CNS Vital Signs

CNS VITAL SIGNS, LLC — PRIVACY POLICY

At CNS Vital Signs, our core business is the development of software tools primarily in the area of cognitive testing. The majority of data produced (including any potential personal data) from CNS Vital Signs software solutions, reside locally with our customers systems infrastructure. When solutions provided by CNS Vital Signs do incorporate CNS Vital Signs infrastructure, the protection of personal data is essential for our company. For these reasons, CNS Vital Signs has issued a corporate policy for the protection of the confidentiality of individually identifiable information in accordance with applicable laws and regulations.

CNS Vital Signs intends that its corporate privacy policy and standard practices and procedures will ensure timely compliance with applicable United States and international laws and regulations, including, as applicable, the Health Insurance Portability and Accountability Act of 1996 (HIPAA) - mandated Standards for Privacy of Individually Identifiable Health Information issued by the U.S. Department of Health and Human Services (HHS) and the European Union (EU) Data Protection Directive.

SCOPE

This Policy applies to all personal information, either in electronic or paper format, received by CNS Vital Signs in the United States.

DEFINITIONS

For purposes of this Policy, the following definitions shall apply:

"Agent" means any third party that uses personal information provided to it by CNS Vital Signs to perform tasks on behalf of and under the instructions of CNS Vital Signs.

"CNS Vital Signs" means CNS Vital Signs LLC, its successors, subsidiaries, divisions and groups in the United States.

"Personal information" means any information or set of information that identifies or could be used by or on behalf of CNS Vital Signs to identify an individual. Personal information does not include information that is encoded or anonymized or publicly available information that has not been combined with non-public personal information.

"Sensitive personal information" means personal information that reveals race, ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, or that concerns health or sex life. In addition, CNS Vital Signs will treat as sensitive personal information any information received from a third party where that third party treats and identifies the information as sensitive.

PRIVACY PRINCIPLES

The privacy principles in this Policy are based on the Safe Harbor Privacy Principles.

NOTICE

Personal information may be collected by a customer using one of our software tools, but in the event CNS Vital Signs collects personal information directly from individuals, it will inform them about the purposes for which it collects and uses personal information about them

CHOICE

CNS Vital Signs will offer individuals the opportunity to choose (opt-out) whether their personal information is (a) to be disclosed to a non-agent third party, or (b) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.

ONWARD TRANSFER

CNS Vital Signs may share an individual's information with agents, contractors or partners of CNS Vital Signs in connection with services that these individuals or entities perform for, or with, CNS Vital Signs. CNS Vital Signs may, for example, provide an individual's personal information to agent contractors or partners for hosting our databases, for data processing services, or to send to that individual the information that he or she requested.

CNS Vital Signs will obtain assurances from its agents that they will safeguard personal information consistently with this Policy. Where CNS Vital Signs knows that an agent, contractor or partner is using or disclosing personal information in a manner contrary to this Policy, CNS Vital Signs will take reasonable steps to prevent or stop the use or disclosure.

DATA INTEGRITY

CNS Vital Signs will use personal information only in a manner consistent with the purposes for which it was collected.

ACCESS AND CORRECTION

Upon request, individuals will be provided with the personal information that CNS Vital Signs holds about them. In addition, upon request, CNS Vital Signs will take reasonable steps to provide individuals with a means to correct, amend, or delete information that is found to be inaccurate or incomplete. Due to regulatory, statistical, and contractual requirements, we are not able to grant direct access to research data to research participants or clinical investigators.

SECURITY

The security of your personal information is very important to CNS Vital Signs. . CNS Vital Signs will employ reasonable safeguards to protect personal information in its possession from loss, misuse and unauthorized access or,disclosure,. Both electronic and paper based records holding personal information are maintained in access controlled facilities for which business continuity plans are required.

ENFORCEMENT

CNS Vital Signs' management, has put into place internal, self-assessment procedures for periodically conducting random reviews of compliance of its relevant privacy practices to verify adherence to the company's Safe Harbor Privacy Policy.

Any employee that CNS Vital Signs determines is in violation of this Safe Harbor Privacy Policy will be subject to disciplinary action up to and including termination of employment.

DISPUTE RESOLUTION

Any questions or concerns regarding the use or disclosure of personal information should be directed to the CNS Vital Signs Management at the email address given below. CNS Vital Signs will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information in accordance with the principles contained in this Policy.

For more information email support@cnsvs.com or call 888.750.6941