PRIVACY POLICY AND DATA PROTECTION

We collect your personal data and other information when you request services, use or register into our products and services, take part in campaigns or research or otherwise interact with us. This includes following categories:

• Information you provide us with. When you request services or for example appointment with a clinic, participate in a research or campaigns or otherwise interact with us, we may ask for information such as your name, email address, phone number, street address, user names and passwords and feedback. We also maintain records of your consents, preferences and settings relating to, for example, location data, marketing and sharing of personal data.
•  Use of products and services. When you access our services online, our web servers automatically create records of your visit. These records typically include IP-address, access times, the sites linked from, pages visited, the links and features used, the content viewed or requested, browser or application type, language and other such information. See also our Cookie policy below. Our applications may contact our servers periodically, for example to check for updates or to send us information relating to service usage. Additionally, we may invite you to join voluntary product and service improvement or research programs where detailed information is collected. In those cases, there may be additional terms for privacy of which we will inform you separately.
•  Positioning and Location data. Location-based services establish location through the use of satellite, mobile, Wi-Fi or other network based positioning methods. These technologies may involve exchanging your location data and unique device and mobile, Wi-Fi or other network related identifiers with Nexstim. We do not use this information to identify you personally without your consent.

When you use our location based services and features, for example location based search, navigation and routing, or request for map data, your location data is sent to Nexstim to serve you with the right content, which may also include location based advertising.

Nexstim’s policy is to request that “Minors” (the age of Minors is determined by local law where you reside) do not engage in legal acts on Nexstim www-sites without the consent of a parent or legal guardian, unless permitted by applicable local law.

Nexstim may process your personal data collected in www.smartfocustmstherapy.com website for the following purposes. One or more purposes may apply simultaneously.

• Providing services. We may use your personal data to provide you with our or our customers’ services, to process your requests or as otherwise may be necessary to perform the contract between you and Nexstim, to ensure the functionality and security of our products and services, to identify you as well as to prevent and investigate fraud and other misuses.
• Accounts. Some services may require an account to help you manage your content and preferences.
• Marketing, advertising and making recommendations. We may contact you to inform you of new products, services or promotions we may offer and to conduct market research when we have your consent or it is otherwise allowed. We may use your personal data to personalize our offering and to provide you with more relevant services, for example, to make recommendations and to display customized content and advertising in our services. This may include displaying Nexstim and third party content.

We may share your personal data if we have your consent to do so. Some services may allow you to share your personal data with other users of the service or with other services and their users. Please consider carefully before disclosing any personal data or other information that might be accessible to other users.

• Nexstim Group companies and authorized third parties such as our customer clinics using our TMS systems. We may share your personal data with other Nexstim group companies or authorized third parties, such as our customer clinics, who process personal data for Nexstim for the purposes described in this Privacy Policy. This may include for example, providing services including customer service.
• Nexstim does not engage in the practice of selling or trading personal data to other companies for promotional purposes. Unless compelled by applicable law or administrative or judicial order, Nexstim will not provide personal data to a third party without your permission, except as necessary to fulfill your requests or manage interactive customer programs. If allowed by applicable local legislation, Nexstim may also exchange personal data between Nexstim’s affiliated (related) companies for the purposes mentioned in this Privacy Policy. Nexstim may also use subcontractors to provide some products or services to you. We also may need to share your personal data with these subcontractors so that they can provide services to us. Our subcontractors are not permitted to use such personal data for any other purposes and we impose confidentiality requirements on their services. In addition to aforesaid, Nexstim may provide aggregate statistics about our customers, sales, traffic patterns, training information and related site information to reputable third parties, but these statistics will not include personally identifiable information.
•  International transfers of personal data. Our products and services may be provided using resources and servers located in various countries around the world. Therefore your personal data may be transferred across international borders outside the country where you use our services, including to countries outside the European Economic Area (EEA) that do not have laws providing specific protection for personal data or that have different legal rules on data protection, for example, the United States of America. In those cases Nexstim will take the needed action to ensure that adequate protection for your personal data as required by applicable laws. For international transfers of your personal data, we rely on agreements that are based on the Standard Contractual Clauses (“SCCs”) of the European Commission. Those can be found here (http://ec.europa.eu/justice/data-protection/international-transfers/transfer/index_en.htm?_ga=2.24276479.452183170.1499838048-819533480.1495432677 ). Nexstim also uses service providers who are deemed adequate via EU-U.S. and Swiss-U.S. Privacy Shield Framework. If you want more information about international transfers, please contact us privacy@nexstim.com.
•  Mandatory disclosures. We may be obligated by mandatory law to disclose your personal data to certain authorities or other third parties, for example, to law enforcement agencies in the countries where we or third parties acting on our behalf operate. We may also disclose and otherwise process your personal data in accordance with applicable law to defend Nexstim’s legitimate interests, for example, in civil or criminal legal proceedings.

We have appropriate physical, technical and managerial controls in place to protect your personal details; for example our online forms are always encrypted and our network is protected and routinely monitored. Within our offices only those who have a business need to access your information and who are trained in handling data securely will have access to your information. We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. Whilst we hope it will never happen, we have procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are required to do so.

When we use external companies to collect or process personal data on our behalf we undertake due diligence on these companies before we work with them, and put a contract in place that sets out our expectations and requirements, including keeping and using your data securely.

Our website may, from time to time, contain links to third party websites. If you follow a link to any of these websites, please note that these websites will have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

We will only keep your personal information for as long as is necessary for the purpose for which it is collected, which may include the purpose of satisfying any legal, accounting or reporting requirements. If you request that we stop sending you materials we will keep a record of your contact details and the appropriate information to enable us to comply with your request not to be contacted by us.

While there are always risks associated with providing personal data, whether in person, by phone or via the internet or other technologies, and no system of technology is completely safe or “tamper”/”hacker” proof, Nexstim has endeavoured to take reasonable precautions which are appropriate to prevent unauthorized access to and improper use of your personal data. For example, Nexstim uses encryption technology when collecting personal data. If Nexstim www sites support on-line interactions, it will use industry standard security measures, to protect the confidentiality and security of online interactions. If used, industry standard security measures like SSL authentication ensure that personal data submitted as part of the process, is reasonably safe from third party interception.

You have right to:

ACCESS YOUR PERSONAL DATA
You have the right to request access to your personal data. This enables you to receive a copy of the personal data we hold about you. Please contact info@nexstim.com to update and/or review your personal data.

REQUEST CORRECTION OF YOUR PERSONAL DATA
You can request that we correct the personal data we hold about you. This enables you to have an incomplete or inaccurate data we hold about you corrected, although note that we may need to verify the accuracy of the new data you provide to us. Nexstim will at your request, free of charge, replenish, rectify or erase any incomplete, inaccurate or outdated personal data retained by Nexstim in connection with the operation of Nexstim Sites and other services. Please contact info@nexstim.com to update and/or review your personal data.

REQUEST DELETION OF YOUR PERSONAL DATA
You have the right to ask us to erase your personal data in certain circumstances. Please note however that there may be circumstances where you ask us to erase your personal data, but we are legally required or entitled to retain it.  Please contact info@nexstim.com to request deletion of your personal data.

WITHDRAW CONSENT
Where we have asked you for consent to process your data, you may withdraw this consent at any time by contacting us. Please note however that we may still be entitled to process your personal data if we have another legitimate reason (other than consent) for doing so. Please contact info@nexstim.com to withdraw your consent.

By showing how and when our guests use Nexstim www-sites, helps us to improve Nexstim www-sites. For the most part, you may visit Nexstim www-sites or use Nexstim products and/or services without having to tell us who you are. However, certain technical information is normally collected as a standard part of your use of Nexstim www-sites. Such information includes, for example, your IP-address, access times, the website you linked from, pages you visit, the links you use, the adbanners and other content you viewed, information about your devices and other such technical information your browser provides us with or as may be otherwise collected in connection with Nexstim products and services.

When you use Nexstim services or Nexstim www-sites, such as www.smartfocustmstherapy.com  or otherwise interact with us over telecommunications networks, certain additional information, such as your mobile subscription number, may be transmitted to us by the telecommunications operator as a standard part of that communication.

Cookies are small files that are sent to and stored in your computer by the websites you visit. When you access Nexstim www-sites, our server may attach a small text file to your hard disk – a cookie. Next time you visit Nexstim www-sites your browser will read the cookie and relay the information back to the website or element that originally set the cookie. Our domains may also include elements that set cookies on behalf of a third party.
To learn more about these technologies and how they work, please see e.g. allaboutcookies.org.

The following type of cookies are used on the Nexstim www-sites at the moment. Please note that the cookies can be changed by us at any time.

Strictly Necessary Cookies

These cookies are essential in order to enable you to move around the website and use its features. Without these cookies certain website functions cannot be provided.

Functionality Cookies

These cookies allow the website to remember the choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features. The information these cookies collect may be anonymized, and they cannot track your browsing activity on other websites.

Performance Cookies

These cookies collect information about how visitors use a website, for instance which pages visitors most often go to. These cookies don’t collect information that identifies a visitor. All information these cookies collect is aggregated and therefore anonymous.

Targeting Cookies or Advertising Cookies

These cookies collect information about your browsing habits in order to make advertising relevant to you and your interests. They also help us to measure the effectiveness of the advertising campaign. They are usually placed by advertising networks with the website operator’s permission. They remember that you have visited a website and this information is shared with other organizations such as advertisers.
If you do not wish to receive cookies, or want to be notified of when they are placed, you can set your web browser to do so, if your browser so permits. You can review the options available to manage cookies in your browser. Different browsers use different ways to disable cookies, but they are usually found under a Tools or Options menu. You can also consult the browser’s help menu. In addition to cookie management, browsers usually let you control files similar to cookies, for example Local Shared Objects, e.g. by enabling the browser’s privacy mode. If you visit Nexstim www-sites and your browser settings accept cookies, we consider this as acceptance of our use of cookies.

Nexstim may update or make changes to this Privacy Policy from time to time. Those changes will always be informed to you by email (to email address you have provided to Nexstim, if any) and by notification in the Nexstim www -pages.

Contact information in privacy issues:  info@nexstim.com