Privacy Policy

Effective date: May 30, 2025

Privacy Notice 

iotaMotion, Inc. (hereinafter also referred as: “iotaMotion”, “we”, “us” or “our) is a company based in St. Paul, Minnesota, USA conducting business within the United States, and understands the importance of privacy to our customers, visitors, suppliers, business partners, employees and other individuals (hereinafter also referred as: “you” or the “user” or the “data subject”). We are committed to protecting and respecting your privacy.  

This privacy policy (“Policy”) applies only to information collected through the website on which it is posted. It does not apply to third-party platforms or to other iotaMotion-operated websites or other iotaMotion-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@iotamotion.com. 

Particular State provisions:  

• Consumer Health Data Policy Addendum  

• California Residents  

Your Consent 

By using this Site, you are consenting 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 consent 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 revoke your consent 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. A link to our Terms of Use  is provided at the bottom of each page 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 iotaMotion 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 

iotaMotion 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” at the bottom of each page of the public areas of this Site. 

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.   

iotaMotion collects the information you manually provide (using your keyboard, mouse, or touchpad) when you use this Site, for example, we collect the information you provide if you complete a “Contact Us” form or similar questionnaire, 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. 

Information Automatically Collected 

iotaMotion 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 spend 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  

We 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 collect using cookies and similar technologies is not, in and of itself, personally identifiable, but we may link it to Personal Data 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. 

Information Collected by Third-Party Cookies 

In addition to the cookies iotaMotion delivers to your computer or mobile device through this Site, certain third parties may deliver cookies to you for a variety of reasons. For example, we use Google Analytics, a web analytics tool that helps us understand how visitors engage with our Sites. To select your preferences regarding cookies, including third-party cookies, you can use the cookie banner available on the iotaMotion website. 

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. Please note that the Add-on does not prevent information from being sent to iotaMotion.   

In addition, if you would like to opt-out of having interest-based information collected by certain entities during your visits to this Site or other websites, please 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 optout 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 mechanism is 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 Data). 

• To contact you with pertinent information about products, clinical trials, or important safety information, and about products and services of ours and of others. 

• For analytical purposes and to research, develop, and improve programs, products, services, and content. 

• To remove your personal identifiers. Once we have de-identified information, it is considered non-Personal Data and we may treat it like other non-Personal Data. 

• 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. 

How We Share Your Information 

With Third–Party Vendors   

iotaMotion 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. 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 Data to these platform vendors, they may gain insights about individuals who respond to the ads we serve.   

For Improved Advertising by iotaMotion 

If you give your consent, we may share a unique identifier, such as a Click ID and/or your hashed e-mail address, with Google or other third parties to help iotaMotion improve its advertising. We do not use these unique identifiers for personally identifying individuals. 

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.  We require such business partners or potential study centers to restrict their use of any personally identifiable information received through our Site to the intended purposes.  

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.  

Business Partners 

In the ordinary course of business, we share some information collected through this Site with business partners such as clinical study sites or health care providers. For example, we may share information with a clinical study site if you provide us with information indicating your interest in a clinical study. We may also share information with health care providers. Our business partners will generally be bound to confidentiality requirements applicable to their organizations. 

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 consenting to the 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.  

iotaMotion will not sell your information to any third parties. 

Other Privacy Notice, Consent, or Agreement 

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. 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 or in accordance with any consent or authorization you otherwise provide.  

How We Protect your Information 

iotaMotion 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 Data 

iotaMotion primarily processes Personal Information in the US. Accordingly, we may store, collect, transfer and process your Personal Data in a country other than your country of residence. The data protection and other laws of countries to which your information may be transferred may be different in your country. By submitting your Personal Data, you agree to any transfer, storing or processing.  

Retention of Your Information 

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

Children’s Privacy 

This Website is not targeted to children under the age of 16 and we do not knowingly collect or solicit Personal Data about such children. If we discover that a child has provided us with Personal Data online through this Website, we will take delete this information as quickly as possible. If you believe we may have received Personal Data from a child under the age of 16, please contact us immediately. 

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 Information about you, how we use or share it, what categories of Personal Information we process, our purposes of processing, and categories of parties we disclosed Personal Information to. 

• Access and portability. You may have the right to access your Personal Information, specific pieces of information, and know of third parties Personal Information 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 Information 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 Information (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 Information 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 Information (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 Information on the basis of that 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 Information 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 to privacy@iotamotion.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.   

• Residents of WA, CA, NV, CT, or others with consumer health data rights please also see the respective Addendums for further details. 

Exercising of Your Privacy Rights 

You may exercise your rights of access, rectification, cancellation and opposition by contacting us at privacy@iotamotion.com. 

Please note that we may ask you to verify your identity before responding to such requests. If you make a request, we will try our best to respond to you as soon as possible. 

Links to Other Websites  

This Policy applies only to the iotaMotion-operated websites on which it is posted. iotaMotion and its affiliates may operate different websites for different purposes and in different countries, where different laws may apply. If you visit another iotaMotion 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 iotaMotion 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. iotaMotion 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 Data. 

Contact us 

If you have any questions regarding this policy or about our privacy practices, or need to contact us for purposes related to this Privacy Policy, please contact us at: 

Data Privacy 

4205 White Bear Pkwy 

St Paul, MN 55110 

(651) 447-4177 

privacy@iotamotion.com  

Addendum: California Residents Privacy Notice 

Effective May 30, 2025 

“Do Not Track” Policy as Required by California Online Privacy Protection Act (CalOPPA) 

Our Service does not respond to Do Not Track (“DNT”) 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 Addendum. 

California Privacy Rights for Minor Users (California Business and Professions Code Section 22581) 

California Business and Professions Code section 22581 allow California residents under the age of 18 who are registered users of online sites, services or applications to request and obtain removal of content or information they have publicly posted. 

To request removal of such data, and if you are a California resident, you can contact us using the contact information provided in this Addendum and include the email address associated with your account. 

Be aware that your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances. 

Addendum: Nevada Opt-Out Rights 

Your Nevada Opt-Out Rights 

We do not sell your Personal Information, but nevertheless we offer an opt out to sales of consumer data in an overabundance of caution as required by, and to ensure compliance with, Nevada law.  Verified requests under Nevada law (NRS 603A) to not make any sale of any covered information we have collected or will collect regarding a consumer, as defined in that law, may be sent to privacy@iotamotion.com. Please include in any such request email “Request for Nevada Opt-Out” in the subject line and in the body of the message.  

Addendum: Consumer Health Data Policy  

(including Washington, Nevada, Connecticut) 

Effective: May 30, 2025 

Various U.S. state laws provide protections for “consumer health data”. This addendum applies to such information by applicable law. 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) and other laws applicable to the same or similar data. It generally includes any information that is linked or reasonably linkable to an individual 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 except as described in this Privacy Policy and this Addendum (or any supplemental privacy notices or statements) or with your consent. 

Categories of Consumer Health Data We Collect and Share 

We process limited Consumer Health Data and may collect Consumer Health Data from various categories including, individual health conditions, treatment, diseases, or diagnosis; dynamics interventions, health-related surgeries or procedures; use or purchase of prescribed medication; bodily functions, vital signs and symptoms; diagnoses or diagnostic testing, treatment, or medication; genetic data; precise location information that could reasonably indicate a consumer’s attempt to acquire or receive health services or supplies (i.e., geofencing); and data that identifies a consumer seeking health care services. 

Sources of Consumer Health Data 

We collect Consumer Health Data directly from you, including when you submit information through our website, or other services or platforms we operate.  

How We Use Consumer Health Data 

We use consumer health data to provide consumers information and education about iotaMotion’s products and help connect them to a provider that can provide them diagnosis and treatment options. 

How We May Share Consumer Health Data 

We may share Consumer Health Data, including the categories of Consumer Health Data, with iotaMotion-affiliated companies, service providers acting on our behalf, and others, including health care providers that you select, as necessary to provide you with the products or services you request or your authorized representatives request on your behalf. 

Exercising Your Rights  

Based on applicable laws in your state, you may have the right to: 

• Confirm whether iotaMotion is collecting, sharing, or selling Consumer Health Data concerning you and to access this data, including: 

• A list of all third parties and affiliates with or to whom iotaMotion 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 iotaMotion to collect and share your consumer health data 

• Request to have Consumer Health Data concerning you deleted and exercise that right by informing iotaMotion of your request for deletion 

• Appeal if iotaMotion does not address an attempt to exercise one or more of these rights to your satisfaction 

You may request that iotaMotion take the actions outlined in the paragraphs above to exercise rights you may have by submitting a request, at any time, to iotaMotion. iotaMotion will seek to respond within forty-five (45) days. permit or require removal in certain circumstances.