Novela Neurotechnologies, Inc. (“Novela”) a corporation headquartered in the United States (“US”) respects the privacy of the clients, employees, business partners, and individuals, among others, with whom it interacts. Novela treats personal information in accordance with both the laws and regulations of the countries from which the information is collected and in which it does business.
Novela collects Personal Information to operate effectively and efficiently and in delivering its Services. Personal Information includes, among others:
Within Novela’s Neureka™ Platform (NNP), Novela does not collect Personal Health Information (NNP) nor make decisions on when, where or how PHI is collected. Novela’s (NNP) does provide features to properly de-identify images (prior to leaving the sender’s workstation) and enforce de-identification workflows according to protocol requirements.
Novela uses Personal Information to establish and manage its relationship with its clients and to perform any related functions, including providing Services and related communications to you.
For example, Novela may use Personal Information to:
Certain Personal Information will be reported to government and regulatory authorities where required by law and for tax or other purposes. Personal Information may also be released to external parties as required or permitted by employment or other statutes and regulations, or by legal process, as well as to parties to whom individuals expressly authorize Novela to release their Personal Information. Novela will not sell any Personal Information to any third party other than in connection with the sale or transfer of all, or substantially all of Novela’s business or assets, or in connection with a merger, consolidation, or other reorganization.
Novela may be forced to disclose Personal Information when compelled by a lawful request made by a recognized public authority or where required to meet national security and or law enforcement requirements. Novela is subject to the investigatory and enforcement powers of the Federal Trade Commission (“FTC”) and or the Food and Drug Administration (“FDA”).
Personal Information may also be made available to third parties providing relevant services under contract, such as auditors and compliance managers, background verification, legal and IT hosting and maintenance providers, among others). Novela will maintain appropriate security and privacy measures with such third parties including how they hold and maintain any Personal Information that is provided to them.
Novela is committed to ensuring that Personal Information is secure. In order to prevent unauthorized loss, alteration, destruction, access, use or disclosure of Personal Information, Novela maintains adequate physical, administrative and technical safeguards, including the following:
Individuals whose Personal Information has been collected by Novela shall have the right to access that data for review, modification or deletion.
Access to review, modify and or delete your Personal Information or otherwise manage the use and disclosure of your Personal Information (“opt-out”) may be initiated by contacting Novela in writing as follows:
Even after it has processed your request for a change or deletion, Novela may retain certain residual information in the backup and/or archival copies of Novela’s database for audit purposes, for its customers’ protection, and to comply with laws or regulations. For example, Novela will retain certain audit trail information for at least as long as is required for the subject electronic records, and it will be available for agency review and copying.
Within Novela’s (NNP), Novela does not monitor the content of images on the network for Personal Information. If notified by the customer that data retained by Novela contains Personal information, Novela will work with the customer to remove such data from its database and to alter the de-identification workflow as required by the customer to eliminate future occurrences.
In instances in which Novela collects Personal Information directly from individuals, it will provide information about the type, use and purpose of the Personal Information it collects, the identity of third parties to which Novela will disclose the Personal Information, and the choices and means that it offers individuals for limiting the use and disclosure of such Personal Information, upon request.
In instances in which Novela receives Personal Information as a service provider for its clients, such clients are responsible for providing appropriate notice to (and obtaining any necessary consent from) the individuals whose Personal Information is transferred to the US.