Last Updated: 03/19/24
Synthesys Brain Health Company and subsidiaries (“Synthesys Brain Health”, “we”, “us”, or “our”) are committed to protecting your privacy.Synthesys Brain Health is a company that brings together products and services from around the globe to further our mission to offer integrated neurodiagnostic solutions. We maintain a publicly accessible website at https://www.synthesyshealth.com (“Site”). Through our Site, we provide information about our solutions, products and services, provide industry news and information, and allow customers and users of our Site to contact us (“Services”).We understand that privacy is exceptionally important to the individuals that use our Site and Services. The purpose of this Privacy Policy is to plainly and transparently disclose to you how we collect, use and share information, and how we attempt to safeguard the data you provide to us.We are committed to securing data that we collect concerning you (“you”) and complying with applicable data protection and privacy laws throughout the world. We take steps to safeguard your information and communications from unauthorized intrusions and access.
The personal information we collect and how we use it, depends on the context of your interactions with us, the choices you make, and the Services and features you use. You provide this personal information directly when you submit inquiry forms, subscribe to receive topical materials and newsletters; inquire about our services or capabilities; apply to participate in our clinical research studies; or apply for a job with us. You may choose not to provide personal information, but in not doing so, we may be unable to complete your request. We collect a certain amount of technical information from our website users about your access and how you interact with the Services. We use this information to improve your experience and help us to manage and protect the Services.We collect and process the following information about you:
•Information you give to us
You provide information to us when you affirmatively provide it to us. For example, you provide information each time you:
• participate in a clinical trial or research program;
• request, obtain or purchase products or Services from us;
• download any information from our Site;• fill in a form on our Site to contact us with an inquiry;
• correspond with us by phone, e-mail or otherwise;• provide us with information requested by us for the verification of your identity; and
• when you report a problem with our Site.
We may also collect information about you when you participate in or register for one of our promotions, events or surveys.The type of information you give us may include your:
1.Contact information (name, company name, title, mailing address, telephone, electronic mail address, facsimile address);
2. Shipping information;
3. Order information;
4. Inquiry information;
5. Date of birth;
6. Order history;
7. Communications to and from
8. Any data required for the participation in a clinical trial or research
This information will be used in accordance with the purposes described in this Privacy Policy and in any applicable privacy notice provided to you at the time at which it was collected.
• Information we collect from you
Each time you visit our Site, we may automatically collect the following information:
1. technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, browser type and version, location information, time zone setting, browser plug-in types and versions, operating system and platform; and
2. information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time), pages you looked at or searched for, and the products and services you have viewed, ordered or searched including, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call
More information on our use of cookies is provided below. More use of third-party tools used to collect information is provided in the “Information we collect from you with third-party processors” section. Synthesys Brain Health records and compiles aggregate demographic data related to our users in order to manage the Services offered. Synthesys collects and analyzes data about the use of the Site to improve service and to improve user experience. As set forth in the section on Cookies below, we also use externally hosted services (e.g. Google Analytics) to collect data.
• Information we collect from you with third-party processors
We also collect information about you using third-party sources. We use this information to conduct research, process our orders, improve our sales process and communications with our customers and prospective customers. We also use this information to improve your experience on our Site.
We do not rent or sell your personal information. In the course of our business operations and where required, we share your personal information with relevant Synthesys Brain Health employees in subsidiary companies within our group. We share your personal information with selected third parties relating to your interactions with us. You will be provided with more specific information about those recipients of your personal information at the point of collection. We also share certain information with service providers that carry out functions or services on our behalf that enable our business operations. This will include our IT applications and systems, website analytics and search engine providers. It also incorporates the protection and securing of our systems and services.Access to any personal information we collect and store is generally restricted to those employees and/or contractors who require it to perform a job or other contracted function. We require vendors and contractors we work with to use reasonable, industry-standard protocols to maintain the confidentiality, security, and integrity of information. We share your personal information where required by applicable laws and regulations. We share your personal information with your consent; as necessary to complete any contract, transaction, action authorized by your or to fulfill your request.
Our Services use cookies (small text files containing a string of alphanumeric characters that we put on your computer) and other similar tracking technologies (like web beacons, tags, and scripts) to provide the Services and to help collect information that we use to administer the Services, to analyze your use of the Services, and to assist with our promotional and marketing efforts. The Options/Settings section of most internet browsers will tell you how to manage cookies and other technologies that may be transferred to your device, including how to disable such technologies.We use the following cookies:
• Analytical/performance cookies. They allow us to recognize and count the number of visitors and to see how visitors move around our websites when they are using it. This helps us to improve the way our websites works, for example, by ensuring that users are finding what they are looking for
• Functionality cookies. These are used to recognize you when you return to our websites. This enables us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
• Targeting cookies. These cookies record your visit to our websites, the pages you have visited and the links you have followed. We will use this information to make our websites and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose. Some third parties may also collect data from you through cookies and other related scripts. The use of third-party cookies is not covered by our Privacy Policy, as we do not have access or control over these
1. A right to access personal data held by us about you, as well as information about how we are using your data.
2. A right to require us to rectify any inaccurate personal data held by us about
3. A right to require us to erase personal data held by us about you, and where the personal data has been made public, for other controllers processing the personal data to also erase links to, or copy or replication of, such personal data. This right will only apply where (for example): we no longer need to use the personal data to achieve the purpose we collected it for; or where you withdraw your consent if we are using your personal data based on your consent; or where you object to the way we process your data (in line with Right 6 below).
4. A right to restrict our processing of personal data held by us about you. This right will only apply where (for example): you dispute the accuracy of the personal data held by us; or where you would have the right to require us to erase the personal data but would prefer that our processing is restricted instead; or where we no longer need to use the personal data to achieve the purpose we collected it for, but you require the data for the purposes of dealing with legal
5. A right to receive personal data, which you have provided to us, in a structured, commonly used and machine-readable format. You also have the right to require us to transfer this personal data to another organization, at your request.
6. A right to object to our processing of personal data held by us about you (including for the purposes of sending marketing materials to you).
7. A right to withdraw your consent, where we are relying on it to use your personal data (for example, to provide you with marketing information about our services or products).
We recognize that privacy rights differ across the world. Our business, systems and Site are designed to comply with all relevant and appropriate national and international legislation with regards to data protection and user privacy, including (without limitation) the General Data Protection Regulation (“GDPR”).We also understand that the obligations of Services may make the exercise of rights difficult to fulfill, for example to maintain the integrity of clinical trials data. If you are a patient in a clinical trial, you should contact the Doctor who is treating you at the clinical trial site. Your identity will not be known to Synthesys Brain Health, as your doctor encoded enrollment data about you with a random patient number. Synthesys Brain Health only has the random patient number. For this reason, we are unable to activate an exercise of rights request from you via this process.You can submit a request to exercise your privacy rights at any time, free of charge, through the “Exercise Your Rights” form. Our privacy team will review your request and respond to you within a reasonable time frame as required by applicable law.
You can opt-out of receiving promotional or marketing communications from us at any time by using the unsubscribe link in the email communications we send. If you or your organization are a Synthesys Brain Health client or business partner, we will still send you non-promotional communications. Where an application that we provide enables you to directly manage your preferences and the personal information you are providing, we will make this readily available to you for you to exercise choice. You can also contact us at any time. The supplemental information notice provided to you for specific Services may provide contact points or instructions on preference election for that Service.
Electronic communication is the most effective and timely way to provide the users of our Site with any optional or required notifications and disclosures. In some circumstances, however, applicable laws may require us to send you disclosures or communications in paper format unless you have affirmatively consented to receiving electronic notifications only in advance of the notification.Through this Privacy Policy, pursuant to 15 U.S.C. § 7001, you hereby affirmatively consent to receive electronic notifications and disclosures from us only (without requiring a paper copy) and you represent that, to date, you have not withdrawn such consent. You have the right to change your mind and withdraw your consent at any time. If you would like to withdraw your consent to receive electronic notifications and/or would like to request paper copies of any electronic notifications you receive, please contact: privacyofficer@synthesyshealth.com. To receive electronic records, you will need access to a smart phone, tablet, laptop or computer with Internet access and either email software (such as Microsoft Outlook) or access to a web-based electronic mail software platform, such as Gmail, Yahoo or other electronic mail provider.
Synthesys Brain Health is a global organization headquartered in the United States. Synthesys Brain Health can confirm that all processing activities undertaken will meet GDPR and other applicable regulations. Synthesys Brain Health will not use other processors (for the agreed upon processing activities) without the permission of the data controller. All processing activities by Synthesys Brain Health will be governed by a contract or binding legal agreement between the processor and data controller, which sets out details such as the duration of the processing, purpose, categories of data processes, obligations of the controller and will state in particular that the processor:
• ensures that the authorized individuals processing the data are committed to confidentiality,
• agrees to apply required security measures, will respect the other conditions referenced above,
• commits to assist the controller in the fulfilment of obligations regarding user rights
• commits to making available to the controller any and all information needed to show compliance and/or to facilitate audits and inspections authorized by the controller
Synthesys Brain Health will retain your personal information for as long as needed for the purposes described in this Privacy Notice and more specifically any supplemental notices relating to individual Services; as necessary to comply with our legal obligations (such as to honor the exercise of rights), resolve disputes, and enforce our agreements; or to the extent otherwise permitted by applicable law. At the end of the retention period, Synthesys Brain Health will delete your personal information in a manner designed to ensure that it cannot be reconstructed or read.
The Site and/or Services may provide links to or the ability to connect with websites, services or applications that are owned and operated by third parties. Clicking on those links or otherwise enabling connections with those services may allow the third party to collect or share information about you. Those third-party websites or services are beyond our control and are not subject to this Privacy Notice. We encourage you to check the privacy policies and terms of use of any third-party websites or services before using them and providing your personal information to them.
The Site and Services are not designed or directed toward anyone under the age of 16. We do not knowingly collect or solicit personal information from anyone under the age of 16. If you are under 16, please do not use the Site or Services or send any personal information about yourself to us. If we discover any personal information of children under sixteen has been collected without verifiable parental consent, we will immediately delete the information.
We update this Privacy Notice from time to time. When we post changes, we will revise the “Last Updated” date at the beginning of this Privacy Notice. If there are material changes to this Privacy Notice or to the ways we will use your personal information, we will notify you either by prominently posting a notice of the changes in the Site or Services before they take effect or by directly sending you a notification. We encourage you to review this Privacy Notice periodically to be informed of how we are using your information and to be aware of any change to the Privacy Notice.
If you have any questions or concerns about our privacy practices or this Privacy Notice, please send us a detailed message by email to privacyofficer@synthesyshealth.com; or write to us at the following address:
Privacy Officer
Synthesys Brain Health Company
900 East Main Street Suite 300
Louisville, KY 40206 USA
This Privacy Policy, and Synthesys’ collection and use of customer information, shall be governed and interpreted in accordance with applicable international laws, laws of the United States and the State of Delaware. Any disputes arising out of this Policy shall be adjudicated in federal court of competent jurisdiction in the United States District Court for the District of Delaware.
DISCLAIMER OF WARRANTIES
YOU EXPRESSLY AGREE THAT YOUR USE OF THE SITE AND SERVICES IS AT YOUR SOLE RISK. THE SITES AND SERVICES ARE PROVIDED TO YOU ON AN “AS IS” AND “AS AVAILABLE” BASIS. WE EXPRESSLY DISCLAIM ALL WARRANTIES OF ANY KIND, WHETHER EXPRESS OR IMPLIED, INCLUDING, BUT NOT LIMITED TO, ANY WARRANTIES REGARDING DATA PRIVACY OR DATA SECURITY.
O THE FULLEST EXTENT PERMITTED BY LAW, YOU EXPRESSLY AGREE THAT SYNTHESYS SHALL NOT BE LIABLE FOR ANY INDIRECT, INCIDENTAL, SPECIAL OR CONSEQUENTIAL DAMAGES, INCLUDING, BUT NOT LIMITED TO, DAMAGES FOR LOSS OF DATA, DATA BREACH, OR DISCLOSURE OF PERSONAL INFORMATION, EVEN IF SYNTHESYS HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES. YOU SPECIFICALLY AGREE THAT SYNTHESYS IS NOT RESPONSIBLE OR LIABLE TO YOU OR ANYONE ELSE FOR ANY VIOLATION OF YOUR RIGHTS OR THE RIGHTS OF ANY OTHER PARTY, INCLUDING, BUT NOT LIMITED TO, INTELLECTUAL PROPERTY RIGHTS, RIGHTS OF PUBLICITY, OR RIGHTS OF PRIVACY. SOME JURISDICTIONS DO NOT ALLOW THE LIMITATION OR EXCLUSION OF LIABILITY FOR INCIDENTAL OR CONSEQUENTIAL DAMAGES, THEREFORE SOME OF THE ABOVE LIMITATIONS MAY NOT APPLY TO YOU. IN ANY EVENT, IF SYNTHESYS IS FOUND TO HAVE VIOLATED ANY OF YOUR RIGHTS, YOU ACKNOWLEDGE AND AGREE THAT ANY DAMAGES RECOVERABLE AGAINST SYNTHESYS ARE LIMITED TO YOUR ACTUAL, PROVEN DAMAGES.