Privacy Policy

Somatus Inc. (“Somatus,” “we,” or “us”) recognizes the importance of protecting the privacy needs of users of our websites and social media pages and through other interactions by email, surveys, or telephone. This Privacy Policy describes the types of personal information we may collect from you or that you may provide (i) through the Somatus website available at https://somatus.com/ (the “Website”); (ii) while using the services and information available via the Website (the “Services”) (the Services, together with the Website, our “Platform”); or (iii) through our social media pages and through other interactions by email, surveys, or telephone. Please read this policy carefully to understand our policies and practices regarding your personal information and how we will treat it. 

This Privacy Policy does not apply to the personal information, including health information, that we collect in the course of providing treatment services or personal information collected through the MySomatus mobile applicable. Please see our HIPAA Notice of Privacy Practices for more information about how we receive and process that personal information.

INFORMATION WE COLLECT AND USE

Through the Platform and by Email and Telephone. We collect and store the following personal information and use it for typical business purposes (including security and anti-fraud purposes), as described more specifically below.

• Personal identifiers. We receive personal identifiers (such as your name, phone number, e-mail address, and mailing address) and use them to respond to your requests, and to communicate with you for marketing, surveys, and informational purposes. We may also collect and use this information to respond to feedback, complaints, and to provide information about our products and services.
• Message content. We receive messages you provide through email, by phone, or a contact us form on the Platform, including in connection with customer service requests, appointment requests, surveys, and complaints. We use this information to respond to your requests and to improve the Platform and our service. We may also use this information to post reviews on our Platform.
• Business-related information. We may receive business-related information when you contact us (such as the name of your organization and the type of organization). We use this information to respond to your requests.
• Location information. We may use some of the information we collect, such as IP addresses, to estimate an approximate location of the device you are using to access our Platform in order to enhance and personalize the features and functionality of the Platform and service offerings.
• Survey information. We may receive survey responses that you submit to us. We use this information for research and other business purposes.
• Professional and education information.  We receive the professional and educational information you submit to the careers area of the Platform.  We use this information to evaluate your application and, if employed, for employment purposes.
• Anonymous or aggregated information. We de-identify or aggregate data we receive and may use and disclose it for any business purpose.
• Inferences. We may draw inferences from the categories of information described above. This information may be used so that we can improve future user experiences with the Somatus and to provide a more personalized experience.

Social Media.  If you post information on our social media pages, we may use the information to respond to your post, to promote our business and services, and in the normal course of our business operations. We may collect personal identifiers, such as your social media username, and other personal characteristics that you have made publicly available on the social media website. Note that the third-party operators of social media websites also receive such information and your posts, and their use of your personal information is governed by their own privacy policies.

Automatically Through the Platform. When you visit our Platform, we and our third-party partners and analytics providers including Google Analytics, collect information by automated means. Such means include the use of cookies, web beacons, web server logs, and other similar technologies.

We may use such technologies to collect personal identifiers (such as your IP address), information about your device (such as your browser characteristics, device IDs and characteristics, operating system version, and language preferences) and information concerning your usage of our Platform (including the link you used to reach a given webpage). For example, we use this information to determine how many users have visited particular webpages, viewed particular content, or opened messages or alerts, and we may also use such information to improve the performance of the Platform, to improve our marketing activities, and to enforce our website service terms, prevent malicious conduct, and for anti-fraud and security purposes.

In some cases, our third-party partners may process information collected by cookies and related technologies that we permit them to use on the Platform. With respect to any social network pages that we may use, please see the privacy policies and any cookie policies of the applicable social network providers as to their automated data collection practices.

As indicated above, we, similar to many other website operators, currently use Google Analytics to collect and process certain Platform usage data. To learn more about Google Analytics and how to opt out, please visit https://tools.google.com/dlpage/gaoptout.

You may be able to change a web browser’s settings to block and delete cookies when you access the Platform through that web browser. However, if you do that, the Platform may not work properly; also, we will still receive basic information (such as last URL visited) when you navigate to the Platform. The Platform does not respond to browser do-not-track signals.

INFORMATION DISCLOSURES
We may provide third parties with the personal information we collect (as described above) for our business purposes to assist us in providing products and services to you, including to put you into contact with a partner or to help us market.

To Provide, Protect, and Improve Our Platform and Services. We disclose personal information as necessary to operate our business, such as with third-party providers, partner practices, and affiliates in connection with providing services to you. For example, we may provide your name, telephone and e-mail address information, to our partner practices. We require that third-party providers use personal information only for that purpose, and we also require assurances that they will appropriately protect personal information entrusted to them. We also may access, preserve, and disclose information if we believe that such action is necessary in our judgment to comply with a legal obligation or to protect and defend our rights or property, or those of others. For example, we may provide information, including IP address information, to our service providers to protect the Platform, such as for fraud detection purposes.

To Comply with the Law and Legal Process. We may access, preserve, and disclose information concerning you if required to do so by law or if we believe that such action is necessary in our judgment to comply with a legal obligation.

Other Sharing. We may share information as described under “Information We Collect and Use” above and for other business purposes as otherwise explained in this Privacy Policy.

Sales, Mergers, and Acquisitions. In the event of a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of Somatus assets, or transition of service to another entity (whether by private sale, through operation of law, as part of a divestiture plan, or otherwise), we will provide personal information and transaction history associated with each such business unit to the persons and/or entities assuming control of such business unit or as otherwise necessary to complete the transaction as permitted by law or contract.

Retention of Personal Information
As a general matter, we only keep information for as long as necessary to fulfill the purposes for which it was collected, as stated in our retention policies, and permitted or required by law, such as to comply with recordkeeping and other legal obligations. There may also be residual information that will remain within our backup files, databases, and other records, which will not be removed or changed, except in accordance with retention policies.

Protection of Personal Information
We strive to process your information securely, in accordance with this Privacy Policy, and in accordance with information security requirements imposed by applicable law. We cannot, however, be responsible for Internet communications that are inherently not completely secure.

Links to Third-Party Websites
The Platform may contain links to other websites, and other websites may link to the Platform. This Privacy Policy does not apply to personal information that you submit to the websites of our business partners, partner practices, or any other third-parties or that are collected by them from you, even if those third-party websites are linked to our Platform or listed in our Cookie Policy. We are not responsible for the privacy practices of such other websites. When you visit another website – via a link from the Platform or otherwise – you should review the privacy policy of that other website. This Privacy Policy applies solely to information provided or obtained on our Platform.

No Use by Children Under the Age of 13
The Platform is not intended for use by children under the age of 13. If you are under the age of 13, you may not use our Platform. We do not knowingly collect, maintain, or use personal information from children under 13 years of age. If we believe that any information has been posted by a child under the age of 13, we will promptly delete that information. Parents may contact us using the methods set forth below to request that information concerning their child be removed from our Platform.

How to Contact Us with Questions
Customer questions, comments, and feedback are very important to us. If you have questions about this Privacy Policy please contact us at:

Somatus Inc.
1861 International Drive
Suite 600
McLean, VA 22102

or by e-mailing us at [email protected].

Privacy Rights
Your state may imposes specific legal requirements and create privacy rights with respect to personal information, and we will comply with restrictions and any requests you submit as required by applicable law. 

When you make a request, we may require that you provide information (such as your name, email address and/or zip code) and follow procedures so that we can verify a request you make and your jurisdiction before responding to it. The verification steps we take may differ depending on your jurisdiction and the request you make. We will match the information that you provide in your request to information we already have on file to verify your identity. If we are able to verify your request, we will process it. If we cannot verify your request, we may ask you for additional information to help us verify your request.

We will respond to your request within the time period required by applicable law. However, we may not always be able to fully comply with your request, and we will notify you in that event when required.

Certain privacy laws permit consumers to use an authorized agent to make privacy rights requests. We require the authorized agent to provide us with proof of the consumer’s written permission (for example, a power of attorney) that shows the authorized agent has the authority to submit a request for the consumer. An authorized agent must follow the process described below to make a request, and we will additionally require the authorized agent to verify his/her own identity and we will confirm the agent’s authority with the consumer about whom the request was made.

California. California consumers have the following privacy rights: to request additional information about our data collection, use, and disclosure practices in connection with the consumer’s personal information; to request access to the specific personal information collected about the consumer; to request the deletion of personal information we have about the consumer; to request a restriction on certain processing of personal information; and to request correction of inaccurate information. Also, California consumers have the right not to receive discriminatory treatment if they exercise the rights listed above.

You may be able to use the Platform to access and update the information that you have provided to us through your use of the Platform or otherwise. If you would like to request access to such information or that we update, correct, or delete any such information, you may call us at (855) 851-8354, or email us at: [email protected]. We will comply with requests you submit as required by applicable law.

We do not rent, sell, or share “personal information” as defined by California Civil Code §1798.83 about you that we collect on the Platform with other people or unaffiliated companies for their direct marketing purposes.

You may be able to use the Platform to access and update the information that you have provided to us through your use of the Platform or otherwise. If you would like to request access to such information or that we update, correct, or delete any such information, you may email us at: [email protected]. We will comply with requests you submit as required by applicable law.

We do not sell your personal information for money or other considerations.  We do not perform targeted advertising across unaffiliated websites.

Notification of Change to the Privacy Policy
We reserve the right to modify this Privacy Policy. Whenever we decide to change this Privacy Policy in a material manner, notice of the change will be posted on the Platform for a reasonable period of time or provided to you using other means. Nevertheless, you should review the Privacy Policy from time to time to be sure you are aware of the most recent version. Please be assured that we will only use information in accordance with the Privacy Policy in effect at the time the information was collected, unless we receive your consent.

Effective: March 1, 2023.