PRIVACY POLICY

Last Updated: January 8, 2026

1. Introduction

This Privacy Policy ("Policy") describes how Pain Management Technologies, Inc., doing business as NerveSpa ("PMT," "NerveSpa," "we," "us," or "our") collects, uses, discloses, and protects information when you visit www.nervespa.com, use any associated mobile applications, purchase products, or otherwise interact with us (collectively, the "Services"). By using the Services, you acknowledge and agree to the practices described in this Policy.

2. Scope of This Policy

This Policy applies to:

• Clinics, practices, and professional healthcare entities ("Clinics")
• Patients and consumers who purchase accessories or consumables directly from PMT
• Visitors to our Site and users of our applications

Note: This Policy does not apply to information collected directly by Clinics from their patients. PMT is not responsible for the privacy practices of independent healthcare providers.

3. Information We Collect

A. Information You Provide Voluntarily

We collect information you provide when you register an account, place an order, submit a form, or contact us, including:

• Name and contact details (email, phone number, shipping and billing address)
• Business or Clinic name and professional credentials (for Clinic accounts)
• Payment-related information (processed securely by third-party providers; PMT does not store full credit card numbers)
• Communications sent to us (emails, support requests, inquiries)

B. Automatically Collected Information

Like most websites, we use cookies and similar technologies to collect:

• IP address
• Browser type and device identifiers
• Operating system
• Pages viewed, time spent on the Site, and referring URLs

Cookies are used to enable site functionality, analyze usage patterns, and improve user experience.

C. Device Usage Data

Local Storage: By default, NerveSpa device usage data (such as frequency of use or device settings) is stored locally on the physical device.

Optional Sync: If a user affirmatively enables optional app synchronization, limited usage data may be transmitted at the user's direction to support app functionality or troubleshooting.

Not a Medical Record: Device usage data is for technical and informational purposes only and does not constitute a formal medical record.

4. How We Use Information

We use information we collect to:

• Process and fulfill orders, invoices, returns, and warranty claims
• Provide customer service and technical support
• Improve device performance, app functionality, and website operations
• Send transactional communications (order confirmations, shipping updates, account notices)
• Send marketing, promotional, or educational communications where permitted by law
• Comply with legal, regulatory, and contractual obligations

We do not use personal information for automated decision-making that produces legal or similarly significant effects.

5. HIPAA & Health Information

No PHI Solicitation: The Services are not intended to collect or store Protected Health Information ("PHI") as defined by HIPAA.

No Business Associate Relationship: PMT is not a "Business Associate" of any Clinic unless a separate written Business Associate Agreement (BAA) is formally executed.

User Responsibility: Users are strictly prohibited from uploading or transmitting medical records or sensitive health information through the Site or App. PMT reserves the right to delete any unsolicited health information received without notice.

6. How We Share Information

We do not sell or rent your personal information.

We may share information only with:

• Service Providers that assist with payment processing, shipping, website hosting, analytics, or customer support
• Legal or regulatory authorities if required by law, subpoena, or to protect the rights and safety of PMT or others
• Business successors in connection with a merger, acquisition, reorganization, or sale of assets

7. Marketing Communications & Opt-Out

We may send newsletters, product updates, educational materials, and promotional offers. You may opt out of marketing emails at any time by clicking the "unsubscribe" link included in the email or by contacting us directly.

Opting out of marketing communications will not affect your receipt of transactional, legal, or administrative emails (such as order confirmations or security notices).

8. Data Security & Retention

We implement reasonable administrative, technical, and organizational safeguards designed to protect personal information from unauthorized access, disclosure, or misuse. We retain personal information only as long as reasonably necessary to fulfill the purposes described in this Policy or as required by applicable Ohio or U.S. federal law. However, no method of transmission or storage is completely secure, and PMT cannot guarantee absolute security.

9. Your Rights (Including State-Specific Rights)

Depending on your state of residence and applicable law (e.g., California, Virginia), you may have the right to:

• Access personal information we hold about you
• Request correction or deletion of personal information
• Opt out of certain uses of personal information

To exercise these rights, contact us at info@paintechnology.com. We may require verification of your identity before processing a request.

10. International Users

The Services are operated and hosted in the United States. If you access the Services from outside the U.S., you consent to the transfer, storage, and processing of your information in the United States in accordance with this Policy.

11. Changes to This Policy

We may update this Privacy Policy from time to time. Any changes will be effective when posted with an updated Last Updated date. Continued use of the Services after changes are posted constitutes acceptance of the revised Policy.

12. Contact Information