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  • Neurolens Privacy Policy 

     

    Last Updated: April 15, 2025  

     

    Neurolens, Inc. (“Neurolens,” “we,” “our,” and/or “us”) values the privacy of individuals who use our website and related services (collectively, our “Services”). This privacy policy (the “Privacy Policy”) explains how we collect, use, and share information from users of our Services (“Users,” “you,” and/or “your”). Throughout this Privacy Policy, we may refer to users who are healthcare providers as “Provider Users” and users who are patients as “Patient Users.” By using our Services, you agree to the collection, use, disclosure, and procedures this Privacy Policy describes. Beyond the Privacy Policy, your use of our Services is also subject to our Terms of Service https://www.neurolens.com/terms-of-service. 

     

    Personal Information 

    For the purposes of this Privacy Policy, "Personal Information" means any information about an identifiable individual, including any information that directly or indirectly identifies such individual. 

     

    Health and social services information 

    For the purposes of this Privacy Policy, "Health and social services information" is sensitive information that makes it possible, even indirectly, to identify an individual who has one of the following characteristics: (i) it concerns the person's physical or mental health and its determining factors, including the person's medical or family history; (ii) it concerns any material taken from the person as part of an evaluation or treatment; (iii) it concerns the health or social services offered to the person; (iv) it was obtained in the performance of a function provided for in the Public Health Act; or (v) any other characteristic determined by government regulation. In addition, information allowing the identification of a person is health and social services information when it is attached to information referred to in the present definition or when it is collected with a view to the registration, enrolment or admission of the person concerned in an institution or to his being taken in charge by another organization in the health and social services sector. 

     

    Personal Information Management Program 

    In order to protect your Personal Information, we have put in place policies, practices and procedures relating to the management of the Personal Information we hold. 

     

    These internal policies and procedures govern the collection, use, disclosure, retention and destruction of personal information, as well as complaint handling, information security and data governance at Neurolens. They also provide the framework for the implementation of Privacy Impact Assessments, where required, as well as the prevention of and response to potential privacy incidents. All these policies and practices have been approved by our Privacy Officer. 

       

    The collection of your Personal Information through our Services complies with the requirements of this program. 

     

    Privacy Officer 

    Our senior executives have delegated the management of the Personal Information Management Program to the Data Privacy Officer. Their duties consist of managing and monitoring Neurolens internal Personal Information Management Program. 

     

    It is the Data Privacy Officer who approves and implements privacy policies and procedures, ensures their proper functioning and reports to Neurolens senior management on the effectiveness of the program. 

     

    It is also the responsibility of the Data Privacy Officer to provide you with the necessary support in the event of a question, complaint, challenge or request relating to the protection of Personal Information: 

     

    Data Privacy Officer  

    Neurolens, Inc.  

    1234 Lakeshore Drive, Suite 200 

    Coppell, TX 75019 

    United States of America  

    privacy@neurolens.com 

     

    We are committed to responding promptly to your requests.  

     

    Upon receipt of a request, the Data Privacy Officer will conduct an investigation. If the complaint is justified, the situation will be corrected. Regardless of our conclusion, we will keep you informed. 

      

    Basis for Processing Personal Information 

    Neurolens needs to collect and process some of your Personal Information in order for you to use our Services. 

     

    When we collect your Personal Information, we ensure that we collect only the information necessary to fulfill one of our purposes, which has been previously disclosed to you, for example, in this Privacy Policy. We use Personal Information in accordance with the privacy laws applicable to our business. 

     

    The following is a description of the basis on which Neurolens collects and processes your personal information:  

     

    Your Consent 

    As required by applicable privacy legislation, Neurolens collects the majority of your Personal Information on the basis of your voluntary consent, favoring collection directly from you.  

     

    For example, Neurolens undertakes to obtain your explicit consent for the collection of any Sensitive Personal Information.  

     

    Other permissible legal basis, such as the performance of our contracts 

    As permitted by applicable privacy laws, Neurolens may collect Personal Information without your express consent, for example, to comply with obligations under applicable laws or to fulfill our contracts. 

     

    Information We Collect 

    Depending on the nature of your activity through our Services, we may collect a variety of information from or about you or your devices from various sources, as described below. 

      

    1. Information You Provide to Us. 

    Registration and Profile Information. When you sign up for an account or register to use our Services, we may ask you for your name, date of birth, email address, and phone number. 

      

    Communications. We receive information about you when you contact us directly and/or sign up to receive updates from us. For example, if you contact us through our website, request an appointment with a provider through the website, we may collect your name, email address, phone number, the contents of your message, and any attachments you may send to us. We also collect information such as your name and email address when you request to receive updates from us or otherwise request that we contact you directly. Similarly, if you request to download content from our website (such as one of our white papers), we collect your name, email address, city, state, and zip code. You can unsubscribe from our promotional emails via the link provided in the emails.  

      

    Careers. If you decide that you wish to apply for a job with us, you may submit your contact information and your resume online. We will collect the information you choose to provide on your resume, such as your education and employment experience. You may also apply through LinkedIn. If you do so, we will collect the information you make available to us on LinkedIn. 

      

    Intake Questionnaires. If you are a Patient User and complete our intake questionnaire (often referred to as a Lifestyle Index), you will be asked to provide certain information regarding your symptoms, as well as demographic information including your name, date of birth, email and phone number. This information will be shared with your healthcare provider to facilitate providing you our Services. 

      

    1. Information We Collect When You Use Our Services. 

    Location Information. When you use our Services, we can infer your general location information, for example by using your internet protocol (IP) address. 

      

    Device Information. We receive information about the device and software you use to access our Services, which may include IP address, web browser type, operating system version, and device identifiers. 

      

    Usage Information. To help us understand how you use our Services and to help us improve them, we automatically receive information about your interactions with our Services, like the pages or other content you view and the dates and times of your visits. 

     

    Patient Users Information. When you use our Services with a Patient User, we can collect the information you provide to the patient management system. This information can be the patient ID (identifier used by the Provider User to associate the patient with an entry in their patient management system), name, last name, date of birth, prescription information such as sphere and cylinder, and eye gaze angle and movement (i.e. Neurolens measurement data) and is categorized by Neurolens as a Health or social services information. 

      

    Information from Cookies and Similar Technologies. We and third-party partners collect information using Cookies, pixel tags, or similar technologies. Any Personal Information we collect using Cookies or on our behalf is treated with the same level of confidentiality as any other Personal Information we hold. Our third-party partners, such as analytics and advertising partners, may use these technologies to collect information about your online activities over time and across different services. Cookies are small text files containing a string of alphanumeric characters. We may use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to our Services. 

     

    1. Essential cookies 

    These Cookies are necessary for the operation of the Services and provide basic functions and may include connecting to our Services, maintaining your session and preventing security threats. We cannot disable these Cookies in our systems without affecting the operation of the Services. However, if you wish, you can block or delete them by changing your browser settings and forcing all Cookies on the Site to be blocked. 

    1. Non-essential cookies 

    Non-essential Cookies provide certain non-essential functionalities on our Services, for functional, analytical or advertising purposes. We will ask for your consent before using these Cookies.  

    • Functional Cookies: We use these Cookies to facilitate non-essential functionalities of our Services, such as the integration of content such as videos or the sharing of Site content on social media. 
    • Advertising Cookies: Our Services displays advertisements. These Cookies help us to track the effectiveness of our advertising campaigns and to personalize our ads so that they are meaningful to you. 
    • Analytical cookies: These cookies store information such as the number of visitors to our Services or the page they have visited. They help us to understand and analyze the performance of our Services and our potential improvements. 

     

    Please review your web browser’s “Help” file to learn the proper way to modify your cookie settings. Please note that if you delete or choose not to accept Cookies from the Service, you may not be able to utilize the features of the Service to their fullest potential. 

      

    1. Information We Receive from Third Parties. 

    Third parties. We may receive additional information about you, such as demographic data, from third parties such as data or marketing partners and combine it with other information we have about you, with your consent or if permitted by law. 

     

    With your consent, healthcare professionals using our Services may also provide us with your vision correction prescription information and Neurolens measurement results. The healthcare professional may also provide his or her observations, notes and remarks concerning his or her examination and assessment of your eye condition, or otherwise record any information concerning prescriptions or referrals to other healthcare professionals for examination, follow-up or management. Refusal to provide your consent will result in the healthcare professional not being able to use the Neurolens Services during your consultation, to assist him/her in his/her decision making. 

      

    How We Use the Information We Collect 

      

    We use the information we collect: 

    • To provide, maintain, improve, and enhance our Services, for example, by helping you find and schedule appointments with providers near you; 
    • To give healthcare professionals access to the Neurolens Services, and otherwise enable them to use it as a diagnostic aid; 
    • To identify and authenticate you in order to manage your file, if applicable, and the information concerning you for the healthcare professional; 
    • To personalize your experience on our Services such as by providing tailored content and recommendations; 
    • To understand and analyze how you use our Services and develop new products, services, features, and functionality, including sending you surveys to ask for your feedback about our Services; 
    • To communicate with you, provide you with updates and other information relating to our Services, provide information that you request, respond to comments and questions, and otherwise provide customer support; 
    • For marketing and advertising purposes, such as developing and providing promotional and advertising materials that may be relevant, valuable or otherwise of interest to you; 
    • To generate anonymized, aggregate data containing only de-identified, non-personal information that we may use to publish reports; 
    • To send you text messages and push notifications; 
    • To find and prevent fraud, and respond to trust and safety issues that may arise; 
    • For compliance purposes, including enforcing our TOS or other legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency; and 
    • For other purposes for which we provide specific notice at the time the information is collected and to which you have consented. 

      

    If we wish to use your Personal Information for a purpose not mentioned above and for which you have not consented, we will ensure that we seek appropriate consent from you or inform you of the change, where permitted by law. 

     

    How We Share the Information We Collect 

    Your Personal Information will not be sold to third parties.  

     

    We share your Personal Information with third parties to (i) fulfill our purposes, (ii) respond to requirements or requests made under applicable laws, (iii) perform tasks contracted to us by our customers. 

     

    Most of the time, you have already consented to such sharing, for example by accepting the consent presented to you when you opened your account. Sometimes applicable laws also allow us to share your Personal Information with third parties without your consent, in specific cases. 

     

    Our employees. In the course of their work, our employees and officers may have access to your Personal Information, for example when you contact us. Their access is limited to what is necessary for the performance of their duties, mainly for customer support, ongoing product and customer experience improvement 

    Providers. We may share any information we receive from you with a provider you have selected for the purpose of providing you optometry services or on behalf of your optometry provider, such as when you request an appointment with a provider or complete an intake form. 

     

    Vendors and Service Providers. We may share any information we receive with vendors and service providers retained in connection with the provision of our Services. In such cases, we implement reasonable contractual and technical safeguards, including Privacy Impact Assessments, to ensure that these third parties keep all Personal Information they process strictly confidential. 

     

     

    Analytics Partners. We use analytics services such as Google Analytics to collect and process certain analytics data. These services may also collect information about your use of other websites, apps, and online resources. You can learn more about Google’s practices by visiting https://www.google.com/policies/privacy/partner/. To help us understand how you use our Services and to help us improve them, we automatically receive information about your interactions with our Services, like the pages or other content you view and the dates and times of your visits. 

     

    As Required by Law and Similar Disclosures. We may access, preserve, and disclose your information if we believe doing so is required or appropriate to: (a) comply with law enforcement requests and legal process, such as a court order or subpoena; (b) respond to your requests; (c) protect your, our, or others’ rights, property, or safety; (d) enforce or verify your compliance with any part of your contracts with us, if applicable; or (e) prevent fraud or other illegal activity perpetrated through the Services. 

     

    Merger, Sale, or Other Asset Transfers. We may transfer your information to service providers, advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell, liquidate, or transfer all or a portion of our assets. The use of your information following any of these events will be governed by the provisions of this Privacy Policy in effect at the time the applicable information was collected. In such case, we limit sharing to what is necessary to assess the feasibility or advisability of the transaction. 

     

    Consent. We may also disclose your information with your permission. 

      

    Retention and Destruction of Personal Information 

    Neurolens will retain your Personal Information only for as long as is necessary to fulfill the purposes for which it was collected, in accordance with our internal document retention policies, to comply with applicable legal, tax or regulatory requirements, or until you request us to destroy it. After such period, any Personal Information concerned and held by Neurolens will be destroyed, deleted or anonymized.  

     

    Your Rights Regarding your Personal Information 

    Depending on applicable laws, where you live and how you interact with our Services, you may be granted certain rights with respect to the Personal Information we hold about you. 

     

    For example, you may be entitled to:  

    • Obtain access to the Personal Information we hold about you; 
    • To correct Personal Information we hold that is inaccurate, misleading or incomplete; 
    • Request the deletion of your Personal Information; 
    • To obtain additional information, for example on the categories of third parties to whom we communicate your Personal Information; 
    • To request the portability of your Personal Information in a structured, commonly used and machine-readable format; 
    • To withdraw your consent at any time, if we have collected and processed your Personal Information with your consent. Withdrawal of your consent will not affect the lawfulness of the processing we carried out prior to your withdrawal, nor the processing of your Personal Information carried out on the basis of legitimate processing grounds other than consent. 
    • To refuse promotional communications from Neurolens; 
    • File a complaint with a privacy control authority, such as a privacy commissioner or the Commission d’accès à l’information. 

     

    File a complaint  

    You may file a complaint with the Data Privacy Officer of Neurolens if you are dissatisfied with our handling of your Personal Information or compliance with this Policy.   

     

    You are also entitled by law to lodge a complaint with a privacy commissioner or any other competent supervisory authority for the protection of personal information.  

     

    Exercising your rights 

    You may review, correct, update, modify or delete the Personal Information you have provided to us using your account. Simply log in to your account and make the changes.   

    You can also exercise your rights listed above by sending a written request to our Privacy Officer. He or she will be happy to assist you in any way he or she can.  

    For your protection, we will only process requests to exercise your rights from the same e-mail address you use to log in to your account. We may also need to verify your identity before processing your request. Depending on the applicable laws, we will inform you of the procedure to follow, the processing time and the information required, if any. We aim to respond to requests promptly, usually within 30 days. 

     

    In the context of the processing activities covered by this Policy, Neurolens does not make decisions based solely on automated processing producing legal effects or similar significant effects. 

     

     

    Your Choices Regarding our Use and Disclosure of Personal Information 

      

    Marketing Communications. You can unsubscribe from our promotional emails via the link provided in the emails. Even if you opt-out of receiving promotional messages from us, you will continue to receive administrative messages from us as long as you keep using our Services. 

      

    Do Not Track. There is no accepted standard on how to respond to Do Not Track signals, and we do not respond to such signals. 

     

    If you choose not to provide us with information we collect, some features of our Services may not work as intended. 

     

    Third Parties 

    Our Services may contain links to other websites, products, or services that we do not own or operate. We are not responsible for the privacy practices of these third parties. Please be aware that this Privacy Policy does not apply to your activities on these third-party services or any information you disclose to these third parties. We encourage you to read their privacy policies before providing any information to them. 

     

    Security 

    The security of your Personal Information is a priority for us.  

     

    Your Personal Information is hosted by our service providers who are committed to using reasonable security measures to preserve the integrity and confidentiality of your Personal Information. 

     

    Our employees and suppliers are informed of the confidential nature of the Personal Information collected and are made aware of the appropriate security measures to prevent unauthorized access to Personal Information. 

     

    We maintain our service and all associated data with technical, administrative and physical safeguards to protect you against loss, unauthorized access, destruction, misuse, alteration and improper disclosure of your Personal Information. These safeguards vary according to the sensitivity of the data in our possession, and are based on the best industry standards. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. 

     

    If you have any questions about the security of your interaction with us (if, for example, you believe that the security of any account you may have with us has been compromised), you may contact us. 

     

    Minor’s Privacy 

    We do not knowingly collect, maintain, or use Personal Information from minors under 14 years of age, and no part of our Services are directed to minors. If a parent or guardian discovers that his or her minor child has provided us with Personal Information without our having obtained the appropriate consent, such parent or guardian has the right, upon request, to inspect the Personal Information provided by the child and/or to require that it be deleted from our files. In this case, you may alert us at privacy@neurolens.com. 

     

    International Visitors 

    Our Services are hosted in the United States and intended for visitors located within the United States. If you choose to use our Services from the European Union or other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you are transferring your Personal Information outside of those regions to the United States for storage and processing. Also, we may transfer your data from the U.S. to other countries or regions in connection with storage and processing of data, fulfilling your requests, and operating the Services. By providing any information, including Personal Information, on or via our Services, you consent to such transfer, storage, and processing. 

     

    Update Your Information or Pose a Question 

    You can update your account and profile information through your profile settings. If you have questions about your privacy related to the use of our Services or this privacy policy, please contact us at privacy@neurolens.commailto:. 

     

    Changes to this Privacy Policy 

    We will post any adjustments to the Privacy Policy on this page, and the revised version will be effective when it is posted. If we materially change the ways in which we use or share Personal Information previously collected from you through our Services, we will notify you through existing Services, by email, or other communication. 

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