Updated April 30, 2019
Great Lakes NeuroTechnologies’s Privacy Approach
Collection and Use of Personal Information
Personal information is data that, using reasonable methods, can identify a single person.
Here are some examples of the types of personal information GLNT may collect and how we may use it:
What personal information we collect
When you create a user ID, purchase a product, download a mobile application (“app”), download a software update, connect to our services, contact us including by social media or participate in an online survey, we may collect a variety of information, including your name, mailing address, phone number, email address, contact preferences, device identifiers, IP address, location information, credit card information and profile information where the contact is via social media.
In certain jurisdictions, we may ask for a government issued ID in limited circumstances including when setting up a wireless account, activating your device, verifying prescriptions, or as required by law.
How we use your personal information
GLNT and its affiliates, its authorized carriers and service providers will use the Customer’s personal information for the purpose of administering GLNT‘s relationship with the Customer, such as, order fulfillment, verifying the customer’s identity and delivery address, authorizing debit/credit card payments and processing any other transactions authorized by the Customer. GLNT may also wish to inform Customers of special offers, undertake product or customer research/development and provide other marketing information to the Customer which GLNT thinks the Customer may find of interest. If a Customer does not wish to receive any marketing information they may request that their details are excluded from any promotional activity by contacting GLNT at the address displayed in section below.
We also use personal information to help us create, develop, operate, deliver, and improve our products, services, content and advertising, and for loss prevention and anti-fraud purposes. We may also use your personal information for account and network security purposes, including in order to protect our services for the benefit of all our users. Where we use your information for anti-fraud purposes it arises from the conduct of an online transaction with us. We limit our uses of data for anti-fraud purposes to those which are strictly necessary and within our assessed legitimate interests to protect our customers and our services. For certain online transactions we may also validate the information provided by you with publicly accessible sources.
We may use your personal information, including date of birth, to verify identity, assist with identification of users, and to determine appropriate services. For example, we may use date of birth to determine the age of GLNT account holders.
From time to time, we may use your personal information to send important notices, such as communications about purchases and changes to our terms, conditions, and policies. Because this information is important to your interaction with GLNT, you may not opt out of receiving these communications without being completely removed from our databases and services.
We may also use personal information for internal purposes such as auditing, data analysis, and research to improve GLNT’s products, services, and customer communications.
Source of your personal information where they are not collected from you
We may have received your personal information from other persons, such as a healthcare provider who was invited or prescribed for you to participate in or utilize GLNT’s products and/or services. We may also validate the information provided by you when creating a user ID with a third party for security and fraud prevention purposes.
Collection and Use of Non-personal Information
We also collect data in a form that does not, on its own, permit direct association with any specific individual. We may collect, use, transfer, and disclose non-personal information for any purpose. The following are some examples of non-personal information that we collect and how we may use it:
We may collect information such as occupation, language, zip code, area code, unique device identifier, referrer URL, location, and the time zone where a GLNT product is used so that we can better understand customer behavior and improve our products, services, and advertising.
If we do combine non-personal information with personal information the combined information will be treated as personal information for as long as it remains combined.
Who May Process Data
Personal information will only be collected with the Customer’s consent.
The Customer’s personal information (as defined above) may be processed by GLNT.
GLNT may disclose or receive personal information or documents about the Customer to/from other companies within the GLNT group, its authorized carriers and its service providers including Credit Reference agencies.
GLNT may be required to disclose personal information or documents about a customer if required to do so by law in accordance with US legislation or other countries’ regulatory bodies or representatives.
GLNT will not disclose your personal information to any third parties without your consent.
GLNT will take all reasonable steps to ensure that personal information that is held is accurate, complete and up to date.
A small file may be sent by GLNT to the Customer’s computer or device when the Customer visits GLNT‘s Website or interacts with the device and/or app. This will enable GLNT to identify the Customer’s computer, device, and/or app, track their behavior on GLNT‘s Website or app, and to identify the Customer’s particular areas of interest so as to enhance the Customer’s future interactions with
apps, GLNT does not automatically log data or collect data apart from information the Customer specifically provides to GLNT. The Customer can change their settings to reject cookies but this may preclude the Customer’s use of certain parts of the Website or app.
GLNT uses Secure Sockets Layer (SSL) encryption when collecting or transferring sensitive data such as credit card information. SSL encryption is designed to make the information unreadable by anyone but the intended receiver. Use of this security measure is often indicated by either an unbroken key or closed lock (depending on your browser) or the ‘https’ (as opposed to ‘http’) prefix on the site address.
Notwithstanding the above, GLNT cannot guarantee the protection of Customers’ personal data transmitted electronically due to the nature of the Internet. Customers should be aware that when personal information is disclosed on the Internet it may be collected by another user and may result in unsolicited messages from other Internet users.
GLNT has your consent to share the information
GLNT needs to provide the information to other companies or healthcare providers to fulfill your request for a product or service. For example; a shipping company, credit card processing company, prescribing physician, or service partner. (Without your consent, these companies do not have the right to use the personally identifiable information provided beyond what is necessary to assist GLNT.)
GLNT finds that your actions violate the usage guidelines outlined in any of the GLNT Terms and Conditions.
GLNT feels that an emergency situation has arisen which requires us to release information before you can be contacted for consent. For example; a verified family emergency.
It may be necessary − by law, legal process, litigation, and/or requests from public and governmental authorities within or outside your country of residence − for GLNT to disclose your personal information. We may also disclose information about you if we determine that for purposes of national security, law enforcement, or other issues of public importance, disclosure is necessary or appropriate. We may also disclose information about you, but only where there is a lawful basis for doing so, if we determine that disclosure is reasonably necessary to enforce our terms and conditions or protect our operations or users. This could include providing information to public or governmental authorities. Additionally, in the event of a reorganization, merger, or sale we may transfer any and all personal information we collect to the relevant third party.
As part of an audit process through which a 3rd party is assessing the security, quality, integrity or such or GLNT’s policies, procedures and systems. All efforts will be made to prevent any such information from being passed any further by using non-personal reference identifiers in any report resulting from such an audit and any such auditor and auditing agency would be bound to confidentiality on any such data or information potentially revealed.
When your information is shared with third parties, we require those third parties to handle it in accordance with relevant laws. Personal information will never be shared with third parties for their marketing purposes.
The GLNT website or app may contain links to other web sites. GLNT is not responsible for the privacy practices of sites owned and operated by other companies. When you leave the GLNT web site, please read the privacy policies of each web site that collects personally identifiable information. This privacy statement applies solely to information collected by GLNT, and such information remains private and secure when you follow links to other web sites.
GLNT is committed to a zero-tolerance, anti-Spamming policy. Under this policy, we prohibit:
Manipulating identifiers, such as email headers, to disguise the origin of any content transmitted to or through GLNT‘s computer systems.
Relaying email through a third party’s mail servers without the permission of that third party.
Using or causing to be used GLNT computer systems to facilitate the transmission of unsolicited, unauthorized material. This includes any promotional materials, URL’s, “junk mail,” “chain letters,” “pyramid schemes,” or any other form of unauthorized solicitation that you may upload, post, email, transmit, or otherwise make available
Using “robots” or otherwise harvesting others’ email addresses from
the GLNT servers for purposes of sending unsolicited or unauthorized material
Uploading, posting, emailing, or transmitting the same message, URL, or post multiple times
Allowing third parties to contact our customer database without the customer’s prior consent
Emailing non GLNT customers promotional or marketing materials without their prior consent
Emailing GLNT customers who have opted out of email based contact promotional or marketing materials without their prior consent.
Voluntary Customer Surveys
In keeping with GLNT’s commitment and obligation to monitor customer satisfaction and improvement opportunities, GLNT may periodically conduct both business and individual
customer surveys. We encourage our customers to participate in these surveys because they provide us with important information that helps us to improve the types of services we offer and how we provide them to you. Your personal information and responses will remain strictly confidential, even if the survey is conducted by a third party. Participation in our customer surveys is voluntary. We take the information we receive from individuals responding to our customer surveys and combine (or aggregate) it with the responses of other GLNT customers to create broader, generic responses to the survey questions (such as gender, age, residence, hobbies, education, employment, industry sector, or other demographic information). We then use the aggregated information to improve the quality of our Services to you, and to develop new services and products. This aggregate, non- personally identifying information may be shared with third parties.
Other Partners and Sponsors
Some GLNT products and services are or may be offered in conjunction with a non- affiliated partner. To provide some of these products and services, the partner may need to collect and maintain personal information. In these instances, you will be notified before any such data is collected or transferred and may decide not to use that particular service or feature. GLNT will share non-personal and aggregate information (except as described above), but not personal information, with such partners in order to administer any such co-branded products or services offered.
It is GLNT‘s policy not to use or share the personal information about individuals in ways unrelated to the ones described above without also providing you an opportunity to opt out or otherwise prohibit such unrelated uses. However, GLNT may disclose personal information about individuals, or information regarding your use of the Services or internet sites accessible through our Services, for any reason if, in our sole discretion, we believe that it is reasonable to do so, including: to satisfy laws, such as the Electronic Communications Privacy Act, regulations, or governmental or legal requests for such
To provide location-based services on GLNT products, GLNT and our partners and licensees may collect, use, and share precise location data, including the real-time geographic location of your GLNT product or device utilizing a GLNT app. Where available, location-based services may use GPS, Bluetooth, and your IP Address, along with crowd-sourced Wi-Fi hotspot and cell tower locations, and other technologies to determine your devices’ approximate location. Unless you provide consent, this location data is collected anonymously in a form that does not personally identify you and is used by GLNT and our partners and licensees to provide and improve location-based products and services. For example, your device may share its geographic location with application providers when you opt in to their location services.
Retention of Personal Information
Revisions to this Policy
GLNT reserves the right to revise, amend, or modify this policy and our other policies and agreements at any time and in any manner.
Conflicts with this Policy
If the terms of any GLNT agreement or Terms & Conditions should conflict with the terms of this Policy with respect to the collection, control, and use of your information, then this Policy shall control.
wishes GLNT to cease processing the information it has about that Customer as a result of the Customer’s use of GLNT‘s web site, please contact GLNT at the address below:
Great Lakes NeuroTechnologies Inc. 6100 Rockside Woods Blvd. N., Suite 415 Cleveland, OH 44131 USA