NuroLux™ Privacy Policy

Effective: 10.2023

This Privacy Policy (“Policy”) describes how NuroLux™, Inc. (“NuroLux™,” “we,” “our,” “us”) collects, uses, and discloses certain personal information obtained through our website at https://www.NuroLux.com/ (the “Site”) and the features made available to you on the Site, including NeuroNavigator™ assessments, Caregiver Academy and Caregiver/Care Plan Concierge Coaching. By visiting our Site and/or using or purchasing the features made available to you on the Site (collectively, the “Services”), you are agreeing to the terms of this Policy.

This Policy applies only to information collected through the Site and therefore does not apply to data we collect in other contexts.

Email: info@nurolux.com

What information we collect and maintain about you

We collect personal and other information from you directly when you provide it to us through the Services. We may also automatically collect certain information about you and your computer, smartphone, or other device when you use, access, or interact with our Services.

User Accounts

  • If you create an account with us, we may collect the following categories of information about you:
  • First and last name
  • Email address
  • Phone number
  • Your child’s and family members’ date of birth
  • Your child’s age at the time of his/her/their autism diagnosis
  • Your child’s autism diagnosis
  • Your location
  • A screening questionnaire relating to your family’s and child’s unique needs
  • Billing and payment information (if you sign up for our membership)
  • Other Personal Information. You can visit the Site without submitting any information that we can use to identify you personally. However, if you use certain features on the Site, such as sign up for updates with us, you will be required to provide personal information. Such information could include, for example, your name, email address, and any information that you choose to provide to us as part of your correspondence.

Protected Health Information. When you set up an account with us, you are creating a direct customer relationship with us that enables you to access and/or utilize the various functions of the Service as a user. As part of that relationship, you voluntarily provide information to us, including but not limited to, your name, date of birth, email address, and mobile phone number, that we do not consider to be “protected health information” or “medical information”. However, in using certain components of the Services, you may also voluntarily provide certain health or medical information that may be protected under applicable laws. At this time, Nurolux is not a “Covered Entity” or “Business Associate” as those terms are defined by the Health Insurance Portability and Accountability Act of 1996, Public Law 104-191, and its related regulations and amendments (collectively, “HIPAA”). It is important to note that HIPAA does not necessarily apply to an entity or person simply because there is health information involved. However, we may, at a later date, based on a change in our business model or relationships with other entities, become subject to certain provisions of HIPAA with respect to “protected health information,” as defined under HIPAA, that you provide to us. In that case, any medical or health information that you provide that is subject to specific protections under applicable state laws (collectively, with PHI, “Protected Information”), will be used and disclosed only in accordance with such applicable laws. However, any information that does not constitute Protected Information under applicable laws may be used or disclosed in any manner permitted under this Privacy Policy. Protected Information does not include information that has been de-identified or anonymized in accordance with applicable laws.

Chat Feature. Our Site utilizes a chat feature to provide customer support. Use of the chat feature is completely voluntary. If you choose to interact with our chat feature, we will collect the information you submit to us. Chat sessions are recorded and used by us and our chat service provider. We may use or disclose the chat session information in accordance with this Privacy Policy. If you do not consent to these terms, please do not use the chat feature and contact us via email. We may now or in the future provide customer support via chatbox or email that utilizes artificial intelligence and natural language processing to understand customer questions and automate responses to them, simulating human conversation.

Phone/Video Recording. From time to time our interactions with you will be conducted over the telephone or video-conference (such as our coaching sessions), and such telephone calls and video conferences may be recorded.

Artificial Intelligence and Predictive Analytics. We use machine learning and artificial intelligence in connection with some of our Services to provide algorithmic predictive analytics for our users (e.g., to help predict the likelihood of costs and outcomes of treatment). We will use the data you submit together with the information submitted from everyone else who uses our Services to improve our algorithms, predictions and our Services, but that usage will be in a de-identified format and in the aggregate with other users’ data so that you are not individually identifiable.

Text Messaging. If you opt in to text messaging, we use your mobile number to send you service- related announcements, such notifications to complete an assessment and appointment reminders. Also, you may choose to receive promotional texts from us based on preferences that you indicate. Participation in mobile messaging is optional and not a condition of purchase. By providing your mobile number and opting in to receive these communications, you are consenting to receive autodialed or prerecorded marketing mobile messages at the phone number associated with your opt-in. The frequency and number of messages you will receive will vary. Message and data rates may apply. While you consent to receive messages sent using an autodialer, the foregoing shall not be interpreted to suggest or imply that any or all of our mobile messages are sent using an automatic telephone dialing system (“ATDS” or “autodialer”). When you opt-in to the service as noted above, we will send you an SMS message to confirm your signup. Text Messaging Opt-Out: You can cancel the SMS service at any time. Just text “STOP”. After you send the SMS message “STOP” to us, we will send you an SMS message to confirm that you have been unsubscribed. In some cases, you may continue to receive service-related notifications. If at any time you need assistance, just text “HELP”. After you send the SMS message “HELP” to us, we will respond with instructions on how to use our service as well as how to unsubscribe.

Server logs. Server logs automatically record information and details about your online interactions with us. For example, server logs may record information about your visit to our Sites on a particular time and day and collect information such as your device ID or IP address.

Cookies. We also use cookies on the Site. Cookies are small files that are stored on your device through the Site. A cookie allows the Sites to recognize whether you have visited before and may store user preferences and other information. For example, cookies can be used to collect or store information about your use of the Site during your current session and over time (including the pages you view and the files you download), your device’s operating system, your device ID, IP address, and your general geographic location. Most browsers will tell you how to stop accepting new cookies, how to be notified when you receive a new cookie, and how to disable existing cookies. Please note, however, that without cookies you may not be able to take full advantage of all of our Sites’ features. In addition, disabling cookies may cancel opt-outs that rely on cookies, such as web analytics or targeted advertising opt-outs.

Google Analytics. We use Google Analytics, which uses cookies to identify the frequency of use of certain areas of our website and to identify preferences. For more information regarding how Google collects, uses and shares your information, please visit www.google.com/policies/privacy/partners/. Google will use this information to analyze your use of the Services, compile reports on activity for us, and perform further services associated with website use and Internet use. Google may also transmit this information to third parties where required by law or to the extent that third parties process these data on behalf of Google. You can deactivate Google Analytics using a browser add-on if you do not wish the analysis to take place. You can download the add-on here: https://tools.google.com/dlpage/gaoptout?hl=en.

Pixel tags. A pixel tag (also known as a web beacon, clear GIF, pixel, or tag) is an image or a small string of code that may be placed in an advertisement or email. It allows companies to set or read cookies or transfer information to their servers when you load a webpage or interact with online content. For example, we or our service providers may use pixel tags to determine whether you have interacted with a specific part of our Services, viewed a particular advertisement, or opened a specific email.

SDKs and mobile advertising IDs. Our Services may include third-party software development kits (“SDKs”) that allow us and our service providers to collect information about your activity. In addition, some mobile devices come with a resettable advertising ID (such as Apple’s IDFA and Google’s Advertising ID) that, like cookies and pixel tags, allow us and our service providers to identify your mobile device over time for advertising purposes.

Third-party plugins. Our Site may include plugins from other companies, including social media companies (e.g., the Facebook “Like” button). These plugins may collect information, such as information about the pages you visit, and share it with the company that created the plugin even if you do not click on the plugin. These third-party plugins are governed by the privacy policies and terms of the companies that created them.

Third-party online tracking and behavioral advertising. We also may partner with certain third parties to collect, analyze, and use some of the personal and other information described in this section. For example, we may allow third parties to set cookies or use web beacons on the Site or in email communications from us. This information may be used for a variety of purposes, including online interest-based advertising, as discussed below (see the section entitled “With whom we share your information”).

Aggregated and de-identified information. From time to time, NuroLux™ may also collect and share aggregated or de-identified information about Site users, such as by publishing a report on trends in the usage of the Site. Such aggregated information will not identify you personally.

How We Use and Process Your Information

We use the information that we collect for a variety of purposes. Our legal bases for processing your personal information are:

  1. our legitimate interest in running and maintaining our business;
  2. performance and fulfillment of our contracts;
  3. your consent; and
  4. compliance with our legal obligations.

In many instances, more than one of these legal bases apply to the processing of your personal information.

The purposes for which we use your information include to:

    • Provide you with our Services;
    • Respond to your questions or requests concerning the Services;
    • Fulfill the terms of any agreement you have with us;
    • Fulfill your requests for our Services or otherwise complete a transaction that you initiate;
    • Send you information about our Services and other topics that are likely to be of interest to you, including newsletters, updates, or other communications, including promotional emails;
    • Improve our artificial intelligence and machine learning;
    • Deliver confirmations, account information, notifications, and similar operational communications;
    • Improve your user experience and the quality of our products and Services;
    • Comply with legal and/or regulatory requirements;
    • Aggregate and de-identify information;
    • Serve advertisements;
    • Analyze how visitors use the Services and various Services features, including to count and

recognize visitors to the Services;

  • Create new products and Services;
  • Manage our business; and
  • For other legitimate business purposes.

 

NuroLux™ may link information gathered through the Site with information that we collect in other contexts. But in that event, we will handle the combined information in a manner consistent with this Policy.

NuroLux™ may obtain your written consent from time to time in electronic form by using online agreements or other acknowledgements on the Services, including for any other contemplated uses of your personal data not addressed in this Privacy Policy. Please read all online agreements carefully before accepting them.

Small Groups and Mentoring Program. As a service to our users, our Site may facilitate the formation of small groups of users and one-on-one mentoring relationships where users can share information and receive feedback from other users. Participation in any small groups and mentor programming is entirely voluntary, and any information users disclose to other users in these sessions is not subject to this Policy.

With Whom and Why We Share Your Information

We share your information with other parties for a variety of purposes, as described below.

Our Coaches and Autism support services. We may share your information with third parties that assist us in offering you our Services, including our NuroLux™ coaches, ABA teams, special education advocates, financial planners, and insurance specialists.

Third Party Payers. We may share your information with third parties who are paying for services on your behalf, such as health insurers and government programs.

Third-party service providers. NuroLux™ may also use other third-party service providers that perform services on our behalf, including web-hosting companies, mailing vendors, payment processor, and analytics providers. These service providers may collect and/or use your information, including information that identifies you personally, to assist us in achieving the purposes discussed above.

Other Third Parties. We may share your information with other third parties when necessary to fulfill your requests for services; to complete a transaction that you initiate; to meet the terms of any agreement that you have with us or our partners; or to manage our business. Examples of third-party sharing necessary for our business purposes includes health care providers, therapists, financial planners, and charity- or research-based grant organizations.

Analytics. We partner with certain third parties to obtain the automatically collected information discussed above and to engage in analysis, auditing, research, and reporting. These third parties may use web logs or web beacons, and they may set and access cookies on your computer or other device. In particular, the Site uses Google Analytics to help collect and analyze certain information for the purposes discussed above. You may opt out of the use of cookies by Google Analytics here.

Interest-based Advertising. The Site also enables third-party tracking mechanisms to collect information about you and your computing devices for use in online interest-based advertising. For example, third parties may use the fact that you visited our Site to target online ads to you. In addition, our third-party advertising networks might use information about your use of our Site to help target advertisements based on your online activity in general. For information about interest- based advertising practices, including privacy and confidentiality, visit the Network Advertising Initiative website or the Digital Advertising Alliance website.

The use of online tracking mechanisms by third parties is subject to those third parties’ own privacy policies, and not this Policy. If you prefer to prevent third parties from setting and accessing cookies on your computer or other device, you may set your browser to block cookies. Additionally, you may remove yourself from the targeted advertising of companies within the Network Advertising Initiative by opting out here, or of companies participating in the Digital Advertising Alliance by opting out here. Although our Site currently does not respond to “do not track” browser headers, you can limit tracking through these third-party programs and by taking the other steps discussed above.

Text Messaging. If you opt-in to mobile messaging, we will share information with platform providers, phone companies, and other third-party service providers who assist us in the delivery of mobile messages.

Business Transactions. We may share your data with a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, liquidation or other disposition of all or any portion of our business, assets or stock with such third party.

Legal purposes. We also may use or share your information with third parties when we believe, in our sole discretion, that doing so is necessary:

  • To comply with applicable law or a court order, subpoena, or other legal process;
  • To investigate, prevent, or take action regarding illegal activities, suspected fraud, violations of our terms and conditions, or situations involving threats to our property or the property or physical safety of any person or third party;
  • To establish, protect, or exercise our legal rights or defend against legal claims; or
  • To facilitate the financing, securitization, insuring, sale, assignment, bankruptcy, or other disposal of all or part of our business or assets.

Your Choices

If you want to learn more about the personal information that NuroLux™ has about you, or you would like to update, change, or delete that information, please contact us by email at info@nurolux.com

You may opt out of receiving marketing emails from us by following the instructions in those emails or by emailing us at info@nurolux.com

We are committed to facilitating the exercise of your rights granted by the laws of your jurisdiction, which may include the right to request the correction, modification or deletion of your personal information and the right to opt out of the sale or sharing of your personal information (as applicable). We will do our best to honor your requests subject to any legal and contractual obligations. If you would like to make a request, cancel your account or request we delete or no longer use your account information to provide you Services, contact us at info@nurolux.com or make changes to any user profile information connected to your account.

External Links

This Site may contain links to third-party websites. If you use these links, you will leave the Site. We have not reviewed these third-party sites and do not control and are not responsible for any of these sites, their content, or their privacy policy. Thus, we do not endorse or make any representations about them, or any information, software, or other products or materials found there, or any results that may be obtained from using them. If you decide to access any of the third-party sites listed on our website, you do so at your own risk.

Data Security and Retention

We employ physical, technical, and administrative procedures to safeguard the personal information we collect online. However, no website is 100% secure, and we cannot ensure or warrant the security of any information you transmit to the Site or to us, and you transmit such information at your own risk.

We retain personal information about you necessary to fulfill the purpose for which that information was collected or as required or permitted by law. We do not retain personal information longer than is necessary for us to achieve the purposes for which we collected it. When we destroy your personal information, we do so in a way that prevents that information from being restored or reconstructed.

Notwithstanding the generality of the foregoing, we store email addresses until the user requests to be unsubscribed.

We do not store payment card information; rather we utilize a payment processor and store only an electronic receipt that sets forth confirming payment details, such as purchase date, the expiration date of the payment card and the payment ID, but not complete payment card information.

International Transfers

The information that we collect through or in connection with the Site is transferred to and processed in the United States for the purposes described above. NuroLux™ also may subcontract the processing of your data to, or otherwise share your data with, affiliates or third parties in the United States or countries other than your country of residence. The data- protection laws in these countries may be different from, and less stringent than, those in your country of residence. By using the Site or by providing any personal or other information to us, you expressly consent to such transfer and processing.

Children

Content on this Site is directed at individuals over the age of 18 and is not directed at children under the age of 13. We do not knowingly collect personally identifiable information from children under the age of 13.

California Disclosures

Do Not Track: We do not track our customers over time and across third party websites to provide targeted advertising on our Site and, therefore, our Site does not respond to Do Not Track (DNT) signals. Some third-party websites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you. If you are visiting such websites, you should be able to set the DNT signal on your browser so that third parties (particularly advertisers) know you do not want to be tracked.

“Shine The Light” Information-Sharing Disclosure: California residents may request a list of all third parties with respect to which we have disclosed any information about you for direct marketing purposes and the categories of information disclosed. If you are a California resident and want such a list, please send us a written request by email to info@nulolux.com with “California Shine The Light Rights” in the subject line.

Changes to this Policy

NuroLux™ may make changes to the Site in the future and as a consequence will need to revise this Policy to reflect those changes. NuroLux™ will post all such changes on the Site, so you should review this page periodically. If we make a material change to the Policy, you will be provided with appropriate notice.

How to Contact Us

Should you have any questions or concerns about this Policy, you can contact us at info@nurolux.com.