Last updated December 5, 2022
electroCore, Inc (doing business as Truvaga) (“Truvaga,” “we,” “us,” or “our”), respects your privacy and is committed to protecting it through our compliance with this policy.
This policy describes the types of information we may collect from you or that you may provide when you visit the website www.truvaga.com
(or “Website”) and our practices for collecting, using, maintaining, protecting, and disclosing the information.
This policy applies to information we collect:
- On this Website.
- In email, text, and other electronic messages between you and this Website.
- When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy.
This policy does not apply to information collected by:
- Us offline or through any other means, including on any other website operated by us or any third party (including our affiliates and subsidiaries); or
- Any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or through the Website.
This Website is not offered or available to users who reside in the European Union (“EU”) or United Kingdom (“UK”). If you reside in the EU or UK: (i) do not provide any personal information to us on or through this Website; and (ii) if you reside in the EU or UK and believe that you have provided us with personal information please contact us at firstname.lastname@example.org
and we will delete any such information.
Children Under the Age of 18
Our Website is not intended for children under 18 years of age. No one under age 18 may provide any information to the Website. We do not knowingly collect personal information from children under 18. If you are under 18, do not use or provide any information on this Website or through any of its features, register on the Website, make any purchases through the Website, or provide any information about yourself to us, including your name, address, telephone number, or email address. If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us at email@example.com
California residents under 16 years of age may have additional rights regarding the collection and sale of their personal information. Please see Your State Privacy Rights
for more information.
SUMMARY OF KEY POINTS
This summary provides key points from our privacy notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for. You can also click here to go directly to our table of contents.
What personal information do we process?
When you visit, use, or navigate our Website, we may process personal information depending on how you interact with Truvaga and the Website, the choices you make, and the products and features you use. Contact firstname.lastname@example.org
to learn more.
Do we receive any information from third parties?
We may receive information from third parties such as Google Analytics and other cookie providers, our credit card processor Stripe, and our affiliates and subsidiaries. For more information regarding information we receive from third parties, contact email@example.com
How do we process your information?
We process your information to provide, improve, and administer our Website, to provide services to you, to fulfill any contractual obligations, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so. Contact firstname.lastname@example.org
to learn more.
In what situations and with which types of parties do we share personal information?
We may share information in specific situations and with specific categories of third parties. Contact email@example.com
to learn more.
What are your rights?
Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. Contact firstname.lastname@example.org
to learn more.
How do you exercise your rights?
The easiest way to exercise your rights is by contacting us at email@example.com
. We will consider and act upon any request in accordance with this policy and any applicable law.
Want to learn more about what Truvaga does with any information we collect? Contact firstname.lastname@example.org
TABLE OF CONTENTS
- WHAT INFORMATION DO WE COLLECT?
- HOW DO WE PROCESS YOUR INFORMATION?
- WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
- HOW LONG DO WE KEEP YOUR INFORMATION?
- HOW DO WE KEEP YOUR INFORMATION SAFE?
- DO WE COLLECT INFORMATION FROM MINORS?
- CHOICES ABOUT HOW WE DISCLOSE YOUR INFORMATION
- CONTROLS FOR DO-NOT-TRACK FEATURES
- HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
- HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
1. WHAT INFORMATION DO WE COLLECT?
Personal information you disclose to us
We collect several types of information from and about users of our Website, including information:
- By which you may be personally identified, such as name, postal address, email address, telephone number, payment information, and any other identifier by which you may be contacted online or offline (“personal information”);
- That is about you but individually does not identify you; and/or
- About your internet connection, the equipment you use to access our Website, and usage details.
We collect this information:
- Directly from you when you provide it to us.
- Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.
- From third parties, for example, our business partners.
Personal Information Provided by You.
The personal information that we collect depends on the context of your interactions with us and the Website, the choices you make, and the products and features you use. The personal information we collect may include the following:
- email addresses
- phone numbers
- mailing addresses
- billing addresses
- debit/credit card numbers
We also may collect information such as:
- Records and copies of your correspondence (including email addresses), if you contact us.
- Your responses to surveys that we might ask you to complete for research purposes.
- Details of transactions you carry out through our Website and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Website.
- Your search queries on the Website.
You also may provide information to be published or displayed (hereinafter, “posted”) on public areas of the Website, or transmitted to other users of the Website or third parties (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk. Additionally, we cannot control the actions of other users of the Website with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.
We may collect data necessary to process your payment if you make purchases, such as your payment instrument number, and the security code associated with your payment instrument. All payment data is stored by Stripe . You may find their privacy notice link(s) here: https://stripe.com/privacy
All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.
Information Collected through Automatic Data Collection Technology
We automatically collect certain information when you visit, use, or navigate the Website. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Website, and other technical information. This information is primarily needed to maintain the security and operation of our Website, and for our internal analytics and reporting purposes.
Like many businesses, we also collect information through cookies and similar technologies.
The technologies we use for this automatic data collection may include:
- Web Beacons. Pages of our Website may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit Truvaga, for example, to count users who have visited those pages and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
- Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Choices About How We Use and Disclose Your Information.
The information we collect includes:
Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Website and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Website (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called “crash dumps”), and hardware settings).
Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Website. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.
Location Data. We collect location data such as information about your device’s location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Website. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. However, if you choose to opt out, you may not be able to use certain aspects of the Website.
We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see Choices About How We Use and Disclose Your Information.
2. HOW DO WE PROCESS YOUR INFORMATION?
We process your personal information for a variety of reasons, depending on how you interact with our Website, including:
- To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service.
- To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.
- To send administrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information.
- To fulfill and manage your orders. We may process your information to fulfill and manage your orders, payments, returns, and exchanges made through the Website.
- To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Website.
- To send you marketing and promotional communications. We may process the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt out of our marketing emails at any time. For more information, see “WHAT ARE YOUR PRIVACY RIGHTS?” below.
- To deliver targeted advertising to you. We may process your information to develop and display personalized content and advertising tailored to your interests, location, and more.
- To post testimonials. We post testimonials on our Website that may contain personal information.
- To protect our Website. We may process your information as part of our efforts to keep our Website safe and secure, including fraud monitoring and prevention.
- To administer prize draws and competitions. We may process your information to administer prize draws and competitions.
- To evaluate and improve our Website, products, marketing, and your experience. We may process your information when we believe it is necessary to identify usage trends, determine the effectiveness of our promotional campaigns, and to evaluate and improve our Website, products, marketing, and your experience.
- To identify usage trends. We may process information about how you use our Website to better understand how they are being used so we can improve them.
- To determine the effectiveness of our marketing and promotional campaigns. We may process your information to better understand how to provide marketing and promotional campaigns that are most relevant to you.
- To comply with our legal obligations. We may process your information to comply with our legal obligations, respond to legal requests, and exercise, establish, or defend our legal rights.
- In any other way you describe when you provide the information.
- For any other purpose with your consent.
We may also use your information to contact you about goods and services that may be of interest to you. If you do not want us to use your information in this way, please email email@example.com
. For more information, see Choices About How We Use and Disclose Your Information.
3. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.
We may share personal information in specific situations described in this section and/or with the following categories of third parties.
Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents (“third parties”) who perform services for us or on our behalf and require access to such information to do that work. We have contracts in place with third parties, which are designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will also not share your personal information with any organization apart from us. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct. The categories of third parties we may share personal information with are as follows:
- Ad Networks
- Sales & Marketing Tools
- Finance & Accounting Tools
- Data Analytics Services
- Communication & Collaboration Tools
- Social Networks
- Payment Processors
- Retargeting Platforms
We also may need to share your personal information in the following situations:
- Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
- Business Partners. We may share your information with our business partners to offer you certain products, services, or promotions.
- To fulfill the purpose for which you provide it. For example, if you give us an email address to use the “email a friend” feature of our Website, we will transmit the contents of that email and your email address to the recipients.
- For any other purpose disclosed by us when you provide the information.
- With your consent.
We may also disclose your personal information:
- To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
- If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Truvaga, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
The categories of personal information we may disclose include:
- email addresses
- phone numbers
- mailing addresses
- billing addresses
- debit/credit card numbers
- Information collected by automatic collection technologies, as set forth above.
4. HOW LONG DO WE KEEP YOUR INFORMATION?
We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information 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.
5. HOW DO WE KEEP YOUR INFORMATION SAFE?
We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. Any payment transactions will be encrypted using SSL technology.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Website like reviews. The information you share in public areas may be viewed by any user of the Website.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.
6. DO WE COLLECT INFORMATION FROM MINORS?
We do not knowingly solicit data from or market to children under 18 years of age. By using the Website, you represent that you are at least 18. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at firstname.lastname@example.org
7. CHOICES ABOUT HOW WE DISCLOSE YOUR INFORMATION
We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:
Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?” below.
However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, replying “STOP” or “UNSUBSCRIBE” to the SMS messages that we send, or by contacting us using the details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?” below. You will then be removed from the marketing lists. However, we may still communicate with you — for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.
Cookies and similar technologies:
Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Website. To opt out of interest-based advertising by advertisers on our Website visit http://www.aboutads.info/choices/
If you have questions or comments about your privacy rights, you may email us at email@example.com
8. CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.
Your State Privacy Rights
State consumer privacy laws may provide their residents with additional rights regarding our use of their personal information. To learn more about California residents’ privacy rights, please see California Resident Privacy Rights below. California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to firstname.lastname@example.org
Colorado, Connecticut, Virginia, and Utah each provide their state residents with rights to:
- Confirm whether we process their personal information.
- Access and delete certain personal information.
- Data portability.
- Opt-out of personal data processing for targeted advertising and sales.
Colorado, Connecticut, and Virginia also provide their state residents with rights to:
- Correct inaccuracies in their personal information, taking into account the information’s nature processing purpose.
- Opt-out of profiling in furtherance of decisions that produce legal or similarly significant effects.
Nevada provides its residents with a limited right to opt-out of certain personal information sales. Residents who wish to exercise this sale opt-out rights may submit a request to this designated address: email@example.com
We may update this privacy notice from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.
9. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
If you have questions or comments about this notice, you may email us at firstname.lastname@example.org
or by post to:
electroCore, Inc. d/b/a Truvaga
200 Forge Way
Rockaway, NJ 07866 United States
10. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it. To request to review, update, or delete your personal information, please submit a request form to email@example.com
California Residents Privacy Rights
California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information above. If you are under 18 years of age, reside in California, and have a registered account with the Website, you have the right to request removal of unwanted data that you publicly post on the Website. To request removal of such data, please contact us using the contact information provided below and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Website, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g., backups, etc.).
CCPA Privacy Notice
The California Code of Regulations defines a “resident” as:
(1) every individual who is in the State of California for other than a temporary or transitory purpose; and
(2) every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose.
All other individuals are defined as “non-residents.”
If this definition of “resident” applies to you, we must adhere to certain rights and obligations regarding your personal information.
What categories of personal information do we collect?
Please review the following chart relating to the categories of personal information we have collected in the past twelve (12) months: