Privacy Policy
Last Updated October 25, 2024
Introduction
NeuroDiagnostics, Inc. d/b/a SYNAPS Dx (“SYNAPS Dx,” “we,” “our” or “us”) respects your privacy and is committed to protecting it through our compliance with this Privacy Policy. This Privacy Policy explains our policies and procedures regarding the collection, use, disclosure, and security of certain information that we have access to when you access or use our websites: synapsdx.com and discerntest.com (the “Sites”), with a focus on information that would be considered “personal data” within the meaning of the EU General Data Protection Regulation (“GDPR”) and similar laws in the United States and other countries (together with GDPR, collectively, the “Data Protection Laws”). As used in this Privacy Policy, “personal data” means information that (either in isolation or in combination with other information held by SYNAPS Dx) enables you (“User”, “you” or “your”) to be identified or recognized.
GDPR applies to you if you are located in the European Economic Area, the United Kingdom or Switzerland (an “EEA Individual”).
For the purposes of GDPR, SYNAPS Dx is considered the data controller. This means that we are responsible for deciding how we use the personal data and other information that we hold. We are a Delaware corporation registered in the United States with an office at NeuroDiagnostics, Inc. d/b/a SYNAPS Dx, Inc., 12441 Parklawn Dr., Suite 2A, Rockville, MD 20852, Att: Privacy Policy.
Please note that by accessing or using the Sites and the various other related content, features and third-party websites available through the Sites (together with the Sites, collectively the “SYNAPS Dx Services”), you are accepting the practices described in this Privacy Policy., subject to any rights or restrictions that might apply under (a) GDPR if you are an EEA Individual, including the rights described in the European Privacy Rights for EEA Individuals provisions below and (b) the other Data Protection Laws if you are a resident in the states or countries in which such Data Protections Laws apply. This Privacy Policy is incorporated by reference into the Terms of Use between you and SYNAPS Dx that govern your access and use of the Sites and the other SYNAPS Dx Services (the “Terms”).
This Privacy Policy describes the types of personal data and other information that we may collect from you or that you may provide when you access or use the Sites or any of the other SYNAPS Dx Services or any of the other features, functions, services, and products, and our practices for collecting, using, maintaining, protecting and disclosing that personal data and other information.
This Privacy Policy applies to personal data and other information we collect or may collect about you and other Users of the Sites and the other SYNAPS Dx Services (“User”, “you” or “your”):
• In accessing and using the Sites or any of the other SYNAPS Dx Services.
• When you sign-up for updates from SYNAPS Dx.
• When you contact us through the Sites.
• When you apply for a job at SYNAPS Dx.
• In e-mail, text and other electronic messages sent through or use of the Sites or any of the other SYNAPS Dx Services.
It does not apply to information collected by any third party, including through any link that may be accessible from or on the Sites or any of the other SYNAPS Dx Services.
Please read this Privacy Policy carefully to understand our policies and practices regarding your personal data and other information and how we will treat it. If you do not agree with our policies and practices, your only choice is not to access or use the Sites or any of the other SYNAPS Dx Services. By accessing or using any of the SYNAPS Dx Services, you agree to this Privacy Policy. This Privacy Policy may change from time to time as described in Changes to Our Privacy Policy below.
Minors under the Age of 18
Neither the Sites nor the other SYNAPS Dx Services are intended for minors under 18 years of age. No one under age 13 may provide any information on or through the Sites or the other SYNAPS Dx Services. We do not knowingly collect personal data from children under 13. If you are under 13, do not use or provide any information on or through any of the SYNAPS Dx Services or any of its features or register on the Sites, use any of the interactive or public comment features of any of the SYNAPS Dx Services or provide any information about yourself to us, including your name, address, telephone number, e-mail address or any screen name, username you may use or any pictures of you. If we learn we have collected or received personal data from a child under 13 without verification of parental consent, we will delete that information. If you believe that we might have any information from or about a child under 13, please contact us at info@synapsdx.com.
Personal data and other Information We Collect About You and How We Collect It
We collect or may collect several types of personal data and other information if you access or use the Sites or any of the other SYNAPS Dx Services, including information by which you may be personally identified:
• Your name, email and any other information that you provide when you contact us;
• Analytics information when you access or use any of the SYNAPS Dx Services;
• Information that is about you but individually does not identify you, such as the date and time of your Sites visit;
• Geo-location information;
• Device and internet information such as the hardware model, operating system version, unique device identifiers, browser type and language information;
• When you report a problem with any of the SYNAPS Dx Services; and/or
• Records and copies of your correspondence (including e-mail addresses), if you contact us.
We collect this personal data and other information:
• Directly from you when you provide it to us.
• Automatically as you navigate through or use the Sites or any of the other SYNAPS Dx Services.
• From third parties, such as our business partners and other third parties that provide us or you with certain services.
Some of the information that we collect automatically may be statistical data and does not include personal data, but we may maintain it or associate it with personal data we collect in other ways or receive from third parties or you provide to us.
Certain situations may also involve your calling us or our calling you. Please be aware and agree that we may monitor, and in some cases, record such calls for staff training or quality assurance purposes.
This policy does not apply to personal data or other information (a) collected by us, or provided by you, when you become a customer or (b) collected by third parties not controlled by SYNAPS Dx, including through any link that may be accessible from or through the SYNAPS Dx Services.
This policy does not apply to information that is considered Protected Health Information as defined by the Health Insurance Portability and Accountability Act of 1996 (HIPAA). For information on our use and disclosure of Protected Health Information, see our Notice of Privacy Practices.
Data Minimization
We take every reasonable step to limit the volume of your personal data that we process to what is reasonably necessary.
We do not Engage in Automated Decision-making without Human Intervention
We do not use automated decision-making without human intervention, including profiling, in a way that produces legal effects concerning you or otherwise significantly affects you.
Consequences of not providing Personal Data and Other Information
You are not required to provide all personal data and other information identified in this Privacy Policy to use the Sites or the other SYNAPS Dx Services or to interact with us offline, but if you do not provide this personal data, we may not be able to respond to your requests.
How We Use Your Personal Data and Other Information
We use personal data and other information that we collect about you or that you provide to us, including any personal data:
• To provide the Sites and the other SYNAPS Dx Services and content that is on them to you.
• To notify you of changes to the Sites and the other SYNAPS Dx Services.
• To enable Service Providers to perform certain responsibilities and provide certain services in connection with the SYNAPS Dx Services and our business and operations.
• To send you promotional communications, such as providing you with information about SYNAPS Dx, features, surveys, newsletters, offers and events, and providing other news or information about us.
• To fulfill any other purpose for which you provide it.
• To carry out our obligations and enforce our rights arising from breaches of the Terms.
• To enhance the safety and security of all of the SYNAPS Dx Services.
• In any other way we may describe when you provide the information.
• For any other purpose with your consent.
As previously noted, some of the information that we collect automatically is statistical data. It helps us to improve the Sites and the other SYNAPS Dx Services, and to deliver a better and more personalized service, including enabling us to:
• Estimate our audience size and better understand usage patterns.
• Store information about your preferences, enabling us to customize the Sites according to your individual interests.
• Speed up your searches.
• Recognize you when you return to the Sites.
Use of Cookies
A cookie is a small file of letters and numbers that we may store on your browser or the hard drive of your computer. When you visit the Sites, we may collect information from you automatically through cookies or similar technology. For further information, visit https://allaboutcookies.org/.
Cookies set by the website’s owner are called “first-party cookies.” Cookies set by parties other than the website’s owner are called “third-party cookies.” Third-party cookies enable third-party features or functionality to be provided on or through the websites (e.g., advertising, interactive content, and analytics). The parties that set these third-party cookies can recognize your computer both when it visits the websites in question and also when it visits certain other websites.
We use first- and third- party cookies in a range of ways to improve your experience on the Sites, including:
• Keeping you signed in
• Understanding your use of the Sites.
There are a number of different types of cookies; however, the Sites use:
• Functionality – we use these cookies so that we recognize you on the Sites and remember your previously selected preferences. These could include what language you prefer and location you are in.
• Advertising – we use these cookies to collect information about your visit to the Sites, including the content you viewed and links followed. While we do not directly share this data, third-party services like Google Analytics may use this information for advertising purposes.
The above website tells you how to remove cookies from your browser. However, if you do not accept cookies (including strictly necessary cookies), the Sites may not operate as intended.
Do Not Track Policy
Your web browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services (including behavioral advertising services) that you do not wish such operators to track certain of your online activities over time and across different websites. We do not honor any web browser “Do Not Track” signals or other mechanisms that provide you with the ability to exercise choice regarding the collection of personally identifiable information about your online activities over time and across third-party websites or online services. At present, no universally accepted standards exist on how companies should respond to do-not-track signals. In the event a final universally accepted standard is established, we will assess and provide an appropriate response to these signals.
Third-party Responsibilities and Services
We may use or partner with other third-party companies, agents or contractors for various purposes in connection with our business and operations (“Service Providers”), including cloud computing and data storage, managing contact information and the marketing and growth of our business and the performance of services on our behalf, such as gathering and analyzing information and the provision of services to you. In the course of performing these responsibilities and providing such services, these other companies may have access to your personal data and other information. We may also share personal data and other information, including your personal data, with these Service Providers in order to enable them to perform these responsibilities and to provide these services. These Service Providers may have adopted their own privacy policies, which are not subject to control by SYNAPS Dx. You should always review the policies of these Service Providers to make sure that you are comfortable with the ways in which they collect, use, maintain, protect and disclose your personal data and other information. We do not list our current Service Providers because they change from time to time. If you would like the names of any of our Service Providers, please email us at info@synapsdx.com.
Google Ads
We may use Google Ads to advertise on third party websites to previous visitors to our Sites. It could mean that we advertise to previous visitors who haven’t completed a task on our Sites, for example using the contact form to make an inquiry. This could be in the form of an advertisement on the Google search results page or a site in the Google Display Network. Third-party vendors, including Google, subject to your consent, use cookies to serve ads based on someone’s past visits to the Sites. Any personal data and other collected information will be used in accordance with this Privacy Policy, as well as Google’s privacy policy https://policies.google.com/privacy.
Google Analytics
We use a tool called “Google Analytics” to collect information about use of the Sites. Google Analytics collects information such as how often Users visit the Sites, what pages they visit when they do so, and what other Sites they used prior to coming to the Sites. We use the information we get from Google Analytics to improve the Sites, the other and their related features, functionality and performance. Google Analytics collects only the IP address assigned to you on the date you visit this Sites, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with personally identifiable information that has not been anonymized and/or aggregated. Although Google Analytics plants a permanent cookie on your web browser to identify you as a unique user the next time you visit the Sites, the cookie cannot be used by anyone but Google. Google’s ability to use and share information collected by Google Analytics about your visits to this Sites is restricted by the Google Analytics Terms of Use and the Google Privacy Policy.
You can set preferences for how Google advertises to you using the Google Ad Preferences Page https://adssettings.google.com/anonymous?hl=en , and if you want, you can opt out of interest-based advertising entirely by cookie settings or permanently using a browser plugin https://support.google.com/My-Ad-Center-Help/answer/12155656?visit_id=638646836006042230-59175201&rd=1 .
Google has additional information available about its Remarketing Privacy Guidelines, Policies, and Restrictions on its website: https://support.google.com/adspolicy/answer/143465?hl=en&visit_id=638646836006042230-59175201&rd=1 .
Microsoft Clarity
We use Microsoft Clarity for similar purposes as Google Analytics.
For information about Microsoft Clarity’s privacy practices, go to: https://www.microsoft.com/en-us/privacy/privacystatement
Heap
We use Heap for similar purposes as Google Analytics.
For information about Heap’s privacy practices, go to: https://www.heap.io/privacy
Storage and Transfer of Your Personal Data and other Information
We may store any data or other information that we collect (personal or otherwise) ourselves or in databases and servers owned and maintained by us, our affiliates, agents or Service Providers. If you access or use the Sites or any of the other SYNAPS Dx Services outside of the United States, personal data and other information that we collect about you may be transferred to servers inside the United States and maintained indefinitely, which may involve the transfer of personal data and other information out of countries located in the European Economic Area and other parts of the world unless otherwise prohibited by applicable law or agreed by SYNAPS Dx and you. By allowing SYNAPS Dx to collect personal data and other information about you, you consent to such transfer and processing of such personal data and other information without restriction. We may also store some personal data and other information locally on your computer or other devices. For example, we may store personal data as local cache so that you can open the Sites and view content faster.
Although Users from all over the world may access the Sites and the other SYNAPS Dx Services, keep in mind that no matter where you live or from where you happen to access the Sites or the other SYNAPS Dx Services, you consent to our processing and transferring personal data and other information in and to the United States and other countries whose data-protection and privacy laws may offer fewer protections than those in your home country.
Disclosure of Your Personal data and Other Information
We will not sell your personal data. If that ever changes, we will notify you as described in Changes to Our Privacy Policy below.
We may use, share, disclose or sell de-identified information about you and the other Users for any purpose without restriction so long as we do not disclose any of your personal data or violate the terms of this Privacy Policy or any applicable law.
We may disclose personal data and other information that we collect or you provide as described in this Privacy Policy:
• To our subsidiaries and affiliates.
• To our Service Providers, contractors and other third parties we use to support the SYNAPS Dx Services and our business.
• To a potential or actual buyer, assignee or other successor (including its related advisors and agents) in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of SYNAPS Dx’s assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal data held by SYNAPS Dx about you and the other Users of the Sites and the other SYNAPS Dx Services are among the assets that may be or are actually transferred.
• To fulfill the purpose for which you provide it.
• For any other purpose disclosed by us when you provide the information.
• With your consent.
We may also disclose your personal data and other information:
• To comply with any court order, law or legal process, including to respond to any government or regulatory request.
• To enforce or apply the Terms.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of SYNAPS Dx, the Users or others.
Choices About How We Use and Disclose Your Personal Data
We strive to provide you with choices regarding the personal data you provide to us. You have the following control over your personal data:
• Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent as described under Use of Cookies above. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website:
https://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html
• Use of your Email/Contact Information. If you do not wish to have your e-mail address/contact information used by SYNAPS Dx to market or otherwise promote our own or third parties’ products or services, you can opt-out through the unsubscribe mechanism at the bottom of the applicable email. This opt out does not apply to information provided to SYNAPS Dx as a result of a product purchase, warranty registration, product service experience or other transactions.
We do not control third parties’ collection or use of your personal data and other information to serve interest-based advertising. You may be able to opt out of receiving personalized advertisements from companies who are members of the Network Advertising Initiative or who subscribe to the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising. For more information about this practice, and to understand your options, please visit: https://youradchoices.com/ and https://optout.networkadvertising.org/?c=1
You may also use TRUSTe’s Preference Manager at https://preferences-mgr.truste.com/ .
Our Legal Bases for Handling Your Personal Data
GDPR and the Data Protection Laws in some other jurisdictions require companies to tell you about the legal bases that they rely on to use or disclose your personal data. To the extent that those laws apply, we rely on the following legal grounds to process your personal data:
• Responding to your requests: We will use your personal data to respond to you when you contact us or your requests.
• Legitimate interests: We may use your personal data and other information for our legitimate interests on the grounds that it furthers our legitimate interests in commercial activities (but only to the extent that such interests are not overridden by the interests or fundamental rights and freedoms of the affected individuals) including:
• Analyzing and improving the Sites and the other SYNAPS Dx Services and our business; and
• Legal compliance: We may use and disclose personal data in certain ways to comply with our legal obligations under European or Member State law or other applicable law.
• Consent: To the extent required by law, and in certain other cases, we handle personal data on the basis of implied or express consent.
Accessing and Correcting Your Personal Data
You may change, correct or delete any personal data that you have provided to us by contacting us at 12441 Parklawn Dr., Suite 2A, Rockville, MD 20852, Att: Privacy Policy.
Your California Privacy Rights
California Civil Code Section § 1798.83 permits Users of the Sites that are California residents to request certain information regarding our disclosure of personal data to third parties for their direct marketing purposes. To make such a request, please send an e-mail to info@synapsdx.com or write to us at: 12441 Parklawn Dr., Suite 2A, Rockville, MD 20852, Att: Privacy Policy.
European Privacy Rights for EEA Individuals
You have the right to ask us not to process your personal data for marketing purposes. You can exercise your right to prevent such processing by contacting us directly at info@synapsdx.com or 12441 Parklawn Dr., Suite 2A, Rockville, MD 20852, Att: Privacy Policy.
If you are an EEA Individual and GDPR applies, and we hold your personal data in our capacity as a controller, you may request that we:
• Provide access to and/or a copy of certain personal data (including, in some cases, in portable form);
• Prevent the processing of your personal data for direct-marketing purposes (including any direct marketing processing based on profiling);
• Update personal data that is out of date or incorrect;
• Delete certain personal data which we are holding about you; provided that the personal data is not required by us for (i) compliance with a legal obligation under European or Member State law or other applicable law or (ii) the establishment, exercise or defense of a legal claim;
• Object to our processing of personal data;
• Restrict the way that we process and disclose certain of your personal data except to the extent that processing is required (i) to comply with a legal obligation under European Member State law or applicable law or (ii) for the establishment, exercise or defense of legal claims;
• Transfer your personal data to a third party to the extent that this is technically feasible; and
• Honor a revocation of your consent for the processing of your personal data (without retroactive effect).
We will consider all requests and provide our response within the time period required by applicable law. Please note, however, that certain personal data and other information may be exempt from such requests in some circumstances, which may include if we need to keep processing your personal data and other information for our legitimate interests or to comply with a legal obligation. We may request that you provide us with additional information to confirm your identity before responding to your request. You have the right to lodge a complaint with the authorities applicable to your situation, though we invite you to contact us with any concern, as we would be happy to try to resolve it directly. You may also have the right to make a GDPR complaint to the relevant Supervisory Authority. A list of Supervisory Authorities is available here: https://edpb.europa.eu/about-edpb/board/members_en.
If you are an EEA Individual in France, you also have the right to set guidelines for the retention and communication of your personal data after your death.
If you reside in a jurisdiction other than the European Economic Area, European Economic Area, the United Kingdom or Switzerland, you may also have similar rights to the above. Please contact us at info@synapsdx.com if you would like to exercise one of these rights, and we will comply with any request to the extent required under applicable law.
In addition, where you believe that we have not complied with our obligation under this Privacy Policy or European law, you have the right to make a complaint to an EU Data Protection Authority, such as the UK Information Commissioner’s Office. Here is a list of local data protection authorities in EEA countries: https://ec.europa.eu/newsroom/article29/items/612080
You can exercise any of these rights by contacting us at info@synapsdx.com or write to us at: 12441 Parklawn Dr., Suite 2A, Rockville, MD 20852, Att: Privacy Policy.
How Long We Store Your Personal Data
We will only retain your personal data, in a form which permits us to identify you, for as long as necessary to fulfill the purposes you provided it or we collected it for. We will retain and use your personal data as necessary to satisfy any legal, accounting or reporting requirements, to resolve disputes or to enforce our agreements and rights. To dispose of personal data, we may anonymize it, delete it or take other appropriate steps. Data may persist in copies made for backup and business continuity purposes for additional time.
Data Security
We understand that the security of your personal data and other information are important. We provide reasonable administrative, technical, and physical security controls to protect your personal data and other information. However, despite our efforts, no security controls are 100% effective. SYNAPS Dx cannot ensure or warrant the security of your personal data and other information. Any transmission of personal data and other information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Sites or through the other SYNAPS Dx Services.
The safety and security of your personal data and other also depends on you. Where you have chosen (or we have given you) a password for access to and use of certain parts of the Sites and/or the other SYNAPS Dx Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
Changes to Our Privacy Policy
We may make changes to this Privacy Policy from time to time. If we do make any such changes, we will post a notice that this Privacy Policy has been updated on the home page of the Sites for at least 30 days. Previous versions will be available upon request by emailing us at info@synapsdx.com . If we make significant changes to how we treat personal data that are materially less protective than provided in this Privacy Policy, we will use reasonable efforts to notify you by e-mail if you have provided your e-mail address to us and/or through a notice on the home pages of the Sites and to attempt to get your consent to the changes. The date this Privacy Policy was last updated is identified above. You are responsible for ensuring that we have an up-to-date active and deliverable e-mail address for you, and for periodically visiting the Sites and this Privacy Policy to check for any changes. Your continued access or use of the Sites or any of the other SYNAPS Dx Services after our efforts to contact you means that you agree to be bound by such changes.
Survival
The policies indicated in this Privacy Policy will remain effective, even if you are no longer accessing or using the Sites or any of the other SYNAPS Dx Services.
To ask questions or comment about this Privacy Policy and our privacy practices or need to reach us for any other reason, you may contact us by e-mail at info@synapsdx.com or by mail at NeuroDiagnostics, Inc. d/b/a SYNAPS Dx, Inc. 12441 Parklawn Dr., Suite 2A, Rockville, MD 20852, Att: Privacy Policy.
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