Privacy Notice

CEFALY Technology attaches great importance to the protection of your privacy.

This Privacy Notice provides you with detailed information regarding the protection of your personal information by CEFALY Technology, whose registered office is located at Boulevard Patience et Beaujonc 3, bte 28, 4000, Liège, Belgium.

We are responsible for the collection, use, and disclosure of your personal information in the course of our activities. The purpose of this Privacy Notice is to inform you of the personal information that we collect, how it is used and disclosed, and your rights related to this information and how to exercise them. We do not sell or rent your personal information to third parties.

1. What personal information do we collect, use, and disclose?
As part of our sales activities, we may collect and use personal information. This information is limited to what is necessary for the realization of our commercial activities.

The following personal information is collected:

  • Identification (for example: last name, first name)

  • Contact (for example: physical and electronic address, phone number)

  • Interactions between you and our different services and supports.


2. Why do we use your personal information?
The main purpose of our information processing is to allow you to make a purchase through our website. We use your information to organize the delivery of products, respond to requests for after-sales service, manage rentals, and any other requests related to the sale.

If you agree, we may occasionally use your information to provide you with information about our products and services (for example, launching a new product). This processing is based on our legitimate interest.

As a manufacturer of medical devices, we are required to carry out safety and efficacy studies on our products. Those post-market studies (retrospective clinical study, analysis of epidemiological data, cost-efficacy and safety studies) are carried out according to the principle of legitimate interest. Your information may be used to contact you to determine if you are interested in participating in one of these studies. In this case, we will ask for your consent prior to the use of your personal information.

3. With whom do we share your information?
The controller is CEFALY Technology. As part of our management, the information may nevertheless be disclosed to third parties, which offer the necessary guarantees of security and confidentiality for purposes such as data storage. This may involve the storage or processing of personal information outside of Canada and local privacy laws may differ from those that apply in Canada. 

Personal information may also be disclosed to comply with applicable legal requirements including where necessary to report an adverse event to a regulatory authority such as Health Canada.

We may also share your information with transport or delivery companies.

When we conduct post-market studies, information analysis companies may receive your information.

4. How long do we keep your personal information?
We keep your personal information for as long as necessary to comply with applicable legal and regulatory provisions, while taking into account operational constraints such as a good quality customer service.

On this basis, your personal information is kept for 10 years after the purchase of our products.

5. What are your rights and how can you exercise them?
According to applicable laws, you have several rights about your personal information, which are:

  • The right of access: you can obtain information about the processing of your personal information, as well as a copy of this information.

  • The right to rectification: if you are thinking that your personal information is not correct, or incomplete, you can require the modification of this information.

  • The right to withdraw your consent: if you have given your consent to the processing of your personal information, you have the right to withdraw this consent at any time.

You can exercise the rights listed above by contacting us by e-mail at privacy@cefaly.com or by writing at the address noted above. We will answer you as soon as possible.  

6. How do we protect your information?
We always use encryption technologies that are recognized as industry standards in the IT sector when we transfer or receive your information on our website. Your information may be stored or processed by a third party who has entered into an agreement with us that requires them to observe this Privacy Notice.

7. What should you know about third-party services?

On our website, we use tools developed by third parties. These third parties may place cookies or other Web tags on your browser for targeted advertising purposes. Those services may automatically record your browsing activities when you visit our website (IP address, cookies, activities on our website). This is the case for example of Google Analytics, Facebook, AddThis, AdRoll, Perfect Audience, Salesforce Marketing Cloud and Klarna.

In order to offer you Klarna’s payment methods, we might in the checkout pass your personal data in the form of contact and order details to Klarna, in order for Klarna to assess whether you qualify for their payment methods and to tailor those payment methods for you. Your personal data transferred is processed in line with Klarna’s own privacy notice.

If you do not wish to be the object of targeted advertising (opt out), the following site allows you to regulate your advertising preferences: www.aboutads.info.

You may also adjust the parameters of your browser to delete or prevent the placement cookies.

8. Who to contact in case of questions or complaints?
You can contact our privacy officer at privacy@cefaly.com or by writing at the address noted above.

Last update: December 9, 2019

 

CeCe Privacy Policy  

Updated March 2024

CEFALY understands that the privacy of your private information is important and we take the protection of personal data that you provide on the CeCe mobile application (the “App”) very seriously. This privacy policy (“Privacy Policy”) describes how we collect, manage, use, protect and disclose the information that you may provide via App. By visiting our App, or by registering as a user of the on-line services that we provide (the “Services”), you agree to the terms of this Privacy Policy and to our Terms of Service as they may be amended from time to time. CEFALY (“we”, “us”, “our”) means our entire company, including our affiliates, subsidiaries and related companies. 

Our App may contain links to third party websites that are not owned or controlled by CEFALY. This Privacy Policy only applies to information collected by CEFALY, and does not apply to any information collected by any third party. Accordingly, we recommend that you read the applicable third party’s privacy policies and terms for more information. 

You may use the CEFALY Connected device (the “Connected device”) when using the App. The Connected device is a medical device approved by the U.S. Federal Drug Administration for the treatment of migraine. It can be used in conjunction with the CeCe mobile application to track CEFALY treatments in real time, and store data about such treatments. 

This App is intended for use in the United States and Canada only. 
 

Collection and Use of Personal Information 

You are not required to provide personal or medical information as a condition of using our App, except as may be necessary to provide you with information, products or the Services at your request. If you request information, products, or Services through the App, or ask us to resolve complaints or concerns, we may require certain information necessary to fulfill your request (e.g., your name, contact information, and other identifying information). Personal information that you provide may be used by CEFALY to provide you with information, such as the Services and educational information about our products or information about new products or services. We may use aggregated and anonymized data for market research and other marketing purposes. Please do not submit any personal information if you do not want it to be collected by us. 

We collect personal information only when you provide it to us, through registration, completion of forms or e-mails, as part of the Services, inquiries or similar situations in which you have chosen to provide the information to us. If you choose not to provide any requested personal information, you may be unable to access certain areas of the App, such as password protected areas, and you may not be able to use the Services, as the use of personal information, including medical information, is necessary for the performance of the Services. We will retain control of and responsibility for the use of any personal information you disclose to us.
 

You may opt-out of any marketing communications you receive from us for new products or services by following the instructions in the communications you receive. We will continue to send communications that are required or necessary to send to the users of our Services. These notifications contain important information, and you may not opt out of receiving these communications without cancelling our Services and requesting us to delete your personal information.  

Data Processed by Us When You Use Our App 

When You Create A CeCe Account 

If you want to access data collected by your mobile device using the App, you must create a CeCe account. When you create an account, we ask for some personal information, including your email address and a password. Your email address will be used to log in to your account. You are responsible for taking reasonable steps to ensure that no unauthorized person has access to your password or account log in information.  

When You Add Information to Your Profile 

You can customize your CeCe experience by adding other types of information to your account, such as: Name, Gender, Birthdate, and information about your personal migraine experience. 

When You Record Data 

Full use of CeCe requires that you record information related to your migraines, such as your pain intensity, your pain location, your symptoms, your triggers, your medication, your reliefs, your menstruation, etc. When you log a treatment or session with CeCe using a Connected device, the treatment time and date, treatment duration, and highest intensity reached will also be automatically recorded. 

Your app activity (including information about your symptoms and triggers, and the Connected device treatment information) is transferred from your mobile device to our servers. This data is stored and used to provide Services and is associated with your account. Each time a sync occurs, we log data about the transmission. Some examples of the logged data are the sync time and date, and the IP address used when syncing. 

When You Use The “Export Report” Feature 

When you use the “Export Report” feature on the App, a PDF report (the “Report”) will be sent to the email that you used to log in the App. Once the Report is sent to your email address, CEFALY assumes no responsibility or liability for the Report download or any sharing of the contents of the Report once delivered to your email address.  

When You Sync Your Mobile Device 

When you sync your mobile device through CeCe, data recorded on your mobile device using the App about your activity (including information about your symptoms and triggers, and the Connected device treatment information) is transferred from your mobile device to our servers. This data is stored and used to provide Services and is associated with your account. Each time a sync occurs, we log data about the transmission. Some examples of the log logged data are the sync time and date, and the IP address used when syncing. 

When You Contact Us For Help 

Whenever you contact CeCe for help, we collect your email address along with additional information you provide in your request so that we can provide you with assistance and improve the Services. 

We may process behavioral analytical data such as, whether notifications (may include alerts, sounds and icon badges) are on or off, whether permission has been given to receive a newsletter and any health data you have provided. This is to personalize the user experience, customize your content and provide personalized offers to you, and to track the performance of the App and user behavior so that we can improve the user experience, and to improve, develop and provide a better personalized product and service.  

How We Use Your Data 

By using, accessing and inputting information in the App, you agree that any and all migraine data (excluding personal information) that you have entered or may enter at a future time, into the App, as well as any data you may enter into related features or Services of the App (which are not present at the moment within the App, but which may be introduced at any time in the future), you consent to the compilation, processing, analyzing as well as anonymous disclosure of the resulting statistics to a third party. 

(i) Where do we store your data: 

We store your data (self-recorded data, phone sensor data and analytics data) in controlled cloud servers, and on some third-party servers that are used as CEFALY’s service providers, such as AWS. Your data may be stored in a location outside your country of residence, including in the United States. 

(ii) How long do we store your data: 

Your data will be stored until we no longer need the information, or until you request deletion of your account and data. Legal, tax, or accounting requirements may require us to keep your data for longer periods. You may request to have your data removed at any time by contacting cece@cefaly.com.  

 

Disclosure of Personal Information 

CEFALY does not sell or rent your personal information to third parties. We may retain third party vendors to assist us to perform services on your behalf. Such third party vendors may be provided with access to your personal information to perform their obligations pursuant to contractual obligations with us, but for no other purpose. We may share your personal information with a company in connection with the sale or transfer of one of our product lines, business units or affiliates to that company. Any service providers are required by contract to use and protect your personal information consistent with this Privacy Policy. CEFALY reserves the right to disclose your personal information to respond to duly authorized information requests from governmental authorities or when otherwise required by law. 

 

Use of Cookies 

Cookies are used in order for us to improve the efficiency of your individual use of the App. Cookies are small text file identifiers that are sent to your web browser and stored on your mobile device. Cookies allow the App to remember your mobile device on return visits. This is particularly important for an app that requires you to sign in as it speeds up your access. We may use both session cookies that are deleted when you close your web browser and persistent cookies that may be used by the App on subsequent visits. When you use our App, we automatically receive the name of your internet service provider, the website that you used prior to our App, the websites that you visit from our App and your Internet protocol address. This information is not linked to personally identifiable information. 

Most web browsers are set up to accept cookies automatically but you can change the web browser’s settings to refuse new cookies, disable existing ones or let you know before new cookies are stored on your mobile device. However, if you refuse or disable cookies, some of the App’s functionality may be lost. We may also include web beacons (also known as web bug, pixel tag or clear GIFs) on our App or e-mails. Web beacons help us monitor the effectiveness of the App or a marketing campaign by measuring the activity of the App or how many users clicked on any elements of the App or opened an email. Web beacons do not automatically obtain personal information from you but can tell us when you have opened your email or visited the App. If you want to delete any cookies or web beacons that are already on your computer or stop cookies or web beacons being stored on your computer in the future, see the “Help” section of your web browser. For additional information about deleting or controlling cookies or web beacons, see www.aboutcookies.org. In addition, you may opt-out of interest based advertising by participating providers by visiting www.networkadvertising.org for details on how to opt-out. 

 

Google Analytics 

Our App and website use Google Analytics. Please refer to “How Google uses data when you use our partners’ sites or apps” for further information (located at https://policies.google.com/technologies/partner-sites). 

 

Do Not Track and Advertising Across Different Websites 

We currently do not change our tracking practices in response to “do-not-track” signals or other similar mechanisms. Third parties that have content or services on our website such as a social feature, analytics service, or an advertising network partner, may obtain information about your browsing or usage habits. These third parties do not change their tracking practices in response to “do-not-track” signals from your web browser and we do not obligate these parties to honor “do-not-track” signals. To learn more about browser tracking signals and “Do Not Track,” please visit www.allaboutdnt.com. 

 

Security 

CEFALY uses reasonable technical and organizational security precautions to protect your personal information from manipulation, loss, destruction or access by unauthorized persons. Any personal data that is provided to CEFALY by you will be encrypted in transit to prevent its possible misuse by third parties. Our security procedures are continuously revised based on new technological developments. Due to the nature of Internet communications, we cannot guarantee that such communications are 100% secure or error-free and disclaim that the information you provide us will remain free from theft, loss, or unauthorized access or use by third parties, despite our best efforts. You are responsible for maintaining the privacy of your own passwords and other special access numbers you might use to access the App. 

 

Children 

Children under the age of 18 are not the intended audience for the App without consent from a parent or guardian. In light of the importance of protecting children’s privacy, we do not knowingly collect personal information from this age group without prior parental or legal guardian consent. 

 

How to Edit or Modify Your Information 

You may edit or modify any personal information or data that you have provided to CeCe from your CeCe account. If you remove migraine data from your account, it will no longer appear to you. Backups of that data will remain associated with your CeCe account in our archive servers. Backups occur continuously and can be recovered up to the past 35 days. 

 

How to Deactivate Your CeCe Account and Delete Information 

You can deactivate your CeCe account by contacting cece@cefaly.com from your user’s email address. When you do, data that can identify you will be removed from the Services, including but not limited to your email and name. Backup copies of this data will be removed from our server based upon an automated schedule, which means it may persist in our archive for a short period, and to a maximum of 30 days. CEFALY may continue to use your de-identified information, including your birthdate and gender, after you deactivate your account. It is important to note that the identifiable data on the aforementioned backups is only deleted once the account is deactivated. 

 

Canadian Users 

Canadian users, except under certain circumstances defined by law, are entitled to access their own personal information collected by CEFALY by contacting us at cece@cefaly.com. We may ask you to pay an administrative fee for accessing or copying your personal information, but will inform you of the anticipated charges (if any) and confirm that you want to proceed before processing your request. If you believe that the personal information about you that we have collected is incomplete or inaccurate, we will correct the information upon verification of the omission or error and of the identity of the person requesting the change. 

 

California Residents 

We do not sell your personal information to third parties for money or other valuable consideration. We do not share your personal information with unrelated third parties other than as part of a contract where they provide a service to us for the business and commercial purposes described in this Privacy Policy. California Civil Code Section 1798.83 permits users who are California residents and who have provided personal information (as defined in Section 1798.83) to request certain information about the disclosure of that information to third parties for their own direct marketing purposes. Note that CEFALY does not share your personal information with third parties for the marketing purposes of such third parties. 

 

Updates to Privacy Policy 

We reserve the right to modify our Privacy Policy at any time so please review the Privacy Policy each time you access the Website and App. Material changes will be indicated on the revised Privacy Policy. Any changes will be effective immediately as of the updated revision date indicated below. 

 

Contact Us 

Please contact us with any problems, questions or suggestions regarding our Privacy Policy at cece@cefaly.com, or CEFALY Technology, Inc., 19 Old Kings Highway South, Darien, CT 06820. 

  

Last updated: March 6, 2024 

 
 

Terms of Service 

By using CeCe, you consent to our Privacy Policy 

  

DISCLAIMER 

The contents of this App (CeCe), such as text, graphics/infographics, images, and other material contained on the App (“Content”) are for informational purposes only and do not, under any circumstances, constitute medical advice nor diagnosis; the Content is not intended to be a substitute for professional medical advice, diagnosis, or treatment. Please do not submit questions seeking medical advice or diagnosis to the email address provided on this App, as we would not be in a position to provide you with medical advice or diagnosis. Always seek the advice of a physician or other qualified health provider with any questions you may have regarding any medical condition. Never disregard professional medical advice or delay in seeking it because of something you have read on any website. 

  

Last updated: May 11, 2022 by CEFALY Technology