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Privacy Policy

Introduction

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This Privacy Policy (the “Policy”) describes the type of personal information that Neosoma (the “Company,” “we” or “us”) gathers from visitors to our website (the “Site”) and Neosoma’s MRI review service (the “Service”). The Site provides information about the Company’s business activities and means through which interested users may learn more about Company. The Service is intended to help healthcare providers with an insightful, empirical, and consistent method to analyze brain tumor MRIs in order to make the best quality treatment decisions for patients.​

 

​Collection, Use, and Sharing of Personal Information

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“Personal Information” means information that can be associated with a particular user. The charts below detail what Personal Information we collect separately with respect to the Site and the Service.​

 

​Collection by the Site

 

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Collection by the Service

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No Sale or Sharing of Personal Information - We do not share or sell this information, except as explained below under “Third-Party Contractors,” “Business Transitions,” and “Compliance with Law and Prevention of Harm.”

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Third-Party Contractors – We may use contractors (“Service Providers”) to perform limited services on our behalf, such as hosting websites and providing email services. Service Providers are required to obtain only the Personal Information they need to deliver the service they were hired to perform, to maintain the confidentiality of Personal Information, and not to use Personal Information for any purpose other than the service they were hired to perform.

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Business Transitions – We may share Personal Information with businesses that are legally part of the same group as the Company, or that become part of that group. We reserve the right – in the event of a business transition such as a merger – to transfer Personal Information to a new business owner, on the condition that such Personal Information must be treated in accordance with this Policy.

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Compliance with Law and Prevention of Harm – We may disclose your Personal Information or any information submitted via the Site or Service if we have a good faith belief that disclosure of such information is helpful or reasonably necessary to: (i) comply with any applicable law, regulation, legal process or governmental request; (ii) enforce any applicable terms of service, including investigations of potential violations thereof; (iii) detect, prevent, or otherwise address fraud or security issues; or (iv) protect against harm to the rights, property or safety of the Company, our users, yourself or the public. We may be required to disclose Personal Information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.

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Aggregated and De-identified Data – As noted above, this Policy addresses the collection and sharing of Personal Information, that is, information that can reasonably be connected with a particular user. We may occasionally de-identify and/or aggregate Personal Information – to the extent permitted by law – to the point that it can no longer be associated with a particular user. When that occurs, such information is no longer Personal Information and not subject to this Policy.

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Particularly with respect to MRI files, as noted above there is certain metadata that is included with MRI files that is specific to a patient, along with the MRI image itself. In the event that we wished to retain the MRI image, we would de-identify that image by removing patient identifiers in accordance with applicable guidance under HIPAA.

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Use, Sharing, and/or Sale of Non-personal Information – We may aggregate data on user behavior with respect to the Site or the Service, including to deliver or improve the Site or Service. This data does not enable identification of individual users and is not Personal Information as defined by this Policy. As such, our use, sharing, and/or sale of non-personal information is not subject to this Policy.

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Choices Regarding Your Personal Information

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You may request information about our collection, use, and disclosure of information (a “Request to Know”), including:

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  • the categories and specific pieces of Personal Information we have collected about the user;

  • the categories of sources from which we have collected the user’s Personal Information;

  • the business or commercial purpose for collecting or selling the user’s Personal Information;

  • the categories of Personal Information we have sold about the user; and

  • the categories of Third Parties with whom we have shared, disclosed for a business purpose, or sold the user’s Personal Information, and which categories of Personal Information we have sold to which categories of Third Parties.

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Users may also request that we delete their Personal Information (a “Request to Delete”).

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Requests to Know

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Users may submit a Request to Know by emailing us at: privacy@neosomainc.com.

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Users may submit two types of Requests to Know: (1) A request for the specific pieces of Personal Information that we have collected about you in the past twelve months; or (2) a request for the categories of Personal Information that we have collected about you in the past twelve months, and we have used and disclosed that Personal Information.

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When you submit a Request to Know, we may ask you to provide certain pieces of information in order to verify your identity, such as your name, email address, and phone number. If you submit a Request to Know for the specific pieces of information that we have collected about you, we may also require you to submit a signed declaration under the penalty of perjury stating that you are the consumer whose Personal Information is the subject of the Request to Know.

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If we are able to verify your identity, we will respond to your Request to Know by: (a) providing the requested information; or (b) explaining why we are not required to provide the requested information. If we are unable to verify your identity, we will respond by explaining why we cannot verify your identity. We will confirm receipt of your Request to Know within 10 days and will respond to your Request to Know within 45 days. If a response requires additional time, we will notify you of the basis for the delay and may extend our response period up to an additional 45 days.

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If we provide the information requested, we will provide the information free of charge and in a readily useable portable format. We have no obligation to provide Personal Information to you more than twice in a 12-month period. If a Request to Know or series of Requests to Know are manifestly unfounded or excessive, we may charge a reasonable fee for processing the Request(s) to Know, or may refuse to process the Request(s) to Know.

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Requests to Delete

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Users may submit a Request to Delete by emailing us at: privacy@neosomainc.com. When you submit a Request to Delete, we may ask you to provide certain pieces of information in order to verify your identity, such as your name, email address, and phone number. If we are able to verify your identity, we will respond to your Request to Delete by (a) deleting your Personal Information and, if applicable, directing any of our Service Providers to delete your Personal Information; or (b) explaining why we are not required to delete your Personal Information. We may choose to delete Personal Information by de-identifying, aggregating, or completely erasing the Personal Information. We will specify the manner in which we delete your Personal Information.

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If a Request to Delete or series of Requests to Delete are manifestly unfounded or excessive, we may charge a reasonable fee for processing the Request(s) to Delete, or may refuse to process the Request(s) to Delete.

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Protection and Retention of Personal Information

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We follow generally accepted industry standards, including the use of appropriate administrative, physical and technical safeguards, to protect Personal Information. This includes use of SSL encryption and measures consistent with TRUSTe certification as well as Verisign registration.

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However, no method of transmission over the Internet or method of electronic storage is entirely secure. Therefore, while we strive to use commercially reasonable means to protect Personal Information, we cannot guarantee its absolute security or confidentiality. Please be aware that certain Personal Information and other information provided by you in connection with your use of the Site or Service may be stored on your device (even if that information is not collected by us). You are solely responsible for maintaining the security of your device from unauthorized access.

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Personal Information will be retained for as long as is reasonably necessary to achieve the purposes set forth in this Policy, and to comply with all applicable laws.

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Other Provisions

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Accessibility and Language – Any person that is unable to access this Policy may request this Policy in an alternative format or language by contacting us at: support@neosomainc.com.

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International Users – The Company and its servers are located in the United States and are subject to applicable local, state, and federal laws. Users who choose to access the Site or Service do so on their own initiative and at their own risk, and are responsible for complying with all applicable laws, rules and regulations. Users who choose to access the Site or Service consent to the use and disclosure of information in accordance with this Policy and subject to such laws. We may limit the Site’s or Service’s availability, in whole or in part, to any person, geographic area or jurisdiction we choose, at any time and in our sole discretion. We do not represent or warrant that the Site or Service or any part thereof is appropriate or available for use in any other jurisdiction.

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Children’s Privacy – The Site and Service are neither directed to nor structured to attract Users under the age of 16. If you are under the age of 16, you are not permitted to use the Site or Service. The Company does not knowingly collect Personal Information from users under the age of 16. If you are a parent with concerns about children’s privacy issues in conjunction with the use of the Site or Service, please contact the Company at: privacy@neosomainc.com.

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Do Not Track Signals and Collection of Information for Third-Party Advertising – The Company is required to disclose how it responds to “Do Not Track Signals” and whether third parties collect personally identifiable information about users when they use online services. The Company honors "do not track" signals and does not track, use cookies, or use advertising when a “do not track” mechanism is in place. The Company does not authorize the collection of personally identifiable information from our users for third-party use through advertising technologies.

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Amendments – We may modify or amend this Privacy Policy from time to time. If we make any material changes, as determined by us, to this Privacy Policy, including in the way in which Personal Information is collected, used or transferred, we will notify you by e-mail to the address specified in your profile or by means of a notice on the Site prior to the change becoming effective.

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Contact Information

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If you have questions about this Policy, please contact: privacy@neosomainc.com.

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Last Updated: April 27, 2023

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