Privacy Policy

Effective Date: 2/16/2025
Sophros, LLC

Sophros, LLC (“Sophros,” “we,” “our,” or “us”) operates with a strict data minimization and privacy-first philosophy. We are committed to protecting personal information, neurological data, behavioral indicators, and any information that may qualify as Protected Health Information (“PHI”) under applicable law.

Sophros does not monetize data. Sophros does not engage in behavioral tracking. Sophros does not sell or broker personal information.

This Privacy Policy describes how information is handled in connection with Sophros’ website, research collaborations, spatial audio systems, and authorized engagements.

1. Data Minimization Commitment

Sophros collects only the minimum information necessary to:

• Respond to direct communications
• Evaluate professional collaborations
• Fulfill contractual obligations
• Conduct authorized research activities

We do not collect information for advertising, behavioral profiling, resale, or unrelated commercial exploitation.

2. Nature of Sophros Services

Sophros develops neuroscience-informed spatial audio systems and may, within authorized research or contractual contexts, analyze:

• Quantitative EEG (“QEEG”) data
• Neurophysiological signals
• Behavioral or cognitive indicators
• Social regulation markers

Sophros does not provide medical diagnosis, medical advice, or clinical treatment through its website.

Where Sophros collaborates with licensed healthcare providers or research institutions, data handling is governed by Business Associate Agreements, research protocols, and applicable federal and state privacy laws.

Website interaction alone does not create a healthcare provider relationship.

3. Information Collected

A. Voluntarily Submitted Information

Sophros may collect:

• Name
• Email address
• Phone number
• Organization
• Professional role
• Information voluntarily submitted through direct inquiry

Sophros does not require medical or neurological data to be submitted through website contact forms.

B. No Tracking, Profiling, or Analytics

Sophros does not use:

• Cookies
• Tracking pixels
• Behavioral advertising technologies
• Session replay tools
• Third-party analytics platforms
• Automated fingerprinting technologies
• AI behavioral profiling systems

We do not collect passive browsing data for analytics or marketing purposes.

Our website is designed to operate without automated surveillance or profiling infrastructure.

4. Neurological and Health-Related Data

In formal research or authorized collaborative engagements, Sophros may receive:

• QEEG recordings
• Neurophysiological data
• Behavioral metrics
• Cognitive performance data

When such information is identifiable and provided through a Covered Entity, it may constitute PHI under HIPAA.

Sophros processes such information only:

• Under written agreements
• Within defined scope of work
• In compliance with applicable law
• Using industry-appropriate safeguards

Sophros does not use neurological data for marketing, advertising, resale, or unrelated secondary purposes.

Sophros does not conduct automated medical decision-making.

Sophros does not independently diagnose medical or psychiatric conditions.

5. HIPAA and Regulatory Safeguards

When acting as a Business Associate, Sophros:

• Implements administrative, technical, and physical safeguards
• Limits access to authorized personnel under confidentiality obligations
• Applies encryption standards where appropriate
• Maintains role-based access controls
• Conducts periodic security assessments
• Maintains internal breach response protocols
• Reports breaches of unsecured PHI as required by law

Individuals seeking to exercise HIPAA rights must contact the originating Covered Entity unless otherwise required by contract.

6. Data Retention

Sophros retains personal or neurological data only:

• For the duration necessary to fulfill contractual obligations
• For the duration required by applicable law
• For the duration specified in research agreements

Data is securely deleted or de-identified when no longer required.

7. Data Security Standards

Sophros employs commercially reasonable safeguards, which may include:

• Encryption in transit and at rest where appropriate
• Secure storage environments
• Access restriction protocols
• Contractor confidentiality agreements
• Segregation of identifiable data from analytical data where feasible

Despite these safeguards, no system can guarantee absolute security.

8. No Sale or Commercial Exploitation

Sophros does not:

• Sell personal information
• Sell Protected Health Information
• License identifiable neurological data
• Share data for behavioral advertising
• Trade data with third-party marketing platforms

9. No Automated Decision-Making

Sophros does not engage in fully automated decision-making processes that produce legal or similarly significant effects on individuals.

QEEG analysis or behavioral modeling is conducted within authorized professional or research contexts and does not replace clinical judgment.

10. Research Governance

Where Sophros participates in research:

• Separate informed consent is required
• IRB oversight may apply
• Data use is defined by protocol
• Participants may withdraw as allowed by law and agreement

Website interaction does not constitute research enrollment.

11. Children and Minors

Sophros does not knowingly collect personal information from children under 13 through its website without proper authorization.

Where neurological or behavioral data involves minors within research or clinical collaborations, parental or legal guardian consent is required in accordance with applicable law.

12. Jurisdiction and Cross-Border Data

Sophros primarily operates within the United States.

Data is not intentionally transferred internationally without appropriate legal safeguards.

If international collaboration occurs, Sophros will apply appropriate data protection mechanisms consistent with applicable law.

13. Limitation of Liability

Sophros is not responsible for information voluntarily transmitted to us outside secure authorized channels.

Sophros is not responsible for privacy practices of third-party institutions, collaborators, or external websites.

Nothing in this policy creates contractual rights beyond those required by law.

14. Policy Updates

Sophros may update this Privacy Policy periodically. Updates will be reflected by a revised effective date.

15. Contact

Sophros, LLC
Rbigelow@Sophrossound.com