Privacy is very important to electroCore, Inc. (and its affiliates) (together, "electroCore"). We also understand that privacy is very important to you. This Privacy Notice tells you how we protect and use information that we gather through electroCore websites (including https://www.electrocore.com/ and https://gammacore.com/about/).
We may change this Privacy Notice at any time and for any reason. Significant changes to the Privacy Notice are discussed below in the Section called “Changes to the Privacy Notice.” We encourage you to review this Privacy Notice each time you visit the website.
The following describes electroCore’s privacy practices, including its policy for information received from or about you during visits to the website. The amount and type of information received depends on how you use the website.
Information that you provide voluntarily During normal website usage, we do not collect or store information that will directly identify you (such as name, mailing address, e-mail address or phone number). However, electroCore may request such information to provide you with a service or correspondence (such as promotional material). Such information (including your name, mailing address, e-mail address, type of request, or other information) is collected, stored, and used consistent with all applicable laws and in a manner appropriate to the nature of your request and is used to fulfill it.
If you decide (without request by electroCore) to send information that will identify you, for example in a message containing comments about this website or otherwise, electroCore will use such information to identify you but will not generally use it except to address or resolve the matter identified in your message.
Some of the personal information that you provide may include sensitive personal information, such as health-related information, which we will use to respond to your inquiry.
When you visit our website, we may collect certain information automatically from your device. In some countries, including countries in the European Economic Area and Switzerland, this information may be considered personal information under applicable data protection laws.
We may collect and store information during normal website usage such as the name of your Internet service provider, the website that referred you to us, the pages you request, and the date and time of those requests. We may use this information to generate statistics and measure site activity to improve the usefulness of customer visits.
Collecting this information enables us to better understand the visitors who come to our Website, where they come from, and what content on our Website is of interest to them. We use this information for our internal analytics purposes and to improve the quality and relevance of our Website to our visitors.
Information you provide to electroCore is used to improve the services we provide you or for the development of our business and is not provided to any unrelated company for that company’s independent use.
We may disclose your personal information to the following categories of recipients:
We may contact you by e-mail, mail or telephone regarding the operation of our sites. Where permitted by law, we may also contact you periodically by e-mail, mail or telephone to provide marketing information regarding programs, products, services and content that may be of interest to you.
If you communicate with us and your communication requests a response from us, we will send you a response via e-mail. The e-mail response or confirmation may include your personal information, including personal information about your health, your name, address, etc. We cannot guarantee that our e-mails to you will be secure from unauthorized interception.
You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you. To opt-out of other forms of marketing (such as postal marketing or telemarketing), then please contact us using the contact details provided under [contact us] [link]. Legal basis for processing personal information (EEA and Swiss visitors only)
If you are a visitor from the European Economic Area or Switzerland, our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.
However, we will normally collect personal information from you only (i) where we need the personal information to perform a contract with you, (ii) where the processing is in our legitimate interests and not overridden by your rights, or (iii) where we have your consent to do so. In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person.
If we ask you to provide personal information to comply with a legal requirement or to perform a contact with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).
If we collect and use your personal information in reliance on our legitimate interests (or those of any third party), [this interest will normally be to operate our platform and communicating with you as necessary to provide our services to you and for our legitimate commercial interest, for instance, when responding to your queries, improving our platform, undertaking marketing, or for the purposes of detecting or preventing illegal activities. We may have other legitimate interests and if appropriate] we will make clear to you at the relevant time what those legitimate interests are.
If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided under [contact us] [link].
We use appropriate technical and organizational measures to protect the personal information that we collect and process about you. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information. On electroCore.com, we do not capture personal information except when an investor chooses to submit personal information to request additional information or updates about the company. We use such information to respond to the investor regarding their request. In the event that you choose to sign up for updates on the gammaCore.com website, we collect first name, last name, email, and zip code which we use to provide the communications that you requested.
Your personal information may be transferred to, and processed in, countries other than the country in which you are a resident. These countries may have data protection laws that are different to the laws of your country.
Specifically, website servers for US data are located in Virginia, USA and web servers for European data are located in Frankfurt, Germany. Personal information is not routinely transferred outside of the EEA or Switzerland except where necessary to respond to product complaints or inquiries. In such instances, we will take appropriate safeguards to require that your personal information will remain protected in accordance with this privacy notice. These include implementing the European Commission’s Standard Contractual Clauses.
We retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements).
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
If you are a resident of the European Economic Area or Switzerland, you have the following data protection rights:
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
California law (CalOPPA) requires electroCore to let you know how we respond to web browser “Do Not Track (DNT) 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.
We do not knowingly collect any personal information from children under the age of 13 through our Website. If you are under 13, please do not give us any personal information. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Notice by instructing their children never to provide personal information to us without their permission. If you have reason to believe that a child under the age of 13 has provided personal information to us, please contact us at [email protected]
This Privacy Notice was first effective as of 01 January 2017. A high-level summary of any subsequent changes, as well as the new effective date will be included in this section.
On June 22, 2018 this Privacy Notice was amended to comply with the new EU General Data Protection Regulation / to become a global policy.
We may update this Privacy Notice from time to time in response to changing legal, technical or business developments. When we update our Privacy Notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material Privacy Notice changes if and where this is required by applicable data protection laws.
If you have questions or comments about this Privacy Notice, please use the Contact Us information found on this website.
The data controller of your personal information is electroCore, Inc.