Consumer Health Data Privacy Policy

Effective Date: May 16, 2025

At Neurogen Biomarking LLC ("Neurogen," "we," "our," or "us"), protecting the privacy and security of your personal and health data is a top priority. This Consumer Health Data Privacy Policy explains how we collect, use, share, and protect your information when you access our services, including digital health assessments, blood biomarker testing, and related communications.

1. Scope and Applicability

This policy applies to all consumer health data collected by Neurogen Biomarking LLC through our website, mobile platforms, events, customer support interactions, and third-party service providers acting on our behalf.

2. What Information We Collect

We may collect the following types of consumer health data:

  • Personal Identifiers: Name, address, email, phone number, date of birth.
  • Health-Related Data:
    • Self-reported cognitive concerns and medical history.
    • Digital cognitive test results.
    • Blood biomarker test results (e.g., p-tau217 and related indicators).
    • Data shared during telehealth or follow-up consults with neurologists.
  • Device and Technical Data: IP address, browser type, device ID, and interaction logs.

3. How We Use Your Information

We use your data to:

  • Provide, manage, and improve our health testing services.
  • Deliver accurate and timely test results.
  • Facilitate telehealth consultations and neurologist follow-ups.
  • Develop and improve early detection tools.
  • Communicate with you about your health journey and offer educational resources.
  • Comply with legal and regulatory obligations.

4. How We Share Your Information

We do not sell your consumer health data.

We may share your information with:

  • Authorized health professionals providing you care through our platform.
  • Third-party service providers (e.g., testing labs, mobile phlebotomists, IT providers) under strict confidentiality agreements.
  • Regulatory bodies when required by law, subpoena, or public health authority.
  • You – upon request, we will provide access to your data or transfer it to a healthcare provider of your choice.

5. Consumer Rights

You have the following rights with respect to your consumer health data:

  • Right to Access: You may request a copy of the personal and health data we hold about you.
  • Right to Withdraw Consent: You may withdraw your consent to data collection or processing at any time, subject to limitations where required by law.
  • Right to Deletion: You may request that we delete your data, and we will comply unless retention is required for legal or medical reasons.
  • Right to Correct: You may request that we correct any inaccurate or incomplete data.
  • Right to Limit Use/Sharing: You may opt out of certain uses or disclosures of your data.

To exercise these rights, please contact us at privacy@neurogenbiomarking.com.

6. Data Security

We implement administrative, technical, and physical safeguards to protect your data, including:

  • Encryption of sensitive health information.
  • Secure data storage and access controls.
  • Routine vulnerability and privacy audits.

7. Data Retention

We retain consumer health data only as long as necessary to:

  • Provide services and support.
  • Meet legal and regulatory obligations.
  • Conduct quality assurance and product development.

8. Children's Privacy

Our services are not intended for individuals under the age of 50. If we learn we have collected data from a minor without appropriate authorization, we will promptly delete it.

9. Release of Information Authorization

AUTHORIZATION FOR THE USE AND/OR DISCLOSURE OF PERSONAL HEALTH INFORMATION

I give my consent to Neurogen to release my records to certain designated third party recipients pursuant to applicable federal and state data protection and confidentiality laws. By clicking “accept” below, I hereby authorize the disclosure of my personal information, including testing results, to the Authorized Recipients defined below.

Definitions.

  • “Authorized Recipients” means the Neurogen Biomarking including its affiliates and subcontractors, my treating Health Care Provider, or other third parties that I agree to in writing;
  • “Health Care Provider” means any duly trained and licensed neurologist, nurse practitioner, physician assistant, and/or any other health care professional with whom I consult; and
  • “Health Information” means any and all health information about me, regardless of the record or form within which it appears, and including, without limitation, all information relating to any injury, sickness, disease, mental health condition, physical condition, drug use, drug abuse or dependence, medical history (including any family health history), medical or clinical status, medical diagnosis, medical treatment or prognosis prepared by or made available to my Health Care Provider(s). For certainty, Health Information specifically includes contact information, clinical notes, progress notes, test results, consultation reports, patient assessment forms, medication lists, orders, and evaluations.

I authorize Neurogen Biomarking, as well as my treating Health Care Provider(s), to disclose to any other Authorized Recipients any of the Health Information about me that is (or, during the period covered by this Authorization, may be) in their possession, custody or control to coordinate and facilitate my care.

I acknowledge that there exists the potential that information disclosed pursuant to this Authorization might be subject to redisclosure by the recipient and, in some circumstances, would no longer be protected by applicable confidentiality laws.

I understand that I have the right to revoke this Authorization at any time, but that my revocation will not be effective to the extent that any of the persons or entities (or classes of persons or entities) I have authorized to use and/or disclose my Health Information have acted in reliance upon this Authorization. My revocation must be in writing and sent to: Neurogen Biomarking LLC, Attn: Privacy Officer, 2525 S Michigan Ave, Chicago, IL 60616.

I understand that the Health Care Provider may not condition treatment, payment, enrollment or eligibility for benefits on whether I, as the patient, sign the Authorization when a prohibition on conditioning of authorizations applies.

This Authorization remains intact unless and until revoked in writing. I authorize each Authorized Recipient to retain Health Information received by it prior to the date of revocation or expiry.

I acknowledge and agree that, to the extent allowed by law, the foregoing shall be governed by and construed according to the laws of the State of Delaware, without regard to conflict of laws principles thereof.

10. Updates to This Policy

We may update this policy periodically. Material changes will be communicated via email or through our website. Please review this policy regularly.

11. Contact Us

If you have any questions about this policy or how your data is handled, please contact:

Privacy Officer

Neurogen Biomarking LLC

123 Innovation Way, Suite 400

Chicago, IL 60601

privacy@neurogenbiomarking.com