NeurAxis, Inc. (“NEURAXIS”) knows you care about your privacy. This Privacy Policy describes how NEURAXIS collects, uses, shares, and secures your information. Our Privacy Policy governs Neuraxis’ online, digital and other service activities including all NEURAXIS operated and controlled Services, NeurAxis.com, ibstim.com, Kidsstomachpain.com and any other applications, social media accounts or platforms, or publicly accessible web sites to the extent they are controlled by or maintained on behalf of NeurAxis.  (collectively, the “Services”).  The Privacy Policy applies to all persons who use our Services (“Users”). However, this Privacy Policy does not pertain to personally identifying information related to an individual’s past, present, or future health, health care, or payment for health care, which is covered when we are acting as a business associate to health care providers pursuant to the Health Insurance Portability and Accountable Act (“HIPAA”).

Agreement & Eligibility

Your Agreement With NEURAXIS
This Privacy Policy constitutes a binding legal agreement between you, as a User who uses and interacts with the Services and NEURAXIS. Before accessing, using, or interacting with the Services you should carefully review the terms and conditions of this Privacy Policy, as well as our Terms of Service https://neuraxis.com/terms-of-service/, which are incorporated into your agreement with NEURAXIS by this reference. This Privacy Policy applies only to the Services, and our collection, use, disclosure, and protection of your information. It does not apply to third party websites, applications, or services.

By using or interacting with any of our Services you signify your consent to our Privacy Policy and Terms of Service, and the collection, use, transfer, storage, and disclosure of your information described in this Privacy Policy. If you do not agree to the terms of our Privacy Policy and Terms of Service, then you may not use or interact with the Services.

This Privacy Policy is meant to help you understand what Personal Information we collect, why we collect it, and how we treat it.  This policy also explains how you can exercise certain rights you may have, including how you can access and delete your information.  This Privacy Policy does not apply to Personal Information that we process from employees, job applicants, and other individuals that we interact with in the employment context.

If you have questions about NEURAXIS’ Privacy Policy or practices, or if you need to contact us about the information, we collect about you, you may contact us using the contact information provided at the end of this Privacy Policy.

WHAT IS PERSONAL INFORMATION?
Personal Information is any information relating to a natural person who is, or can be, identified either directly or indirectly from such information and includes information such as a person’s contact information (such as name, address, telephone number, email address), demographic information (such as gender, date of birth, and zip code) and Internet activity (such as browsing history or devices being used), or other information directly linked to that person.  You are not legally required to provide Personal Information to us, but if you refuse to provide such information, some of the features on our Services may not work as intended.  Some Personal Information we collect may be Sensitive Personal Information such as information about health or medical status of you or your child.

HIPAA and PHI
Certain Personal Information that is individually identifiable to you and that relates to your past, present or future health, health care, or payment for healthcare may be “protected health information” or “PHI” and governed by HIPAA and its implementing regulations.  We may collect, use and disclose PHI in accordance with HIPAA when we are acting as a business associate to providers.

NOTICE OF COLLECTION OF PERSONAL INFORMATION

Through your use of our Services, we collect, and may have collected over the past 12 months, your Personal Information in the following ways:

Information you provide directly to us

We collect information that you choose to provide directly to us, including:

• Basic information and identifiers: When you choose to contact us through the online form on our Services, we may ask that you provide us with your first name, last name, email address and an optional phone number and, in some cases, the date of birth of the child for whom you are seeking information about our products.  This information enables us to respond to your comments.
• NEURAXIS Account Information: NEURAXIS may require you to register for an account in order to use certain Services features (an “NEURAXIS Account”). We do not require you register to view much of the information on our Services. However, if you do register, you will gain access to those areas and features of the Services that require registration. NEURAXIS will collect certain information about you in connection with your registration for your NEURAXIS Account, which may include Personal Information such as your first name, last name, gender, birth date, address, zip code, email address, phone number, a username, password, personal profile, pictures and your location.
• Search Queries and other network activity. We collect information related to the searches you perform on our Services to understand information that is of interest to you.
• Payment Transaction Information:You may provide, either to us or to our third party vendors, certain information to complete payments for our products or services including your name, address, credit or debit card number, card expiration date, CVV code, and billing address (collectively, “Payment Information”), along with your delivery or shipping address, to complete payment transactions.  We consider the Payment Information we collect from you private and will not make such information public. We may collect and store information related to your purchases.  We may also collect health insurance information or other health related information.
• Correspondence Information:If you email us, subscribe to our newsletters or mailing lists, or purchase products or services through the Services, or provide us with information about your child’s experience with our products, we may keep your message, email address, and contact information to respond to your requests, provide the requested products or services, and to provide notifications or other correspondences to you. If you do not want to receive e-mail from us in the future, please let us know by sending us an email or writing to us at the address below. Please note requests to remove your email address from our lists may take some time to fulfill. We may also still contact you regarding certain important announcements or notifications.  If you call us, we may record the phone call we have with you.
• Protected classification characteristics under state or federal law such as race, national origin, medical condition, gender, veteran status;
• Internet or other electronic activity such as browsing history, search history and information related to your use of our Services;
• Audio, electronic, visual, thermal, olfactory, or similar information (for example if we record a phone call with you)
• Geolocation Data for example we may collect information related to where you are accessing our services.
• Sensitive Personal Information such as information related to your or your child’s health.

We do not collect or process sensitive Personal Information for the purpose of inferring characteristics about you.

Information We Collect Automatically

We collect certain information about you when you visit our websites and use the Services through the use of tracking technologies including:

Unique Identifiers: When you use or access the Services, we may access, collect, monitor, store on your device, and/or remotely store one or more “Unique Identifiers,” such as a universally unique identifier (“UUID”). A Unique Identifier may remain on your device persistently, to help you log in faster and enhance your navigation through the Services. Some features of the Services may not function properly if use or availability of Unique Identifiers is impaired or disabled.

Log File Information: When you use our Services, we may receive log file information such as your IP address, browser type, access times, domain names operating system, the referring web page(s), pages visited, location, your mobile carrier, device information (including device and application IDs and type), search terms, and cookie information. We receive log file data when you interact with our Services, for example, when you visit our Services, sign into our Services, or interact with our email notifications. NEURAXIS uses log file data to provide, understand, and improve our Services, and to customize the content we show you. NEURAXIS may link this log file to other information NEURAXIS collects about you via the Services.

Public Information: NEURAXIS may also collect information about you from publicly available sources. Information you make publicly available in any public or open forum, such as on a social network, may be considered public information for the purposes of this Privacy Policy, and may be accessed and collected by NEURAXIS. Please be aware that any content or information you share with or provide to third parties using or related to your use of the Services is nether private, nor confidential. NEURAXIS is not responsible for any content or information you post or share with third parties. If you do not wish for certain information to be public, please do not share it.

Cookies and Other Tracking Technologies

Cookies are text files sent to your Internet-connected device or browser that enable us to run analytics and better understand user interaction with the Services.  Cookies can automatically collect certain information about your network connection, your IP address and other information regarding your interaction with the Services.  In addition, we also use third-party cookies which are cookies that come from a domain different than our Services – as well as other tracking technologies, such as web beacons and pixels from third-party partners (e.g., Facebook, Google Analytics) which allow us to monitor user activity and Services traffic.  More specifically we may use cookies and other tracking technologies for the following purposes:

• To monitor usage patterns and analyze our Services performance to gain useful knowledge about how our Services is used so that we can keep improving them for users like you;
• To enhance your experience while using our Services, allowing you to navigate between pages efficiently, store your preferences and generally improve your experience on our Services;
• We may track your activities over time and across third-party websites and apps or online services to display advertisements or information on third-party websites or apps;
• To identify that you are a human being, and not a bot or other piece of automated software, in order to protect our Services from spam and abuse.

Social Media

We may link with social media platforms and social media plug-ins.  If you access our Services through a social media account (such as Facebook) we may gain access to information you provided to or through that social media account.  When you use our Services, social media platforms may place a cookie or other tracking technology on your computer which may allow the social media platform to receive information about your use or access on our Services.

Third Parties

If we use third parties to help us manage our Services and operations, those third parties may also collect Personal Information while they are providing us with their services.  For example, they may collect information to help us analyze our Services performance.

HOW DO WE USE YOUR INFORMATION?
We collect and use your information so that we can operate effectively and provide you with the best experience. We also use the information we collect for the following purposes:

• Correspondence with you. We use your Personal Information to respond to your requests and comments you submit through the online contact form on our Services.
• Improving our Services and services. Conducting data analysis and audits; developing new products and services; enhancing our Services; improving our services; identifying usage trends and visiting patterns; conducting customer satisfaction, market research, and quality assurance surveys; determining the effectiveness of our promotions and meeting contractual obligations.
• We may use your information to personalize your experience because your information helps us to better respond to your individual needs.
• Marketing and promotions. We may send you emails and messages about news and new promotions, features, products and services, and content.  We may also use information with other parties for marketing, advertising, or other uses.
• Safety and security. Using security systems to maintain the safety and security of you and our guests, visitors and employees at our offices.
• Legal proceedings and requirements. Investigating or addressing claims or disputes relating to your use of our services; or as otherwise allowed by applicable law; or as requested by regulators, government entities, and official inquiries.

HOW DO WE SHARE YOUR INFORMATION?
We do not sell your personal information to third parties for monetary consideration and have not done so in the previous 12 months.  Depending on your browser preferences, we may share Personal Information we collect on our Services for cross-context behavioral advertising or targeted advertising. We have shared or may share information as follows:

With our service providers and business partners.
We may provide Personal Information to our vendors, consultants, marketing partners, research firms, and other service providers or business partners. This may include, for example:

• Contractors, service providers, and other third parties we use to support our business;
• Payment processors and facilitators;
• Cloud storage providers;
• Marketing partners and marketing platform providers;
• Social media networks and video hosting and sharing platforms;
• Data analytics providers;
• Research partners;
• Consultants, lawyers, accountants and other professional service providers; and
• Insurance and financing partners.

With your consent.
We may share your information other than as described in this policy if we notify you and you consent to the sharing.  For example, if you want to provide us with a testimonial or more publicly share your experiences, we will obtain additional consent from you before sharing that information.

For legal reasons or in the event of a dispute.
We may share your information with third parties for legal reasons or in the event of a dispute.  This may include, for example:

• In connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or into another company;
• To comply with a court order, search warrant, subpoena, or other legal process;
• To comply with legal, regulatory, or administrative requirements of any government or law enforcement authority; and
• To establish or exercise our legal rights and to protect and defend us in connection with any threatened or actual legal action, claim or dispute.

We may have shared all of the categories of Personal Information listed above in previous 12 months.

WHERE DO WE STORE YOUR INFORMATION?
Please note information NEURAXIS collects about you may be transferred, processed and/or accessed by us in the United States, or another country where we, or our Service Providers operate. Please be aware Personal Information may be transferred to, and maintained on, computers located outside of your state or country where the privacy laws may differ from and may not be as protective as those where you live. If you are located outside the United States and choose to allow us to collect information about you, please be aware that NEURAXIS may transfer your Personal Information to the United States and process and store it there. By allowing collection of your Personally Identifiable Information, you consent to having your personal data transferred to, processed, and stored in the United States.

HOW LONG DO WE KEEP YOUR INFORMATION?
We will only store Personal Information for as long as it is needed to fulfill the purposes for which it was collected, subject to data retention periods imposed upon us by applicable law. How long we retain your Personal Information depends on different factors, such as whether we need the information to maintain your account, comply with legal obligations, resolve disputes or enforce other applicable contracts and policies. In addition, the data we collect may be stored in databases owned by the providers of the third-party sites.  We have put into place commercially reasonable security measures in an effort to protect Personal Information from loss, misuse, or alteration while it is under our control. Please note, however, that security incidents can occur even if reasonable steps are taken to prevent such incidents; for example, we cannot guarantee that information provided through the Services will not be illegally accessed on our servers or intercepted while being transmitted to us over the internet. Additionally, we have absolutely no control over the security of other third-party sites you might visit, interact with, or do business with.

HOW SECURE IS YOUR INFORMATION?
We implement reasonable administrative, organizational and technical safeguards and security measures to protect personal information within our control from unauthorized access, acquisition, disclosure, destruction or alteration, accidental loss, misuse or damage. We regularly review and monitor such safeguards and security measures. Although we take reasonable steps to safeguard personal information, no practices are 100% secure, and we do not guarantee the security of your information.

When Personal Information (such as a credit card or bank account number) is transmitted to other websites, it is protected through the use of encryption, such as the Secure Sockets Layer (SSL) protocol. As no data security protocol is impenetrable, NEURAXIS cannot guarantee the security of our systems or databases, nor can we guarantee that Personal Information we collect about you will not be breached, intercepted, destroyed, accessed, or otherwise disclosed without authorization. Accordingly, any information you transfer to or from Services is provided at your own risk.

Please do your part to help us keep your information secure. You are responsible for maintaining the confidentiality of your password and NEURAXIS Account and are fully responsible for all activities that occur under your password or NEURAXIS Account. NEURAXIS specifically reserves the right to terminate your access to the Services and any contract you have with NEURAXIS related to the Services in the event we learn or suspect you have disclosed your NEURAXIS Account or password information to an unauthorized third party.

Data Security Incidents
In the event that any information under our control is compromised as a result of a breach of security or other data security incident, NEURAXIS will take reasonable steps to investigate the situation and where necessary, notify those individuals whose information may have been compromised and take other steps in accordance with applicable laws and regulations. We are not responsible for the functionality, privacy, or security measures of any other organization.

CHILDREN’S DATA 

Our Services is directed to and intended for use only by those who are 18 years of age or over.  We do not knowingly collect, sell, or share the Personal Information from any person under 18 years of age. If you believe we have collected the Personal Information from a person under 18 years of age, please notify us and the Personal Information will be removed.  If you are a parent or guardian and are providing us with Personal Information related to someone 18 years of age or younger, by submitting the information you are verifying that you have the authority to do so and are the legal parent or guardian of the child. 

Aggregate and De-identified Information
We sometimes aggregate or de-identify information we collect, and the types of systems and browsers of users for internal purposes, so that we may improve the Services. Personal Information does not include “aggregate” or “de-identified” information. Aggregate or de-identified information is data we collect about a group of users, from which individual identities have been removed. Aggregate or de-identified data helps us understand trends and user needs so that we can better consider new products and services, and tailor existing products and services to customer desires. You understand that we may commercialize aggregate or de-identified information by any and all means, and that you will receive no payment or other consideration in respect of such use. In addition, we may share and disclose aggregate or de-identified information for any purpose.

Consent to Communications
By using the Services and providing your contact information, such as your name, phone number, and email address, you consent to receiving email and text messages to tell you about the Services. These communications may include messages sent through the use of landline phone, cellular phone, and text messages (including SMS and MMS).  We may use an automatic telephone dialing system (or “auto-dialer”), which may employ artificial or pre-recorded voice or “robotexts.”  Your carrier’s standard rates and charges may apply. You may opt-out from receiving email communications at any time by emailing optout@neuraxis.com.

YOUR CHOICES.

You can make the following choices about your personal information.

• Not provide us with Personal Information. If you choose to do this, we may not be able to provide you with our services or respond to any queries you may have.
• Refuse cookies in your browser by changing its settings. Based on your browser, you can block cookies by activating a setting on your browser allowing you to refuse cookies. You can also delete cookies through your browser settings. If you turn off cookies, you can continue to use the Services; however, certain features may not work effectively.
• Unsubscribe from promotional emails and other marketing material. You can unsubscribe from marketing material from us at any time by clicking the “Unsubscribe” link contained in the email, or by emailing us at optout@neuraxis.com.  Please note that withdrawing your consent to receive promotional emails will not prevent us from sending you administrative communications or legal notices; or emails about changes to our terms, policies, or business practices.

Do Not Track Signals
Our Services is not configured to read or respond to “do not track” settings or signals in your browser headings.

HOW WILL WE NOTIFY YOU OF CHANGES TO THIS POLICY?
We may occasionally update this policy.  If we make significant changes, we will notify you of the changes on our Services or through other means, such as email.

EXTERNAL LINKS
Our Services may provide links to third party websites, services, and applications that are not operated or controlled by us. While we attempt to facilitate access only to those Third-Party Services that share our respect for your privacy, we cannot take responsibility for the content, privacy policies, or practices of those Third-Party Services. We encourage you to review and understand the privacy practices of any Third-Party Services before providing any information to or through them. Your interactions with these features are governed by the Privacy Policy of the Third-Party Service that provides the feature.

OTHER IMPORTANT INFORMATION
Contact Us. Questions, comments and complaints about our data practices can be sent to our data privacy office by contacting the Neuraxis Privacy Officer at privacy@neuraxis.com or writing to us at:

NeurAxis, Inc
C/O Privacy Officer
11611 N Meridian St, Suite 330
Carmel, IN 46032

State Privacy Law Disclosures
Depending on where you reside, some states may provide you with certain additional rights and protections in relation to your Personal Information, including information that you provide to us when you interact with us online and offline.  The rights described below do not apply to information that is covered by HIPAA, for example information Neuraxis receives as a business associate to a health care provider.  You may have the right to:

• Request access to the Personal Information we have collected from you;
• Request disclosure of the Personal Information we have collected and shared about you
• Request disclosure of the categories of Personal Information we have disclosed for a business purpose
• Request that we delete your Personal Information
• Request correction of any incorrect or incomplete personal data we have about you
• Request to limit the use and disclosure of sensitive Personal Information
• Request to opt-out of the sharing of personal information for cross-context behavioral marketing purposes or targeted advertising.

You can exercise the rights that apply to you without receiving retaliatory or discriminatory treatment.

To exercise any rights that may be available to you, or to appeal our decision regarding any of these rights, you can contact the Neuraxis Privacy Officer at privacy@neuraxis.com or writing to us at:

NeurAxis, Inc
C/O Privacy Officer
11611 N Meridian St, Suite 330
Carmel, IN 46032

We may need to collect information from you to verify your identity, such as your name, email address or other information, before providing a substantive response to the request. In accordance with applicable laws, you may designate an authorized agent to make requests on your behalf to exercise your rights. Before accepting such a request from an agent, we will require that the agent provide proof you have authorized them to act on your behalf, and we may need you to verify your identity directly with us. We will respond to your request in a timely manner as required under applicable law.  If you are not satisfied with our response, depending on where you live you may have the right to appeal our decision by contacting us using the contact details set out below.

In certain circumstances you may be able to designate an authorized person to make a request on your behalf. To determine if this applies to you, please contact the Neuraxis Privacy Officer at privacy@neuraxis.com or writing to us at:

NeurAxis, Inc
C/O Privacy Officer
11611 N Meridian St, Suite 330
Carmel, IN 46032

California Privacy Rights Regarding Direct Marketing
If you are a California resident, you may request information regarding the disclosure of your Personal Information to third parties for their direct marketing purposes.

Shine the Light – California residents also have the right to request that we provide you with (a) a list of certain categories of personal information we have disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year and (b) the identity of those third parties. To exercise this right, contact us at the address below.

If you exercise any of these rights you will not be discriminated against in any way.

You may exercise these rights by contacting the Neuraxis Privacy Officer at privacy@neuraxis.com or writing to us at:

NeurAxis, Inc
C/O Privacy Officer
11611 N Meridian St, Suite 330
Carmel, IN 46032

Consumer Health Data Privacy Policy for Washington and Nevada Residents

This Washington Consumer Health Data Privacy Policy (“Policy“) describes the practices of Neuraxis (“Company” or “We“) for collecting and using Washington and Nevada residents’ consumer health data. Consumer health data is any data that is linked or reasonably linkable to a specific individual and that identifies that individual’s past, present, or future physical or mental health status that Company collects or controls the collection of (“consumer health data“). This section does not apply to health information that we collect that is covered by HIPAA.

Consumer Health Data We May Collect About You
We collect and use different types of consumer health data from and about you.  If you are a parent or guardian and are providing us with health data related to someone 18 years of age or younger, by submitting the information you are verifying that you have the authority to do so and are the legal parent or guardian of the child.  The information we collect may include:

• Information about any of the following:
  • individual health conditions, treatment, diseases, or diagnoses;
  • diagnostic testing, treatment, or medication;
  • medical interventions;
  • health-related surgeries and procedures;
  • use or purchase of prescribed medication;
  • bodily functions, vital signs, symptoms, or measurements of physical or mental health status;
  • Data identifying a consumer seeking health care services;
  • Precise location information that reasonably indicates a consumer’s attempt to receive or acquire health services or supplies; or
  • Any inferences of the above categories derived, extrapolated, or inferred from non-health information.

We use these categories of consumer health data for the following purposes:

• Fulfilling the purposes for which you provided the data or that were described when it was collected;
• Performing the services or providing the goods that you request from us and responding to your questions or requests for information;
• Notifying you about changes to our sites, applications, products, or services;
• Facilitating services and operations performance, security, and integrity, including:
  • Undertaking activities to prevent, detect, and investigate security incidents that compromise the availability, authenticity, integrity, or confidentiality of stored or transmitted consumer health data or that otherwise threaten to compromise the performance, security, or integrity of our business;
  • Performance analytics, identity verification and authorization, site and application optimization, and quality control;
  • Recordkeeping and auditing.
  • Complying with our legal obligations and risk management, audit, investigations and reporting, and other legal and compliance reasons.
  • Measuring or understanding the effectiveness of non-personalized advertising and delivering non-personalized advertising served as part of your current interaction with you.
  • Our internal research and product or service design and development.

Consumer Health Data Sources
We collect consumer health data from the following sources:

• You, including when you request information from us or sign up for email lists or programs;
• Your device when you visit or interact with our sites, applications, or services, including through cookies, web beacons, and similar technologies that automatically send us information when you browse, use, visit, or otherwise interact with our sites, applications, or services;
• Authorized/legal representatives, family members, and caregivers;
• Payment processors and other financial institutions;
• Our business and marketing partners, who provide us with information about consumers who are viewing our content across other Servicess or applications, purchasing our products, or interacting with our promotions, benefits, or programs.

Consumer Health Data Disclosures
We only sell your consumer health data if you give us your permission.

We may disclose any of the consumer health data categories listed above to processors, service providers, and contractors that help us provide products and services to you.  We may also share your consumer health data with healthcare providers.

We may also disclose consumer health data as permitted by applicable law including:

• With your consent.
• To prevent, detect, protect from, or respond to security incidents, identity theft, fraud, harassment, or malicious or deceptive activities.
• To a third party acquiring our assets if Company sells its business or otherwise is part of a merger, acquisition, bankruptcy, or other transaction involving a third party taking control of our assets or business.
• To investigate, report, or take legal action to protect our rights, property, and safety and the rights, property, and safety of others.
• To protect your or others’ vital interests, including health and safety.

Your Privacy Rights
You have specific rights with respect to your consumer health data. You have the right to:

• Request confirmation that we collect, share, or sell your consumer health data.
• Request access to your consumer health data that we have collected or control, including:
  • a list of all third parties and affiliates that we have shared or sold your consumer health data to; and
  • the email addresses or other online method to contact those third parties and affiliates.
• Withdraw your consent for our collection and sharing of your consumer health data.
• Request that we delete your consumer health data.

To exercise any of your rights under Washington consumer health privacy law, please

To make an inquiry or comment about this Policy or our privacy practices, contact the Neuraxis Privacy Officer at privacy@neuraxis.com or writing to us at:

NeurAxis, Inc
C/O Privacy Officer
11611 N Meridian St, Suite 330
Carmel, IN 46032