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CNS VITAL SIGNS, LLC — PRIVACY POLICY

At CNS Vital Signs, LLC ("CNSVS") our core business is the development of software tools primarily in the area of cognitive testing. The protection of personal data is essential for our company. CNSVS has created this privacy policy in order to demonstrate its commitment to the privacy and protection of your personal information. To better protect your privacy, CNSVS provides this notice explaining our information practices and the choices you can make about the way your information is collected and used. We will request your affirmative consent to the processing of your personally identifiable information using a click-through button, and your grant of such consent will result in a tracking cookie being placed on your browser.

CNSVS 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) General Data Protection Regulation (EU) 2016/679.

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.

"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.

"Personally Identifiable Information" or "PII" means personal information that can be used to identify a natural person, such as name, telephone number, email address, date of birth, and home or business mailing address, or information related to physical characteristics and gender.

"Software" means the CNSVS software made available or downloaded from the Website and subject to the terms of the CNSVS License Agreement.

"Website” means our website located at www.cnsvs.com.

Personal Information Collection

CNSVS may collect PII, when you access certain areas of our Website or our Software that requires registration or your contact information. CNSVS uses a third party payment processor for services that require payment; however, CNSVS does not store any credit card information.

At other times, CNSVS may collect aggregated information that cannot be used to directly identify you. Aggregated information may include statistical information about the types of classes of users on our Website, or demographical and statistical information about individuals that use the Software. For example, we may aggregate non-personal information, such as the number of visitors to a particular area of the Website or individuals that have used the Software. CNSVS will not use aggregated information in a way that can be linked directly back to individual persons.

How CNSVS Collects Personal Information

CNSVS may use any number of tools to collect information about you and the web browser that you use to connect to our Website. For example, cookies are tiny text files that we place on your computer’s hard drive when you visit our Website. We may use cookies to personalize your Website. You do not have to accept our cookies, and browser settings can be used to prohibit the placement of cookies on your devices. You also may delete cookies after they have been placed on your hard drive. If you do not accept or choose to delete our cookies, some areas of our Website that you access may take more time to work, or may not function properly.

CNSVS may also collect additional information from your web browser each time you visit our Website. We may collect information on the pages that you visit, and other actions that you take while using our Website. This information may include the type of browser, the time that your browser was used to access our Website, and the referring website address.

Our Use and Disclosure of Your Personal Information

When you register on one of our Websites, you will be given the opportunity to select the types of information that you consent to receive such information. Based on your selections, CNSVS may use your personal information to contact you via mail, email, or messaging in order to give you updates about CNSVS’s services that may be of interest to you. We also use return e-mail addresses to answer the e-mail we receive from you. We may also use your IP address to help protect CNSVS.

Additional uses of your non-personal and personal information will be to provide you with customer support, to perform functions that are described to you at the time of collection, and to enforce our Website’s terms and conditions of Use.

CNSVS may also disclose your personal information as is necessary to: (a) comply with a subpoena or court order; (b) cooperate with law enforcement or other government agency; (c) establish or exercise our legal rights; (d) protect the property or safety of our company and employees, contractors, vendors, and suppliers; (e) defend against legal claims; (f) help with internal and external investigations; or (g) as otherwise required by law or permitted by law. We may disclose your information in connection with the sale or merger of CNSVS or any transaction that involves the sale or assignment of some or all of our assets.

Data Storage and Security

CNSVS uses third party service providers to host our Website and the online version of our Software, and CNSVS makes reasonable efforts to ensure that our third party service providers have implemented physical, electronic, and procedural security measures to assist with safeguarding your personal information, and to help protect against unauthorized access and disclosure. Notwithstanding our efforts, the Internet has inherent security risks. CNSVS cannot promise, and you should not expect, that the information that you submit or upload to the Website, whether personal information or other information, will always be impenetrable from attacks by cyber criminals. You should take care with regard to how you handle and disclose your personal information or any username or password that you are required to use to access services on our Website.

Children and Data Collection

Our Website is a public website that is viewable by anyone without restriction. However, our Website content is neither directed toward minors nor children who are under the age of 13. We do not knowingly collect personal information from children under the age of 13 without parental consent. If CNSVS or its Internet service providers become aware that a minor or a child under the age of 13 has provided us with personal information without parental consent, that information will be deleted from our databases. Parents who have questions about personal information that may have been submitted by a child or on behalf of a child under the age of 13 should email us at policies@cnsvs.com.

California Residents

CNSVS will not share any personal information about you with outside third-parties for their direct marketing purposes to the extent prohibited by California law, unless you agree otherwise as authorized by your prior written consent.

California residents have the right to request information from CNSVS regarding the manner by which CNSVS shares personal information with affiliated companies and third parties for their direct marketing purposes. To find out what and how we share such information, you may send us an e-mail request at policies@cnsvs.com or mail a request to: Director of Security and Infrastructure, CNS Vital Signs, 598 Airport Blvd, Suite 1400, Morrisville, NC, 27560.

If you include "MyData" in the subject line, you will receive the following information:

  1. The categories of information we disclosed to third parties for their direct marketing purposes during the preceding calendar year, if any;
  2. The names and addresses of the third parties who received information for their direct marketing purposes; and
  3. Examples of the products and services subject to the third-party’s direct marketing programs, if the nature of the third party’s business cannot be determined from their names.
How You May Access and Change the Information that CNSVS Collects

The first time that you provide us with registration information through our Website, you may be offered the opportunity to subscribe to and receive additional information about our products and services. After your initial registration, you may review your information at any time and make changes, corrections, or deletions by contacting customer service at policies@cnsvs.com. Each commercial e-mail that we send to you will offer you the opportunity to opt-out of continuing to receive such messages. We may take up to ten (10) business days to process your opt-out requests. In some instances, we may have already shared your information with one of our authorized third parties before you changed your information preferences. In those cases, you may have to directly contact those third parties to opt-out of receiving their communications. FTC email compliance guidance allows us to send you transactional and relationship e-mail without offering you the opportunity to opt-out of receiving those types of e-mail.

General Information and Privacy Support Contact

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

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

CNSVS may update this privacy policy from time to time, and you should take the time to review it each time that you visit our Website. If you require additional information about CNSVS’s privacy commitment, or have any questions, please contact us at policies@cnsvs.com.

CNSVS's 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 Privacy Policy. Any employee or agent that CNSVS determines is in violation of this Privacy Policy will be subject to disciplinary action up to and including termination of employment or engagement.

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

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CNS Vital Signs is a world leader in the design and development of neurocognitive and behavioral assessment tools and technologies. We provide clinicians and researchers with leading-edge technologies for improved neurocognitive and behavioral evaluation and management capabilities.

FDA Medical Device Registration Number: 3006559064

SOC2 Type 2 Compliant