country in which the personal information was collected or where we are satisfied that there is an appropriate justification under applicable data protection laws for the transfer. Regulatory approval for transfers will also be obtained in circumstances where required.

Your Rights

Neurologx acknowledges that data protection laws in certain jurisdictions provide Users with certain statutory rights to their Personal Information. Depending on the applicable jurisdiction, you may have the statutory right to take certain actions in regards to your Personal Information.

If you wish to exercise these rights, please email us at johno@neurologx.io and we will respond within a reasonable timeframe, and no later than permitted by applicable law.

Please note that aggregate and/or anonymous information derived from your Account and/or use of the Services may remain on Neurologx servers.

What Choices Do I Have Regarding Use of My Personal Information?

We may send periodic promotional emails to you. You have the right to opt-out of marketing messages at any time by following the instructions in such marketing messages or by contacting us at: johno@neurologx.io. Please note that it may take up to 10 business days for us to process opt-out requests. If you opt-out of receiving promotional emails, we may still send you emails about your account or any services you have requested or received from us.

We may also call or text you to communicate with you about Services you have requested or received from us. We will obtain your consent for this type of communication upon our initial outreach. You have the option to opt out of text messages by clicking the opt-out link in our initial outreach or by replying to the text message with your communication preferences. To opt out of phone calls, you may explicitly ask us to opt-out and we will record and honor your request.

Security of My Personal Information

We have implemented reasonable precautions to protect the information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our best efforts, no data security measures can guarantee security.

Minors

Our Services are not designed for minors and we do not knowingly collect personal data from minors. If we discover that a minor has provided us with personal data in violation of applicable law, we will delete such information from our systems. If you’re a parent and you believe we have collected your child’s information in violation of applicable law, please contact us at johno@neurologx.io.

We reserve the right to request proof of age at any stage so that we can verify that minors are not using the Services.

Contact Us

If you have questions about the privacy aspects of our Services or would like to make a complaint, please contact us at johno@neurologx.io.

Changes to this Policy

This Policy is current as of the Effective Date set forth above. We may change this Policy from time to time, so please be sure to check back periodically. We will post any changes to this Policy on our Site. If we make any changes to this Policy that materially affect our practices with regard to the personal information we have previously collected from you, we will endeavor to provide you with notice in advance of such change by highlighting the change on our Site.