Effective date: 30 March 2026 | English Version
This Statement explains how NeuroPace, Inc. (“NeuroPace”, “we”) collects, uses and discloses personal information on our website, in our products and through any other channel (“Services”) and what we do to keep it secure.
We may update this Statement from time to time; by using the website, you agree to the most recent version. Additional privacy conditions may apply depending on the choices you make on our website, for example, if you use our electronic patient diary or choose to participate in our patient ambassador program.
Some features of this website are for the exclusive use of medical professionals who may prescribe or use NeuroPace products. Therefore, we restrict access to these features to individuals who meet certain requirements, such as those who have submitted an approved registration form. This Statement applies to all users of our website.
INFORMATION WE COLLECT
We may collect personal and non-personal information about you.
Personal information is any information that identifies you or makes you identifiable. We may collect or process the following types of personal information:
- Information you provide to us, for example: name, contact information (such as telephone number, email address, physical address), date of birth, other demographic information such as your age, education, gender, interests, your location (or where the device you are using to access the website is located based on your Internet Protocol [IP] address); medical information such as your health status or medical problems, the medical care provided to you (including dates of surgery or doctor appointments) or payment for medical care, and any information you have provided that is included in a diary, planner, record, comment form or in an open field. For healthcare providers in the United States, we collect the National Provider Identifier (NPI) or state license number and contact information. Some features of our website invite you to submit information about yourself (for example, a patient testimonial), to receive specific information (for example, about our educational offerings), or to participate in an activity (such as a survey or contest). We may send you educational materials about our products and therapies when you complete a form, enter certain information, or answer some questions. We may also offer ways to personalize your website experience by providing us with personal information.
- Information collected through our medical device products, including device serial number, raw data, and reports.
- Usage information collected automatically. When you visit our website, we automatically collect information about which pages or tools you use and how you use them, including the following:
- We collect information about your interactions with the website, such as the pages or other content you access, and other actions you take.
- If you have an account, we automatically collect information when you log in. This may include your IP address, access times, hardware and software information, device information, device event information (e.g., crashes, failed logins, browser type), the webpage you viewed or interacted with before or after using our service, and other relevant information. We collect and monitor this data to track the security and privacy of your account.
- We may use various tracking technologies to collect and store information about your use of our website and products. We use these tools to ensure you receive a personalized experience, to provide you with certain features, to keep your account secure, and to improve and optimize our offerings. Please see the section below titled “Cookies and Similar Technologies” for more information.
- Information from medical professionals or third parties. NeuroPace may occasionally collect medical information about you from your doctor’s medical records or their office. We may also allow you to connect or transfer your information to or from a third-party application or service. We may collect your personal information through various channels, including the following:
- by virtue of your choice to own and use our products,
- through personal contact with our employees, for example, in an epilepsy event,
- by phone,
- through our website,
- through correspondence (email or traditional mail),
- through third parties who have your permission to disclose your information to us (such as when you leave a message on our answering service), and
- If you are a medical professional, by registering to access the parts of our website intended exclusively for you.
Anonymous and non-personal information does not identify you, so we use and share that information freely without restrictions, for example, to make the website more useful to visitors and for other business purposes, such as creating reports for internal use, providing (including by selling) aggregated information to third parties about how people use our website.
We may combine personal information with non-personal information. In such cases, we consider the combined information to be personal information.
USE OF PERSONAL INFORMATION
We may use your personal information for some or all of the following reasons:
- In general:
- to answer your questions,
- to provide you with information about our patient programs, clinical trials, and research,
- to send you information you have requested about NeuroPace products, programs, resources, events, or services, or those of others, that we believe may be of interest to you,
- to send you product updates,
- to conduct market research or analysis, or for our other marketing initiatives and campaigns,
- to send you a NeuroPace newsletter, to send you marketing communications, and for other related activities,
- to improve our website or personalize content for you based on your preferences or expressed interests,
- to respond to subpoenas or other requests for information from a court or regulatory body,
- to safeguard your interests, such as notifying you in the event of a privacy breach or other security incident as appropriate,
- to protect our interests, such as our rights and property in case of fraud, unauthorized use of the product, or other legal harm or damage,
- to manage and administer our business, including to provide and support our products or services with third-party contractors or service providers who are bound by confidentiality obligations, such as an answering machine service or a business travel expense management service,
- in connection with any proposed or existing financing, sale, collateral, assignment, or other proposed or actual disposition of our business or assets (including accounts) for the purpose of evaluating or carrying out the proposed transaction, including compliance with audit or reporting requirements regarding the transaction,
- other business and legal purposes, including compliance with statutes, regulations, guidance and best practices.
- If you are a patient who has one of our medical devices:
- to provide and support the product,
- for product registration and medical device tracking,
- to report any adverse event,
- to create, receive, maintain and transmit your data in order to enable the use of the product and for your physicians to adjust and administer your therapy,
- to communicate with the epilepsy center, doctor’s office, hospital, physicians and other health professionals involved in your care, and insurance companies that may pay for all or part of it, and
- for any other reason, with your consent.
- If you are a medical professional:
- to provide education and training on the use of our products,
- to provide samples or demonstration devices and other educational aids,
- to notify you or invite you to webinars, symposia, conferences, congresses and other professional meetings in which NeuroPace participates or believes may be of interest to you.
- If you are a medical professional with a NeuroPace account, for example, for the Patient Data Management System (PDMS) database or one who provides services to NeuroPace:
- to manage and administer your account,
- to provide you with clinical and technical support regarding our products,
- to comply with our obligations, such as reporting transfers of value under the Sunshine Act.
HOW WE PROTECT YOUR PERSONAL INFORMATION
NeuroPace takes responsibility for protecting your personal information, and we use reasonable security measures to prevent unauthorized use or disclosure and inadvertent loss or unacceptable alteration of such information.
If you are a patient with a NeuroPace product, we maintain all personal information we have on the product in compliance with HIPAA Security Rule requirements. We also keep our customer files secure and limit access to them only to personnel who need to use the information to perform their job responsibilities, such as customer service.
We may ask you to answer some questions to verify your identity if you call us for customer service.
We may require you to set a username and password to access certain areas of our website or to set up an account. Keeping your username and password information secure is your responsibility. If you believe your login credentials have been compromised, please inform us by contacting our Privacy Officer at privacy@pre-prod.np-mtl.com.
We cannot guarantee that the information you provide to us through our website or by email is 100% secure because we cannot make the internet 100% secure. Therefore, please keep this in mind when submitting information to us through the website or by email.
TRANSFERS OF PERSONAL INFORMATION
We may share your personal information in the following ways:
- We may use third parties to perform certain services on our behalf in connection with the Services, such as the following:
- process and store data, including your personal information;
- track, analyze and modify our Services;
- to carry out marketing, advertising and distribution;
- help us provide customer support; and
- to support our security and IT initiatives.
Google Analytics is one of our analytics service providers. Learn more about how Google collects and uses data here . To opt out of Google Analytics advertising features, use Google’s Ad Settings . To opt out of Google Analytics altogether, use this link .
The third parties we work with are not permitted to use the information we share with them beyond what is necessary to assist us. We have agreements in place with these third parties to ensure they use appropriate security measures when processing your personal information in accordance with this policy.
However, certain third-party service providers have their own privacy policies regarding the information we are required to provide to them. We encourage you to read these providers’ security policies to understand how your personal information is handled. In particular, remember that some providers may be located in or have facilities in a different jurisdiction than either you or us. If you choose to proceed with a transaction that involves the services of a third-party service provider, then your information may be subject to the laws of the jurisdictions in which that service provider or its facilities are located.
- We may disclose and transfer your personal information to a subsequent owner, co-owner, or operator of NeuroPace or the Services; or in connection with a merger, consolidation, restructuring, sale of substantially all of our interests or assets (i.e., bankruptcy proceedings), or other corporate change. We will notify you of any choices you may have regarding your personal information when we are involved in a merger, bankruptcy, or corporate reorganization.
- We may share your personal information if reasonably necessary to:
- comply with a valid legal process (e.g., subpoenas, stock subscription rights, court orders, etc.);
- comply with requests or investigations by public authorities;
- comply with applicable laws or regulations;
- to enforce or apply NeuroPace policies or the policies of our business partners;
- to protect the security or integrity of the Services; or
- to protect the rights, property or safety of NeuroPace, our employees or users, partners and affiliates or other natural persons.
- For any other purpose, with your consent. We may share your personal information on your behalf or at your request. We will only do so with your explicit consent. If you consent to sharing your information, you may withdraw it at any time. Withdrawing your consent will not invalidate or reverse the legality of any previous transfer, and in some cases, personal information may not be recoverable once shared. If you wish to withdraw your consent, please contact us at privacy@pre-prod.np-mtl.com .
COOKIES AND SIMILAR TECHNOLOGIES
A cookie is a small data file (text) that is sent to your browser and can be stored on your computer or mobile device when you visit a website. NeuroPace uses both temporary and persistent cookies to enhance your ability to use and navigate our website, and to help us manage and improve it, including by providing us with information about how people find and use our website, and to assess how well it is performing for its intended purposes, such as analyzing trends and statistics. NeuroPace may use third-party providers to collect information for analysis. If you do not allow cookies, you may not have access to all the features of our website.
You will find social media buttons on our website that you can use to share information or interact on social networks (such as Facebook, Twitter, and LinkedIn). These features may include the use of web beacons or clear GIFs, small graphics placed on a website to track which pages were viewed and what information is collected. They can be used to measure traffic and evaluate user behavior.
LINKS TO THIRD-PARTY SITES
NeuroPace may link to a third-party website from its website. If we do so, the links are provided for informational purposes only, and NeuroPace in no way endorses the website or the website providers to which the links lead. We are not responsible for the content of the website or its privacy practices.
VOLUNTARY EXCLUSION
You have the right to opt out of receiving marketing materials from NeuroPace. You can ask us not to use your personal information for marketing purposes. You can unsubscribe from any email communication we send you. If you receive materials from us that you do not want, or believe we are using your personal information without your permission, please contact our Privacy Officer at privacy@pre-prod.np-mtl.com.
CHILDREN/MINORS
The NeuroPace website is not intended for use by children under the age of 18. NeuroPace does not knowingly collect personal information from minors. If we discover that a child has provided us with personal information online, we will take steps to delete it. If you believe we have received personal information from a minor, please contact our Privacy Officer at privacy@pre-prod.np-mtl.com.
NOTICE TO CALIFORNIA RESIDENTS
- Marketing . California law permits residents of the state to request from NeuroPace a notice that identifies the categories of personal information we share with our affiliates or third parties for marketing purposes and provides contact information for those affiliates or third parties. If you are a California resident and would like a copy of this notice, please send a written request to the address provided in the “Concerns” section.
- Do Not Track signals . We do not currently monitor or take any action regarding Do Not Track signals or other mechanisms, which means we collect information about your online activity while you use our website and after you leave it.
- Privacy . This section applies only to individuals residing in California under the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws (collectively, the “California Laws”).
Personal Information Collected.
Under California law, NeuroPace is required to disclose the categories of personal information we have collected in the past 12 months, the reason we collected it, where we obtained the personal information about you, and the third parties with whom we share it. NeuroPace collects identifiers, personal information under California Civil Code Section 1798.80 , protected classifications under federal and California law, business information, electronic network activity information, geolocation data, employment-related information, and inference data as defined and described under California law. We collect this information for the purposes described in the “Use of Personal Information” section above. The information may be shared with third parties, such as our service providers, as described in the “Transfers of Personal Information” section above.
Privacy Rights of California Residents
Under California law, residents have the rights (“Rights”) listed below. Your right of access and your right of deletion are not absolute and are subject to certain exceptions. For example, we may not disclose specific personal information if such disclosure would create a substantial, uncertain, and unreasonable risk to the security of the personal information, your account with us, or the security of our network systems.
- Disclosure and Access Rights : California residents have the right to request in writing from a company (i) a list of the categories of personal information, such as name, address, email address, and the type of services provided, that a company has disclosed to third parties (including independent affiliates that are separate legal entities) during the immediately preceding calendar year for the third parties’ direct marketing purposes, and (ii) the names and addresses of all those third parties. In addition, California residents have the right to request that we disclose to them (i) the categories of personal information we have collected about them, (ii) the categories of sources from which the personal information is collected, (iii) the business or commercial purpose of the information collection, (iv) the categories of third parties with whom we have shared personal information, and (v) the specific personal information we have about an individual.
- Rights to Deletion : California residents have the right to have their personal information deleted, unless it is necessary for the company or service provider to do the following:
- complete a transaction for which personal information was collected, provide a good or service requested by residents, or execute a contract between the company and residents;
- detect security incidents;
- protect against malicious, deceptive, fraudulent or illegal activities (or prosecute those responsible);
- debug to identify and repair functionality errors;
- exercise or guarantee another person’s right to exercise freedom of expression or other legal right;
- comply with the California Electronic Communications Privacy Act, which requires the production or access of electronic communications information or electronic device information with a search warrant;
- participate in research of public interest (if the person has given their informed consent);
- allow exclusively internal uses aligned with the expectations of the person given their relationship with the business;
- fulfill a legal obligation;
- Otherwise, the information should be used internally in a legal manner consistent with the context in which the person provided it.
- Do Not Sell : California residents have the right to opt out of the sale of their personal information. We do not sell personal information.
California residents can exercise their privacy rights by contacting us at privacy@pre-prod.np-mtl.com or by calling us at 1-866-726-3876.
Response Time . We will address any request to exercise the rights described above in accordance with applicable California law. When a request is made, we may verify your identity to protect your privacy and security. We will respond to written rights requests within 45 days of receipt via email or mail to the address listed above. Please note that we are only required to respond to an individual twice in a 12-month period.
REVISIONS TO THIS PRIVACY STATEMENT
NeuroPace reserves the right to modify this Statement at any time. If we make a significant change, we will post a notice on our homepage for a reasonable time after the change to inform you that you should review the privacy statement again because the change has been implemented.
CONCERNS
Contact NeuroPace’s privacy officer if you believe NeuroPace has violated this Statement or any applicable law: privacy@pre-prod.np-mtl.com .
