Newton, Inc. (“Newton,” “we,” “our,” and/or “us”) values the privacy of individuals who use our website and related services (collectively, our “Services”). This privacy policy (the “Privacy Policy”) explains how we collect, use, and share information from users of our Services (“Users,” “you,” and/or “your”). Throughout this Privacy Policy, we may refer to users who are healthcare providers as “Provider Users” and users who are patients as “Patient Users.” By using our Services, you agree to the collection, use, disclosure, and procedures this Privacy Policy describes. Beyond the Privacy Policy, your use of our Services is also subject to our Terms of Service.

Personal Information

For the purposes of this Privacy Policy, “Personal Information” means any information about an identifiable individual, including any information that directly or indirectly identifies such individual.

Health and social services information

For the purposes of this Privacy Policy, “Health and social services information” is sensitive information that makes it possible, even indirectly, to identify an individual who has one of the following characteristics: (i) it concerns the person’s physical or mental health and its determining factors, including the person’s medical or family history; (ii) it concerns any material taken from the person as part of an evaluation or treatment; (iii) it concerns the health or social services offered to the person; (iv) it was obtained in the performance of a function provided for in the Public Health Act; or (v) any other characteristic determined by government regulation. In addition, information allowing the identification of a person is health and social services information when it is attached to information referred to in the present definition or when it is collected with a view to the registration, enrolment or admission of the person concerned in an institution or to his being taken in charge by another organization in the health and social services sector.

Personal Information Management Program

In order to protect your Personal Information, we have put in place policies, practices and procedures relating to the management of the Personal Information we hold. These internal policies and procedures govern the collection, use, disclosure, retention and destruction of personal information, as well as complaint handling, information security and data governance at Newton. They also provide the framework for the implementation of Privacy Impact Assessments, where required, as well as the prevention of and response to potential privacy incidents. All these policies and practices have been approved by our Privacy Officer.

The collection of your Personal Information through our Services complies with the requirements of this program.

Privacy Officer

Our senior executives have delegated the management of the Personal Information Management Program to the Data Privacy Officer. Their duties consist of managing and monitoring Newton internal Personal Information Management Program.

It is the Data Privacy Officer who approves and implements privacy policies and procedures, ensures their proper functioning and reports to Newton senior management on the effectiveness of the program.

It is also the responsibility of the Data Privacy Officer to provide you with the necessary support in the event of a question, complaint, challenge or request relating to the protection of Personal Information:

Data Privacy Officer
Newton, Inc.
181 Grand Avenue, Ste 225
Southlake, TX 76092
United States of America
privacy@newton.tech

We are committed to responding promptly to your requests. Upon receipt of a request, the Data Privacy Officer will conduct an investigation. If the complaint is justified, the situation will be corrected. Regardless of our conclusion, we will keep you informed.

Basis for Processing Personal Information

Newton needs to collect and process some of your Personal Information in order for you to use our Services. When we collect your Personal Information, we ensure that we collect only the information necessary to fulfill one of our purposes, which has been previously disclosed to you, for example, in this Privacy Policy. We use Personal Information in accordance with the privacy laws applicable to our business.

The following is a description of the basis on which Newton collects and processes your personal information:

Your Consent

As required by applicable privacy legislation, Newton collects the majority of your Personal Information on the basis of your voluntary consent, favoring collection directly from you. For example, Newton undertakes to obtain your explicit consent for the collection of any Sensitive Personal Information.

Other permissible legal basis, such as the performance of our contracts

As permitted by applicable privacy laws, Newton may collect Personal Information without your express consent, for example, to comply with obligations under applicable laws or to fulfill our contracts.

Information We Collect

Depending on the nature of your activity through our Services, we may collect a variety of information from or about you or your devices from various sources, as described below.

Information You Provide to Us

Registration and Profile Information: When you sign up for an account or register to use our Services, we may ask you for your name, date of birth, email address, and phone number.

Communications: We receive information about you when you contact us directly and/or sign up to receive updates from us. For example, if you contact us through our website, request an appointment with a provider through the website, we may collect your name, email address, phone number, the contents of your message, and any attachments you may send to us. We also collect information such as your name and email address when you request to receive updates from us or otherwise request that we contact you directly. Similarly, if you request to download content from our website (such as one of our white papers), we collect your name, email address, city, state, and zip code. You can unsubscribe from our promotional emails via the link provided in the emails.

Careers: If you decide that you wish to apply for a job with us, you may submit your contact information and your resume online. We will collect the information you choose to provide on your resume, such as your education and employment experience. You may also apply through LinkedIn. If you do so, we will collect the information you make available to us on LinkedIn.

Intake Questionnaires: If you are a Patient User and complete our intake questionnaire (often referred to as a Lifestyle Index), you will be asked to provide certain information regarding your symptoms, as well as demographic information including your name, date of birth, email and phone number. This information will be shared with your healthcare provider to facilitate providing you our Services.

Information We Collect When You Use Our Services

Location Information: When you use our Services, we can infer your general location information, for example by using your internet protocol (IP) address.

Device Information: We receive information about the device and software you use to access our Services, which may include IP address, web browser type, operating system version, and device identifiers.

Usage Information: To help us understand how you use our Services and to help us improve them, we automatically receive information about your interactions with our Services, like the pages or other content you view and the dates and times of your visits.

Patient Users Information: When you use our Services with a Patient User, we can collect the information you provide to the patient management system. This information can be the patient ID (identifier used by the Provider User to associate the patient with an entry in their patient management system), name, last name, date of birth, prescription information such as sphere and cylinder, and eye gaze angle and movement (i.e. Newton measurement data) and is categorized by Newton as a Health or social services information.

Information from Cookies and Similar Technologies: We and third-party partners collect information using Cookies, pixel tags, or similar technologies. Any Personal Information we collect using Cookies or on our behalf is treated with the same level of confidentiality as any other Personal Information we hold. Our third-party partners, such as analytics and advertising partners, may use these technologies to collect information about your online activities over time and across different services. Cookies are small text files containing a string of alphanumeric characters. We may use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to our Services.

Google Ads
We use Google Analytics and Google Ads advertising features, including remarketing, to create advertising audiences and show relevant advertisements to visitors across Google’s advertising network.  You can opt out via Google’s Ad Settings.

Meta
We use Meta Pixel to measure advertising effectiveness, create advertising audiences, and deliver relevant advertisements on Meta platforms.  Manage your preferences via Meta’s Ad Preferences.

LinkedIn
We use LinkedIn Insight Tag to measure campaign performance, create advertising audiences, and deliver relevant advertisements on the LinkedIn platform.  You can opt out in LinkedIn’s settings.

Essential cookies

1. Non-essential cookies: Non-essential Cookies provide certain non-essential functionalities on our Services, for functional, analytical or advertising purposes. We will ask for your consent before using these Cookies.
2. Functional Cookies: We use these Cookies to facilitate non-essential functionalities of our Services, such as the integration of content such as videos or the sharing of Site content on social media.
3. Advertising Cookies: Our Services displays advertisements. These Cookies help us to track the effectiveness of our advertising campaigns and to personalize our ads so that they are meaningful to you.
4. Analytical cookies: These cookies store information such as the number of visitors to our Services or the page they have visited. They help us to understand and analyze the performance of our Services and our potential improvements.

Please review your web browser’s “Help” file to learn the proper way to modify your cookie settings. Please note that if you delete or choose not to accept Cookies from the Service, you may not be able to utilize the features of the Service to their fullest potential.

Information We Receive from Third Parties.

Third parties. We may receive additional information about you, such as demographic data, from third parties such as data or marketing partners and combine it with other information we have about you, with your consent or if permitted by law.

With your consent, healthcare professionals using our Services may also provide us with your vision correction prescription information and Newton measurement results. The healthcare professional may also provide his or her observations, notes and remarks concerning his or her examination and assessment of your eye condition, or otherwise record any information concerning prescriptions or referrals to other healthcare professionals for examination, follow-up or management. Refusal to provide your consent will result in the healthcare professional not being able to use the Newton Services during your consultation, to assist him/her in his/her decision making.