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Synchron Privacy Policy

Last Updated: October 30, 2023

Thank you for your interest in Synchron. Your privacy is important to us, and this Privacy Policy describes how Synchron, Inc. (“Synchron”, “we”, “our”, or “us”) obtains, uses, shares, discloses and otherwise processes personal information when you access and use https://www.synchron.com/, https://www.synchronbci.com/, and any content and functionality offered on or through the sites (collectively, the “Services”).

We may change this Privacy Policy from time to time. The “Last Updated” date at the top of this Privacy Policy indicates when this Privacy Policy was last revised. Any changes will become effective when we post the revised Privacy Policy. Any capitalized terms not defined herein are defined in the Synchron Terms of Service available at https://www.synchron.com/terms-of-service.

Please note that the Services are not designed for or directed to children under the age of 18, and we do not knowingly collect personal information from anyone under the age 18. If we become aware that we have collected personal identifiable information from children, we will take steps to remove that information from our servers.

This Privacy Policy does not apply to our privacy practices in connection with clinical trials. Those policies are governed by the applicable clinical trial protocols and informed consents. The Synchron COMMAND trial protocol is currently available at https://clinicaltrials.gov/study/NCT05035823.

HOW WE COLLECT PERSONAL INFORMATION

We may use the following methods to collect information about you when you visit or use the Services:

Information we collect automatically through your use of the Services, such as via cookies and pixel tags, as described further below

  • Information you directly provide to us, such as:
    • through the Services
    • when you communicate or interact with us directly, whether at your own instigation or in response to a query or a prompt from us
  • In the context of clinical trials that we sponsor or that may be of interest to you, we may obtain information that your physician provides to us or that our service providers or research partners provide

Online platforms, such as LinkedIn, Instagram, or Twitter, if you engage with our content or communicate with us on those platforms

WHAT TYPES OF PERSONAL INFORMATION WE COLLECT

We may collect the following types of personal information from and/or about you:

Contact information, such as your name, email address, mailing address, and phone number

  • Internet and Network Identifiers, such as your IP address and other information regarding your geolocation
  • Information in correspondence you provide or are asked to provide

In the context of clinical trials that we sponsor or that may be of interest to you, we may also collect the following types of personal information from and/or about you: (1) biographical and demographic information, such as your date of birth, age, gender, marital status, education history, and information regarding any parents or legal guardians or legally authorized representatives; and (2) health and medical information, such as information about your medical insurance coverage, physical and mental health conditions, diagnoses, and treatments, genetic information, and family medical history

HOW WE USE COOKIES AND SIMILAR TECHNOLOGIES

We may use cookies, pixel tags, and similar technologies to collect information about your use of the Services. Cookies are strings of information that a website stores on a visitor’s computer, and that the visitor’s browser provides to the website each time the visitor returns. Pixel tags (also called web beacons) are small blocks of code placed on websites that allow Synchron or a third party to see that you have looked at that page. We may use cookies and web tags to enable our servers to recognize your web browser and tell us how and when you use the websites. This information may be used by us and our service providers to analyze and track data, improve the operation of our Services, and better understand your online activity. We may also use Google Analytics to evaluate website traffic and usage data to help us improve our products and services. For more information about how Google collects and processes data visit https://policies.google.com/te.... For more information about how to opt out of having your information used by Google Analytics, visit https://tools.google.com/dlpag....

Your web browser may allow you to stop accepting cookies from the Services you visit, through your browser’s settings. Please note that if you do not accept cookies, the Services may not function properly. Your web browser may also be configured to send “Do Not Track” signals to the online services that you visit. We currently do not recognize Do Not Track signals.

HOW WE USE PERSONAL INFORMATION

We may use your personal information for the primary purposes for which it is collected or for other related purposes that are permitted by law, including:

To communicate with you, including contacting you about the Services or responding to your inquiries

  • To maintain, provide, improve and protect the Services
  • To verify your identity and respond to your requests, questions and feedback
  • To comply with regulatory and legal obligations, and to protect and exercise our legal rights or defend against legal claims
  • To protect your, our, and our partners’ rights

Uses consistent with our disclosure and your consent at the time of collection of information

HOW WE SHARE PERSONAL INFORMATION

We may share your personal information with the following entities and providers and/or for the following purposes:

service providers and vendors who perform services on our behalf, including security, communication, hosting, and analytics services

  • Synchron’s corporate affiliates
  • in connection with research and development, including sharing your information with other researchers, academic institutions, and regulatory agencies
  • healthcare professionals, providers, and organizations
  • professional advisors, such as accountants, lawyers, and auditors, as necessary in the course of the provision of such services
  • to comply with legal and regulatory obligations
  • to enforce our Terms and otherwise protect our rights
  • to prevent harm to Synchron, you, or other users of the Services
  • in connection with an actual or potential corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in Synchron

as otherwise authorized with your consent

We take reasonable steps to ensure that these entities and providers are bound by adequate confidentiality and privacy obligations in relation to the protection of your personal information.

Please note that we do not sell your personal information or share personal information with third parties for targeted advertising purposes.

HOW WE PROTECT PERSONAL INFORMATION

While no service is completely secure, we have implemented safeguards to help keep your personal information safe. We maintain administrative, data security and physical safeguards that are intended to appropriately protect against accidental or unlawful destruction, accidental loss, unauthorized alteration, unauthorized disclosure or access, misuse and any other unlawful form of processing, of the personal information in our possession. We employ security measures such as firewalls to protect against intruders, building redundancies throughout our network (so that if one server goes down, another can cover for it) and testing for and protecting against network vulnerabilities. Despite these protections, we cannot guarantee that your data will never be compromised, and you should take measures to protect your personal information.

HOW WE STORE PERSONAL INFORMATION

Synchron is based in the United States and any information you provide to us, including via our Services, will be stored in the United States. We retain your personal information for as long as is necessary to fulfill the purposes for which it was collected and processed in accordance with applicable laws and this Privacy Policy, as long as necessary to achieve the purposes described in this Privacy Policy, for example, to comply with our legal obligations, to protect us in the event of disputes and to enforce our agreements and to protect our and others’ interests. The precise periods for which we keep your personal information vary depending on the nature of the information and why we need it. Factors we consider in determining these periods include the minimum required retention period prescribed by law or recommended as best practice, the period during which a claim can be made with respect to an agreement or other matter, whether the personal information has been aggregated or pseudonymized, and other relevant criteria. We may also anonymize or de-personalize your personal information so that it can no longer be associated with you, and such information may be retained indefinitely.

YOUR RIGHTS AND CHOICES

If you no longer wish to receive marketing communications from Synchron, you may opt-out by following the instructions we have provided in the relevant communication (e.g. by clicking an “unsubscribe” link) or by contacting us at privacy@synchron.com. We also will retain personal information in order to comply with the law, protect our and others’ rights, resolve disputes or enforce our legal terms or policies, to the extent permitted under applicable law. If you opt-out of receiving communications from us, we may still send you necessary communications such as administrative messages, which you cannot opt-out of.

In the event we collect personal information directly from you, we will rely on the personal information you provide, so it is important that this information be updated and accurate. If your personal information changes or is otherwise inaccurate, please contact us at legal@synchron.com with the updated information.

THIRD PARTY SITES AND CONTENT

For your convenience and information, we may provide links to websites and other third-party content that are not owned or operated by Synchron. These links are not an endorsement, authorization or representation that we are affiliated with that third party. We do not exercise control over third party websites or services and are not responsible for their actions. Other websites and services follow different rules regarding the use or disclosure of the personal information you submit to them. We encourage you to read the privacy policies of the other websites you visit and services you use.

HOW TO CONTACT US

If you need to contact us for any reason specified above, or if you have any questions or concerns about our Privacy Policy, you may contact us at privacy@synchron.com.

California Consumer Privacy Act (CCPA) Disclosure

This section of our Privacy Policy informs residents of California about their rights and the data practices of Synchron in accordance with the California Consumer Privacy Act (“CCPA”). The CCPA grants California residents certain rights concerning their personal information, including:

Right to Know: California residents have the right to request that we disclose the personal information we have collected about them, including the categories of information, sources, and the specific pieces of information collected.

  • Right to Delete: You have the right to request the deletion of your personal information, subject to certain exceptions outlined in the CCPA.
  • Right to Opt-Out: If we sell your personal information, you may opt-out of such sales.

Right to Non-Discrimination: We will not discriminate against you for exercising CCPA rights.

We may collect the following categories of personal information as defined by the CCPA:

  • Identifiers (e.g., name, email address, IP address)
  • Categories of personal information under Cal. Civ. Code § 1798.80 (e.g., name, address, telephone number)
  • Commercial information (e.g., transaction history)
  • Internet or other electronic network activity (e.g., browsing history)
  • Geolocation data
  • Professional or employment-related information
  • Inferences drawn from the above information for creating a profile

To exercise your CCPA rights, please submit a verifiable request to us through legal@synchron.com.