Privacy Policy

Effective date: May 1, 2024

Privacy Notice

Impulse Dynamics (USA) Inc. and its subsidiaries (“Impulse Dynamics”, “we”, “us” or “our) conduct business within the United States, United Kingdom, European Union (“EU”), European Economic Area (“EEA”), and various other countries and regions across the globe. We understand the importance of privacy to our customers, visitors, suppliers, business partners, employees, and other individuals (“you”, the “user”, or “data subject”). We are committed to protecting and respecting your privacy.

Some of the information we collect through this Site or using our Services may be “Personal Data” as defined below. This Impulse Dynamics Privacy Policy (“Policy”) applies only to information collected through the website on which it is posted (“Site”) as well as any other applications (apps), events, newsletters, communications, or services provided by or on behalf of Impulse Dynamics that link or reference this Policy (“Services”). It does not apply to third-party platforms or to other Impulse Dynamics-operated websites or other Impulse Dynamics-operated platforms where it is not linked or referenced. This Policy may be supplemented or amended from time to time by additional privacy notices (“Privacy Notices”), provided at the time we collect your information. For example, certain pages of this Site may contain Privacy Notices providing more details about the information we collect on those pages, why we need that information, and choices you may have about the ways we use that information. In other cases, specific Privacy Notices may be required to comply with the privacy laws of one of the countries, provinces, or states in which we do business.

Among other things, this Policy describes:

• What information we collect about you
• How and on what basis we use the information we collect
• How we collect your Personal Data
• How long we keep your Personal Data
• How we share the information we collect
• How we protect your information
• How you can access and control your information
• How you can contact us

If you have a disability, you may request access to this Policy in an alternative format by contacting privacy@impulsedynamics.com .

What is Personal Data?

Personal Data means any information relating to an identified or identifiable natural person (“Data Subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Your acknowledgment of this Policy

By using this Site, including your choices regarding cookie settings, or using the Services, you are acknowledging and agreeing to the collection, use, disclosure, and transfer of your information as described in this Policy (and any additional Privacy Notices that apply to you). If you do not agree to the collection, use, disclosure and transfer of your information as described in this Policy (and any Privacy Notices that apply to you), you may not use this Site or the Services. If you have questions about this Policy, or any Privacy Notice, please contact us using the information provided below.

Where any of your Personal Data is processed based on your consent, you may revoke your consent to the collection, use, disclosure, and transfer of your information as described in this Policy (and any Privacy Notices that apply to you) by contacting us directly.

Complete agreement for use of the Site

This Policy is part of the Terms of Use that govern your use of this Site. A link to our Terms of Use is provided at the bottom of each page of this Site.

Except as written in any other disclaimers, policies, or other notices on this Site, this Policy and the Terms of Use are the complete agreement between you and Impulse Dynamics with respect to your use of this Site. Any terms we use in this Policy without defining them have the definitions given to them in the Terms of Use. There may be additional terms that apply to particular materials on or sections of this Site.

Changes to this Policy

Impulse Dynamics reserves the right to update or modify this Policy and any Privacy Notice, at any time and without prior notice, by posting the revised version of the Policy or Privacy Notice on this Site. These changes will only apply to the information we collect after we have posted the revised Policy or Privacy Notice on this Site.

Your use of this Site or the Services following any such change constitutes your agreement that all information collected from or about you after the revised Policy is posted will be subject to the terms of the revised Policy. You may access the current version of this Policy at any time by clicking on the link marked “Privacy” at the bottom of each page of the public areas of this Site.

How do we collect your Personal Data?

How we collect Personal Data will depend upon the nature of your dealings with us. We collect and use non-Personal Data differently from Personal Data.  Whenever it is reasonable and practical to do so, we will collect your Personal Data directly from you. We may also collect Personal Data from third parties, including in the course of providing products to you such as from our distributors, sales agents, your healthcare practitioners, your caregiver/family member, guardian, publicly available information and databases supplied by third parties.

If you are one of our suppliers, distributors, sales agents, or a healthcare professional that uses our products, your Personal Data may be collected from you, your employer, other employees, or third parties. Similarly, if you are a prospective employee, we may collect information through third parties such as recruiters.

If you choose not to provide some Personal Data to us, this may affect our ability to provide products or services to you.

Information We Collect

Generally, Personal Data we collect may include but is not limited to:

• Name and contact details
• Details of your company, industry, role, and accreditations
• Information from your visits to our websites, including the IP address, type of browser, device (including unique device identifiers) and operating system you use, network information, access times, pages viewed, links clicked on, cookie information
• Details of products you have inquired about or that we have supplied to you, including any additional information necessary to deliver those products and to respond to your inquiries
• Credit information, payment, credit card and debit card or bank account information for product deposits, purchases or refunds
• Information that you provide to us directly through one of our websites, apps or that you email to use; and
• Information you provide in customer surveys, interviews, or case studies.

It is important that the Personal Data we hold about you is accurate and current. Please let us know if your Personal Data changes.

Product User Data

If you are a someone who uses our products including clinical trial participants: we may collect additional specific information about your use of our products and you, such as your gender, date of birth, your medical history and conditions, treatment, device information, family and social history, medical inquiries you or your physician make, and adverse events you report. We may receive some of this information from third parties, such as our distributors, sales agents, or your health care professional. Some of this information may be, but is not always, anonymized, or de-identified. If you are a clinical trial participant, your information will be used in accordance with the informed consent and applicable law.

Suppliers, Customers or Other External Stakeholder Data

If you are a supplier, customer, distributor, sale agent, or a healthcare professional that implants our products: we may collect additional specific information including information about your professional details, practice specialty and areas of interest, membership of professional associations, product usage and your dealings with us.

If you are an employee, contractor, or applicant: we may collect additional specific information including your gender, date of birth, contact details, information collected in our employment records, including tax file number, job application, reference checks, curriculum vitae/resume, records of training, documentation of performance appraisals and disciplinary matters, employment terms, and medical condition or history. We may receive some of this information from third parties such as recruiters or from reference checks.

Personal Data You Manually Provide through this Site

Impulse Dynamics collects the information you manually provide (e.g., using your keyboard, mouse, or touchscreen) when you use this Site. For example, we collect the information you provide if you choose to complete a pre-screening questionnaire entitled, “Am I a Candidate?” or similar questionnaire, contact us with questions, or otherwise interact with this Site.  Some of the information you may choose to manually provide will be Personal Data including but not limited to:

• Contact data: such as name, title, address, phone number, mailing address, and email.
• Other identifiers: such as device ID or serial number, various types of personal health information (e.g., health insurance information, medical information, and the like), online identifiers, and other similar identifiers.
• Communication data submitted by you: such as questions and feedback.
• Demographic data: such as language, age, and gender.
• Marketing preferences: such as e-mail subscription and frequency preferences.

Information Automatically Collected through this Site

Impulse Dynamics collects information through this Site that is sent to us automatically by your web browser or mobile device. This information may include but is not limited to:

• Product use and application data (including date and time of your visit)
• IP address
• The browser you are using (including name and version)
• Your location and other geographic data
• The website you came from and the website you visit after leaving
• Pages viewed on the Site
• Links clicked on the Site
• Time spent on a particular page of the Site or the Site as a whole
• Site data used to facilitate the use of the Site such as login and technical data

The information we receive may depend on your browser or device settings as well as your cookie settings. The information we receive from your web browser and device typically is not, in and of itself, personally identifiable. However, we may combine it with other information that either does, or may, identify you.

Information Collected by Cookies and Other Technologies through this Site

We use “cookies” and other technologies to collect information and support certain features of this Site. For example, we may use these technologies to:

• Collect information about the ways visitors use this Site—which pages they visit, which links they use, and how long they stay on each page
• Support the features and functionality of this Site—for example, to save you the trouble of reentering information already in our database or to prompt the settings you established on previous visits
• Personalize your experience when you use this Site; and
• Improve our marketing efforts, including through use of targeted advertising.

The information we collect using cookies and similar technologies is not, in and of itself, personally identifiable, but we may link it to Personal Data that you provide. If you do not wish to receive cookies, you may choose to reject cookies in your cookie settings when you visit our Site. You may also set your browser to reject cookies or to alert you when a cookie is placed on your computer. Although you are not required to accept cookies when you visit this Site, you may be unable to use all of the functionality of this Site if you or your browser rejects cookies.

Information Collected by Third-Party Cookies through this Site

In addition to the cookies Impulse Dynamics delivers to your computer or mobile device through this Site, certain third parties (Tracking and Performance Cookies) may deliver cookies to you for a variety of reasons. For example, we may use a web analytics tool that helps us understand how visitors engage with our Sites.

Other third parties may deliver cookies to your computer or mobile device for the purpose of tracking your online behaviors over time and across nonaffiliated websites and/or delivering targeted advertisements either on this Site or on other websites.

You have choices about the collection of information by third parties on our Sites. You may use the cookie pop-up banner on the Site to decline non-essential cookies. Additionally, you may download an Opt-out Browser Add-on to opt-out of Google Analytics by clicking here. Similarly, to opt-out of cookies used for interest-based advertising by similar services globally, click here or here.

You will be directed to an industry-developed website that contains mechanisms for choosing whether each listed entity may collect and use data for online behavioral advertising purposes. It may be that some of the third parties that collect interest-based information on this Site do not participate in the industry-developed opt-out website, in which case the best way to avoid third-party tracking of your online behaviors may be through your browser settings and deletion of cookies. Please note that the industry-developed opt-out mechanisms are device and browser specific. If you wish to opt-out from having interest-based information collected by participating entities across all devices and browsers, you need take the steps outlined above from each device and browser.

Our Legal Basis for Processing Personal Data

We may process the Personal Data we collect/receive under the following legal bases.

• Legitimate interest. We can process your Personal Data if (i) we have a genuine and legitimate reason; and (ii) are not harming any of your rights and interests. We will use your Personal Data in order to help us provide you with our services and to give you the most appropriate information, products and services and to provide you with the best experience when dealing with us. Whenever we process your Personal Data for our legitimate interests, we will consider and balance any potential impact on you and your rights under data protection law.
• In some cases, we will only process your information where you have given your consent. For example, if you sign up for email communications, provide your phone number for phone communication, or where you may be providing special categories of Personal Data such as your health information. Please note that we may have a different legal basis for processing (e.g., legitimate interest) in some cases so that consent is not needed. When our use and sharing is not readily apparent when you provide your information, we will provide additional information at the time we collect the information regarding our purposes and use of the information. We will obtain your consent before we process health information about you.
• To fulfill our obligations to you under a contract. If you purchase a product from us, we may process your Personal Data in order to fulfill our contract with you.
• As required by law. Where we are required to comply with our legal obligations, or to establish and defend our legal rights, or to prevent and detect crimes such as fraud.

How We Use Your Information

Collected through this Site

We may use the information we collect through this Site for various purposes, including but not limited to:

• To provide you with access to this Site.
• To respond to your requests.
• To personalize your access to our Site.
• To develop records (including records of your Personal Data).
• To contact you with pertinent information about products, clinical trials, or important safety information, and about products and services of ours and of others.
• For analytical purposes and to research, develop, and improve programs, products, services, and content.
• To remove your personal identifiers. Once we have de-identified information, it may be considered non-Personal Data and if so, we may treat it like other non-Personal Data.
• To enforce this Policy and other rules about your use of this Site.
• To protect someone’s health, safety, or welfare.
• To protect our rights or property.
• To comply with a law or regulation, court order or other legal process, such as preventing, detecting, and investigating security incidents and potentially illegal or prohibited activities.

Collected through our Services

Generally, the purpose for which we collect Personal Data will be apparent from the way in which we collect it or will be disclosed before or at the time of collection. We may use your information, including Personal Data to:

• Provide you and your healthcare professionals with product support.
• Respond to and fulfill queries and requests you, your healthcare professional and our distributors, sales agents and suppliers may make.
• Administer, improve, and promote our products.
• Analyze the performance of our products.
• Improve our services and services of our third-party suppliers, distributors and sales agents.
• Monitor the safety of our products and record, analyze and respond to and act on medical queries, complaints, and safety reports and to report as required to regulatory bodies and other relevant companies which market and sell our products.
• Notify you of matters concerning the safety of our products which we consider you should be notified of or to notify you as may be required by law or regulation.
• Generate and maintain customer lists for the purposes of our own market research and to enable us or our distributors or sales agents to undertake marketing to you and others.
• Perform clinical trials and other research organized by us which you have agreed to be involved in.
• Administer patient support, health awareness/management programs or other similar programs organized by us.
• Organize and administer conferences, symposia, seminars or other events and meetings.
• Generate and maintain our investor information to comply with legal requirements and to enable reporting to investors.
• Provide you with information such as our press releases.
• To maintain our register of shareholders and investor communication lists and to make offers and communicate with our shareholders and investors.
• Comply with applicable laws, regulations, guidance, codes of conduct, product approvals, license requirements and ethical requirements including to comply with demands or requests made by regulators, governments, courts and law enforcement authorities.

How We Share Your Information

Our headquarters are in the United States, and we have offices and distributors, and use service providers, in other jurisdictions. As part of a global group of companies located in different countries, we may disclose your information to other companies in our corporate group, or to databases or servers overseas which may be provided to us by our third-party service providers. As a result, your Personal Data is sometimes shared with others and transferred and processed outside of your home country. We may share your Personal Data with:

• Companies within our group.
• Third parties who we have a business relationship with, including distributors, agents, suppliers, healthcare professionals and advisors. This would also include companies that provide technology services to us, our professional advisors, and auditors.
• Governments, regulators, courts, and law enforcement authorities.
• Other third parties in connection with any reorganization or sale of all or any part of our business.

We will not sell, share, or otherwise distribute Personal Data about you to any person, except as provided in this Policy and in accordance with applicable law and regulation. The circumstances in which we may disclose that information include where:

• We may share your information with selected third-party service providers in connection with our business operations, for example, email or cloud service providers.
• We expressly tell you at the time you supply the information, or it is expressly permitted under any agreement with you.
• The information is aggregated and/or no longer personally identifiable.
• It is necessary to provide you with the products which you have requested.
• It is requested by third parties for use in the ordinary operation of our business. We will only disclose your Personal Data to reputable third parties and only on a confidential basis.
• Disclosure is in response to demands or requests made by regulators, governments, courts, and law enforcement authorities.
• Permitted or required by law, regulation, or applicable guidance.

How We Protect your Information

Impulse Dynamics takes reasonable precautions to provide a level of security appropriate to the sensitivity of the information we collect. Although we seek to use reasonable measures to help protect your information against unauthorized use or disclosure, we cannot guarantee the security of information provided over the Internet or stored electronically, whether by us or a third party.

Transfer and Storage of your Personal Data

We may store, collect, transfer, and process your Personal Data in a country other than your country of residence. These countries include the United States, the United Kingdom, or countries in the European Union. The data protection and other laws of countries to which your information may be transferred may be different in your country.

For Residents of Europe and the United Kingdom

The European Commission and the UK Information Commissioner’s Office (ICO), have the power to determine, based on the General Data Protection Regulation (“GDPR”) or UK GDPR respectively, whether a country offers an adequate level of data protection by making an ‘adequacy decision’. Neither the European Commission nor the UK ICO have adopted a currently active adequacy decision regarding the United States. Instead, with respect to any transfers of information to the United States, we rely on other legal bases to lawfully transfer Personal Data. We will implement appropriate measures to protect and secure your Personal Data when it is transferred outside of your home country, in accordance with applicable data protection and privacy laws, including in the case of EU residents, with your consent or through the use of approved model standard contractual clauses along with supplementary measures, where determined necessary. The European Commission has determined that the transfer of Personal Data pursuant to the Standard Contractual Clauses along with supplementary measures provides for an adequate level of protection of your Personal Data. Similarly, the UK has adopted International Data Transfer Agreements. Under these standardized agreements, you have similar rights as if your Personal Data was not transferred.

You may request more information about our data transfer methods by contacting us through the methods below.

Retention of Your Information

We will always keep Personal Data for the period required to comply with applicable laws, regulations, guidance, codes of conduct, product approvals, license requirements, ethical and safety requirements. We may also maintain your information as required to comply with any contract of which we are a party. Otherwise, we keep your Personal Data:

• For as long as needed to provide you with access to product and longer to assist us in best addressing any safety matters that may arise with respect to our products.
• Where you have contacted us with a question or request, for as long as necessary to allow us to respond to your question or request.

Children’s Privacy

This Website is not targeted to children under the age of 18 and we do not knowingly collect or solicit Personal Data about such children. If we discover that a child has provided us with Personal Data online through this Website, we will delete this information as quickly as possible. If you believe we may have received Personal Data from a child under the age of 18, please contact us immediately.

Your Rights

Marketing Email Opt-Out

You may revoke your consent for the receipt of marketing communications that we send to you at any time by using the “unsubscribe” functionality included in our emails to you or by contacting us directly. You should note that this will not affect all communications from us, such as notices we are legally obligated to provide or if we are responding to an email, you send us.

Data Subject Rights

Your rights will vary depending on which laws apply. You may make a request to exercise any rights that you may have, and we will comply with any laws that apply. You may have the following rights:

• Know. You may have the right to know about and confirm the existence of Personal Data about you, how we use or share it, what categories of Personal Data we process, our purposes of processing, and categories of parties we disclosed Personal Data to.
• Access and portability. You may have the right to access your Personal Data, specific pieces of information, and know of third parties Personal Data was disclosed. You may have a right to obtain a copy of your data, including in a machine-readable format.
• Correction. You may have the right to correct or amend your data if it is incomplete, inaccurate, or outdated.
• Deletion or elimination. You may have the right to request your Personal Data be deleted or eliminated. Subject to applicable law, we may deidentify this data in certain circumstances.
• Restriction. You may have a right to restrict processing of your data in some circumstances, such as if processing is excessive or unlawful, the accuracy of the data is contested, the controller no longer needs the data for its primary processing purposes but is needed for legal or compliance purposes, or if (in California) the data is sensitive Personal Data like health information and it is being used for purposes beyond those reasonably necessary to perform services or provide goods requested.
• Objection and opt–out. You may have the right to object to or opt-out of processing of Personal Data about you in certain circumstances. This can include cases where that data is used for direct marketing (including email or telephonic marketing), shared with third parties for their own marketing or for retargeting or cross-contextual marketing, sold to third parties, used to make certain automated or artificially-generated decisions or profiles about you, used for historical or scientific research, or used to contact you with automated/prerecorded voice telephonic messages in some cases.
• Consent and cancelation of consent. You may have the right to consent, and to withhold or cancel that consent, for some practices, including processing of sensitive Personal Data or data on children, or where we use consent as our lawful basis for processing or transfer. If you cancel your consent, we will not further collect or process the Personal Data on the basis of that consent unless allowed or required by applicable law.
• Non–discrimination. We will not discriminate against you for exercising your rights. This does not necessarily include, where permitted by applicable law in your jurisdiction, cases where a difference in price or services offered is reasonably related to the value provided by Personal Data you provide, or where you consent to participate in a voluntary program offering incentives (such as a loyalty program).
• Appeal. You may have the right to appeal decisions we make about the exercise of your rights. To submit an appeal to a decision we made about the exercise of your rights, you may send an email to privacy@impulsedynamics.com. Please enclose a copy, or otherwise specifically reference our decision on your data subject request, to allow us to address your appeal. We will strive to comply with applicable law when we respond to your appeal.
• Make a complaint. You may have the right to complain to regulators, such as your state attorney general, local data protection agency or authority, or other public bodies responsible for data protection and privacy enforcement. If you are not satisfied with our response to your request or if you have concerns about our data practices.

Submitting a Request or Inquiry

• If you want to submit a request or inquiry to us regarding privacy rights you may have, you or your Authorized Agent can contact us using our contact information below. 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 respond within 45 days, unless shorter periods are required by law. 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 will respond to reasonable requests in accordance with applicable law and subject to legal and contractual restrictions. We will not discriminate against you for exercising these rights.
• There may be times where we cannot comply with your request. For example, if such disclosure would interfere with the privacy of others or if it would result in a breach of confidentiality. We will provide an explanation for our refusal to grant access.
• California residents, please also see the respective Privacy Addendum for further details.

Data Subject Rights Contact

Impulse Dynamics

privacy@impulsedynamics.com

Data protection office (For residents of Europe or United Kingdom)

privacy@impulsedynamics.com

Links to Other Websites

This Policy applies only to the Impulse Dynamics-operated websites on which it is posted. Impulse Dynamics and its affiliates may operate different websites for different purposes and in different countries, where different laws may apply. If you visit another Impulse Dynamics website, please take a moment to review the privacy policy posted on that site to learn what information may be collected through that site and how it is processed. This Site may also contain links to websites that are not operated by or on behalf of Impulse Dynamics or its affiliates. These links are provided for your reference and convenience only and do not imply any endorsement of the products sold or information provided through these websites, nor any association with their operators. Impulse Dynamics does not control these websites and is not responsible for their data practices. Any information you provide to third parties on their websites is covered under their privacy and data collection policies and is not covered by this Policy. We recommend you review the privacy policy posted on any site you visit before using the site or providing any Personal Data

Contact Us

If you have any questions regarding this policy or about our privacy practices or need to contact us for purposes related to this Policy, please contact us.

Email:              privacy@impulsedynamics.com

Mail:  
             
Impulse Dynamics
50 Lake Center Executive Park
401 Route 73 N, Bldg. 50, Ste 100
Marlton, NJ 08053

Further Information on Privacy

You may also contact your local supervisory authority or regulator for more information about your privacy rights.

State Privacy Notice Addendums

Addendum: California Residents Privacy Notice

Effective May 1, 2024

If you are a California resident, you have the rights set forth in this section. Please see the “Exercising Your Rights” section below for instructions regarding how to exercise these rights.

The California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), defines “Personal Information” as information that identifies, relates to, or could reasonably be linked with you or your household.

Please note that we may process Personal Information of our customers’ end users or employees in connection with our provision of certain services to our customers. If we are processing your Personal Information as a service provider, you should contact the entity that collected your Personal Information in the first instance to address your rights with respect to such data.

If there are any conflicts between this section and any other provision of this Privacy Policy and if you are a California resident, the portion that is more protective of Personal Information shall control to the extent of such conflict. If you have any questions about this section or whether any of the following rights apply to you, please contact us via the contact information provided below.

Categories of Personal Information We Collect and Share

We may have collected the following categories of personal information from consumers through our websites, apps, services, devices, or other services 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
  • Telephone number
  • Account name
  • Social security number
  • Driver’s license number, or
  • Other similar identifiers
• Characteristics of protected classifications under California/federal law (e.g., age, race, sex, medical condition, etc.)
• Medical information

• Health insurance information
• Financial information, including credit card 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)
• 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

“Personal information” under these state laws does not include information that is

• publicly available from government records,
• de-identified or aggregated consumer information,
• health or medical information covered by 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.

Categories of Sources of Personal Information

We obtain the categories of personal information listed above from the following categories of sources:

• Directly from consumers’ interactions with us, including with our devices, applications, websites, services, and representatives
• Publicly available sources
• Customers, including health care providers and insurance providers
• Organizations with whom we partner to provide services to consumers

Use or Disclosure of Personal Information

In the past 12 months, we have used or disclosed the personal information we collect for our operational purposes and for one or more of the following business purposes:

• To provide products and services to consumers
• To respond to consumer requests
• To improve and personalize consumer access to and experience on our website, for example, by telling consumers about new features, products, or services that may be of interest to them
• To develop records, including records of consumers’ personal information
• To contact consumers with information that might be of interest to them, 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 activities to monitor and maintain the quality or safety of our products and services
• For activities described to consumers when collecting their personal information or as otherwise permitted under applicable state privacy laws
• For U.S. healthcare providers, to link name, National Provider Identifier (NPI), state license number, and/or IP address to web pages they visit, for compliance, marketing, and sales activities
• 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, apps, and services function as intended, including debugging and repairing
• To comply with a law or regulation, court order or other legal process

The examples provided above come from the CCPA and other statutes, as noted. They are reproduced here for your convenience to help you understand the types of information that are considered within each category. It is not meant to imply that we collect all such information listed in the examples. We only collect the specific pieces of Personal Information described in our Privacy Policy.

Sensitive Personal Information We Collect and Our Purposes for Collection and Use

The CPRA’s definition of “sensitive personal information” includes the following types of information:

• Social security number, driver’s license number, state identification card number, or passport number
• A consumer’s account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account
• Biometric information processed for the purpose of identifying a consumer
• Health and medical information

Right to Limit the Use of Sensitive Personal Information

California residents have the right to limit the use of sensitive personal information in some circumstances. Impulse only collects sensitive personal information, as defined by applicable California law, with your consent and only uses the sensitive personal information for the use disclosed at the time of collection. Impulse does not use sensitive personal information for inferring characteristics about you. Impulse will only use your sensitive personal information to provide you with the services you requested. Impulse does not share your sensitive personal information with third parties.

You can find a list of the categories and specific types of sensitive personal information that we may collect above. We only collect and use sensitive personal information to provide you with products and services.

Use of Personal Information

We may use or disclose the Personal Information we collect for business or commercial purposes as described in the Privacy Policy.

Sharing your Personal Information

We disclose your Personal Information for a business purpose to the following categories of third parties:

• Third-party vendors and service providers as described in our Privacy Policy
• All other third parties described in our Privacy Policy

We may share your Personal Information. You have the right to opt-out of sharing or selling of your Personal Information.

Your Rights

By law if you are a resident of California, you have the following rights:

• The right to notice. You must be properly notified which categories of Personal Information are being collected and the purposes for which the Personal Information is being used.
• The right to access / the right to request. You have the right to request certain information about our collection and use of your Personal Information over the past 12 months. In response, we will provide you with the following information:
  • The categories of Personal Information that we have collected about you
  • The categories of sources from which that Personal Information was collected
  • The business or commercial purpose for collecting or selling your Personal Information
  • The categories of third parties with whom we have shared your Personal Information
  • The specific pieces of Personal Information that we have collected about you

If we have disclosed your Personal Information to any third parties for a business purpose over the past twelve (12) months, we will identify the categories of Personal Information shared with each category of third-party recipient. If we have sold your Personal Information over the past twelve (12) months, we will identify the categories of Personal Information sold to each category of third-party recipient.

• We may share or sell your Personal Information (as the term “sale” is defined in the CCPA). You have the right to opt-out of sale of your Personal Information as described below.
• The right to know about your Personal Information. You have the right to request and obtain from us information regarding the disclosure of the following:
  • The categories of Personal Information collected
  • The sources from which the Personal Information was collected
  • The business or commercial purpose for collecting or selling the Personal Information
  • Categories of third parties with whom we share Personal Information
  • The specific pieces of Personal Information we collected about you
• The right to delete Personal Information. You have the right to request that we delete the Personal Information that we have collected about you. Under the CCPA, this right is subject to certain exceptions. For example, we may need to retain your Personal Information to provide you with access to the Site or complete a transaction or other action you have requested. If your deletion request is subject to one of these exceptions, we may deny your deletion request.
• The right not to be discriminated against. We will not discriminate against you for exercising your rights under the CCPA. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under the CCPA. However, we may offer different tiers of our Site as allowed by applicable data privacy laws (including the CCPA) with varying prices, rates or levels of quality of the goods or services you receive related to the value of Personal Information that we receive from you.

Exercising Your Rights

To exercise the rights described above, you or your Authorized Agent (defined below) may make a request that (1) provides sufficient information to allow us to verify that you are the person about whom we have collected Personal Information, and (2) describes your request in sufficient detail to allow us to understand, evaluate and respond to it. Each request that meets both of these criteria will be considered a valid request (“Valid Request”). We may not respond to requests that do not meet these criteria. We will only use Personal Information provided in a Valid Request to verify your identity and complete your request. You do not need an account to submit a Valid Request.

You may submit a Valid Request by email to privacy@impulsedynamics.com  or toll-free telephone call 856-642-9933.

We will work to respond to your Valid Request within 45 days of receipt. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive, or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request.

You may also authorize an agent (“Authorized Agent”) to exercise your rights on your behalf. To do this, you must provide your Authorized Agent with written permission to exercise your rights on your behalf, and we may request a copy of this.

Do Not Sell or Share My Personal Information

We may sell or share Personal Information when the Service Providers we partner with (for example, our advertising partners) use technology on the Site in a way deemed a “sale” of Personal Information as defined by the California Consumer Privacy Act (CCPA). “Sale” and “sharing” includes only disclosures that are defined as a “sale” or “sharing” by the CCPA.

If you wish to opt out of the use of your Personal Information for interest-based advertising purposes and these potential sales as defined under the CCPA, you may do so by following the instructions below.

Website

You can opt out of the sale or sharing of your Personal Information by following our instructions presented on the Site at our “Do Not Sell/Share My Personal Information” link. If you submit a request through this link, you will be opted out of any sale or sharing of Personal Information.

If you want to stop the use of third-party Cookies for interest-based advertising, you may also follow the instructions in the “Cookies” section of our Privacy Policy. Please note that this opt-out is specific to the browser you use. You may need to opt out on every browser that you use and anytime you clear your browser’s cache.

Mobile Devices

Your mobile device may give you the ability to opt out of the use of information about the apps you use in order to serve you ads that are targeted to your interests:

• “Opt Out of Interest-Based Ads” or “Opt Out of Ads Personalization” on Android devices
• “Limit Ad Tracking” on iOS devices

You can also stop the collection of location information from your mobile device by changing the preferences on your mobile device.

Global Privacy Control (“GPC”)

You may also opt out of the sale or sharing of your Personal Information by GPC signals. When you visit our Site with a GPC signal active, you will be informing us through the GPC signal that you opt out of the sale or sharing of your Personal Information. You will need to activate your GPC signal for each supported browser or browser extension you use.

“Do Not Track” Policy as Required by California Online Privacy Protection Act (CalOPPA)

Our Service does not respond to Do Not Track (“DNT”) signals. However, some third-party websites do keep track of your browsing activities. If you are visiting such websites, you can set your preferences in your web browser to inform websites that you do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of your web browser.

California’s Shine the Light law

Under California Civil Code Section 1798 (California’s Shine the Light law), California residents with an established business relationship with us can request information once a year about sharing their Personal Data with third parties for the third parties’ direct marketing purposes.

If you’d like to request more information under the California Shine the Light law, and if you are a California resident, you can contact us using the contact information provided in this Policy.

California Privacy Rights for Minor Users (California Business and Professions Code Section 22581)

California Business and Professions Code section 22581 allow California residents under the age of 18 who are registered users of online sites, services or applications to request and obtain removal of content or information they have publicly posted.

To request removal of such data, and if you are a California resident, you can contact us using the contact information provided in this Policy and include the email address associated with your account.

Be aware that your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.

Addendum: Washington State Residents Rights Under the

My Health My Data Act (“MHMDA”)

Effective June 30, 2024

Categories of Consumer Health Information We Collect and Share

If you are a Washington resident, this addendum applies to you and you have the rights set forth in this section. Please see the “Exercising Your Rights” section below for instructions regarding how to exercise these rights.

“Consumer Health Data” is used in this addendum as it is defined in the Washington My Health My Data Act (MHMDA). It generally includes any information that is linked or reasonably linkable to a Washington resident and that identifies that individual’s past, present, or future physical or mental health status. Excluded from Consumer Health Data are certain types of health information, such as when we must collect, use and disclose health information to meet our regulatory obligations or as part of a clinical trial. We do not collect, share, or sell Consumer Health Data unless we have your consent.

Impulse Dynamics may Collect the following categories of Washington Consumer Health Data about Washington Consumers:

• Individual health condition, treatment, disease, or diagnosis information;
• Health-related surgery or procedure information;
• Use or purchase of prescribed medication information;
• Diagnosis or diagnostic testing, treatment, or medication information;
• Genetic data
• Precise Location Information that could reasonably indicate a Washington Consumer’s attempt to acquire or receive health services or supplies; and
• Data that identifies a Washington Consumer seeking Health Care Services

Impulse Dynamics may Collect Washington Consumer Health Data, described above, online and offline in a few different ways:

• Washington Consumer Health Data that you provide. We may Collect Washington Consumer Health Data that you provide when you use our Services, participate in a promotion or reward program, attend Impulse Dynamics programs or events, participate in a clinical trial, engage with customer service on phone calls and any other way that you may be able to interact with us. With your permission, we may also Collect Washington Consumer Health Data from another source provided by you like your connected device or profile.
• Washington Consumer Health Data from third-party sources. We may Collect Washington Consumer Health Data from third-party sources including, but not limited to, third-party service providers, or business partners. In addition, we also may Collect Washington Consumer Health Data from industry and patient groups and associations you participate in and provide permission for disclosing to us Washington Consumer Health Data or combine information we have collected from multiple sources. We may engage third-party service providers to provide certain interactive features on our Services. Your use of these interactive features is voluntary, and we may retain the Washington Consumer Health Data that you submit through these features. For example, we may offer an interactive survey or chat feature when you use our Services to assist you with identifying information about Impulse Dynamics products and services related to certain health conditions or for other customer service purposes. By using these features, you understand that our vendors may process the information obtained through the feature to provide the Services on our behalf.
• Washington Consumer Health Data collected from devices you use to connect with us or use our Services. Impulse Dynamics Collects Washington Consumer Health Data through our websites and apps and automatically from devices you use to connect to our Services. For more information about this, please see our “Cookies and Other Technologies” section in Impulse Dynamics’s Privacy Policy.
• Washington Consumer Health Data collected with business partners. We sometimes work with other organizations to provide you with our Services.
• Drawn from the other information we Collect. Depending on your use of the Services, we may make inferences related to Washington Consumer Health Data.

Impulse Dynamics may Collect, and use the Washington Consumer Health Data described above to the extent necessary to provide the Services or an Impulse Dynamics product, requested by a Washington Consumer or with the Washington Consumer’s Consent, including to:

• Provide the Services, including as requested by Washington Consumers, such as providing educational information;
• Monitor visits to, and maintain, our Services, websites and apps ;
• Fulfill your requests, orders, or transactions related to the Services, including customer support;
• Support your use of Impulse Dynamics products and services;
• Manage and send transactional communications;
• Manage and send marketing communications and to develop marketing strategies for the Services (including cross-context behavioral and targeted advertising purposes);
• Use for scientific research purposes;
• Oversee the business development of the Services and research insights to understand how people use the Services; and
• Prevent, detect, protect against, and respond to security incidents, identity theft, fraud, harassment, malicious or deceptive activities, or any activity that is illegal under Washington state or federal law; comply with law; and preserve the integrity and security of our systems; and investigate, report, or prosecute those responsible for any illegal action under Washington state or federal law.

We may also Collect and use Washington Consumer Health Data for our internal business purposes, such as data analysis, audits, developing new products, enhancing our Services, identifying usage trends and determining the effectiveness of our promotional campaigns. We may also use inferences drawn from Washington Consumer Health Data to create a profile reflecting your preferences.

Where we require the Washington Consumer’s Consent for Collection for a specified purpose, a description of those purposes is provided to you at the time of Collection.

The categories of Third Parties (which does not include our Processors) with which Impulse Dynamics may Share Washington Consumer Health Data are: suppliers of services that support the Services, business partners, , e-commerce support vendors,  government agencies and law enforcement, analytics and research providers.

Impulse Dynamics may share the following categories of Washington Consumer Health Data: individual health condition, treatment, disease, or diagnosis information; health-related surgery or procedure information; use or purchase of prescribed medication information; symptoms, or measurement of physical status information; diagnosis or diagnostic testing, treatment, or medication information; Precise Location Information that could reasonably indicate a Washington Consumer’s attempt to acquire or receive health services or supplies data that Identifies a Washington Consumer seeking Health Care Services; information Processed to Associate or Identify a Washington Consumer with the data listed herein that is derived or extrapolated from non-health information, such as proxy, derivative, inferred, or emergent data by any means, including algorithms or machine learning.

Impulse Dynamics may also disclose or transfer Washington Consumer Health Data to:

• Our Processors to provide goods and services in a manner consistent with the purpose for which the Washington Consumer Health Data was Collected and disclosed;
• Parties with whom the Washington Consumer has a direct relationship for the purpose of providing a product or service requested by the Washington Consumer, in circumstances where we maintain control and ownership of the data and the party only uses the Consumer Health Data at our direction for the purpose for which the Washington Consumer Health Data was Collected or Consented to; or
• External parties as an asset that is part of a merger, acquisition, bankruptcy, or other transaction in which the party may assume control of all or part of our assets

Exercising Your Rights Under MHMDA

As a resident of Washington, you have the right to:

• Confirm whether Impulse Dynamics is collecting, sharing, or selling Consumer Health Data concerning you and to access such data, including:
  • A list of all third parties and affiliates with whom Impulse has shared or sold the Consumer Health Data
  • Access an active email address or other online mechanism that you may use to contact these third parties
• Withdraw consent from Impulse Dynamics to collect and share your consumer health data
• Request to have Consumer Health Data concerning you deleted and exercise that right by informing Impulse of your request for deletion
• Appeal if Impulse Dynamics does not address an attempt to exercise one or more of these rights to your satisfaction

You may request that Impulse take the actions outlined above in paragraphs to exercise your rights under MHMDA by submitting a request, at any time, to Impulse. Impulse must respond within forty-five (45) days unless an extension is requested (for up to 45 additional days).