Privacy Policy

Last updated: January 1, 2025 | Effective date: January 1, 2025

NucliVision Inc. ("NucliVision", "we", "us", "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard information about you when you visit our website at nuclivision.co (the "Site") or contact us. Please read this policy carefully. If you disagree with its terms, please discontinue use of the Site.

This policy does not govern the processing of Protected Health Information (PHI) or clinical data by NucliVision's medical device software products. Those products operate within hospital information networks under separate data processing agreements with healthcare institution customers, in compliance with the Health Insurance Portability and Accountability Act (HIPAA) and applicable state medical privacy laws.

1. Information We Collect

1.1 Information You Provide Directly

When you interact with our Site, you may provide us with personal information, including:

Contact Information: Your name, email address, phone number, job title, organization name, and department when you submit our contact form, request a product demo, or subscribe to our newsletter.
Professional Information: Your medical specialty, type of institution (hospital, imaging center, academic medical center), country and region, and your role in the procurement or evaluation process for medical imaging software.
Communications: Content of messages you send to us, including questions, comments, requests for information, and feedback about our products or services.
Event Registration Data: If you register for a NucliVision webinar, conference presentation, or sponsored event, we collect your name, email, organization, and role for logistical and follow-up purposes.

1.2 Information Collected Automatically

When you visit our Site, certain information is automatically collected through your browser and our web infrastructure:

Log Data: Your IP address (anonymized after processing), browser type and version, operating system, the referring URL that brought you to our Site, pages viewed, time spent on each page, and the date and time of your visit.
Device Information: Screen resolution, device type (desktop, tablet, mobile), and general hardware category as reported by your browser's User-Agent string.
Cookies and Local Storage: We use a minimal cookie/localStorage implementation limited to recording your consent preference. See our Cookie Policy for complete details on what we store and why.

1.3 Information We Do Not Collect

NucliVision explicitly does not collect:

Protected Health Information (PHI) through this website. Our clinical software operates entirely within hospital networks.
Payment card information. We do not process payments through this website.
Social security numbers or government identification numbers.
Biometric data of any kind.
Information from children under 18 years of age. Our Site is intended for healthcare professionals and institutional procurement personnel.

2. How We Use Your Information

We use the information we collect for the following purposes, each tied to a lawful basis for processing:

2.1 Responding to Inquiries (Legitimate Interest / Contract Performance)

Contact form submissions and demo requests are used solely to respond to the specific inquiry submitted. A member of our clinical or commercial team will follow up by email or phone using the contact details provided. We do not add you to any marketing list without your explicit consent.

2.2 Product and Service Communication (Consent / Contract Performance)

If you have requested information about a specific NucliVision product or entered into a trial or evaluation agreement, we will communicate with you about that product, including technical documentation, regulatory status updates, clinical validation progress, and implementation information.

2.3 Marketing Communications (Consent Only)

We may send you newsletters, product updates, white papers, and announcements about NucliVision's regulatory milestones and clinical validation progress if you have explicitly opted in to receive such communications. You can unsubscribe at any time by clicking the unsubscribe link in any email or by contacting us at [email protected]. We do not send unsolicited marketing emails.

2.4 Website Analytics and Improvement (Legitimate Interest)

Aggregated, anonymized web analytics data helps us understand which sections of our Site are most useful, identify technical problems, and improve user experience. We do not use analytics to build individual user profiles or to track visitors across websites.

2.5 Legal and Regulatory Compliance

We may process your information to comply with legal obligations, including responding to valid legal process, regulatory inquiries from the FDA or other health authorities where NucliVision operates, or requests from law enforcement with appropriate legal authority.

2.6 Business Operations (Legitimate Interest)

Internal business functions including CRM record-keeping for institutional relationships, tracking the status of product evaluations, and managing our pipeline of clinical validation and regulatory affairs activities.

3. Disclosure of Your Information

3.1 Service Providers

We share information with third-party service providers who perform functions on our behalf, including:

Email and CRM platforms: We use enterprise email and CRM tools to manage contact records and respond to inquiries. These providers process data under contractual data processing agreements.
Web hosting infrastructure: Our website is hosted on cloud infrastructure. Hosting providers have access to server logs as part of normal infrastructure operation.
Legal and professional advisors: Our attorneys, accountants, and regulatory consultants may access information necessary to provide services to NucliVision.

We do not sell, rent, or trade your personal information to third parties for their independent marketing purposes under any circumstances.

3.2 Business Transfers

If NucliVision is involved in a merger, acquisition, financing, reorganization, bankruptcy, or sale of company assets, information we have collected may be transferred as part of that transaction. We will notify you via prominent notice on our Site or by email if such a transfer materially affects your personal information, and your rights under applicable law will continue to apply.

3.3 Legal Requirements

We may disclose your information if required to do so by law or in response to valid requests by public authorities (e.g., court orders, subpoenas, requests from regulatory agencies with jurisdiction). We will endeavor to notify you before disclosure where legally permitted to do so.

3.4 Protection of Rights

We may disclose information where we believe disclosure is necessary to: (a) protect the rights and property of NucliVision and our users; (b) investigate potential violations of our Terms of Use; (c) respond to claims that content violates the rights of third parties.

4. Data Storage and Security

4.1 Storage Location

Our website and contact form data are stored on servers located in the United States. If you are located outside the United States, please be aware that your information may be transferred to, stored, and processed in the US where our servers are located and our central database is operated.

4.2 Security Measures

We implement appropriate technical and organizational security measures to protect your personal information:

TLS 1.3 encryption for all data in transit between your browser and our servers.
Contact form data is transmitted over encrypted connections and stored in access-controlled systems.
Access to contact records is limited to NucliVision employees and contractors with a legitimate business need.
We conduct periodic reviews of our data handling practices and update them as our operations evolve.
We do not store payment card information on our systems.

No method of transmission over the Internet or electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your information, we cannot guarantee its absolute security.

4.3 Data Retention

We retain personal information for as long as necessary to fulfill the purposes for which it was collected:

Contact form inquiries: 24 months from the date of submission, unless the inquiry leads to an ongoing business relationship.
CRM records for active institutional relationships: Duration of the relationship plus 3 years.
Marketing opt-in records: Until you unsubscribe or request deletion, plus 1 year to maintain proof of consent.
Web server logs: 90 days in identifiable form, then aggregated and anonymized.

After applicable retention periods, we securely delete or anonymize data in accordance with our data retention schedule.

5. Your Privacy Rights

5.1 Rights for All Users

Regardless of your location, you have the right to:

Access: Request a copy of the personal information we hold about you.
Correction: Request correction of inaccurate or incomplete personal information.
Deletion: Request deletion of personal information we hold about you, subject to legal obligations that may require us to retain certain data.
Opt-out of marketing: Unsubscribe from marketing communications at any time.

To exercise any of these rights, contact us at [email protected] with the subject line "Privacy Rights Request." We will respond within 30 days.

5.2 Rights Under the General Data Protection Regulation (GDPR)

If you are located in the European Economic Area (EEA), United Kingdom, or Switzerland, you have the following additional rights under the GDPR and applicable national data protection law:

Right to Restriction: You may request that we restrict the processing of your personal data in certain circumstances (e.g., while a correction request is pending).
Right to Data Portability: Where processing is based on consent or contract, you may request that we provide your personal data in a structured, commonly used, machine-readable format.
Right to Object: You may object to processing based on legitimate interests, including processing for direct marketing purposes. Where you object to direct marketing, we will cease that processing.
Right to Withdraw Consent: Where processing is based on consent, you have the right to withdraw consent at any time. Withdrawal does not affect the lawfulness of processing prior to withdrawal.
Right to Lodge a Complaint: You have the right to lodge a complaint with your national data protection supervisory authority. For EU residents, a list of supervisory authorities is available on the European Data Protection Board website. For UK residents, the supervisory authority is the Information Commissioner's Office (ICO) at ico.org.uk.

Our lawful bases for processing under GDPR are: (a) legitimate interests for analytics and security; (b) performance of a contract or pre-contractual steps for product inquiries and demo requests; (c) consent for marketing communications; (d) legal obligation for regulatory compliance requirements.

For GDPR inquiries, contact our Data Protection contact at [email protected] with the subject line "GDPR Request."

5.3 Rights Under the California Consumer Privacy Act (CCPA) and CPRA

If you are a California resident, the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA) grants you specific rights regarding your personal information:

Right to Know: You have the right to request disclosure of the categories and specific pieces of personal information we have collected about you, the categories of sources from which we collected it, our business or commercial purpose for collecting it, and the categories of third parties with whom we share it.
Right to Delete: You have the right to request deletion of personal information we have collected about you, subject to certain exceptions.
Right to Correct: You have the right to request correction of inaccurate personal information we maintain about you.
Right to Opt-Out of Sale or Sharing: NucliVision does not sell or share personal information as defined under CCPA. We do not sell your data to data brokers, advertisers, or any third party for commercial purposes.
Right to Non-Discrimination: We will not discriminate against you for exercising any of your CCPA rights.

To submit a CCPA rights request, contact us at [email protected] with the subject line "California Privacy Rights Request." We will respond within 45 days as required by law.

In the preceding 12 months, NucliVision has collected the following categories of personal information from California residents who contacted us through the Site: identifiers (name, email address), professional or employment-related information (organization, job title), and internet or other electronic network activity (website usage logs).

6. Cookies and Tracking Technologies

We use minimal cookie and localStorage technology. Our current implementation uses only a single localStorage entry (nv_cookie_consent) to record your cookie notice acceptance. We do not use third-party tracking cookies, advertising cookies, or behavioral analytics services that create persistent user profiles or track you across websites.

For complete details on our cookie practices, including how to control or delete stored preferences, please see our Cookie Policy.

7. International Data Transfers

NucliVision is based in the United States. If you are located in the EEA, UK, Switzerland, or another jurisdiction with data transfer restrictions, please be aware that your personal information will be processed in the United States. The US may not have the same level of data protection as your home jurisdiction.

Where required by applicable law, we implement appropriate safeguards for international transfers, including standard contractual clauses approved by the European Commission or UK Information Commissioner's Office, or we rely on adequacy decisions where applicable.

By using our Site and submitting your information, you acknowledge the transfer, storage, and processing of your information in the United States in accordance with this Privacy Policy.

8. Clinical Software and HIPAA

NucliVision develops AI-based nuclear medicine imaging software classified as a medical device. Our clinical products are designed to process imaging data exclusively within the secure confines of hospital information systems (PACS, RIS, and VNA environments). NucliVision's clinical software does not transmit identifiable patient data to NucliVision's servers or any external system.

NucliVision enters into Business Associate Agreements (BAAs) with covered entities (healthcare providers and health systems) as required under HIPAA. Processing of PHI in connection with our clinical products is governed by those BAAs and our clinical data processing agreements, not this website privacy policy.

If you have questions about data handling in connection with NucliVision's clinical products, contact our regulatory and compliance team at [email protected].

9. Third-Party Websites and Links

Our Site may contain links to third-party websites, including links to publications in medical journals, conference proceedings, regulatory agency resources (FDA, EMA), and professional societies (SNMMI, EANM). This Privacy Policy does not apply to those websites. We are not responsible for the privacy practices of third-party sites and encourage you to review the privacy policies of any third-party site you visit.

10. Children's Privacy

Our Site is intended for healthcare professionals, hospital administrators, medical device procurement personnel, and investors. The Site is not directed to individuals under 18 years of age, and we do not knowingly collect personal information from children. If we learn that we have collected personal information from a child under 18, we will delete that information promptly. If you believe we may have information from or about a child, please contact us at [email protected].

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our information practices, legal requirements, or business operations. When we make material changes, we will update the "Last updated" date at the top of this page and, where required by applicable law, notify affected users by email or by prominent notice on the Site. We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information.

Continued use of the Site after the effective date of any updated policy constitutes your acknowledgment and acceptance of the updated policy.

12. Contact Information

If you have questions, concerns, or requests relating to this Privacy Policy or our data practices, please contact us:

NucliVision Inc.
Avenue Louise 523, 1050 Brussels, Belgium
United States
[email protected]
+32 2 880 4210

We aim to respond to all privacy inquiries within 10 business days. For formal rights requests under GDPR or CCPA, we will respond within the legally required timeframe (30 days for GDPR, 45 days for CCPA).

For EU/EEA residents, you may also contact the Data Protection Authority in your member state. A directory of EEA supervisory authorities is maintained by the European Data Protection Board at edpb.europa.eu.