Your privacy is very important to Wave Neuroscience, Inc. ("Wave Neuro," “our,” "us," or "we"). This Privacy Policy applies to information we collect from all sources, including without limitation through our website at https://www.waveneuro.com/ (the "Site ") and through any services and/or products we offer or provide, to include mobile applications (collectively “Services”).  This Privacy Policy is intended to explain how we collect your personal information, what types of personal information we collect, how we use your personal information, with whom your personal information may be shared, how we protect and how long we store it, and what choices you have about how that information is used.  This Privacy Policy also describes the choices you can make about how we collect and use your personal information.  

BY ACCESSING AND/OR USING THE SITE AND/OR SERVICES OR SUBMITTING INFORMATION TO US, YOU UNDERSTAND AND AGREE THAT YOUR USE OF THE SITE AND/ SERVICES AND ANY DISPUTE OVER PRIVACY IS SUBJECT TO THIS PRIVACY POLICY.  IF YOU DO NOT AGREE WITH THIS PRIVACY POLICY, PLEASE DISCONTINUE USE OF THE SITE AND SERVICES.  

Please note that certain personal information collected through the Site and/or Services may be considered health related data under applicable data protection laws.  

What Types of Personal information We May Collect:

The personal information we collect will vary based on your use of the Site and Services, actions you elect to take, and the personal information you elect to submit to us, including your:

• Personal identification information, including your name, e-mail address, postal address, telephone number, quantitative electroencephalogram data (gender, birth date, right- or left-hand dominance, and information you provide regarding your concerns); 
• Sensitive personal information, such as your credit card number or other payment information for purchases, billing address, and associated email address;
• Information we receive from any third party, such as our affiliates, referral sources, or service providers you engage, which refer you to Wave Neuro or which access or use the Site or Services on your behalf or in connection with services they provide to you;
• Device and connection information, including without limitation details regarding your Internet Protocol (“IP”) address, browser, operating system, and screen display; and 

Tracking information and metadata regarding your use of the Site.  

How We Collect Your Personal information:

We collect your personal information in different ways when you access various parts of the Site and when you use our Services, including:

• Personal information you submit when using our Services or when you communicate with us by telephone, email, or via the Site;  
• Financial information you submit when you sign up for or purchase our Services;
• Personal information you submit through participation in our surveys;
• Through third party tools used to collect user behavior, such as through cookies (a "cookie" is a small data file that can be stored on your device (computer or mobile) when you visit certain Internet sites); 
• Through third party web technologies used to provide functionality of the Site, including Webflow, Google Analytics, and Hotjar, which may collect certain personal information (e.g., your IP address) through websites operated by such third parties; and 
• Information submitted by or obtainable from your Internet service provider, software, computer, mobile device, or other method of accessing the Site (which you may be able to control through the settings of your software and devices) which we collect in our server logs. 

How We Process and Use Your Personal information:

We may process and use your personal information primarily to perform Services you request, provide and maintain the Site secure, for improving the Site, and for marketing efforts.  We may use your personal information in the following ways:

• By providing you access and functionality of the Site and for identifying defects and improving the Site;
• By using log files to collect, store, and track personal information to analyze trends, for statistical and/or marketing purposes, administer and monitor traffic around the Site, to improve the Services, and to gather demographic information about our user base as a whole;
• To send periodic emails or other communications to you and otherwise conduct internal marketing campaigns; 
• We may process your personal information because it is necessary for our or a third party's legitimate interests; 
• To disclose information that is necessary to identify, contact, or bring legal action against someone who may be violating our terms and conditions of use or this Privacy Policy or to otherwise protect Wave Neuro and our customers;
• To enforce any of our rights under the terms and conditions of use, this Privacy Policy, and any other rights we may have;
• When we have your specific or, where necessary, explicit consent to do so; 
• For fraud prevention; 
• By using cookies to track and target the interests of our users to enhance the experience of the Site; and 
• We may also process your personal information for compliance with our legal obligations, including to satisfy laws, such as the Electronic Communications Privacy Act, regulations, or governmental or legal requests for such information or otherwise meet our compliance and regulatory obligations, both in the US and the EU, including with respect to any EU Member State where we are providing our Services.  

With Whom Will We May Share Your Personal information:

We generally do not share your personal information, but we may share your personal information:

• If we have received your advance permission to do so;
• With our employees, if necessary for the development, improvement, and provision of the Site and Services;
• With our third party processors, who meet the requirements of this of this Privacy Policy, when necessary for the purposes of providing the Site and Services;
• With our credit card processing companies, fraud preventions services, and third party vendors who meet the requirements of this Privacy Policy, as necessary to provide the Site and Services;
• To comply with a legal obligation or to protect and defend our rights or property, if we believe in good faith that such action is necessary; and 
• With third parties, subject to a reasonable obligation of confidentiality, in connection with any merger, acquisition, asset sale, financing, or other capital transaction involving the sale of all, or substantially all, of our assets.  

How We Protect Your Personal information:

The Site has security measures in place to protect the loss, misuse, and alteration of the personal information under our control. While we use industry standards to protect the integrity and security of our network and systems, no method of transmission over the Internet is completely secure and we cannot guarantee that our security measures will prevent third-party “hackers” from illegally obtaining personal information. All payment information is transferred using encryption during transmission, such as SSL (Secure Socket Layer) protocols.  In addition, your personal information is stored in databases that are on a virtual private cloud (Webflow).

How Long We Retain Your Personal information:

We retain your personal information for as long as necessary to provide you with Services, until you request that we delete it, or otherwise for as long as permitted or required to resolve disputes or collect outstanding fees or for legal and regulatory purposes. Aggregate information, which is not personal information, is retained indefinitely to improve the functionality of the Site and Services.

Your Personal information Protection Rights and Choices:

You have the following rights in relation to our processing of your personal information.  Please note that these rights are not absolute, and we may be entitled to refuse requests where exceptions apply.  You have the right to: 

• To obtain access to, and copies of, the personal information that we hold about you; 
• To require us to correct the personal information we hold about you if it is incorrect;
• To require us to delete or restrict your personal information in certain circumstances ((e.g., if Wave Neuro is using your personal information on the basis of your consent and has no other legal basis to use such, you may request your personal information be deleted when you withdraw your consent); 
• To require us to restrict our data processing activities in certain circumstances;
• Select whether we share your personal information with third parties by or change your selection by e-mailing us at privacy@waveneuro.com and placing “share” or “do-not-share” in the subject line (please include your full name); 
• To object to any of our particular processing activities of your personal information;
• To receive from us the personal information we hold about you, in a reasonable format specified by you, including for the purpose of you transmitting that personal information to another data controller; 
• Where our processing is based on your consent, you may withdraw that consent, without affecting the lawfulness of our processing based on consent before its withdrawal; 
• If you are not satisfied with how we are processing your personal information, you can make a complaint to a data protection supervisory authority in the US or EU, as applicable, including the data protection regulator in the EU country where you are located; and 
• To request that we restrict the processing of your personal information pending our investigation and/or verification of your claim, if you believe your personal information is inaccurate, no longer necessary for our business purposes, or if you object to our processing of your personal information. 

If you want to exercise any of the rights described above, or submit a complaint on how we have handled your personal information, please contact us by e-mail at privacy@waveneuro.com. 

You also have choices regarding the collection, use, and sharing of your personal information:  

• You may opt-out of receiving e-mails or newsletters and other offers by clicking on the unsubscribe link at the bottom of any of our e-mails or newsletters; and 
• You may be able to configure your browser to reject cookies, but doing so will limit the functionality and negatively impact your experience using the Site

California Residents Privacy Rights:

Under California Civil Code sections 1798.83-1798.84, California residents are entitled to ask certain businesses to respond to requests about the business practices related to disclosing personal information to third parties for the third parties’ direct marketing purposes. Alternately, businesses may have in place a policy not to disclose personal information of customers to third parties for the third parties' direct marketing purposes if the customer has exercised an option to opt-out of such information-sharing. We require you to expressly opt-in to any disclosure of your personal information to third parties for the third parties' direct marketing purposes, which is stricter than required under California law.  If you are a California resident and would like a copy of this Privacy Policy, please submit a written request to the address below.

Visiting the Site from Outside the United States:

If you are visiting the Site from outside the United States, please be aware that your information will typically be transferred to, stored, and processed in the United States where our servers are located and our central database is operated. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country. Please be assured that we seek to take reasonable steps to ensure that your personal information is protected.  If you are located outside the United States and choose to provide information to us, please note that we transfer the data, including personal information, to the United States and process it there.  Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

Children’s Privacy and International Considerations:

Protecting the privacy of young children is especially important to us. For that reason, Wave Neuro does not knowingly collect or maintain personal information from children under 16 years of age.  If Wave Neuro learns that personal information of children under 16 years of age has been collected on or through the Site, Wave Neuro will take the appropriate steps to delete such personal information. If you are the parent or legal guardian of a child under 16 years of age who has become a registered user of the Site or otherwise has used the booking engine or our Services, please contact us by email at privacy@waveneuro.com to have your child’s transactions terminated and personal information deleted.

Third Party Websites:

Since our Site uses third party technology (e.g., a cookie placed by Google Analytics) to collect information about your use of our Site, third parties may provide advertising and links on the Site to third party websites.  At some third party websites, you can purchase third party products and services or register to receive materials. In many cases, you may be asked to provide contact information, such as your name, address, email address, phone number, and credit/debit card information.  Wave Neuro has no control over the third parties' use of any personal information you provide them. We strongly encourage you to review the third parties' privacy policy before providing any of your information.

Additionally, please be aware that if you visit third party (non-Wave Neuro) websites where you are prompted to login or that is customizable, you may be required to accept cookies. Our affiliates, partners, and advertisers may also use their own cookies. We do not control use of these cookies and expressly disclaim responsibility for information collected through them.  

Our Contact Information:

If you have any questions about this Privacy Policy or any concerns regarding the collection, use and disclosure of your personal information, or to instruct us regarding your choices regarding your personal information, you may contact us using any of the following ways: 

By email: 

privacy@waveneuro.com

By mail: 

Wave Neuroscience, Inc. 

1601 Dove Street, Suite 205 

Newport Beach, CA 92660

Attention: Privacy Officer 

We will attend to your questions, concerns, or instructions promptly.

Changes to our Privacy Policy:

Wave Neuro reserves the right to revise, amend, or modify this Privacy Policy and our other policies and agreements at any time and in any manner, in our sole discretion, by posting any changes on the Site.  We will alert you to changes to this Privacy Policy by placing a notice on the Site, by sending you an e-mail, and/or by some other means. If you use the Site and/or Services after any changes to the Privacy Policy have been posted, you understand and agree that your use of the Site and/ Services and any dispute over privacy is subject to the revised Privacy Policy.  If you do not agree to the terms of this Privacy Policy or any revised Privacy Policy, please exit the Site immediately and discontinue your use of the Site and Services.