Privacy Policy

Date Last Revised: June 10, 2024

Protecting your personal  information is our priority. This Privacy Policy applies to https://laceauditorytraining.com/, and Neurotone AI, Inc. (“Neurotone”) and governs the collection, disclosure and usage of personal information through the website https://laceauditorytraining.com/ (the “Site”)and Neurotone’s platform (the “Platform”).  The Site and Platform may be collectively referred to as the Services. Please read this Policy carefully, because by using the Site and/or Platform, you are acknowledging that you understand and agree to the terms of this Policy, and consent to the types of information and the manner in which we may collect, use and disclose such information. If you do not agree to the terms of this Policy, please do not use the Site or Platform.

In certain situations, we may be considered a Business Associate as defined by HIPAA (the federal Health Insurance Portability and Accountability Act) of certain Covered Entities (as also defined in HIPAA), and as such we may have certain federal, state and contractual restrictions on how we can use your Protected Health Information (“PHI”).  When acting as a Business Associate, we may only use or disclose your PHI or Personal Information as required by law or as permitted by the Business Associate Agreement (“BAA”) that we have in place with a specific Covered Entity. Please be aware that when you give other individuals access to your PHI or Personal Information, they may be able to use, reproduce, distribute, display, transmit, and/or communicate the data to others and the public.  We shall not have any responsibility for access, use, or disclosure of your PHI or Personal Information by people you authorized to have access to your user account.

If you are using the Site or Platform in coordination with a healthcare provider (“Medical Provider”), you are granting access to and use of your PHI and Personal Information to the Medical Providers and their personnel.  You expressly consent to the access, use and disclosures outlined in this paragraph.

Collection of your Personal Information

In order to better provide you with products and services offered, Neurotone may collect personally identifiable information, such as your:

• First and Last Name

• Billing Address

• E-mail Address

• Phone Number

If you purchase Neurotone’s products and services, we may collect information through our payment processor. All payment information is securely stored by our payment processor.

We do not collect any personal information about you unless you voluntarily provide it to us. However, you may be required to provide certain personal information to us when you elect to use certain products or services. These may include: (a) registering for an account; (b} signing up for special offers from selected third parties; (c) sending us an email message; or (d) submitting your credit card or other payment information when ordering and purchasing products and services. To wit, we will use your information for, but not limited to, communicating with you in relation to services and/or products you have requested from us. We also may gather additional personal or non-personal information in the future.

Use of your Personal Information

Neurotone collects and uses your personal information to register, operate and deliver the services you have requested. During registration, a user is required to give certain information (such as name, phone number and email address). This information is used to contact you about the products/services on our Site and/or Platform in which you have expressed interest or subscribed to and allow you to easily update your personal information.

Neurotone may also use your personally information to inform you of other products or services available from Neurotone and its affiliates.

Sharing Information with Third Parties

Neurotone does not sell, rent or lease its customer lists to third parties. Except as provided herein, unless you ask or provide your consent to do so, we will not share your Personal Information with any third party outside of our organization, except as necessary with our service providers and subcontractors in order to troubleshoot issues you may have with our Site, the Platform or your account. Only employees, service providers and subcontractors who need the personal information to perform a specific job are granted access to personal information. If you do not want your information to be shared with our employees, service providers and subcontractors, upon your request, we will not share your information. However, your ability to access and use the Site and the Platform may be limited or interrupted.

Neurotone may share data with trusted partners to help perform statistical analysis, send you email or postal mail, provide customer support, or arrange for deliveries. All such third parties are prohibited from using your personal information except to provide these services to Neurotone, and they are required to maintain the confidentiality of your information.

Please note that with the exception of certain limited information as specified in the Platform, your Medical Providers and clinicians will have access to the information that you input into the Platform. Specifically, your Medical Provider will be able see data related to your use of the Platform. Your personal information and PHI may be included by your Medical Provider as part of your health records and use of such information by your Medical Provider will be governed by your Medical Provider’s privacy and other policies.  

Neurotone may disclose your personal information, without notice, if required to do so by law or in the good faith belief that such action is necessary to: (a) conform to the edicts of the law or comply with legal process served on Neurotone or the site; (b) protect and defend the rights or property of Neurotone; and/or (c) act under exigent circumstances to protect the personal safety of users of Neurotone, or the public.

Third Party Websites

The Site or Platform may contain links to other websites. Any Personal Information you provide on linked pages or sites is provided directly to that third party and is subject to that third party’s privacy policy. This Policy does not apply to such linked sites, and we are not responsible for the content or privacy and security practices and policies of these websites or any other sites that are linked to or from the Site and/or the Platform. We encourage you to learn about their privacy and security practices and policies before providing them with Personal Information.

De-Identified Data

We may use non-identifiable anonymous data that is based on users’ access or use of the Site and/or Platform that may be used by us to improve the Site and/or the Platform. We may also use anonymized data based on your use of the Platform, including de-identified health data and combine such de-identified data with data or other anonymous data (“Aggregate Data”).  Aggregate Data may include information that describes the habits, usage patterns, survey responses and/or demographic information of users as a group,  but does not identify any particular users. We may provide anonymized data and Aggregate Data to our third party collaborators and partners or use such Aggregate Data for future research studies and publications.

Tracking User Behavior

Neurotone may keep track of the websites and pages our users visit within Neurotone, in order to determine what Neurotone services are the most popular. This data is used to deliver customized content and advertising within Neurotone to customers whose behavior indicates that they are interested in a particular subject area.

Automatically Collected Information

Information about your computer hardware and software may be automatically collected by Neurotone. This information can include: your IP address, browser type, domain names, access times and referring website addresses. This information is used for the operation of the service, to maintain quality of the service, and to provide general statistics regarding use of the Neurotone website.

Use of Cookies

The Neurotone website may use “cookies” to help you personalize your online experience. A cookie is a text file that is placed on your hard disk by a web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you.

One of the primary purposes of cookies is to provide a convenience feature to save you time. The purpose of a cookie is to tell the Web server that you have returned to a specific page. For example, if you personalize Neurotone pages, or register with Neurotone site or services, a cookie helps Neurotone to recall your specific information on subsequent visits. This simplifies the process of recording your personal information, such as billing addresses, shipping addresses, and so on. When you return to the same Neurotone website, the information you previously provided can be retrieved, so you can easily use the Neurotone features that you customized.

You have the ability to accept or decline cookies. Most Web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of the Neurotone services or websites you visit.

In some countries, we are not permitted to collected personal information through the use of cookies without your expressed consent. This section assumes that if applicable you have given such consent or reside in a country without such a requirement.

Security of your Personal Information

Neurotone secures your personal information from unauthorized access, use, or disclosure. Neurotone uses the following methods for this purpose:

We strive to take appropriate security measures to protect against unauthorized access to or alteration of your personal information. Unfortunately, no data transmission over the Internet or any wireless network can be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, you acknowledge that: (a) there are security and privacy limitations inherent to the Internet which are beyond our control; and (b) security, integrity, and privacy of any and all information and data exchanged between you and us through this Site cannot be guaranteed.

Right to Deletion

Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will:

• Delete your personal information from our records; and

• Direct any service providers to delete your personal information from their records.

Please note that we may not be able to comply with requests to delete your personal information if it is necessary to:

• Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us;

• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;

• Debug to identify and repair errors that impair existing intended functionality;

• Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;

• Comply with the California Electronic Communications Privacy Act;

• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent;

• Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us;

• Comply with an existing legal obligation; or

• Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.

Children Under Thirteen

Neurotone does not knowingly collect personally identifiable information from children under the age of thirteen. If you are under the age of thirteen, you must ask your parent or guardian for permission to use this website.

E-mail and SMS Communications

From time to time, Neurotone may contact you via email for the purpose of providing announcements, promotional offers, alerts, confirmations, surveys, and/or other general communication. In order to improve our Services, we may receive a notification when you open an email from Neurotone or click on a link therein.

If you would like to stop receiving marketing or promotional communications via email from Neurotone, you may opt out of such communications by clicking on the UNSUBSCRIBE button.

We may send you notifications related to your use of the Services via text or SMS messaging. If you do not wish to receive text messages, please follow the instructions provided to you in the text or SMS message.  You may also make a request using the Contract Information provided below.

Changes to this Statement

Neurotone reserves the right to change this Privacy Policy from time to time. We will alert you that changes have been made by indicating on the Policy the date it was last revised and we will use commercially reasonable endeavors to notify you about significant changes in the way we treat personal information by sending a notice to the primary email address specified in your account, by placing a prominent notice on our website, and/or by updating any privacy information. Your continued use of the website and/or Services available after such modifications will constitute your: (a) acknowledgment of the modified Privacy Policy; and (b) agreement to abide and be bound by that Policy.

California Residents

Pursuant to the California Consumer Privacy Act (“CCPA”), we may collect the following categories of Personal Information:

• Identifiers, such as name and government-issued identifier

• Personal information, as defined in the California safeguards law, such as contact and financial information

• Characteristics of protected classifications under California or federal law, such as age, gender, medical conditions, and marital status  

• Commercial information, such as transaction information and purchase history

• Internet or network activity information, such as browsing history and interactions with our websites

• Geolocation data, such as device location

• Audio, electronic, visual and similar information, such as call and video recordings  

We may collect this Personal Information directly from California residents themselves, medical providers, or caregivers.

We may use this Personal Information for legitimate business purposes to operate, manage, and maintain our business, to provide our products and services, for our employment purposes, and to otherwise accomplish our business purposes and objectives. Our business purposes and objectives include, for example, developing, improving, repairing, and maintaining our products and services;, and marketing our products and services; conducting research, analytics, and data analysis; maintaining our facilities and infrastructure; undertaking quality and safety assurance measures; conducting risk and security controls and monitoring; detecting and preventing fraud; performing identity verification; performing accounting, audit, and other internal functions, such as internal investigations; complying with law, legal process, and internal policies; maintaining records; and exercising and defending legal claims.

We may disclose the following Personal Information to our affiliates and third parties, such as our service providers, for the operation of our legitimate business purposes:

• Identifiers, such as name and government-issued identifier

• Personal information, as defined in the California safeguards law, such as contact and financial information

• Characteristics of protected classifications under California or federal law, such as age, gender, medical conditions, and marital status

• Commercial information, such as transaction information and purchase history

• Internet or network activity information, such as browsing history and interactions with our websites

• Geolocation data, such as device location

• Audio, electronic, visual and similar information, such as call and video recordings  

We have not “sold” Personal Information for purposes of the CCPA. For purposes of this CCPA Notice, “sold” or “sale” means the disclosure of Personal Information for monetary or other valuable consideration but does not include, for example, the transfer of Personal Information as an asset that is part of a merger, bankruptcy, or other disposition of all or any portion of our business.

If you are a California resident, you may request that we:

• Disclose to you the following information covering the 12 months preceding your request:

• The categories of Personal Information we collected about you and the categories of sources from which we collected such Personal Information

• The specific pieces of Personal Information we collected about you

• The business or commercial purpose for collecting Personal Information about you  

• The categories of Personal Information about you that we otherwise shared or disclosed and the categories of third parties with whom we shared or to whom we disclosed such Personal Information

• Delete Personal Information we collected from you

• Correct any inaccurate Personal Information that we have collected

To make a request for the disclosures, deletion, or correction described above, please contact us at using the information provided below.  In some instances, we may decline to honor your request where an exception applies, such as where the disclosure of Personal Information would adversely affect the rights and freedoms of another California resident.

You have the right to be free from unlawful discrimination for exercising your rights under the CCPA