Site means the public website
Platform means the Curelator services accessible by registering and login in to a N1-Headache account, either a patient or a clinician account. It includes the mobile apps, Web dashboard and areas of the website protected by a password.
Service means either the Site or the Platform
User means an individual or an organization that created or has access to the N1-Headache platform, by registering to a free or a premium account.
Visitor means an individual other than a User who uses the Site but has not registered to use the Service
Personal Data means any information allowing to personally identify a natural person.
Curelator does not share, sell or distribute subscriber information except to provide Curelator services to subscribers as set forth herein.
All identifiable subscriber information is maintained in a secure database encrypted to prevent inadvertent or malicious accessing of subscriber information by unauthorized parties.
Curelator shall take reasonable measures appropriate to protect subscriber information from loss, misuse, alteration or destruction, and, where possible, will require any third parties to whom subscriber information is transferred to take comparable steps to protect that security.
Information we collect on the Service
Curelator collects different types of information. The legal bases for processing of Personal Data are that the processing is required for providing the Service in accordance with our Terms of Service and that the processing is performed in our legitimate interests, in the public interest and/or upon your consent, which are explained in the section “How we use your information” of this Policy.
What informations we collect
User-provided information: When you use the Service, you may provide and we may collect Personal Data. Such Personal Data includes email address, name, age, date of birth, mailing address or other billing information. You may also provide health related information such as symptoms, medications taken and missed as well as lifestyle, emotional state and preferences data.
Automatically collected information: When you use the Service as a User or as a Visitor, we may collect information using automated methods, including but not limited to cookies, tracking pixels and other variety of "beacons".
- Devices type, Web browser, IP address and geolocation of that IP address.
- The Web pages or sites you visited just before using our website.
- The pages and content you interact with on our website, including the dates, times and duration of the interactions.
- The app screens and UI elements you interact with on our mobile apps, including the dates, times and duration of the interactions.
- Upon your consent, the location data provided by your mobile device or Web browser location services.
- Information on the interactions with our marketing and transactional email messages, such as whether you open and/or click on a message and when.
Other sources: We may obtain information, including Personal Data, from third parties and sources other than Curelator services, such as our partners and advertisers. If we combine or associate information from other sources with Personal Data that we collect through our Services, we will treat the combined information as Personal Data in accordance with this Policy.
How we use your information
We use the information we collect in a variety of ways in providing our services and operate our business, including:
- To operate, maintain, improve and provide all features offered to Curelator customers and website visitors.
- To respond to comments and questions about the company and the products.
- To provide customer support to the users of the platform.
We use anonymized information to provide selected research groups and individual researchers with daily diary, profile, medication and demographic data with the goal of improving the knowledge of the disease, influencing factors, impact, potential and existing therapies effectiveness. The results of these research project are presented in relevant publications, journals and meetings.
Upon consent, we share Personal Data and health information with your treating clinician and health organization to improve their understanding of your personal health situation and make better decisions about your treatment options, risks and effectiveness. Your Personal Data is shared using compliant means, is password protected and encrypted during transit.
- For administrative purposes such as customer service and billing.
- To notify customers and mailing lists subscribers of new product and services offerings.
- To inform subscribers about new research, findings and publications.
You have the ability to opt-out of receiving any promotional communications as described below under "Your Rights."
We use anonymized and aggregated information to analyze the usage trends of the Service, to improve the Platform and the Site, and to develop new features, products and services.
Cookies and Tracking
- Keep track of user login and authentication on the Platform.
- Monitor the usage and effectiveness of the Service, such as number of visitors, pages viewed and content interaction.
Analytics and Advertisement
We make sure the data sent to Google Analytics is protected and anonymized and is used solely for the purpose of administering the Service, understanding usage trends, Users and Visitors preferences and resolving technical issues.
We use Facebook Pixel tracking technology to measure and optimize conversion and create custom audience for our advertisement campaigns. We may also share email addresses with Facebook to improve the effectiveness of our ads and sponsored content targeting.
We use Fabric to track performance, stability and usage of the mobile applications.
To whom we share your information
Third party service providers
We employ third party service providers to help us with the development, maintenance, hosting, backup and other services required to operate the Service. Some of these third parties may have access to or process a minimal set of Personal Data necessary to perform their function. Our contracts with third party providers requires them to preserve the confidentiality of the information that is shared with them.
Curelator may also, at subscriber request, share their personal, medical and behavioral information with the subscriber's physician or any other individual or entity that the subscriber instructs Curelator to so inform.
Anonymized and/or aggregated information
Although Curelator will never share any identifiable subscriber information, Curelator may, from time to time, disclose anonymized individual or aggregate information relating to particular diseases or disorders, behaviors or modifications as part of our research and to researchers doing work for or on behalf of Curelator, sponsors, or other business partners, and any such disclosure to such third parties is bound by the privacy protections set forth herein.
Law enforcement, legal process and compliance
Curelator will disclose subscriber information outside the scope of these provisions only as required to do so by law or compelled by court or government or administrative agency of competent jurisdiction. Personal information from subscribers is subject to Federal and local laws.
Change of ownership
Curelator reserves the right to transfer our user databases together with any personally identifiable information contained in them, to any third-party acquiring our assets after notice and the opportunity for a subscriber to request that personally identifiable information not be transferred. Should Curelator or our assets ever be sold, acquired, merged, liquidated, reorganized, or otherwise transferred, we will place a prominent notice on the homepage of the N1-Headache website.
Subscribers to N1-Headache retain ownership of their personal, medical and behavioral information.
As such, you have the right to access, correction, deletion of your personal data at any time and within a reasonable period of time. You can modify some of your information through the use of our Service. You can request modification, export in a portable format and deletion of your personal data, or request the restriction of the processing of your personal data under certain circumstances, by writing an email to email@example.com. We retain the information we collect about and from you for as long as necessary to fulfill a business purpose or comply with a legal request. If your account becomes inactive, we will keep your Personal Data for a period of 7 years after which you will be notified one month prior to deletion of your account and Personal Data. All other data We may keep an anonymized version of your data for the purpose of medical research. This information will be kept in such a way that it will be impossible to re-identify it. We may also keep records for legal and administrative requirements.
When processing is based on your explicit consent, you can withdraw this consent at any time, by either closing you account or writing an email to firstname.lastname@example.org. This may affect the features offered by the Service.
You have the right to notify the data protection authority if you believe that we are infringing your privacy rights.
You can opt-out of our commercial communications by following the instructions given at the bottom of such communication, or by writing an email to email@example.com.
Nonetheless, Curelator shall not have liability for disclosure of any subscriber information obtained or disclosed due to errors in transmission or the unauthorized acts of third parties. Subscribers are hereby reminded that transmission of information via the Internet or over mobile networks is not completely secure. Despite our best efforts, no matter how extensive, Curelator cannot and does not guarantee the security of subscriber data transmitted to and from Curelator or over mobile networks; any transmission is at subscriber's own risk.
Special Notice to California Residents -- Your California Privacy Rights
California's Shine the Light law provides California residents with the right to receive disclosures about any sharing of their personal information with other companies.
If you are a California resident and you provided your personal information to Curelator, then, once each calendar year, you may submit a written request for information about the information we shared, if any, with other companies for their use in direct marketing. To submit your written request, please send a written request to:
210 Broadway, Floor 201
Cambridge, MA 02139
with "Request for California Privacy" in the letter subject line.
You must include sufficient detail for us to locate your file; at a minimum, your name and postal address.
Within 30 days of receiving your request, we will send you a list of the categories of personal information disclosed to third parties for third-party direct marketing purposes during the immediately preceding calendar year, along with the names and addresses of these third parties.
We reserve our right not to respond to requests sent more than once in a calendar year, or requests submitted to an address other than the one posted in this notice. Please note that the California Shine the Light law does not cover all information sharing. Our disclosure only includes information covered by the law.
California Do Not Track
Curelator does not track its customers over time and across third party websites to provide targeted advertising and therefore does not respond to Do Not Track (DNT) signals.
Policy Updates, Consent and Questions
Please contact us with any questions, comments, concerns or complaints about this Policy, your Personal Data, our use and disclosure practices, or your consent choices by email at firstname.lastname@example.org or by a written request to:
210 Broadway, Floor 201
Cambridge, MA 02139