Introduction

This Privacy Notice describes the types of information Neuro Wellness Spa or any of its divisions, brands, or affiliates (collectively, “Neuro Wellness Spa”, “we” and “us“) collect from and about you when you:

• Visit any of our websites where this Privacy Notice is posted (each a “Site”)
• Visit or enroll in a treatment program at any of our clinics or facilities (each a “Facilities”)
• Contact or interact with us via email, phone, or video call (“Online Service”)
• Submit information to the official social media pages (“Social Media Pages”) we operate
• Otherwise contact or interact with us offline (“Offline Services”)

The Sites, Facilities, Online Services, and Offline Services are collectively referred to as the “Services.” This Privacy Notice also explains how Neuro Wellness Spa may use and share your personal information, as well as your ability to control certain uses of it.

By using or accessing the Services, you agree to the collection, storage, use and disclosure of your personal information as described in this Privacy Notice, and agree to the Terms of Use which are incorporated by reference. If you do not agree, please do not access or use the Services.

For ease of reference, you may click on any of the following links to jump to one of the sections addressed below:

• Information We Collect
• How We Use Information
• Information We Share
• Choices and Opt Outs
• Data Security
• Children’s Information
• Third Party Content, Links, and Plug-ins
• Public Forums
• Changes to this Privacy Notice
• Contact Us
• U.S. State Privacy Rights

Neuro Wellness Spa encourages you to read this Privacy Notice in full to learn how we treat personal information obtained through the use of our Services.

Information We Collect

Information You Provide

We collect personal information from you when you choose to share it with us, such as through use of our Services, through our Social Media Pages, and other ways you communicate with or contact us.

The personal information we collect may include your contact information, device identification information, internet browsing, history, interactions, tendencies, products or services purchased, medical / health information, medical insurance information, demographics information, employment information, payment information, physical characteristics, date of birth, Social Security number, and other content you provide to us.

Information Automatically Collected

We, or our service providers, may use a variety of technologies such as cookies, web beacons, pixel tags, log files or other technologies to collect personal information about visitors to, and users of, our Site. We may also collect personal information through your interactions with our emails and online advertisements. We use this information to keep track of analytics and certain statistical information, to ensure the Sites function properly, to better understand how users interact with the Sites, to personalize our relationship with you, and for other purposes consistent with this Privacy Notice.

For example, we may automatically collect certain information from you, including but not limited to your browser type, device type, operating system, Internet Protocol (“IP”) or Media Access Control (“MAC”) address, mobile device identifier or other unique device identifier of any of your computer(s) or device(s) that are used to access the Site, geolocation, software version, phone model, phone operating system, carrier information, and the domain name from which you accessed the Site. We also may collect information about your use of the Site, including the date and time you visit, the areas or pages that you visit, the amount of time you spend viewing or using the Site, the number of times you return to the Site, other click-stream or Site usage data, emails that you open, forward or click-through to our Site, and other Sites that you may visit.

Third Party Analytic Technologies

We use third parties’ analytics and tracking tools to better understand who is using the Services, how people are using the Services, how to improve the effectiveness of the Services and related content, and to help us or those third parties serve more targeted advertising to you across the Internet. To support this interest-based advertising solution, we, or our service providers, may use information about your visits to our Sites or Social Media Pages, and information from your mobile device and email.

 

These third parties may use technology such as cookies, web or hardware beacons, pixel tags, log files, or other technologies to collect and store information automatically collected. They may also combine information they collect from your interaction with the Services with information they collect from other sources. We do not have access to, or control over, these third parties’ use of cookies or other tracking technologies.

 

Please visit “Choices and Opt Out” for further information on how to opt out, including information about ‘Do Not Track’ and how to disable cookies.

 

Combination of Information

We may combine the personal information we collect from and about you, including personal information you provide to us and information we automatically collect, with personal information collected offline, across other computers or devices that you may use, and from third party sources.

How We Use Information

We may use personal information collected from or about you for any of the following purposes:

• To respond to your inquiries, provide you with the Services, and to contact and communicate with you when necessary or as otherwise permitted by this Privacy Notice;
• To validate, confirm, verify, and provide medical and other healthcare services (including to process payment transactions, schedule appointments, and contact you about your treatment, including by email or telephone);
• To enhance your online experience on our Site, including as a way to recognize you and welcome you to the Site;
• To review the usage and operations of our Services, develop new products or services, and conduct analysis to enhance or improve our content, products, and services;
• To contact you with information, deliver email communications, newsletters, promotional material, and other correspondence from Neuro Wellness Spa or on behalf of our affiliates and brands;
• To communicate with you regarding your enrollment in one of our treatment programs;
• To protect the security or integrity of the Services and our business;
• To comply with legal and regulatory requirements and respond to requests from courts or other government bodies;
• To present advertising to you, including through partnerships with social media platforms and internet search engines; or
• For other purposes disclosed at the time you provide your information or otherwise with your consent.

Additionally, if you use our Services to connect with a third party service, you authorize us to use information from and about you, on your behalf, to interact with these third party services based on your requests.

Information We Share

We may disclose the personal information we collect from or about you either (i) when we have your permission to do so or (ii) in any of the following situations:

• Affiliates and Brands: We may share your personal information with Neuro Wellness Spa affiliates or brands for business, operational, promotional, marketing, or other purposes consistent with this Privacy Notice.
• Service Providers: We may share your personal information with service providers that provide business, professional, or technical support functions for us, help us operate our business, or other activities in support of the Services and/or our businesses. These service providers are authorized to use your personal information only as instructed by us. We may also receive information collected by these service providers and combine it with the information we have collected.
• Third Parties:  We may share your personal information with third parties that we believe may have offers of interest to you if you opt-in to such sharing. We may also receive information collected by these third parties and combine it with the information we have collected. Your information may also be collected and processed by third parties, such as the payment providers you select, who will process your information independently in accordance with their own privacy notices.
• For Business Transfers: We may share or transfer your information in connection with, or during negotiations of, any merger, sale of our assets, financing, or acquisition of all or a portion of our business to another company.
• Legal Matters; Compliance with Law: We may disclose personal information collected from or about you to the government or to other third parties to comply with applicable laws, rules, regulations, governmental and quasi-governmental requests and investigations, court orders, subpoenas or other legal process, such as in connection with suspected illegal activity associated with any of the Sites or our business and to protect against harm to the Services, to us, or others. We reserve the right to release information collected through any of the Sites to law enforcement or other government officials, as we, in our sole discretion, deem necessary or appropriate.

We may disclose any categories of personal information listed in “Information We Collect” to third parties and service providers.

Choices and Opt Outs

Cookies, Targeted Advertising and Do Not Track Disclosures

Certain parts of our Site require cookies. You are free to set your browser or operating system settings to limit certain tracking or to decline cookies, but by doing so, you may not be able to use certain features on the Site or take full advantage of all of our offerings. Please refer to your Web browser’s or operating system’s website or “Help” section for more information on how to delete and/or disable your browser or operating system from receiving cookies or controlling your tracking preferences.

We may use cookies or other technologies to deliver more relevant advertising and to link data collected across other computers or devices that you may use. To understand your choices for receiving more relevant advertising or to manage your settings, please review the information below:

• To learn more about the use of cookies or other technologies to deliver more relevant advertising and to know your choices with respect to collection and use of the data by these third party tools, you may visit the [Page Name] opt-out page at [Hyperlink]. Please note, if you choose to opt out of targeted advertising, you may still continue to receive generic advertising unless you opt out of such advertising in accordance with “Opt Out Preferences”, below.
• On your mobile device, you may also adjust your privacy and advertising settings to control whether you want to receive more relevant advertising.

Opt Out Preferences

To opt-out of marketing communications, you may use one of these methods:

• Electronic Promotional Offers: If you do not want to receive emails from us regarding special promotions or offers, you may (i) click the unsubscribe link in the footer of any email; or (ii) contact us at the contact information listed in the “Contact Us” section below.
• Direct Mail Promotional Offers: If you do not want us to send you any promotional offers through direct mail, you may contact us at the contact information listed in the “Contact Us” section below.

If you receive marketing communications from one or more brands within the Neuro Wellness Spa family of affiliated brands, you must opt-out individually from each of the brands from which you are receiving brand-specific marketing communications. Your instructions to limit the use of your information for these purposes will be processed as soon as reasonably practicable.

If you are a resident of California, Virginia, Colorado, Connecticut, or Utah, you can learn more about your privacy rights below.

Online Advertising

For information about opting out of third party advertising, visit: NAI Opt-Out or DAA. You will leave this Website for a separately managed online site where you can specify your preferences. You can also click on the icon that may appear on some of our advertising served through this technology. We may use more than one third party company for placing this advertising, which would require you to opt out of each company.

Google Analytics

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Services. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network. Depending on Your location, we may utilize Google Analytics.  You can opt out of Google Analytics across all websites you use.  To do so, visit this website.  For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy.

Supported Web Browsers and Do Not Track Signals

We recommend that you use the latest web browser versions to optimize your experience. Older web browser versions may not be able to access or utilize all pages on our website as intended.

We may not be able to receive or honor web browser “Do Not Track” signals and our Site may continue to collect information in the manner described within this Privacy Notice.

Data Security

The security of customer information is very important to us, and we take a number of steps to safeguard it.

We have taken certain physical, administrative, and technical steps to safeguard the personal information we collect from and about our customers and Site visitors.

The security of your information is important to us, but no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially reasonable means to protect your information, we cannot guarantee its absolute security.

Children’s Information

Protecting children’s privacy is important to us. We do not direct the Services to, nor do we knowingly collect any personal information from, children under the age of 16. If Neuro Wellness Spa learns that a child under the age of 16 has provided personal information to the Site, it will use reasonable efforts to remove such information from its files.

Third Party Content, Links, and Plug-ins

The Site may have links to third party websites or applications, which may have privacy policies that differ from our own. We are not responsible for the practices of such sites.

The Site may also offer you the ability to interact with social plugins from third party social media sites, which may allow us and/or the social media site to receive personal information from or about you. In some cases, we may know that you clicked on a social plugin, such as a Facebook Like or Twitter Follow button, or receive other information from the social media sites. Similarly, if you have previously provided personal information to a third party operating a plug-in on the Site, then such third party may recognize you on the Site. Your use of social network plugins is subject to each social media site’s privacy policy, which may be different from ours, so please read these policies carefully to understand their policies and your options. As with linked sites, we have no control over the information that is collected, stored, or used by social network plugins, and are not responsible for the practices of such sites.

Public Forums

Any personal information you choose to disclose through our Services, in blogs, on discussion or message boards, in chat rooms, interactive forums, rating or reviews, or on other public areas on the Site, or other third-party websites that this Site may link to, becomes public information. Please exercise caution when disclosing personal or other information in these public areas. We are not responsible for the personal information you choose to post. To request removal of your personal information from our Site, you may contact us using the “Contact Us” section below.

Changes to this Privacy Notice

We reserve the right to make changes to this Privacy Notice at any time. When we do, we will post the change(s) on the Site. Please visit this page periodically so that you will be apprised of any such changes. Your continued use of our Services after any modification to this Privacy Notice will constitute your acceptance of such modification. If we change the Privacy Notice in a material way, we will provide appropriate notice to you.

Contact Us

If you have any questions or comments regarding this Privacy Notice or any of the practices described herein, you can contact us by:

• Calling us at 877-847-3984
• Emailing us at info@neurowellnessspa.com; or
• Writing to us at 1983 W 190th St #200, Torrance, CA 90504

U.S. State Privacy Rights

Residents of California, Virginia, Colorado, Connecticut, and Utah have certain rights concerning the processing and use of their Personal Data.  The rights described herein are subject to exemptions under applicable law.  For purposes of this section, the term “Personal Data” includes both “Personal Information” and “Personal Data” as defined by applicable law.

If your Personal Data is subject to a privacy law in your state, you may have certain privacy rights with regard to that information.  You may have the right to:

• Know, access, and confirm your Personal Data.
• Delete the Personal Data we have about you, subject to exceptions under applicable law.
• Correct inaccuracies in your Personal Data.
• Obtain your Personal Data in a portable and readily usable format.
• Opt-out of the use or processing of your Personal Data for profiling or targeted advertising.
• Opt-out of the sale of your Personal Data.

Under certain state laws, you may also have the right not to receive discriminatory treatment for the exercise of any of these privacy rights.  We will not discriminate against you because you have exercised any of your rights.

Certain state laws may also provide you the right to appeal our decisions regarding your rights requests if we do not respond to your requests or do not take action regarding your requests. Additionally, if you are a resident of the state of California, you may have a right to pursue legal action for improper handling of your Personal Data.

How to Submit a Request

If you wish to exercise the rights listed above, and are a resident of a state that provides such privacy rights, you may submit a request by emailing info@neurowellnessspa.com, by calling us toll-free at 877-847-3984, or by using the form below. We will provide your Personal Data to you in writing in a readily usable format.  If you choose to submit your request via email, you must include “Privacy Rights Request” in the subject line and clearly provide us with the following information: what type of request you are making, your full name, email address, and valid physical address.  You may only make one request per email.

We are required to provide you with access to your Personal Data or delete your Personal Data only in response to verifiable consumer requests. In order to protect our customers’ personal information, we will verify your identity following receipt of your request. We will compare the information you provide to us in your request to any information we may have in our possession in order to verify your request. We may also contact you to request additional information in relation to your request. Please promptly respond to any follow-up inquiries so that we may verify your identity. For security purposes, our verification process requires an exact match of at least three data points you provide to us with data points we maintain in our records. The information collected through this process will be used for verification purposes only. Please provide your state of residence and at least three of the following data points when you submit your request:

• First and last name
• Email address associated with your Neuro Wellness Spa account
• Telephone number associated with your Neuro Wellness Spa account
• If you have used our Services or Facilities, please provide the date of your last visit or appointment (day, month, and year)
• Mailing address

If you request that we provide you with specific pieces of information about you, we may apply heightened verification standards than what we would apply to other types of requests. This measure is in place to help ensure that Personal Data is not disclosed to any person who does not have the right to receive it.

Authorized Agent

Please note that you may authorize an agent to exercise any of these rights on your behalf by emailing info@neurowellnessspa.com, by calling us toll-free at 877-847-3984, or by using the form below. If you use an agent, we will take measures to verify your agent’s authorization similar to the verification described above for fulfilling any access or deletion requests. We may require more information to ensure proper verification of you and your agent’s identity and authorization.

Categories of Personal Data Disclosed for a Business Purpose

We share Personal Data about you with service providers and third parties for business purposes, such as operational purposes and other purposes related to providing you with the Services you seek from us.  For more information about the business purposes for which we disclose Personal Data, see “How We Use Information” and see “Information We Collect” for what types of information may be shared.

“Do Not Sell” Rights; Sharing for Cross-Context Behavioral Advertising, Profiling, or Targeted Advertising

We may disclose your Personal Data for the following purposes, which are not a sale: (i) for reasons mentioned above; (ii) if you direct us to share Personal Data; (iii) to comply with your requests under applicable law; and (iv) as otherwise required or permitted by applicable law.

We do not sell Personal Data or share Personal Data about you for purposes of cross-context behavioral advertising, profiling, or targeted advertising.

Deletion Rights

You may request that we delete your Personal Data that we have collected directly from you.  Under applicable law, we may decline to delete your Personal Data under certain circumstances, for example, if we need the Personal Data to complete transactions or provide products or services you have requested or that are reasonably anticipated, for security purposes, for internal business purposes (including maintaining business records), to comply with law, or to exercise or defend legal claims.  Note also that we are not required to delete your Personal Data that we did not collect directly from you.  We require a reasonable or high degree of certainty that the requester is the consumer for which a deletion request is applicable, depending on the sensitivity of the Personal Data.

Additional California Privacy Rights

We do not share Personal Data as defined by California Civil Code Section 1798.83 (“Shine the Light Law”) with third parties for their direct marketing purposes absent your consent.  If you are a California resident, you may request information about our compliance with the Shine the Light Law by emailing us at info@neurowellnessspa.com or sending a letter to Neuro Wellness Spa 1983 W 190th St #200, Torrance, CA 90504, (Attention: Emily Pedersen – Privacy Inquiry).  Any such request must include “California Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code.  Please note that we are only required to respond to one request per individual each year.

Sensitive Personal Information and Sensitive Data

If you are a resident of California, we will not process your Sensitive Personal Information, and if you are a resident of Virginia, Colorado, or Connecticut, we will not process your Sensitive Data (as that term is defined under the Virginia Consumer Data Protection Act; the Colorado Privacy Act; and Connecticut’s Act Concerning Personal Data Privacy and Online Monitoring) without your prior consent.

HIPAA Policy

The Health Insurance Portability & Accountability Act of 1996 (HIPAA) is a Federal program that requires that all medical records and other individually identifiable health information used or disclosed by us in any form, whether electronically, on paper, or orally are kept properly confidential. HIPAA gives you, the patient, the right to
understand and control how your personal health information (PHI) is used. HIPAA provides penalties for covered entities that misuse personal health information.

As required by HIPAA, we prepared this explanation of how we are to maintain the privacy of your health information and how we may disclose your personal information.

We may use and disclose your medical records only for the following purposes: treatment, payment, and health care operation.

• Treatment means providing, coordinating, or managing healthcare and related services by one or more healthcare providers. An example of this is if you are referred to a primary care doctor or another specialist.
• Payment means such activities as obtaining reimbursement for services, confirming coverage, billing or collections activities, and utilization review. An example of this would include sending your insurance company a bill for your visit.
• Health Care Operations include the business aspects of running our practice, such as conducting quality assessments and improving activities, auditing functions, cost management analysis, and customer service. An example of this would be patient survey cards.
• The practice may also be required or permitted to disclose your PHI for law enforcement or other legitimate reasons. In all situations, we shall do our best to assure its continued confidentiality to the extent possible.

We may also create and distribute de-identified health information by removing all reference to individually identifiable information.

We may contact you, by phone or in writing, to provide appointment reminders or information about treatment alternatives or other health-related benefits and services, in addition to other fundraising communications, that may be of interest to you. You do have the right to “opt out” with respect to receiving fundraising communications from us.

The following use and disclosures of PHI will only be made pursuant to us receiving a written authorization from you:

• Most uses and disclosure of psychotherapy notes (these are not part of your medical record under HIPAA);
• Uses and disclosure of your PHI for marketing purposes, including subsidized treatment and health care operations;
• Disclosures that constitute a sale of PHI under HIPAA; and
• Other uses and disclosures not described in this notice.

You may revoke such authorization in writing and we are required to honor and abide by that written request, except to the extent that we have already taken actions relying on your prior authorization.

You may have the following rights with respect to your PHI.

• The right to request restrictions on certain uses and disclosures of PHI, including those related to disclosures of family members, other relatives, close personal friends, or any other person identified by you. We are, however, not required to honor a request restriction except in limited circumstances which we shall explain if you ask. If we do agree to the restriction, we must abide by it unless you agree in writing to remove it.
• The right to reasonable requests to receive confidential communications of Protected Health Information by alternative means or at alternative locations.
• The right to inspect and copy your PHI.
• The right to amend your PHI.
• The right to receive an accounting of disclosures of your PHI.
• The right to obtain a paper copy of this notice from us upon request.
• The right to be advised if your unprotected PHI is intentionally or unintentionally disclosed.

If you have paid for services “out of pocket”, in full and in advance, and you request that we not disclose PHI related solely to those services to a health plan, we will accommodate your request, except where we are required by law to make a disclosure.

We are required by law to maintain the privacy of your Protected Health Information and to provide you the notice of our legal duties and our privacy practice with respect to PHI.

This notice if effective as of January 1, 2020 and it is our intention to abide by the terms of the Notice of Privacy Practices and HIPAA Regulations currently in effect. We reserve the right to change the terms of our Notice of Privacy Practice and to make the new notice provision effective for all PHI that we maintain. We will post and you may request a written copy of the revised Notice of Privacy Practice from our office.

You have recourse if you feel that your protections have been violated by our office. You have the right to file a formal, written complaint with our office and with the Department of Health and Human Services, Office of Civil Rights. We will not retaliate against you for filing a complaint.

Effective Date (last updated):  May 31, 2024