Reia Privacy Policy

PLEASE NOTE:   THIS SITE AND ALL REIA SERVICES ARE INTENDED FOR USE ONLY BY ADULTS (18 YEARS OF AGE OR OLDER, 19 YEARS OF AGE OR OLDER IN ALABAMA).   IF YOU ARE UNDER AGE 13, YOU MAY NOT USE THIS SITE.   IF ANY USER BECOMES AWARE OF ANY USE BY A CHILD, PLEASE CONTACT US IMMEDIATELY SO THAT WE CAN DELETE THE INFORMATION.

FAILURE TO ACCEPT COOKIES ON OUR SITE MAY RESULT IN YOUR INABILITY TO ACCESS CERTAIN INFORMATION ON OUR SITE OR NAVIGATE OUR SITE.   IF YOU DO NOT AGREE WITH THIS PRIVACY POLICY, YOU MAY NOT USE OUR SITE OR OTHER SERVICES, SUCH AS OUR NEWSLETTERS, REPORTS OR FORMS.

WE RESERVE THE RIGHT TO AMEND THIS PRIVACY POLICY AT ANY TIME WITH OR WITHOUT PRIOR NOTICE IN ACCORDANCE WITH LAW.  IT IS YOU RESPONSIBILITY TO REVIEW THIS PRIVACY POLICY EVERY TIME YOU ACCESS OUR SITE (INCLUDING OTHER SERVICES). 

IF YOU ACCESS US THROUGH OR ON SOCIAL MEDIA, SUCH AS TWITTER, FACEBOOK OR INSTAGRAM, BE AWARE THAT THIS POLICY MAY DIFFER FROM THE PRIVACY POLICIES OF THOSE PROVIDERS.  THIS POLICY REFLECTS POLICIES IN EFFECT FOR OUR SITE AND OTHER INFORMATION YOU PROVIDE US DIRECTLY, NOT TO INFORMATION PROVIDED OR SOURCED THROUGH SOCIAL MEDIA.  YOU ARE RESPONSIBLE FOR READING AND UNDERSTANDING SOCIAL MEDIA PRIVACY POLICIES.

Scope

This Reia Website Privacy Policy applies to Users of our website (sometimes the “Service” or the “Site”) and unless specified in connection with a particular purpose (such as a specific consent in connection with a medical device trial or research), applies to personal information collected in relation to the Site and all of our services however provided, including without limitation, to California and Nevada residents.   Residents of these states should note information specific to them below.   Information in this Privacy Policy in general is provided in accordance with California privacy requirements. 

Reia respects your privacy and wants you to be familiar with how we collect, use, and disclose information.  This Privacy Policy describes our practices in connection with information that we or our service providers collect through the website operated and controlled by us from which you are accessing this Privacy Policy as well as other Reia services to which you may subscribe or have access though the internet or otherwise.

We encourage you to read the full Privacy Policy before using our Site or any other services provided by us or providing us with any personal information.  By providing personal information to us or by using our Site or other services provided by us, you acknowledge that you have read and understand this Privacy Policy and agree with it.

Questions or requests concerning Site privacy should be directed to: hello@reiahealth.com

We will retain your personal information for as long as needed or permitted in light of the purpose(s) for which it was obtained.  The criteria used to determine our retention periods include:  (i) the length of time we have an ongoing relationship with you and provide the Service to you; (ii) whether there is a legal obligation to which we are subject; and (iii) whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation, or regulatory investigations).

We may retain anonymized data indefinitely for our use with respect to the operation of our Site and for any other internal purposes, including data analysis with respect to our medical devices.   Anonymized data is data that has been stripped of personally identifiable information.

What is Personal Information?

Personal information is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular person or household.  Personal information does not include information that is de-identified (anonymized) or aggregated.

Personal Information REIA Collects

We may collect the following types of information in connection with this Site (also see additional information below):

  • Unique identifiers (such as your name or an ID number)

  • Contact information (such as telephone number, email address, or mailing address)

  • Professional information (such as company and title)

  • Commercial information (such as your communication preferences, survey data, or other information you provide in order for us to respond to your inquiry)

  • Audio, video, or visual information (such as a recording of your voice or image if you participate in a corporate event- you will always be notified of any recording in advance)

  • Individual profile information

  • Internet and technical information (such as your IP address, device identifiers, browser type, ISP, and data from cookies and web beacons)

Sources of the Personal Information We Collect

We collect personal information used in relation to this Site from the following sources:

  • Directly from you (e.g., through a submission you make on our “Contact Us” page or when registering for an event, if you submit a request to receive our newsletters or if you fill out and submit any form we have available on our site for public use, from cookies when you access any information or page on the Site, from telephone calls with you, postal communications, through responses to surveys or applications). 

  • From Third Parties acting on your behalf (e.g., if your employer provides information about you in connection with a corporate event)

  • From first and third party cookies that help us operate and assess the Site (see our “Cookies” section below for more information)

Our Business or Commercial Purposes for Collecting, Using and Disclosing Personal Information

We collect, use, and disclose your Personal Information for the following purposes:

  • To provide you with a requested service

  • To verify your identity and registration

  • To communicate with you in response to your inquiry or a requested service

  • To gather your feedback or survey/form responses

  • To host or participate in educational, corporate or other events on behalf of or in connection with REIA business activities

  • For REIA’s analytics purposes.  We do not share your information with any advertisers or use your information for marketing purposes other than for internal REIA marketing purposes, such as to select product evaluators or participants in REIA medical device trials

  • To administer, assess, personalize, and improve our Site and services

  • To conduct research, statistical analysis, survey/demographical interpretation, and other data studies based on the data collected

  • To maintain network security and performance and protect against cyber-attacks

  • To comply with and enforce applicable laws, industry standards, and our own policies and terms

  • For auditing, reporting, corporate governance, and internal operations

  • For due diligence and implementation of commercial transactions, including reorganizations, mergers or other disposition of all or any portion of our business, assets or stock

  • To exercise and defend legal rights

  • As otherwise described to you at the point of collection or with your consent

Categories of Third Parties With Which We Share Personal Information

We may share your personal information with:

  • Agents and services providers who perform website and other services on our behalf, such as hosting this Site, sending communications, or hosting/managing events in which REIA participates.  Note that hosting service providers may use facilities and servers outside the US

  • Third parties involved in events you register for, including physical and virtual sites that host an event.  We do not control use of information we may provide in this context, and you are advised to review any privacy policies applicable under this paragraph

  • Any entity that acquires all or a portion of our business, assets, or stock, including in connection with a merger, reorganization, or other commercial transaction.  In such transactions, user information generally is one of the transferred business assets. Also, if either REIA or any of REIA’s assets are acquired (including through bankruptcy proceedings), your personal information may be one of the transferred assets.

  • Authorities, subject to applicable laws, including to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include such authorities outside your country of residence.

Third Parties

We do not sell personal information to any third parties, and have not done so in the preceding 12 months.   We do not accept advertising on our site. 

REIA works with health care providers subject to strict Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) regulations.  Please note that outside of these relationships REIA is not otherwise currently subject to such regulations except in connection with particular agreements with such providers, such as physicians and hospitals.  Our current clinical trial partner provides us only with de-identified information (in other words, we do not receive personal information tied to the performance evaluations of our device, only certain technical and performance evaluations that are anonymous as to users’ information).

Our third-party service providers and successors to whom we disclose information are required by law and/or contractual requirements to keep your personal information confidential and secure. These parties may not use or disclose it except as reasonably necessary to provide services to you or as otherwise permitted by law.

We may also use or share de-identified information that is not reasonably likely to identify you for commercially legitimate business purposes with our service providers, and business partners, including without limitation, health care providers participating in studies, testing and/or evaluation of our products and services. 

We and our third-party partners use cookies and other tracking technologies to analyze website traffic and facilitate our informational and marketing purposes

Children’s Personal Information

We do not knowingly collect personal information from children under 13.  If we learn that we have collected any personal information from a child under the age of 13 without verifiable parental consent, we will delete that information from our files as quickly as possible.  If you believe that we may have collected information from a child under 13, please contact us at the email address provided below.

Cookies

We and our service providers may automatically collect and use information in the following ways as you navigate around the Site:

Through your browser:  Certain information is collected by most browsers, such as your Media Access Control (MAC) address, computer type (Windows or Mac), screen resolution, operating system name and version, and Internet browser type and version.  We may collect similar information, such as your device type and identifier, if you access the Site through a mobile device.  We use this information to ensure that the Site functions properly.

Using cookies:  Cookies are pieces of information stored directly on the computer you are using.  Cookies allow us to collect information such as browser type, time spent on the Site, pages visited, and language preferences.  We and our service providers use the information for security purposes, to facilitate navigation, display information more effectively, and to personalize your experience while using the Site.  We also use cookies to recognize your computer or device, which makes your use of the Site easier, such as to remember your request for additional information, to order our newsletters or other communications and to submit your information to us, such as through a form on the Site.  In addition, we use cookies to gather statistical information about Service usage in order to continually improve its design and functionality, understand how individuals use it, and to assist us with resolving questions.  

Please note that we do not use cookies associated with advertisers as we do not permit advertising on our site.  Certain providers we may use, such as Twitter or Facebook, may use cookies for advertising purposes.  Please refer to their Privacy Policies.

You can refuse to accept these cookies by following your browser’s instructions; however, if you do not accept them, you may experience some inconvenience in your use of the Service.  You may also not receive advertising or other offers from us that are relevant to your interests and needs.  To learn more about cookies, please visit http://www.allaboutcookies.org.

Using Flash cookies:  Our use of Adobe Flash technology (including Flash Local Stored Objects (“Flash LSOs”)) allows us to, among other things, serve you with more tailored information, facilitate your ongoing access to and use of the Service, and collect and store information about your use of the Service.  If you do not want Flash LSOs stored on your computer, you can adjust the settings of your Flash player to block Flash LSO storage using the tools contained in the Website Storage Settings Panel.  You can also control Flash LSOs by going to the Global Storage Settings Panel and following the instructions.  Please note that setting the Flash Player to restrict or limit acceptance of Flash LSOs may reduce or impede the functionality of some Flash applications.

Using pixel tags, web beacons, clear GIFs, or other similar technologies:  These may be used in connection with some Service pages and HTML formatted e mail messages to, among other things, track the actions of users and e mail recipients, measure the success of our marketing campaigns, and compile statistics about Service usage.

IP address:  Your IP address is a number that is automatically assigned to your computer by your Internet Service Provider.  An IP address is identified and logged automatically in our server log files whenever a user visits the Service, along with the time of the visit and the pages visited.  Collecting IP addresses is standard practice and is done automatically by many online services.  We use IP addresses for purposes such as calculating Service usage levels, diagnosing server problems, and administering the Service.  We may also derive your approximate location from your IP address.

Device Information:  We may collect information about your mobile device, such as a unique device identifier, to understand how you use the Service.

Security

We seek to use reasonable organizational, technical, and administrative measures designed to protect personal information under our control. However, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure.  If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you have with us has been compromised), please immediately notify us at: hello@reiahealth.com

Your Rights as a California Resident

Under California law, some California residents have specific rights regarding their personal information.  These rights are subject to certain exceptions as described below.  Further, if you are a current, former, or prospective employee or if we have collected or processed your personal information in connection with our business with a company, partnership, sole proprietorship, nonprofit or government agency, and you are an employee, owner, director, officer, or contractor of that entity, rights 1-3 below are not available to you until at least January 1, 2023.

When required, we will respond to most requests within 45 days, unless it is reasonably necessary for us to extend our response time. 

1. Right to Disclosure of Information

You have the right to request that we disclose certain information regarding our practices with respect to personal information. If you submit a valid and verifiable request and we confirm your identity and/or authority to make the request, we will disclose to you any of the following at your direction:

The categories of personal information we have collected about you in the last 12 months.

The categories of sources for the personal information we have collected about you in the last 12 months.

Our business or commercial purpose for collecting that personal information.

The categories of third parties with whom we share that personal information.

The specific pieces of personal information we collected about you.

If we sold your personal information for a business purpose, a list of the personal information types that each category of recipient purchased.

If we disclosed your personal information to a third party for a business purpose, a list of the personal information types that each category of recipient received.

 2. Right to Delete Personal Information

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions.  If you submit a valid and verifiable request and we can confirm your identity and/or authority to make the request, we will determine if retaining the information is necessary for us or our service providers to:

Complete a transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you

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

Debug products to identify and repair errors that impair existing intended functionality.

Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;

Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.);

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 the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent;

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

Comply with a legal obligation; and/or

Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

If none of the above retention conditions apply, we will delete your personal information from our records and direct our service providers to do the same.

How to exercise the above rights

To exercise your rights to disclosure or deletion described above, please submit a verifiable consumer request to us as follows:

Only you or a person legally authorized to act on your behalf may make a verifiable consumer request related to your personal information.

You may make a verifiable consumer request for access or deletion no more than twice within a 12-month period. In connection with your request, we will require you to:

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.  Depending on the nature of your request and the sensitivity of the information we hold about you, we may ask you to confirm various data elements we already have on file such as your mailing address and phone number, or, in case of sensitive personal information, we may require you to submit a copy of a government issued identification.

Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

You will not be required to create an account with us in order to submit a verifiable request, though we may communicate with you about your request via a pre-established account if applicable.  However, in order to safeguard the personal information in our possession, if we cannot verify your identity or authority to act on another’s behalf, we will be unable to comply with your request.  We will only use personal information you provide when submitting a verifiable request to confirm your identity or authority, or to fulfill your request.

3. Right to Opt out of Sales of Your Personal Information

As a California resident, you have the right to direct a business that sells your personal information to third parties not to sell your personal information.  This right is referred to as “the right to opt-out.”  Because we do not sell your personal information, we do not provide any mechanism for you to exercise the right to opt out.

4. Right to Non-Discrimination

You may exercise your rights under the CCPA without discrimination.  For example, unless the CCPA provides an exception, we will not:

Deny you goods or services;

Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;

Provide you a different level or quality of goods or services; or

Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

We may offer you financial incentives to provide us with personal information that is reasonably related to the information’s value.  This could result in different prices, rates, or quality levels for our products or services.  Any financial incentive we offer will be described in written terms that explain the material aspects of the financial incentive program.  You must opt-in to any financial incentive program and may revoke your consent at any time by contacting us as indicated below

5. Direct Marketing and Do Not Track Signals

Under California’s “Shine the Light” law, California residents may request and obtain a notice once a year about the personal information we shared with other businesses for their own direct marketing purposes.  Such a notice will include a list of the categories of personal information that were shared (if any) and the names and addresses of all third parties with which the personal information was shared (if any).  The notice will cover the preceding calendar year. To obtain such a notice, please contact at hello@reiahealth.com. In addition, under this law you are entitled to be advised how we handle “Do Not Track” browser 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.

Nevada Personal Information Collection and Purposes of Use

We collect certain personal information of Nevada consumers through our Internet websites or other online service.  This information may include one or more of the following elements of personally identifiable information as identified by law and our practices:

  • A first and last name.

  • A home or other physical address that includes the name of a street and the name of a city or town.

  • An electronic mail address.

  • A telephone number.

  • A Social Security Number (note: this must be listed as provided by law – we do not collect Social Security Numbers unless required to participate in an actual product clinical trial supervised by a physician, hospital or other similar provider, and then only in accordance with HIPAA regulations and privacy requirements to which the provider is subject).

  • An identifier that allows a specific person to be contacted either physically or online.

  • Any other information concerning a person collected from the person through the Internet website or online service of the operator, and maintained by the operator in combination with an identifier in a form that makes the information personally identifiable.

We collect this personal information for the following purposes:

  • to respond to your inquiries and to fulfill your requests;

  • to send you important information regarding our relationship with you or regarding this website, changes to our terms, conditions, and policies and/or other administrative information;

  • for audits, to verify that our internal processes function as intended and are compliant with legal, regulatory, or contractual requirements;

  • for fraud or crime prevention, and for technical security monitoring purposes;

  • to facilitate the development of new products and services;

  • to enhance, improve or modify our website or products and services;

  • for data analysis that will allow us to understand website usage trends;

  • to determine the effectiveness of our promotional campaigns, so that we can adapt our campaigns to the needs and interests of our users.

  • to better understand you, so that we can personalize our interactions with you and provide you with information and/or offers tailored to your interests.

Your Privacy Rights

Right to access and/or correct your personal information, or opt out of sale of personal information

If you would like to review, correct, or update your personal information, you or your authorized representative may submit your request via hello@reiahealth.com.  We will respond to your verified request as soon as reasonably practicable, but no later than sixty (60) days after receipt.  If circumstances cause any delay in our response, you will be promptly notified and provided a date for our response.

We generally do not disclose or share personal information for profit.  Under Nevada law, you have the right to direct us to not sell or license your personal information to third parties.  To exercise this right, if applicable, you or your authorized representative may submit a request to: hello@reiahealth.com. We will respond to your verified request as soon as reasonably practicable, but no later than sixty (60) days after receipt.  If circumstances cause any delay in our response, you will be promptly notified and provided a date for our response.

Contact Us

You can contact us with questions about this Privacy Notice for Nevada Residents or to exercise your rights as described in this Notice at hello@reiahealth.com

THIRD PARTY SITES AND SERVICES

This Service may contain links to sites of third parties. This Privacy Policy does not address, and we are not responsible for, the privacy, information, or practices of any third parties, including any third party operating any site or online service (including, without limitation, any application) that is available through this Service or to which this Service contains a link.  The availability of, or inclusion of a link to, any such site or property on the Service does not imply endorsement of it by us.

Dated:  October 6, 2021