Last Updated: October 21, 2024

Please read this Privacy Policy (this “Privacy Policy”) carefully. To use the Services that Syntrillo, Inc. and its affiliates (collectively, “Syntrillo”, “we,” “us,” or “our”) provide, you as a user of the Services must accept this Privacy Policy (“User”, “you”, “your”). If you do not consent to the terms of the Privacy Policy, please do not access or use the Services.

Each User’s participation is also governed by the Medical Service Terms and Conditions, which are entered into and agreed to by each User prior to using Website and the Mobile App (collectively, our “Services”). Unless we define a term in this Privacy Policy, all capitalized terms used in this Privacy Policy have the same meanings set forth in our Terms & Conditions. This Privacy Policy also applies to User’s use of interactive features or downloads that: (i) Syntrillo owns or controls; (ii) are available through the Website or the Mobile App; or (iii) interact with the Website (including through social media) and/or the Mobile App.

This Privacy Policy applies to our Services operated in the United States and we provide this Privacy Policy explaining our online information practices and the choices you can make about the way information is collected and used in connection with the Service. By using our Services, User acknowledges and accepts this Privacy Policy.

We operate in accordance with applicable data protection legislation and regulations. We recognize the importance of protecting the privacy of Personal Information collected from our users.

1. PERSONALLY IDENTIFIABLE INFORMATION AND USER CONTENT WE COLLECT

We collect Personal Information when you use our Services, create an account with us or provide Personal Information to us. “Personally Identifiable Information” (PII) is any information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly with a particular individual, including, but not limited to, a first and last name, unique identifier, email address, a home, postal or other physical address, and phone number. “User Content” is any information generated by you in the course of using the Services. The categories of PII and User Content we may collect about you are:

1. Information you provide to us

• We collect information you give us when you register with us for an account, when you use our Services, when you participate in surveys or promotional activities, give us feedback, or when you otherwise choose to provide your information to us.

• When you sign up for an account we may collect your name, address, phone number, email address, race, ethnicity, title, birth date, sex, gender identification, credit card information, together with other information such as occupation and personal interests. We may also ask for financial information to help pay for services where applicable.

• When you use our Services, such as logging into your account or speaking with our administrative staff, we may collect your name, address, email address, phone number, birth date, credit card information, audio (with your permission), photos and videos (with your permission), or other files in media storage or other shared storage directories (with your permission), and/or request access to your microphone or camera in order to verify your identity and provide Services to you.

• From time-to-time, we invite users to volunteer to participate in surveys or promotional activities or give us feedback. When a user participates, we request certain Personal Information such as name and email address. We may use this information to follow-up with the participants, or, if applicable, to notify contest winners and award prizes

  
  

2. Communications from you

   When you use our Services (for example on our website), complete electronic forms, or contact us by online chat, email, phone, or text, we may automatically collect and store certain information about you and the activity you engaged in, for example: your name and contact information; information that you voluntarily provide to us; the nature of your communication; the purpose of the interaction, and the action we took in response to your inquiry or request
   
   

3. Information related to your use of the Services

   We may automatically collect information about your use of the Services (we refer to this information as “Usage Data“), including information sent by your device. For example, we may collect:

   • Device information, such as your hardware model, IP address (the Internet address of your computer), unique device identifiers, and other information such as your browser type and operating system.

   • Website usage information regarding customer traffic patterns and website usage. This may include the web page that you were visiting before accessing our website or mobile application, the pages or features of our website or mobile application you browsed to inform us which part of our website, app and Services you visit and how much time you spend there.

   • Information about your preferences to make your use of the website more productive through the use of cookies.

   
   

4. Information sent by your mobile devices

   We collect certain information that your mobile devices send when you use our Services, such as the unique identifier, user settings and the operating system of your device, as well as information about your use of our services on your mobile device.
   
   

5. Location information

   When you use our online Services, we may collect and store information about your general location by converting your IP address into a rough geo-location, so we can, for example, provide you with information about services available in your geographic market. 

2. PROTECTED HEALTH INFORMATION

Syntrillo is committed to protecting the privacy of your protected health information (“Protected Health Information”, or PHI). Protected Health Information is a subset of Personal Information that is information about you, including demographic information, that may identify you and that relates to your past, present or future physical or mental health or condition; related health care services; or related to the past, present, or future payment for the provision of health care to you.

3. DATA COLLECTION

a. Information that Syntrillo Collects. Syntrillo gathers various components of Protected Health Information, Personally Identifiable Information and User Content (collectively, “Data”) in the course of our business to provide you a valuable service. Elements of Protected Health Information that we gather includes, but is not limited to, information and details regarding your health, your risk factors, and your stroke history. Personal Information that we collect includes, but is not limited to, your first and last name, email address, profile picture, and age. User Content includes, but is not limited to direct messages between users and stroke experts. Data includes, but is not limited to : User provided data, metadata, system data and statistical information that will be published such as descriptive statistics, coefficients and visualizations.

b. Receipt and Collection of Data. Syntrillo may collect and process Data when User registers for or uses the Services, interacts with the Services, uses any aspect of our Services or otherwise contacts Syntrillo. Specifically, we receive and/or collect Data from you when we receive survey or assessment responses, and when you interact with a stroke expert. Data is collected first and foremost to provide personalized stroke care, but also to conduct clinical trials, and research on Syntrillo products and other products. In each case, you will only be required to provide the Data that we need in order to be able to provide the services you have requested.

c. Consent and Modification. By using the Service, you consent to the terms of this Privacy Policy and to our processing of Data for the purposes set forth herein. If you do not agree to this Privacy Policy, please do not use the Service. We reserve the right, at our discretion, to change this Privacy Policy at any time, which change shall become effective upon posting by the Company on the Website, the Mobile App, via the Service or sending you an email or other notification. You will be deemed to have agreed to Additional Terms (as defined in the Clinical Terms & Conditions) by your decision to continue accessing the Services following the date in which such Additional Terms become effective.

4. HOW SYNTRILLO USES YOUR DATA

Syntrillo uses the Users’ Data that Syntrillo collects for the following general purposes: to provide personalized stroke care, to fulfill User’s request for use of certain features of the Website and/or the Mobile App, to conduct surveys, perform product research, and for Syntrillo’s billing purposes. Syntrillo will collect only as much Data as Syntrillo needs for the purposes specified in this Privacy Policy, for purposes specified at the time of collection of the Personal Information, or for other purposes that you consent to in the future.

Syntrillo aims to protect personal information using technical controls and staff policies with the aim of preventing Syntrillo personnel from identifying individuals when not necessary and only for the provision of services to User. Except as set forth in this Privacy Policy or as specifically agreed to by User, Syntrillo will not disclose any information Syntrillo gathers from User on Syntrillo’s Website, Mobile App and Services. Except as set forth in this Privacy Policy, Syntrillo does not share User’s Personal Information with third parties for those third parties’ direct marketing purposes. Syntrillo may transmit personally identifiable information to third parties about Users that is stored on third-party platforms.  Syntrillo might inform third parties about aggregated de-identified data regarding the number of unique users who visit and/or use Syntrillo’s Services, the demographic breakdown of the registered users of Syntrillo’s Services, or the activities that users engage in while on Syntrillo’s Website and/or Mobile App.

Your User specific Data will be used to provide your personalized care. Your Data will also be combined with data from other Users. This will allow Syntrillo to conduct research studies including clinical trials, and research on products developed by Syntrillo now or in the future.  There will be a need to follow individual users, and aggregate their data, across several Syntrillo products. Mathematical, statistical and Artificial Intelligence tools and methods will be applied to this combined data set. The objectives are, but are not limited, to develop clinical and marketing algorithms in the field of Stroke Prevention. 

5. USE OF THIRD-PARTY TECHNOLOGY

Syntrillo utilizes custom-built software and third-party commercial software to provide the Services.

Syntrillo may use third-party platforms for communication between you and Syntrillo (e.g. EHR/patient portal, direct messaging platforms, etc), and automation of data collection, transfer and processing (such as, but not limited to, Amazon Web Services). When using a third-party managed technology environment or service, your information is subject to their safety and security procedures. Syntrillo has entered into agreements under HIPAA with each of these third-party entities to ensure privacy and security are maintained in the various environments. Each party is responsible for maintaining compliance with HIPAA and Privacy laws within their own platforms.

6. PERSONAL DATA ACCESS REQUESTS

Users can at any time request details of data held by Syntrillo.  Requests will be handled within 28 days. Users can also request that Personal Data held about themselves be permanently deleted from systems directly managed by Syntrillo.  Syntrillo will respond to such requests within 28 days and subject to the needs to comply with any State or Federal law preventing the deletion shall provide confirmation of data deletion.

7. NOTICE TO CALIFORNIA RESIDENTS

If you are a California resident, California law may provide you with additional rights regarding our use of your personal information.

8. MORE INFORMATION

How can I get more information about the Privacy Policy?

If User has questions or concerns about the Privacy Policy, User can contact Syntrillo at privacy@syntrillo.com.

Updates/Modifications

Syntrillo reserves the right to amend this Privacy Policy at any time as needed with notice provided to User. Changes will take effect upon User’s acceptance of the modified terms and User’s continued use of the Website, Mobile App and/or Services.