If you have a request concerning your medical records, please visit our data subject request portal here.
Your privacy is important to us at Nevro, and so is being transparent about our data protection practices.
If you are an organization (for example, a hospital, business associate, service provider, or professional advisor), we would ask that you provide this Notice to your directors, officers, employees, partners and other staff who have or have had dealings with us on your behalf.
This Notice should be read along with any additional notice that we provide when we collect or otherwise process your personal data.
This Notice describes the types of information we collect, the purposes for which it is used, and the choices you have with respect how we use your data. We encourage you to read this Notice to understand our privacy practices before using our Services.
If you are a California resident and would like to exercise your California privacy rights, please see our California Consumer Privacy Act Notice.
How we use information and in reliance on what lawful basis
We use the information we collect about you to:
- Communicate with you: We may contact you to respond to your inquiries, requests, and/or send important service messages. For example, we may contact you to provide customer support, or schedule appointments. It is in our legitimate interest to organize calls and meetings between you and our staff, manage our relationship with you and for us to conduct our business.
- Provide and improve our Services and Sites: We use information we collect to provide and analyze how you use our Services / Sites, develop new products and services, and improve functionality, efficiency, and quality of our Services / Sites. We have a legitimate interest to properly manage and administer our relationship with you and to ensure that we are effective and efficient as we can be.
- Nevro HF10 Therapy: We collect personal data in order to provide you with the necessary devices to support the trial and/or implant of the devices and to optimize the HF10 Services. In detail, Nevro collects and processes your personal data to understand your specific needs for implant and treatment, to invoice and bill your medical provider for the device, to contact your physician if necessary to plan and to perform the HF10 therapy, to provide the Services in connection with the patient agreement you have entered into with your treating doctor or hospital and to perform Nevro's related therapy support obligations towards the treating doctor or hospital. These activities are carried out where in our legitimate interests and to comply with our legal obligations. If you are located in Europe you will be provided with a separate notice which details the information collected when you receive HF10 Therapy.
- Perform data analytics for patient outcomes: The information we collect is anonymized and aggregated to perform data analytics. This data helps us improve the quality of our Services, optimize our algorithms for HF10 Therapy, and present patient outcomes to current and prospective customers. We have a legitimate interest to manage our business and improve our Services / Sites.
- Billing: Depending on your location, we may collect your name, date of birth, insurance number, and other health information, as necessary, to use for billing purposes. It is in our legitimate interest to bill you for services provided to us. It may also be necessary to perform, or to enter into, contracts with you (for example, to process payment details). In some cases, it may also be necessary for us to comply with our legal obligations to perform anti-money laundering/know your customer checks.
- Marketing and advertising: We only publish testimonials, send marketing emails and newsletters, or call you about our Services, with your consent. We advertise our Services on social media platforms, such as Facebook, but we will not directly contact you or collect your information through these platforms. In the U.S., we engage in behavioral advertising and partner with third parties, such as Google, to provide you targeted advertisements on our Sites. See “Your choices and rights” section below to learn how to manage your communication preferences.
- Coordinate events and manage visitors: We use your name and contact information to coordinate events where you are attending including, travel arrangements if you attend a Nevro-hosted professional education event that requires you to travel outside of your city. Where we process visitor personal data it is in our legitimate interest to keep our offices secure and manage our business.
- Sale of information (CCPA): We do not sell patient or physician information as defined by the CCPA. See more information here.
Where we require your personal data to comply with legal requirements, failure to provide this information means we may not be able to accept you as a customer / patient and/or you may be unable to receive Services from us. We will tell you when we ask for your information whether it is a statutory or contractual requirement to give us the information and the consequences of not providing the information.
Individuals located in EEA/UK: Please note that you have a right to object to processing of your personal data where that processing is carried out for our legitimate interest or for direct marketing purposes.
How we share information
We share information about you with third parties as follows:
- Service providers: We provide your information to third party service providers to help us perform our Services and operate the Sites. These service providers are ized to use your information only as necessary to provide services on our behalf and under our direction. We use service providers for business activities such as relationship management, content management, data center hosting services, customer support, document management, marketing, and email administration. We also provide your personal data to professional advisors (for example, accountants, lawyers or other consultants) and, independent public accountants and auditors, ized representatives of internal control functions.
- Nevro Corp. and Nevro affiliated companies: As necessary, we share information we have about you with our affiliated companies to operate and improve our Services. Nevro affiliated companies are owned or operated by Nevro Corp. This Notice applies to the information we share with our affiliates.
- Legal purposes: We disclose your information when we believe that disclosure is (1) reasonably necessary to comply with any applicable law, regulation, subpoena, legal process or enforceable governmental request; (2) necessary to enforce the provisions of this Notice; or (3) necessary to protect against harm to the rights, property, or safety of Nevro, our customers, or the public as required or permitted by law.
- Transactions: We may also disclose your personal data to any third party that acquires, or is interested in acquiring, all or part of our assets or shares, or that succeeds us in carrying on all or part of our business.
International data transfers
Given the global nature of our business we may transfer your personal data outside of the country in which you originally provided it to us. These countries may not have the same level of data protection as the country in which you provided your personal data to us. In particular, if you are located in EEA/UK your personal data will be transferred to the United States which the European Commission has determined does not provide an adequate level of data protection. Where we transfer your personal data from the EEA/UK we rely on our intra-group EU-style data transfer agreement (known as standard contractual clauses). Where we transfer your personal data from the EEA/UK to other recipients outside of the EEA/UK, we will enter into a similar data transfer agreement with the recipient or seek assurances from the recipient that they are EU/Swiss-U.S. Privacy Shield certified or have Binding Corporate Rules in place.
Your choices and rights
Where appropriate or legally required, we will describe how we use personal data we collect so you can make choices about how your data is used. You can notify us during the information collection process and change your preferences at any time.
- Marketing communications: With your consent, we may contact you by email or phone to provide additional information about our Services. If you would like to opt-out of further marketing communications, you can click the link in the bottom of any marketing email, or email us at email@example.com.
- Patient care communications: Subject to applicable law, we may call, email, or send SMS texts after your procedure to schedule appointments and facilitate follow up treatment.
- Transactional communications: We send transactional emails if you submit a message through the “Contact Us” form on our websites, to notify you about changes to our Services, and to send other disclosures as required by law.
For California consumers, please see our California Consumer Privacy Act Notice for information about your rights and how to exercise them.
For other individuals, depending on your country or state and as required by law, you have the right to:
- Access and receive a copy of your personal data;
- Update, amend, delete or correct incomplete or inaccurate data;
- For CA consumers, additionally:
- Request to delete information;
- For EEA/AUS individuals, additionally:
- Request that we stop processing your personal data;
- Withdraw your consent to the processing of your personal data;
- Object to the processing of your data;
- The portability of personal data – i.e., ask for a copy of your personal data to be provided to you, or a third party, in a digital format; and
- Lodge a complaint with a Data Protection ity/EU Supervisory ity.
We can correct or delete incorrect data, or provide a copy of your personal data upon request, but we reserve the right to request where necessary, additional information to verify your identity before we process your request and to maintain a copy of all requests for our legal records. If you wish to exercise these rights, please submit your request here and we will respond to verifiable requests within 30-45 days, depending on the applicable state or country regulations (if any). Applicable privacy laws may give you the right to file a complaint with a government regulator if you are not satisfied with our response.
How we store and secure information
We maintain appropriate administrative, technical, and physical safeguards designed to protect your personal data from loss, misuse, unized access, disclosure, alteration, and destruction. We maintain a Corporate IT Security Policy and use-tested access and security controls to ensure that your data is secure. We also require third party service providers acting on our behalf or with whom we share your information also provide such security measures in accordance with industry standards.
We use data hosting service providers in the U.S. and EEA to host the information we collect in connection with our HF10 Therapy. The servers which store the information we collect are kept in a controlled environment. Where data is transferred over the Internet as part of our website, the data is encrypted using industry standard SSL (HTTPS) and multi-factor authentication is required for remote access to most systems containing sensitive information.
Although we implement safeguards designed to protect your information, it is impossible to guarantee absolute security in all situations. If you have any questions about security of our Services, please contact us at firstname.lastname@example.org.
We retain your information for as long as needed to comply with our legal obligations (such as maintaining medical records and reporting to regulatory ities), resolve disputes, and enforce our rights. We also may retain your information to support our business operations and develop our Services. The criteria used to determine the retention periods include:
- how long the personal data is needed to provide the Services and operate the business;
- the type of personal data collected; and
- whether we are subject to a legal, contractual or similar obligation to retain the data (e.g., mandatory data retention laws, government orders to preserve data relevant to an investigation, or data that must be retained for the purposes of litigation or disputes.
Other important privacy information
Our Services are intended for a general audience and are not directed to children. We do not knowingly collect personal information online from minors under the age of 16. If you believe that a minor under the age of 16 may have provided us with personal information, please contact us at email@example.com and we will promptly delete that information from our records.
Third party services, applications, and websites
Certain third party services or websites you use, or navigate to or from our Services (such as social media sites) may have separate user terms and privacy policies that are independent of this Notice. We are not responsible for the privacy practices of these third party services or applications. We recommend carefully reviewing the user terms and privacy statement of each third party service, website, and/or application prior to use.
Changes to Privacy Notice
We may update this Notice to reflect changes in our personal data practices or relevant laws. We will notify you if we make any material changes by revising the "effective date" at the top of this Notice. We encourage you to review this Notice for updates each time you use our Services.