Privacy Policy

Last modified: 04/01/2024

Sonex Health, Inc. (“Sonex“, “we”, “us“ or “our“) understands the importance of privacy to our customers, visitors, suppliers, business partners, employees and other individuals (“you”, “user”, or “data subject”). We are committed to protecting and respecting your privacy.

This Sonex Privacy Policy (“Policy”) tells you how we protect and use information that we gather through this Sonex Medical website which consists of (https://sonexhealth.com),(https://curemycarpaltunnel.com) and (https://ctrstudy.com) (collectively, the “Site”) which is hosted in the United States. This Site is intended for a U.S. audience. This Policy applies only to the website(s) on which it is posted. It does not apply to third-party platforms or to other Sonex-operated websites or other Sonex-operated platforms on which it is not posted. It also does not apply to information collected through other channels, such as over the phone or in person, or as part of a clinical study.

Some of the information we collect through this Site may be “personal data” as defined below, collected when you visit or use this website.

This Policy may be supplemented or amended from time to time by additional privacy notices (“Privacy Notices”), provided at the time we collect your information. For example, certain pages of this Site may contain Privacy Notices providing more details about the information we collect on those particular pages, why we need that information, and choices you may have about the ways we use that information. In other cases, specific Privacy Notices may be required to comply with the privacy laws of one of the countries, provinces, or states in which we do business.

If you have a disability, you may request access to this Policy in an alternative format by contacting info@sonexhealth.com.

By using this Site, you agree to the collection, use, disclosure, and transfer of your information as described in this Policy (and any Privacy Notices that apply to you). If you do not agree to the collection, use, disclosure and transfer of your information as described in this Policy (and any Privacy Notices that apply to you), you may not use this Site. If you have questions about this Policy, or any Privacy Notice, please contact us using the information provided below..

You may withdraw your agreement for the collection, use, disclosure, and transfer of your information as described in this Policy (and any Privacy Notices that apply to you) by contacting us directly.

Complete Agreement

This Policy is part of the Terms of Use that govern your use of this Site. Except as written in any other disclaimers, policies, or other notices on this Site, this Policy and the Terms of Use are the complete agreement between you and Sonex with respect to your use of this Site. Any terms we use in this Policy without defining them have the definitions given to them in the Terms of Use. There may be additional terms that apply to particular materials on or sections of this Site.

Changes to this Policy

Sonex reserves the right to update or modify this Policy and any Privacy Notice, at any time and without prior notice, by posting the revised version of the Policy or Privacy Notice on this Site. These changes will only apply to the information we collect after we have posted the revised Policy or Privacy Notice on this Site.

Your use of this Site following any such change constitutes your agreement that all information collected from or about you after the revised Policy is posted will be subject to the terms of the revised Policy. You may access the current version of this Policy at any time by clicking on the link marked “Privacy Policy” at the bottom of each page of the public areas of this Site.

This Policy was last updated on 04/01/2024. The update included a complete revision of the Policy, including more details about how we collect and use Personal Information.

Information We Collect

Personal Data means any information relating to an identified or identifiable natural person (“Data Subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Personal Data You Manually Provide.
Sonex collects the information you manually provide (using your keyboard, mouse, or touchpad) when you use this Site, such as if you complete a pre-screening questionnaire or similar questionnaire, contact us with questions, or otherwise interact with this Site. Some of the information you may choose to manually provide will be Personal Data including but not limited to:

Contact data: such as name, title, address, phone number, mailing address, and email.
Other identifiers: such as device ID or serial number, various types of personal health information (e.g., health insurance information, medical information, and the like), online identifiers, and other similar identifiers.
Communication data submitted by you: such as questions and feedback.
Demographic data: such as language, age, and gender.
Marketing preferences: such as e-mail subscription and frequency preferences.

Examples of volunteering Personally Information on this Site include filling out a “Contact Us” form or sending Sonex an email through this Site. By submitting information on the “Contact Us” form, you acknowledge that we may reply to you by email

Information Automatically Collected
Sonex collects information that is sent to us automatically by your web browser or mobile device. This information includes but is not limited to:

Product use and application data (including date and time of your visit)
IP address
The browser you are using (including name and version)
Your location and other geographic data
The website you came from and the website you visit after leaving
Pages viewed on the Site
Links clicked on the Site
Time spent on a particular page of the Site or the Site as a whole
Site data used to facilitate the use of the Site such as login and technical data

The information we receive may depend on your browser or device settings. The information we receive from your web browser and device typically is not, in and of itself, personally identifiable. However, we may combine it with other information in an attempt to identify you or we may combine it with information that does identify you.

Information Collected by Cookies and Other Technologies
A cookie is a small piece of text sent to your browser by a website you visit. It helps the site remember information about your visit, which can make it easier to visit the site again and make the site more useful to you.
We may use “cookies” and other technologies to collect information and support certain features of this Site. For example, we may use these technologies to:

Collect information about the ways visitors use this Site—which pages they visit, which links they use, and how long they stay on each page
Support the features and functionality of this Site—for example, to save you the trouble of reentering information already in our database or to prompt the settings you established on previous visits
Personalize your experience when you use this Site; and
Improve our marketing efforts, including through use of targeted advertising.

The information we may collect using cookies and similar technologies is not, in and of itself, personally identifiable, but we may link it to Personal Information that you provide. If you do not wish to receive cookies, you may set your browser to reject cookies or to alert you when a cookie is placed on your computer. Although you are not required to accept cookies when you visit this Site, you may be unable to use all of the functionality of this Site if your browser rejects our cookies.

We may use both session and persistent Cookies for the purposes set out below:

Necessary / Essential Cookies

Type: Session Cookies
Administered by: Us
Purpose: These Cookies are essential to provide You with services available through the Site and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services.

Cookies Policy / Notice Acceptance Cookies

Type: Persistent Cookies
Administered by: Us
Purpose: These Cookies identify if users have accepted the use of cookies on the Site.

Functionality Cookies

Type: Persistent Cookies
Administered by: Us
Purpose: These Cookies allow us to remember choices You make when You use the Site, such as remembering your login details or language preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter your preferences every time You use the Site.

Tracking and Performance Cookies

Type: Persistent Cookies
Administered by: Third Parties
Purpose: These Cookies are used to track information about traffic to the Site and how users use the Site. The information gathered via these Cookies may directly or indirectly identify you as an individual visitor. This is because the information collected is typically linked to a pseudonymous identifier associated with the device you use to access the Site. We may also use these Cookies to test new advertisements, pages, features or new functionality of the Site to see how our users react to them.

Information Collected by Third-Party Cookies

In addition to the cookies Sonex delivers to your computer or mobile device through this Site, certain third parties (Tracking and Performance Cookies) may deliver cookies to you for a variety of reasons. For example, we may use a web analytics tool that helps us understand how visitors engage with our Sites.

Other third parties may deliver cookies to your computer or mobile device for the purpose of tracking your online behaviors over time and across nonaffiliated websites and/or delivering targeted advertisements either on this Site or on other websites.

You have choices about the collection of information by third parties on our Sites. For example, if you don’t want information about your visit to this Site sent to Google Analytics, you may download an Opt-out Browser Add-on by clicking here. Similarly, to opt-out of cookies used for interest-based advertising by similar services globally, click here or here.

You will be directed to an industry-developed website that contains mechanisms for choosing whether each listed entity may collect and use data for online behavioral advertising purposes. It may be that some of the third parties that collect interest-based information on this Site do not participate in the industry-developed opt-out website, in which case the best way to avoid third-party tracking of your online behaviors may be through your browser settings and deletion of cookies. Please note that the industry-developed opt-out mechanisms are device and browser specific. If you wish to opt-out from having interest-based information collected by participating entities across all devices and browsers, you need take the steps outlined above from each device and browser.

How We Use Your Information

We may use the information we collect through this Site for various purposes, including the but not limited to:

To provide you with access to this Site.
To respond to your requests.
To personalize your access to our Site.
To develop records (including records of your Personal Information, e.g., for service or product support).
To contact you with pertinent information about products, clinical trials, or important safety information, and about products and services of ours and of others.
To evaluate your eligibility or interest to enroll in clinical studies.
For analytical purposes and to research, develop, and improve programs, products, services, and content.
To guide and inform marketing and sales activities.
To remove your personal identifiers. Once we have de-identified information, it is considered non-Personal Information and we may treat it like other non-Personal Information.
To enforce this Policy and other rules about your use of this Site.
To protect someone’s health, safety, or welfare.
To protect our rights or property.
To comply with a law or regulation, court order or other legal process, such as preventing, detecting and investigating security incidents and potentially illegal or prohibited activities.

Sonex will not share Personal Information about you collected from this website with an unrelated third party except as provided in this Policy. We may share for the following purposes.

With Third–Party Vendors
Sonex shares information collected through this Site with third-party vendors who act for us or on our behalf. For example, we may use third-party vendors to design and operate this Site; to conduct surveys and clinical studies; and to help us with our promotional efforts (such as to operate our Mobile Messaging Program as described below). These third-party vendors may need information about you to perform their functions on our behalf. In general, we require our third-party service providers and vendors to restrict their use of any personally identifiable information received through our Site to the intended purposes.

With Third-Party Social Media Platforms
We may also use third-party social media platforms to offer you interest-based ads. To offer such ads, we may convert your email address into a unique value which can be matched by platform vendors with a user on their platform. Although we do not provide any Personal Information to these platform vendors, they may gain insights about individuals who respond to the ads we serve.

For the Purpose of Determining your Eligibility for a Clinical Study
If you choose to provide information through our Site to see if you qualify to participate in a clinical study, we may share your information with business partners or potential study center(s) so that they may contact you to see if you are a suitable candidate for one of our clinical studies.

With Health Care Providers
Your Personal Information may be shared with a physician or other healthcare provider if: (i) you request to be put in contact with a physician or other healthcare provider, (ii) you are seeking more information about whether a product or service may be right for you, or (iii) you or someone else’s safety or wellbeing is in question.

In Aggregate or De-Identified Form
We use information collected through this Site to create a compiled, aggregate view of usage patterns. We may share aggregate information with third parties for various purposes including so they can better understand our user base. We may also share with third parties information about how particular individuals use this Site, but only on a de-identified basis (“Individualized Data”). Individualized Data is not personally identifiable, but it does reflect the usage patterns of a particular Site user, as opposed to Site users collectively. For clarity, we may use and share aggregated or de-identified data without restriction.

As Part of a Business Transfer
Your information may be transferred to successor organization if, for example, we transfer the ownership or operation of this Site to another organization or if we merge with another organization or liquidate our assets. If such a transfer occurs, the successor organization’s use of your information will still be subject to this Policy and the privacy preferences you have expressed to us.

To Comply with Laws and Protect Our Rights and the Rights of Others
We may disclose your information when we, in good faith, believe disclosure is appropriate to comply with the law, a court order or a subpoena. We may also disclose your information to prevent or investigate a possible crime, such as fraud or identity theft; to protect the security of this Site; to enforce or apply our online Terms of Use or other agreements; or to protect our own rights or property or the rights, property or safety of our users or others.

As Described in a Privacy Notice or Click-Through Agreement
We reserve the right to disclose your information as described in any Privacy Notice posted on a page of this Site where you provide that information. By providing your information on that page you will be agreeing to or consenting to the use and disclosure of your information as described in that privacy notice. We also reserve the right to disclose your information as described in any click–through agreement to which you have agreed.

Sonex will not sell your information to any third parties.

How We Protect Your Information

Sonex takes reasonable precautions to provide a level of security appropriate to the sensitivity of the information we collect. Although we use reasonable measures to help protect your information against unauthorized use or disclosure, we cannot guarantee the security of information provided over the Internet or stored in our databases and will not be responsible for breaches of security beyond our reasonable control.

Transfer and Storage of Your Personal Information

We may store, collect, transfer, and process your Personal Information in the United States. Privacy and data protection laws in the U.S. may be different than your country. By submitting your Personal Information, you agree and acknowledge such transfers, storage, and processing, including onward transfers.

Retention of Your Information

Sonex retains the Personal Information collected on this Site as long as necessary to fulfill the purpose for which it is collected or as permitted or required by applicable law.

Children’s Privacy

This Website is not targeted to children under the age of 13 and we do not knowingly collect or solicit Personal Information about such children. If we discover that a child has provided us with Personal Information online through this Website, we will take steps to delete this information as quickly as possible. If you believe we may have received Personal Information from a child under the age of 13, please contact us immediately at Info@sonexhealth.com

Marketing E-mail Opt-out

We may contact you to provide information about products, services and content that may be of interest to you. You may revoke your consent for the receipt of marketing communications that we send to you at any time by using the “unsubscribe” functionality included in our emails to you or by contacting us directly.

You should note that this will not affect all communications from us, for example, we are legally required to provide notices such as notification of a data breach in which case you should expect to receive a notification via email. We may also communicate with you for business purposes including to respond to communications from you, such as if you submit an online form on our Site.

Data Subject Rights
Your rights will vary depending on which laws apply, and different laws may apply depending on where or your data is located. You may make a request to exercise any rights that you may have, and we will comply with any laws that apply. You may have the following rights:

Know. You may have the right to know about and confirm the existence of Personal Data about you, how we use or share it, what categories of Personal Data we process, our purposes of processing, and categories of parties we disclosed Personal Data to.
Access and portability. You may have the right to access your Personal Data, specific pieces of information, and know of third parties Personal Data was disclosed. You may have a right to obtain a copy of your data, including in a machine-readable format or have it transferred to someone else.
Correction. You may have the right to correct or amend your data if it is incomplete, inaccurate, or outdated.
Deletion or elimination. You may have the right to request your Personal Data be deleted or eliminated. Subject to applicable law, we may de-identify this data in certain circumstances.
Restriction. You may have a right to restrict processing of your data in some circumstances, such as if processing is excessive or unlawful, the accuracy of the data is contested, the controller no longer needs the data for its primary processing purposes but is needed for legal or compliance purposes, or if the data is sensitive Personal Data (e.g., health information) and it is being used for purposes beyond those reasonably necessary to perform services or provide goods requested.
Objection and opt–out. You may have the right to object to or opt-out of processing of Personal Data about you in certain circumstances. This can include cases where that data is used for direct marketing (including email or telephonic marketing), shared with third parties for their own marketing or for retargeting or cross-contextual marketing, sold to third parties, used to make certain automated or artificially-generated decisions or profiles about you, used for historical or scientific research, or used to contact you with automated/prerecorded voice telephonic messages in some cases.
Consent and cancelation of consent. You may have the right to consent, and to withhold or cancel that consent, for some practices, including processing of sensitive Personal Data (such as health information) or data on children, or where we use consent as our lawful basis for processing or transfer. If you cancel your consent, we will not further collect or process the Personal Data on the basis ofthat consent unless allowed or required by applicable law.
Non–discrimination. We will not discriminate against you for exercising your rights. This does not necessarily include, where permitted by applicable law in your jurisdiction, cases where a difference in price or services offered is reasonably related to the value provided by Personal Data you provide, or where you consent to participate in a voluntary program offering incentives (such as a loyalty program).
Appeal. You may have the right to appeal decisions we make about the exercise of your rights. To submit an appeal to a decision we made about the exercise of your rights, you may send an email info@sonexhealth .com. Please enclose a copy, or otherwise specifically reference our decision on your data subject request, to allow us to address your appeal. We will strive to comply with applicable law when we respond to your appeal.
Make a complaint. You may have the right to complain to regulators, such as your state attorney general, local data protection agency or authority, or other public bodies responsible for data protection and privacy enforcement. If you are not satisfied with our response to your request or if you have concerns about our data practices.

Submitting a Request or Inquiry

If you want to submit a request or inquiry to us regarding privacy rights you may have, you or your authorized agent (someone acting on your behalf) can contact us using our contact information below. You do not have to create an account with us to submit a request.
Your request will be confirmed within ten days of receipt and we will respond within 45 days, unless shorter periods are required by law. If we need more than 45 days, we will notify you that your request is being delayed.
We can only respond to your request if it is verifiable. This means we are obligated to take reasonable steps to verify your identity or your authorized agent’s authority and your right to access the information you request. In the process of verifying your request, we may contact you to ask for additional information that will help us do so, including government-issued IDs containing your name and address, utility bills containing that same information, and/or unique identifiers like usernames. We will only use that additional information in the verification process, and not for any other purpose. Once we have received and verified the requested information from you, we will contact you with our response to your request, including any data, if applicable. If we do not hear from you or are unable to verify your identity for the request, we will contact you to inform you that we cannot process your request because we cannot verify your identity.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
We will respond to reasonable requests in accordance with applicable law and subject to legal and contractual restrictions. We will not discriminate against you for exercising these rights.
There may be times where we cannot comply with your request. For example, if such disclosure would interfere with the privacy of others or if it would result in a breach of confidentiality. We will provide an explanation for our refusal to grant access.
Washington residents, please also see the respective Privacy Addendum for further details.

Data Subject Rights Contact
Sonex Health
Marketing Department
950 Blue Gentian Road, Suite 200
Eagan, MN 55121
888-518-8780
info@sonexhealth.com

Mobile Messaging Program

Sonex operates a mobile messaging program to send communications about its products and services. You may enroll by opting to receive text messages, including SMS and MMS text messages. The mobile messaging program is completely voluntary, and you may choose not to participate by not opting into the program. You will be responsible for message and data rates which may apply based on your mobile service provider.

By enrolling, signing up, or otherwise agreeing to participate, we will use the phone number you have provided us to communicate with you, including to send automated promotional and/or transactional communications in various formats. Transactional messages relate to an existing or ongoing transaction and may include appointment reminders and satisfaction surveys. Promotional messages will promote our products and services and may include educational materials or other information. You will be able to opt-out at any time by replying “STOP, QUIT, CANCEL, OPT-OUT, and/or UNSUBSCRIBE” to any text messages from us. Although you might not receive product information or updates as frequently if you opt-out of the program, opting out will not interfere with any future or ongoing business relationship between you and Sonex.

By providing your mobile phone number, you affirm that you are the owner or authorized user of the associated mobile phone, and that there is an established business relationship between yourself and Sonex. If you change your mobile phone number or are no longer the owner or authorized user of the mobile phone number, you will promptly notify us using the contact information in this Policy.

We may change the telephone number or short code we use to operate the program and we will notify you of any such change. You acknowledge that any requests sent to a telephone number or short code that has been changed may not be received by us and we will not be responsible for failing to honor a request sent to a telephone number or short code that has been changed.

Links to Other Websites

This Policy applies only to the Sonex-operated websites on which it is posted. Sonex and its affiliates may operate different websites for different purposes and in different countries, where different laws may apply. If you visit another Sonex website, please take a moment to review the privacy policy posted on that site to learn what information may be collected through that site and how it is processed. This Site may also contain links to websites that are not operated by or on behalf of Sonex or its affiliates. These links are provided for your reference and convenience only and do not imply any endorsement of the products sold or information provided through these websites, nor any association with their operators. Sonex does not control these websites and is not responsible for their data practices. Any information you provide to third parties on their websites is covered under their privacy and data collection policies and is not covered by this Policy. We urge you to review the privacy policy posted on any site you visit before using the site or providing any Personal Information.

Contact Us

If you have any questions regarding this Privacy Policy or about our privacy practices, or need to contact us for purposes related to this Policy, please contact us at info@sonexhealth.com

Addendum: California Residents Privacy Notice
Effective April 1, 2023

“Do Not Track” Policy for California Online Privacy Protection Act (CalOPPA)

Our Site does not respond to Do Not Track signals. However, some third-party websites do keep track of your browsing activities. If you are visiting such websites, you can set your preferences in your web browser to inform websites that you do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of your web browser.

California’s Shine the Light law

Under California Civil Code Section 1798 (California’s Shine the Light law), California residents with an established business relationship with us can request information once a year about sharing their Personal Information with third parties for the third parties’ direct marketing purposes.

If you’d like to request more information under the California Shine the Light law, and if you are a California resident, you can contact us using the contact information provided in this Policy.

Addendum: Washington My Health My Data Act (“MHMDA”)
Effective June 30, 2024

Categories of Consumer Health Information We Collect and Share

If you are a Washington resident, this addendum applies to you and you have the rights set forth in this section. Please see the “Exercising Your Rights” section below for instructions regarding how to exercise these rights.

“Consumer Health Data” is used in this addendum as it is defined in the Washington My Health My Data Act (MHMDA). It generally includes any information that is linked or reasonably linkable to a Washington resident and that identifies that individual’s past, present, or future physical or mental health status. Excluded from Consumer Health Data are certain types of health information, such as when we must collect, use and disclose health information to meet our regulatory obligations or as part of a clinical trial. We do not collect, share, or sell Consumer Health Data unless we have your consent.

See the chart below for categories of Consumer Health Data we may collect and process about you, if you give us your consent.

Category of Consumer Health Data	Purpose for Processing Data	Source of Information	Shared / Recipients
Individual health conditions, treatment, diseases, or diagnosis	•Consumer education and outreach •Product improvement	•Consumer opt-in •Consumer surveys	•Service providers •Healthcare providers
Dynamics interventions
Health-related surgeries or procedures
Use or purchase of prescribed medication
Bodily functions, vital signs, symptoms
Diagnoses or diagnostic testing, treatment, or medication
Genetic data	N/A	N/A	N/A
Precise location information that could reasonably indicate a consumer’s attempt to acquire or receive health services or supplies (geofencing)	•Consumer education and outreach	•Consumer opt-in	•Service providers •Healthcare providers
Data that identifies a consumer seeking healthcare services	•Consumer education and outreach •Physician finder support	•Consumer opt-in •Consumer surveys	•Service providers •Healthcare providers

Exercising Your Rights Under MHMDA

As a resident of Washington, you have the right to:

Confirm whether Sonex is collecting, sharing, or selling Consumer Health Data concerning you and to access such data, including:
- A list of all third parties and affiliates with whom Sonex has shared or sold the Consumer Health Data
- Access an active email address or other online mechanism that you may use to contact these third parties
Withdraw consent from Sonex to collect and share your consumer health data
Request to have Consumer Health Data concerning you deleted and exercise that right by informing Sonex of your request for deletion
Appeal if Sonex does not address an attempt to exercise one or more of these rights to your satisfaction

You may request that Sonex take the actions outlined in the paragraphs above to exercise your rights under MHMDA by submitting a request, at any time, using the contact information within this Privacy Policy to Sonex. Sonex must respond within forty-five (45) days unless an extension is requested (for up to 45 additional days).