INTRODUCTION
This Privacy Statement explains how SPR Therapeutics (“SPR”) handles personal information that we collect online through our website, emails, electronic surveys, social media channels and through our offline interactions with you. This Privacy Statement does not apply to third-party websites to which SPR may link.
This website is intended only for United States (“US”) and Canadian residents 18 years of age and older. By using this website, you agree to the terms of the most recent version of this Privacy Statement. Please read our Terms of Use to understand the general rules about your use of this website. Except as written in any other disclaimers, policies, terms of use, or other notices on this website, this Privacy Statement and the Terms of Use are the complete agreement between you and SPR with respect to your use of this website. You may be subject to additional terms that may apply when you access specific services or materials on certain areas in this website, or when you follow a link from this website.
WHAT IS PERSONAL INFORMATION?
Personal information is information that we can use to specifically identify you, such as your:
- Name
- Address
- Unique personal identifier (e.g., device ID, online identifier)
- Internet Protocol address
- Email address
- Account name
- For U.S. healthcare providers, a National Provider Identifier# (NPI) and/or a state license number
- Social security number
- Driver’s license number
- Passport number, or
- Other similar identifiers
- Characteristics of protected classifications under state/federal law (e.g., age, race, sex, medical condition, etc.)
- Medical information
- Health insurance information
- Financial information, including credit card numbers and account numbers
- Biometric information (e.g., imagery of the iris, retina, fingerprint, face, or other data that contain identifying information)
- Commercial information (e.g., purchase history)
- Usernames in combination with passwords or log-in information
- Internet or other electronic network activity information (e.g., browsing history, interaction with our website, etc.)
- Geolocation data
- Audio, electronic, visual, thermal, olfactory, or similar information (e.g., call recordings)
Professional, employment-related, or other similar information. In some places on this website or otherwise you have the opportunity to provide us personal information about yourself, to elect to receive particular information, or to participate in an activity. For example, you may fill out a registration form, a survey, or an e-mail form and you may elect to receive educational material about our products.
HOW DOES SPR KEEP AND USE PERSONAL INFORMATION?
We may keep and use personal information we collect from you to:
- provide products and services to consumers
- respond to your requests
- personalize your access to our website, for example, by telling you about new features that may be of interest to you
- develop records, including records of your personal information
- contact you with information that might be of interest to you, including, to the extent permitted by law, information about clinical trials and educational and marketing communications about products and services of ours and of others
- for analytical purposes and to research, develop and improve programs, products, services and content
- for U.S. healthcare providers, to link your name, National Provider Identifier (NPI), state license number, and/or your IP address to web pages you visit, for compliance, marketing, and sales activities
- remove your personal identifiers (your name, e-mail address, social security number, etc.). In this case, you would no longer be identified as a single unique individual. Once we have de-identified information, it is non-personal information and we may treat it like other non-personal information.
- enforce this Privacy Statement and other rules about your use of this website
- protect someone’s health, safety or welfare
- protect our rights or property
- comply with a law or regulation, court order or other legal process
- to conduct audits and perform troubleshooting activities of our websites, products, and services
- to detect and protect against security incidents and deceptive, malicious, or fraudulent activity
- to ensure our website, products, and services function as intended, including debugging and repairing.
DOES SPR EVER SHARE PERSONAL INFORMATION WITH THIRD PARTIES?
SPR will not share your personal information collected with an unrelated third-party without your permission, except as otherwise provided in this Privacy Statement.
In the ordinary course of business, we will share some personal information with companies that we hire to perform services or functions on our behalf. In cases in which we share your personal information with a third-party vendor, we will not authorize them to keep, disclose or use your information with others except for the purpose of providing the services we asked them to provide.
We may be legally compelled to release your personal information in response to a court order, subpoena, search warrant, or to comply with federal, state, or local laws. We may cooperate with law enforcement authorities in investigating and prosecuting website visitors who violate our rules or engage in behavior which is harmful to other visitors (or illegal).
We may disclose your personal information to third parties if we feel that the disclosure is necessary to:
- enforce this Privacy Statement and the other rules about your use of this website
- protect our rights or property and to defend against legal claims
- protect someone’s health, safety or welfare
- fulfill obligations relating to a corporate sale, merger, dissolution, or acquisition
- comply with a law or regulation, court order or other legal process
- comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by federal, state, or local authorities
- cooperate with a government agency request for emergency access to a consumer’s personal information if a natural person is at risk or danger of death or serious physical injury, provided that:
- the request is approved by a high-ranking agency officer
- the request is based on the agency’s good faith determination
- the agency agrees to petition a court for an appropriate order within three days and to destroy the information if the order is not granted
Please note: In addition to the ways that we may keep, disclose, and use information described in this Privacy Statement, we also may keep, disclose, and use personal information in ways that we believe are consistent with FDA and other governmental guidance, directions, regulations, and laws, including HIPAA, where applicable.
COLLECTING ONLINE INFORMATION
If you visit our website to read or download information, such as information about a health condition or about one of our products, we may collect certain non-personal information about you from your computer or mobile device. This information may include:
- The name of the domain from which you access the Internet
- The Internet Protocol address (“IP Address”) of the device you are using
- The type of browser and operating system you are using
- The date and time you access our website
- The internet address of the site from which you linked directly to our website
- Which pages you have visited on our website
- The search terms you use
- The links on which you click
We also collect data through Google Analytics to track the location and number of visitors to our website. Learn about how Google uses this information.
Cookies: We also may collect this information through cookies, pixels, web beacons, and similar technologies (“cookies”), that work through placing a small file (like a text file or graphic) in your browser files. Cookies are used to collect information for business purposes, such as enabling essential website functions and improving the user experience. You are free to decline our cookies if your browser permits, but some parts of our website may not work properly for you if you do so. SPR may use third-party tracking, advertising, and content providers to act on our behalf to track and analyze your usage of our sites and to enable certain essential website functions, such as navigation. These third parties may collect, and share with us, as we may request, website usage information about visits to our sites, measure and research the effectiveness of our advertisements, and track page usage and paths followed during visits through our sites. Also, these third-party providers may place our Internet banner advertisements on other sites that you visit, and track use of our Internet banner advertisements and other links from our marketing partners’ sites to our sites. Please refer to your browser Help instructions to learn more about managing cookies. And see below for an explanation how to opt out of our use of cookies.
CHOICES ABOUT COOKIES AND OPT-OUT OPTIONS
SPR provides all individuals the opportunity to opt out of having personal information used for certain purposes. To tell us how you would like SPR to use or not use your data, please contact SPR at data@sprtherapeutics.com or 866-329-9313. SPR cannot allow individuals to opt out of our maintenance of data SPR is obliged to keep for administrative, legal or security purposes.
For more information on third-party advertising-related cookies and how to opt out of some cookies as you choose, see the descriptions and links below.
Click here to visit the Network Advertising Initiative site to set preferences and opt out of third-party targeting cookies.
Visit aboutads.info and allaboutcookies.org to find general information and opt-out.
WHAT DOES SPR DO WITH NON-PERSONAL INFORMATION?
Non-personal information is information that cannot identify you or be tied to you. We are always looking for ways to better serve you and improve this website. We will use non-personal information from you to help us make this website more useful. We also will use non-personal information for other business purposes. For example, we may use non-personal information or aggregate non-personal information to:
- create reports for internal use to develop programs, products, services or content
- customize the information or services that are of interest to you
- share it with third parties
- provide aggregated information on how visitors use our site, such as ‘traffic statistics’ and ‘response rates,’ to third parties
HOW DOES SPR PROTECT MY ACCOUNT INFORMATION?
Certain of our webpages permit healthcare providers to create a user account and login to that account. The information in this section applies to those webpages:
Viewing/Editing Personal Information: You may change the information you have provided by logging into your account and editing the information.
Storage of Personal Information: SPR may store your personal information on servers in the United States of America. If you choose to close your account, we will maintain copies of your information in our internal records, systems, and databases, in accordance with our data retention schedules unless expressly asked to remove it via the steps listed above. We will continue to treat your personal information in accordance with this Privacy Statement.
Protecting Personal Information: We take security seriously by implementing reasonable security procedures and practices to protect your personal information. You also play a big part in protecting the privacy of your personal information. When you create an account, we ask you to select a password that is unique to you. To protect your personal information from unwanted disclosure, you should not give your password to anyone with whom you would not share your personal information. Our website may also log you out after a period of inactivity and require you to log in again. When you are ready to leave this website, always “log off” and close your browser to help protect the confidentiality of your information.
WHAT HAPPENS IF THE PRIVACY STATEMENT CHANGES?
We may update this Privacy Statement from time to time and those changes will be made directly on our website. These changes are effective immediately after they are posted on this page. We encourage you to review this page periodically for any changes.
WHAT ABOUT PRIVACY ON OTHER WEBSITES?
This website may contain links to other websites. Some of those websites may be operated by SPR, and some may be operated by third parties. We provide the links for your convenience, but we do not review, control, or monitor the privacy practices of websites operated by others. This Privacy Statement does not apply to third-party websites, including any website that is not owned or operated by SPR. We are not responsible for the performance of websites operated by third parties or for your business dealings with them. Therefore, whenever you leave this website, we recommend that you review each website’s privacy practices and make your own conclusions regarding the adequacy of these practices.
DOES SPR EVER COMMUNICATE DIRECTLY WITH VISITORS TO THIS WEBSITE?
We may contact you periodically by e-mail, mail, telephone, or text if you agree to that contact. The purpose would be to provide information regarding programs, products, services and content that may be of interest to you. In addition, some of the features on this website allow you to communicate with us using an online form. SPR’s response to you may include your personal information, including personal information about your health, your name, address, etc.
ARE THERE SPECIAL RULES ABOUT CHILDREN’S PRIVACY?
We care about protecting the online privacy of children. We will not intentionally collect any personal information (such as a child’s name or e-mail address) from children under the age of 13 on our website. If you think that we have collected personal information from a child under the age of 13, please contact us.
WHAT ABOUT WEBSITE SECURITY?
Security is very important to us. We also understand that security is important to you. We have implemented security measures to protect your personal information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. While we have implemented security measures, please keep in mind that “perfect security” does not exist on the Internet or elsewhere and no transmission of information is guaranteed to be completely secure. In particular, e-mail sent to or from this site may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail.
HOW TO CONTACT SPR
If you have questions or comments about this Privacy Statement, please contact us at data@sprtherapeutics.com or 866-329-9313.
Consumer health Data policy – Washington My health my data Act
SPR never collects Consumer Health Data from consumers who are not SPRINT PNS patients, and even then, SPR does not collect Consumer Health Data without explicit prior written consent.
If, and only if, you are a SPRINT PNS Patient who has given explicit prior written consent to provide the following data during your 60-day SPRINT PNS treatment window, the following categories of data may be collected and used in the following ways:
Categories of Consumer Health Data: The following categories of health data may be collected to the extent that the following are related to your treatment with the SPRINT PNS System:
- Individual health conditions, treatment, diseases, or diagnosis
- Previous and current medical interventions, including pain management and medication usage
- Individual health conditions and treatment
- Pain experience and symptoms, such as your average and worst pain scores
- Specific usage and error data and settings from your SPRINT PNS System
- Usage and experience with the device including relief felt and other metrics including quality of life, sleep, and physical function
Purposes for which Data is Collected:
- Contact you directly to answer your questions about your SPRINT PNS System
- Ship any additional SPRINT supplies you may need
- Contact you by phone, text or email to collect information about your experience with the SPRINT PNS System during or following your use of the System
- Share your responses with your health care provider
Sources of Consumer Health Data from which data is collected:
SPR only collects the above data from the patient themselves after obtaining explicit prior written consent.
Categories of Consumer Health Data that is Shared:
SPR will not share your personal health data unless to share information regarding your treatment experience to your health care provider. SPR will only share the categories of the above that are directly related to providing treatment information to your provider, as necessary.
Sharing of Consumer Health Data to Third Parties and/or Affiliates:
Outside of your healthcare provider and other reporting obligations, SPR does not share or provide access to any other consumer health data with any third parties or affiliates.
supplemental PRIVACY NOTICE for california residents
This notice for California residents supplements the information contained in this Privacy Statement and applies solely to residents of the State of California. We adopt this Supplemental Notice to comply with California law, including the California Privacy Rights Act of 2020 (CPRA) and other California law. Any terms defined in the CPRA have the same meaning when used in this Supplemental Notice. Under the CPRA, you have certain rights in relation to some of your personal information, including the right to certain disclosures and explanations of rights. This section explains your rights under California law.
CALIFORNIA ‘DO NOT TRACK’ DISCLOSURES
California law (CalOPPA) requires SPR to let you know how we respond to web browser ‘Do Not Track (DNT) signals’. Because there currently is not an industry or legal standard for recognizing or honoring DNT signals, we do not honor Do Not Track requests at this time.
CALIFORNIA Shine the light law
California Civil Code Section 1798.83 permits California residents who are individual customers of SPR to request certain information regarding SPR’s disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact us at data@sprtherapeutics.com or 866-329-9313. Be sure to include your name and address, and your email address if you wish to receive a response by email. Otherwise, we will respond by postal mail within the time required by law.
CALIFORNIA PRIVACY RIGHTS ACT OF 2020
Categories of Personal Information We Collect
SPR collects information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California consumer or household (“personal information”). We may have collected the following categories of personal information from consumers through our websites, services, or devices within the twelve (12) months preceding the effective date of this Privacy Statement:
- Identifiers such as
- Name
- Address
- Unique personal identifier (e.g., device ID, online identifier)
- Internet Protocol address
- Email address, or
- Other similar identifiers
- Characteristics of protected classifications under California/federal law (e.g., age, race, sex, medical condition, etc.)
- Personal information categories listed in the California Consumer Records statute (Cal. Civ. Code § 1798.80(e)) (e.g., medical information and health insurance information);
- Biometric information (e.g., imagery of the face, or other data that contain identifying information)
- Commercial information (e.g., purchase history)
- Internet or other electronic network activity information (e.g., browsing history, interaction with our website, etc.)
- Geolocation data
- Sensory data (Audio, electronic, visual, thermal, olfactory, or similar information, such as call recordings)
- Professional, employment-related, or other similar information
- Sensitive person information (see below)
“Personal information” under the California Privacy Rights Act does not include information that is
- publicly available from government records,
- lawfully obtained, truthful information that is a matter of public concern
- de-identified or aggregated consumer information,
- excluded from the CPRA’s scope, such as
- health or medical information collected by entities subject to the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA)
- or clinical trial data, or
- certain personal or financial information covered under certain sector-specific privacy laws.
For additional information, please see the section above called “How Does SPR Keep and Use Personal Information”.
“Sensitive personal information” under California Privacy Rights Act means
- Personal information that reveals:
- A consumer’s social security, driver’s license, state identification card, or passport number
- A consumer’s account log-in information, fainancial accounts, debit or credit card numbers with any required security or access codes, passwords, or credentials allowing access to a consumer’s account
- A consumer’s precise geolocation
- A consumer’s racial or ethnic origin, religious or philosophical beliefs, or union membership
- Contents of a consumer’s mail, email, and text messages
- The processing of biometric information for the purpose of uniquely identifying a consumer
- Personal information collected and analyzed concerning a consumer’s health
- Personal information collected and analyzed concerning a consumer’s sex life or sexual orientation
“Sensitive personal information” under California Privacy Rights Act does not include information that is
- publicly available from government records,
- lawfully obtained, truthful information that is a matter of public concern, or
- de-identified or aggregated consumer information.
Categories of Sources of Personal Information
We obtain the categories of personal information listed above from the following categories of sources:
- Directly or indirectly from consumers or their caregivers or agents’ interactions with us, including with our websites, services, and representatives
- Customers, including health care providers and insurance providers
- From third parties in connection with the provision of services
Use or Disclosure of Personal Information
Please see the section above called “How does SPR Keep and Use Personal Information” in our Privacy Statement.
How We Share Personal Information
SPR will not share consumers’ personal information with an unrelated third party without permission, except as described below. SPR may share or transfer personal information as part of a transaction, such as a merger or acquisition, under which a third party acquires or full or partial ownership of SPR. In the ordinary course of business, we will share some personal information with companies, such as service providers, that we hire to perform services or functions on our behalf. Some companies performing services on our behalf may collect personal information for us. In all cases in which we share consumers’ personal information with a third party vendor, we require them to keep personal information confidential, and will only allow them to keep, disclose, or use consumers’ information to provide the services we asked them to provide. We may be required to release consumers’ personal information in response to a court order, subpoena, search warrant, law, or regulation. We may cooperate with law enforcement authorities in investigating and prosecuting users who violate our rules or engage in behavior which is harmful to other users or illegal. In addition, we may keep, disclose, and use consumers’ personal information in order to comply with U.S. FDA and other governmental guidance, directions, regulations, and laws.
De-Identification of Protected Health Information
In certain instances, we collect Protected Heath Information as defined under the Health Insurance Portability and Accountability Act of 1996 (HIPAA). We may de-identify such information, meaning that you would no longer be identified as a single unique individual. Once we have de-identified information, it is no longer personal information and we may treat it like other non-personal information. We may disclose deidentified patient information. Entities to whom we disclose de-identified information are prohibited from re-identifying or attempting to re-identify it. Anyone with whom we contract who receives any de-identified data derived from Protected Health Information is prohibited by law from attempting to re-identify that data.
Categories of Personal Information We Sell
We do not sell personal information of California consumers, including minors.
Rights under California Law
- Right to Access/Know. If you are a California consumer, you have the right to ask us to send you the following information up to two times in a twelve-month period:
- The categories of personal information we have collected about you.
- The categories of sources from which we collected the personal information.
- Our business or commercial purpose for collecting personal information.
- The categories of third parties with whom we share personal information.
- What categories of personal information we disclose about you for business purposes.
- The specific pieces of personal information we have collected about you.
- What personal information is sold or shared and to whom.
- Right to Delete. If you are a California consumer, you have the right to ask us to delete the personal information about you we have collected. We may deny the request if the information is necessary to:
- complete a transaction, including providing a requested or reasonably anticipated good or service, or fulfill a contract between the consumer and SPR;
- detect and protect against security incidents, malicious, deceptive, fraudulent, or illegal activity, or take against those responsible for such activity;
- debug to identify and repair errors impairing intended functionality;
- exercise free speech or another right provided for by law;
- comply with the California Electronic Communications Privacy Act;
- engage in research in the public interest adhering to applicable ethics and privacy laws where the consumer has provided informed consent;
- enable solely internal uses reasonably aligned with the consumer’s expectations based on the consumer’s relationship with SPR;
- comply with a legal obligation; or
- otherwise use the information internally in a lawful manner compatible with the context in which the consumer provided the information.
- Right to Opt-out. If a business sells or shares personal information to third parties, California consumers have the right, at any time, to opt out of the sale or disclosure of their personal information to third parties. SPR does not sell or share personal information to third parties.
- Right to correct inaccurate personal information. If you are a California consumer, you have the right to ask us to correct any personal information about you we have collected.
- Right to limit use and disclosure of sensitive personal information. If you are a California consumer, you have the right to ask us to to limit the use of your sensitive personal information and limit our use of such data to what is necessary to perform our services.
- Right to non-discrimination or retaliation. The CPRA grants California consumers the right not to be discriminated or retaliated against for exercising your privacy rights. If you exercise your privacy rights, we will not discriminate against you.
Submitting a Request or Inquiry
If you are a California resident and you want to submit a request or inquiry to us regarding your California rights, you or your authorized agent can contact us here, send an email to data@sprtherapeutics.com or call us at 866-329-9313. You do not have to create an account with us to submit a request.
Your request will be confirmed within ten days of receipt, and we will do our best to respond within 45 days. If we need more than 45 days, we will notify you that your request is being delayed.
We can only respond to your request if it is verifiable. This means we are obligated to take reasonable steps to verify your identity or your authorized agent’s authority and your right to access the information you request. In the process of verifying your request, we may contact you to ask for additional information that will help us do so, including government-issued IDs containing your name and address, utility bills containing that same information, and/or unique identifiers like usernames. We will only use that additional information in the verification process, and not for any other purpose. Once we have received and verified the requested information from you, we will contact you with our response to your request, including any data, if applicable. If we do not hear from you or are unable to verify your identity for the request, we will contact you to inform you that we cannot process your request because we cannot verify your identity. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
supplemental PRIVACY NOTICE for Nevada residents
Section 603A of the Nevada Revised Statutes permits Nevada residents who are SPR Therapeutics consumers to at any time, submit a request to an operator of a website in Nevada directing the operator not to make any sale of any covered information the operator has collected or will collect about the consumer. SPR Therapeutics does not currently “sell” or plan to sell covered information as defined in the Nevada law. If you are a Nevada resident, you may submit a verified request to data@sprtherapeutics.com or 866-329-9313 to opt out of sales and we will record your instructions and incorporate them in the future if our policy changes. We will respond within the time required by law.
supplemental PRIVACY NOTICE for Washington Residents
The Washington My Health My Data Act provides consumers a number of rights including the right to:
- Confirm whether SPR is collecting, sharing, or selling your consumer health data
- Request a list of all third parties and affiliates with whom SPR has shared or sold your consumer health data
- Withdraw consent from SPR’s collection and sharing of your consumer health data
- Request deletion of consumer health data by contacting us and informing us of your decision
If you are a Washington resident, you may submit a verified request at any time to data@sprtherapeutics.com or 866-329-9313 to request any of the above as it relates to your data, and we will respond as required and within the time required by law.
This Privacy Statement was last modified on April 1, 2024.
