ELG3 Privacy Policy

Last modified: September 25, 2018

1. Introduction

ELG3 Corporation and XP Technology, LLC, (“ELG3, & XP Technology” or “We”) respect your privacy and are committed to protecting it through our compliance with this policy. We are recruiting participants for an investigational study (the “Study”) to evaluate the effectiveness of a non-invasive device for testing A1C and glucose in diabetic patients. The hope is that the device, the Easy Light Glycometer (“ELG”) will reduce the need for finger sticks by becoming FDA cleared for marketing as a universal, non-invasive testing device used to monitor A1C and glucose that are comparable to the effectiveness of a whole-blood fingerstick test.

This Privacy Policy (our “Privacy Policy”) describes the types of information we may collect from you or that you may provide to determine if you are a candidate to participate in our Study, and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy applies to information we collect through telephone calls or messages between you and our investigators to determine if you are a candidate to participate in our study. If selected to participate in the Study, you may be asked to provide additional medical information which will be covered under a HIPAA-required notice of privacy practices and not this policy. This policy also does not apply to any information collected by us for other purposes, or information collected by any third party, including your doctor even if they provide information related to determine if you are a candidate to participate in the Study.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to submit information to determine if you are a candidate to participate in the Study. By submitting information to determine if you are a candidate to participate in the Study, you agree to this Privacy Policy. This Privacy Policy may change from time to time (see Changes to Our Privacy Policy). Your continued participation in the Study after we make changes is deemed to be acceptance of those changes, so please check this Privacy Policy periodically for updates.

2. Age requirements to participate

Our Study is only intended for individuals between 25-65 years of age. No one outside of this age range should provide any information to us to participate in the Study. We do not knowingly collect Personal Data from individuals outside of this age group. If you are outside this age group, do not provide us information to participate in the Study. If we learn we have collected or received Personal Data from individuals outside this age group, we will delete that information.

3. Information We Collect About You and How We Collect It

When you contact us to determine if you are eligible to participate in the Study, we will collect information by which you may be personally identified, such as name and telephone number and other information we may ask to determine your eligibility to participate in the Study.

4. How We Use Your Information

We use information that we collect about you or that you provide to us to provide you with information regarding our Study and to determine if you are eligible to be a candidate to our Study.

5. Disclosure of Your Information

We do not share, sell, or otherwise disclose your Personal Data for purposes other than those outlined in this Privacy Policy. However, we may disclose aggregated information about our Study participants, and information that does not identify any individual, without restriction.

We may disclose Personal Data that we collect or you provide as described in this privacy policy:

  • to clinics, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep Personal Data confidential and use it only for the purposes for which we disclose it to them;
  • to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of ELG3 Corporation’s and XP Technology, LLC, assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by ELG3 Corporation and XP Technology, LLC about our Study participants is among the assets transferred;
  • to your medical provider; and
  • with your consent.

We may also disclose your Personal Data:

  • to comply with any court order, law, or legal process, including to respond to any government or regulatory request;
  • if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of ELG3 Corporation and XP Technology, LLC, our Study participants, clinical staff, or others.

6. Choices About How We Use and Disclose Your Information

We do not control the collection and use of your information collected by third parties. When possible, these organizations are under contractual obligations to use your Personal Data only for providing the services to us and to maintain this information strictly confidential. These third parties may, however, aggregate the information they collect with information from their other customers for their own purposes.

7. Accessing and Correcting Your Information

You can review and change your Personal Data by contacting us through the Contact Information below to ensure that it is complete, accurate, and as current as possible. We may also not be able to accommodate your request if we believe it would violate any law or legal requirement or cause the information to be incorrect.

8. Data Security

We have implemented measures designed to secure your Personal Data from accidental loss and from unauthorized access, use, alteration, and disclosure.

9. Changes to Our Privacy Policy

We may change this Privacy Policy at any time. It is our policy to post any changes we make to our Privacy Policy on this page. If we make material changes to how we treat Personal Data after you have provided information to become a Study participant, we will notify you through the contact information we have on file. The date this Privacy Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date contact information for you.

10. Contact Information

To ask questions or comment about this Privacy Policy and our privacy practices, please contact us at:

ELG3 Corporation
75 South Clinton Ave., Suite 510,
Rochester, N. Y. 14604

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