Effective December 19, 2023

This Privacy Policy (the “Privacy Policy”) describes how Treace Medical Concepts, Inc. (“we,” “us,” or “our”) and our affiliated entities collect, use, and share your personal information. This Privacy Policy applies to your use of our websites (including www.treace.com, www.Lapiplasty.com, www.AlignMyToe.com, www.FixMyToe.com and www.LapiplastyOutreach.com), and all other digital and online services provided by us, as well as information collected offline (collectively, our “Services”), and describes our privacy practices relating to the Services.

We value your privacy and are committed to protecting your personal information. Please review this Policy in order to understand how we collect, use, and share personal information.

We reserve the right to change this Privacy Policy at any time. If we change our Privacy Policy, we will post an updated version. Please check back periodically to see if our Privacy Policy has been updated. Updates to the Privacy Policy will be referenced by the “Last Updated and Effective Date” date shown above.

1. Personal Information We Collect About You and Its Business Purpose.

We collect personal information about you for a variety of business reasons as indicated in the chart below. Please note the specific pieces of personal information we may collect about you can vary depending on the nature of your interactions with us. We may or may not collect all pieces of information referenced below as it relates to you.

As used herein, “personal information” is information that identifies, relates to, or could reasonably be linked directly or indirectly with you. Personal information does not include: (1) publicly available information or lawfully obtained, truthful information that is a matter of public concern; or (2) information that is deidentified or aggregated consumer information. We also collect “sensitive personal information,” which is a subset of person information, as set forth below.

Set for the below are the categories of personal information we collect and have collected in the preceding 12 months, the categories of sources from which the personal information was collected and the business or commercial purpose for the collection.

Category of Personal Information	Examples	Categories of Sources from which Personal Information Collected	Business or Commercial Purposes
PERSONAL INFORMATION
Identifiers	Real name Alias Postal address Unique personal identifier Online identifier Internet protocol address Email address Account name Cookie information Social security number* Driver’s license number* Passport number*	Directly from you (including but not limited to by information you submit on our website, when you contact us via email, telephone, online chat, or the Patient Call Center, when you complete an assessment to determine if you are a candidate for our products/services, when you register or maintain an account, when you register for one of our events, when you apply for employment, or when you otherwise contact us)From your healthcare providersAutomatically when we collect information about you through your use of our services From surveys and promotions From content you post or share publicly on forums or social media pages Third party sources	To help you determine if you may be a candidate for our products/services To assist you with finding a doctor qualified to perform a procedure using our products/services and arranging appointments with the doctor that you select To respond to questions, requests, and comments from you To provide and send educational information about bunions and our products/services To send promotional offers and advertisements regarding our products/services To operate and improve our websites and Services For customer service, security, and to detect, prevent and mitigate fraudulent, harmful or illegal activities For purposes of hiring and employment with us
Commercial Information	Records of products purchased, obtained, or considered, or other purchasing or consuming histories or tendencies	Directly from you From your healthcare providers	To respond to questions, requests, and comments from you To provide and send educational information about bunions and our products/services To operate and improve our websites and Services For customer service, security, and to detect, prevent and mitigate fraudulent, harmful or illegal activities
Biometric information	X-rays	Directly from you From your healthcare providers	To help you determine if you may be a candidate for our products/services To assist you with finding a doctor qualified to perform a procedure using our products/services and arranging appointments with the doctor that you select
Internet Information	Internet or other electronic network activity information Browsing history Search history Information regarding your interaction with an internet website, application, or advertisement Cookie information	Directly from you Automatically when you visit our website	To send educational information about bunions and our products/services To send promotional offers and advertisements regarding our products/services To operate and improve our websites and Services For customer service, security, and to detect, prevent and mitigate fraudulent, harmful or illegal activities
Geolocation Data</P	Your general location	Directly from you Automatically when you visit our website	To help you determine if you may be a candidate for our products/services To assist you with finding a doctor qualified to perform a procedure using our products/services and arranging appointments with the doctor that you select To respond to questions, requests, and comments from you To provide and send educational information about bunions and our products/services To send promotional offers and advertisements regarding our products/services To report product experience information to the FDA or other regulatory agencies To assist in providing medical education and training
Audiovisual Information	X-rays Phone call or meeting recordings Text messages Emails Security camera recordings	Directly from you Automated means through our security systems, telecommunication systems and online meeting systems From your healthcare providers	To help you determine if you may be a candidate for our products/services To assist you with finding a doctor qualified to perform a procedure using our products/services and arranging appointments with the doctor that you select To respond to questions, requests, and comments from you For customer service, security, and to detect, prevent and mitigate fraudulent, harmful or illegal activities To report product experience information to the FDA or other regulatory agencies To assist in providing medical education and training
Professional or Employment Information	Your professional information Your employment information	Directly from you Your healthcare providers Consumer reporting agencies Our service providers Your prior employers Publicly available sources	For purposes of hiring and employment with us In connection with patient testimonials or references (with your approval) For medical education presentations
Education information	Your education information, including high school and college information, dates of graduations and degrees obtained	Directly from you Consumer reporting agencies Our service providers Your prior employers Surveys and promotions Publicly available sources	For purposes of hiring and employment with us In connection with patient testimonials or references (with your approval) For medical education presentations
Inferences	Information identified to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes	Automatically based on the sources identified above	To help you determine if you may be a candidate for our products/services To assist you with finding a doctor qualified to perform a procedure using our products/services and arranging appointments with the doctor that you select To respond to questions, requests, and comments from you To provide and send educational information about bunions and our products/services To send promotional offers and advertisements regarding our products/services For customer service, security, and to detect, prevent and mitigate fraudulent, harmful or illegal activities
SENSITIVE PERSONAL INFORMATION
Sensitive Personal Identifiers*	Social security Driver’s license State identification card Passport number	Directly from you	To recruit employees and perform background screening
Sensitive Protected Characteristics**	Sex Age	Directly from you From your healthcare providers	To help you determine if you may be a candidate for our products/services To assist you with finding a doctor qualified to perform a procedure using our products/services and arranging appointments with the doctor that you select To provide and send you information about our products/services To report product experience information to the FDA or other regulatory agencies To respond to questions, requests, and comments from you To assist in providing medical education and training
Health Information	Medications taken Information regarding foot conditions	Direct from you Our service providers From your healthcare providers	To treat foot conditions To engage in quality improvement activities

* This only applies to job applicants.

** We may receive this information as part of our quality control processes or FDA reporting obligations.

Cookies and Tracking Technologies. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer. Cookies contain information that is transferred to your computer’s hard drive. We use cookies or similar technologies, such as web beacons and tracking pixels to analyze trends, administer our website, personalize content and ads, track users’ movements around our website to provide you with the most relevant browsing experience, and to gather demographic information about our user base as a whole. You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on our website or of the service we provide as some of our features or services may not function properly without cookies.

We use the following cookies:

• Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
• Functionality/preference cookies. These are used to recognize you when you return to our website. This enables us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
• Statistical, analytical or performance cookies. These allow us to recognize and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
• Marketing/targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests.
• Third party cookies. These cookies are placed on your device by a website from a domain other than our website. Please note that various third parties may also use these types of cookies, over which we have no control. These named third parties may include, for example, advertising networks and providers of external services like web traffic analysis services. These third party cookies are likely to be analytical cookies or performance cookies or targeting cookies.

If you want to remove existing cookies from your device you can do this using your browser options. If you want to block future cookies being placed on your device you can change your browser settings to do this. Please bear in mind that deleting and blocking cookies may have an impact on your user experience as parts of the site may no longer work. Unless you have adjusted your browser settings to block cookies, our system may issue cookies as soon as you visit our site or click on a link in a targeted email that we have sent you, even if you have previously deleted our cookies.

In addition, we use web beacons and pixels, which are images that can be placed in web pages and some forms of email. These technologies can be used to deliver cookies and to collect information about your use of the site. Finally, we may also collect information through tracking pixels. A tracking pixel is a transparent graphic image (usually 1 pixel x 1 pixel or Javascript tag) that is placed on a web page and, in combination with a cookie, allows us to collect information regarding the use of the page of the site that contains the tracking pixel. We may use tracking pixels to trigger ads on participating websites based on activity tracked from the browser on a device used to visit our Sites. Other entities may have access to some of this information.

By using your website and services you affirmatively agree to the use of cookies disclosed in this Privacy Policy.

Public Forums, Testimonials, and Patient Stories. We offer features on our websites that allow users to connect and share their stories. You do not have to use these features, but if you do, please use common sense and good judgment when posting in these communities or sharing your information, photos, or videos with others. Please be aware that any personal information you choose to submit in any communities, forums, or reviews can be read, collected, or used by others, and could be used to send unsolicited messages to you. Despite our safety and privacy controls, we cannot guarantee that you will not encounter inappropriate or illegal conduct from others when using the Services. You can help us to make our websites (including public forums) welcoming for all users by reporting any offensive or unwelcome conduct to us.

Patient Health Information. In performing our core functions, we are not a covered entity or a business associate as defined under the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) and the Health Information Technology for Economic and Clinical Health Act of 2009 (the “HITECH Act”). However, we routinely conduct business with medical practices, and as a result, situations arise when we may receive and store identifiable patient health information. We do so in accordance with applicable laws, rules and regulations, including those under HIPAA and the HITECH Act. For more information on your healthcare provider’s information-sharing practices, please contact the provider’s office.

Aggregated Data. We may aggregate or de-identify your personal information so that it can no longer be linked to you. Aggregated/de-identified information may be used for any purpose.

2. Sale, Sharing and Disclosure of Personal Information.

We do not “sell” your personal information, as the term “sell” is commonly understood to mean the exchange of data for money.  However, other companies, such as Google Analytics, Third-Party Sites and Other Third Parties (outlined below) may have access to your personal information.  This access and certain other functions described below may be deemed to be a “sale” under the California Consumer Protection Act, as amended by the California Privacy Rights Act (“CCPA”) or sharing of personal information for cross-context behavioral advertising.  We do not have actual knowledge of any sale of personal information of minors under 16 years of age.  The chart below shows the categories of personal information we have sold and/or shared (as defined by the CCPA) in the past 12 months, the categories of third parties who may have received your personal information in connection with the foregoing and the business purpose for the foregoing.

Categories of Personal Information Sold or Shared in the Past 12 Months	Categories of Third Parties	Business or Commercial Purposes
PERSONAL INFORMATION
Identifiers	Our business partners and physician network Our customers, including doctors you select through the “Find a Doctor” tool and their practices and facilities Data analytics providers like Google Analytics Third party advertising and marketing companies Companies providing recruiting, background check and other employment related services	To provide or advertise our products/services to you To assist with our Online Chat functionality (see below) To assist with our Patient Call Center (see below) To assist us with marketing through broadcast and streaming media, video, social media, text and email To investigate and report product experience information to the FDA or other regulatory agencies
Commercial Information	Third party advertising and marketing companies Our customers, including doctors you select through the “Find a Doctor” tool and their practices and facilities	To provide or advertise our products/services to you To fulfill a transaction
Internet Information	Our customers, including doctors you select through the “Find a Doctor” tool and their practices and facilities Data analytics providers like Google Analytics Third party advertising and marketing companies Companies providing recruiting, background check and other employment related services	To assist us with marketing through broadcast and streaming media, video, social media, text and email To analyze cookie information for marketing purposes
Geolocation Data	Our customers, including doctors you select through the “Find a Doctor” tool and their practices and facilities Data analytics providers like Google Analytics Third party advertising and marketing companies	To help you determine if you may be a candidate for our products/services To assist you with finding a doctor qualified to perform a procedure using our products/services and arranging appointments with the doctor that you select To respond to questions, requests, and comments from you To provide and send you information about bunions and our products/services To send promotional offers and advertisements regarding our products/services
Audiovisual Information	Our customers, including doctors you select through the “Find a Doctor” tool and their practices and facilities Third parties advertising and marketing companies	To help you determine if you may be a candidate for our products/services To assist you with finding a doctor qualified to perform a procedure using our products/services and in arranging appointments with the doctor that you select To respond to questions, requests, and comments from you To provide and send you educational information about bunions and our products/services To send promotional offers and advertisements regarding our products/services To investigate and report product experience information to the FDA or other regulatory agencies
Professional or Employment Information	Companies providing recruiting, background check and other employment related services	To assist with our hiring process To report product experience information to the FDA or other regulatory agencies To assist with medical education and training In connection with patient testimonials or references (with your approval)
Educational Information	Our customers, including doctors you select through the “Find a Doctor” tool and their practices and facilities Companies providing recruiting, background check and other employment related services	To assist with our hiring process To report product experience information to the FDA or other regulatory agencies To assist with medical education and training In connection with patient testimonials or references (with your approval)
Educational Information	Our business partners and physician network Our customers, including doctors you select through the “Find a Doctor” tool and their practices and facilities	To report product experience information to the FDA or other regulatory agencies To assist with medical education and training In connection with patient testimonials or references (with your approval)
Inferences	Our customers, including doctors you select through the “Find a Doctor” tool and their practices and facilities Data analytics providers like Google Analytics Third party advertising and marketing companies	To help you determine if you may be a candidate for our products/services To send educational information about bunions and our products/services To send promotional offers and advertisements regarding our products/services
SENSITIVE PERSONAL INFORMATION
Sensitive Protected Characteristics	Companies providing recruiting, background check and other employment related services	To assist with our hiring process
Health Information	Healthcare providers Sales representatives	To connect patients with doctors for treatment of foot conditions To assist with tasks related to healthcare procedures

 

Online Chat.  Some of our websites offer an online chat feature where you can ask questions and get real-time answers about our products/services. We use service providers to help us run our online chat feature. If you choose to use this feature, the content of the chat messages, as well as your name, email address, and other personal information you provide, may be shared with our chat service providers.

Lapiplasty® Patient Call Center.  Some of our websites offer a phone number, online appointment form or other ways to interact where you can ask questions and get answers about our products/services or request an appointment with the doctor that you select using the “Find a Lapiplasty® Doctor” tool. We use service providers to help us run this Patient Call Center. If you choose to use the Patient Call Center, the content of your phone, text or other conversations or online forms or other interactions, as well as your name, phone, email address, insurance information and other personal information you provide, may be shared with our Patient Call Center service providers and with the office of the doctor that you select through the “Find a Doctor” tool.

Google Analytics.  We use Google Analytics to ensure website functionality and improve our website and services.  This software may record information such as your IP address, location, age and gender, browser type and language, operating system, access time, duration of visit, pages you view within our website, search terms you enter and other actions you take while visiting us, the pages you view immediately before and after you access the services, how often you use our Services, aggregated usage and performance data, app errors and debugging information.  Google Analytics is owned and controlled by Google LLC.  Data collected by Google is subject to its privacy policy.  To learn how Google uses data related to website analytics, please click here. You may opt-out of having your activity on our website made available to Google Analytics by installing the Google Analytics browser add-on, available here.

Ads on Third-Party Sites.  We use third-party advertising companies to place ads on other sites. For example, we share personal information with third-party platforms (such as Google, Facebook, Instagram, LinkedIn, YouTube, and Twitter) to market our products and services to you while you are browsing the internet or using social media. For more information on how these sites use your personal information to target advertising to you, please visit their websites.

Other Third-Parties. We engage third-parties to help us design and operate our websites and Services, understand how users interact with our websites and Services, improve website security, and assist us with marketing our products through social media, online chat, Patient Call Center, email and text marketing, and television, streaming media and other online video and audio advertising placement. These companies may use cookies, tracking pixels, and similar technologies to collect information about your use of our websites and Services as well as information about your use of other websites over time.

In addition, the chart below shows the categories of personal information we have disclosed to our service providers and contractors for the business purposes identified below during the last 12 months. 

• • Auditing and Ad Impression: We use personal information for auditing purposes related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.
  • Security and Fraud Detection: We use personal information for our security and fraud detection services including detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity; and prosecuting those responsible for that activity.
  • Functionality & Debugging: We use personal information to engage in debugging to identify and repair errors that impair existing intended functionality.
  • Short-Term / Transient Use: We use personal information for short-term, transient use, including, but not limited to, non-personalized advertising shown as part of a consumer’s current interaction with the business, provided that the consumer’s personal information is not disclosed to another third party and is not used to build a profile about the consumer or otherwise alter the consumer’s experience outside the current interaction with the business.
  • Services on Our Behalf: We may disclose personal information in order to receive services performed on our behalf, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, connecting patients with doctors for treatment of foot conditions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on our behalf. We may also disclose personal information to evaluate job applicants and assist in the recruiting and hiring processes (“Employment Purposes”).
  • Advertising and Marketing Services: We use personal information to provide advertising or marketing services on our own behalf.
  • Research & Development: We use personal information for our internal research related to technological development and demonstration.
  • Quality Control & Improvement of Services: We use personal information to verify, maintain, and improve our products. Among other things, we may use personal information to provide medical education and training to doctors, employees, agents, and consumers (“Medical Education”).¹

¹ This may also be considered Research & Development.

The following chart sets forth the categories of personal information we disclose for a business purpose.

Categories of Personal Information that We Disclose	Business Purposes for the Disclosure of Personal Information
PERSONAL INFORMATION
Identifiers	Auditing and Ad Impression Security and Fraud Detection Functionality & Debugging Short-Term / Transient Use Services on Our Behalf, Including Employment Purposes Advertising and Marketing Services Research & Development Quality Control &Improvement of Products Medical Education
Commercial Information	Auditing and Ad Impression Security and Fraud Detection Functionality & Debugging Short-Term / Transient Use Services on Our Behalf Advertising and Marketing Services Research & Development Quality Control & Improvement of Products, Including Medical Education
Biometric Information	Services on Our Behalf Research & Development Quality Control & Improvement of Products, including Medical Information
Internet Information	Auditing and Ad Impression Security and Fraud Detection Functionality & Debugging Short-Term / Transient Use Services on Our Behalf Advertising and Marketing Services Research & Development Quality Control & Improvement of Products, including Medical Education
Geolocation Data	Auditing and Ad Impression Security and Fraud Detection Functionality & Debugging Short-Term / Transient Use Services on Our Behalf Advertising and Marketing Services Research & Development Quality Control & Improvement of Products, including Medical Education
Audiovisual Information	Auditing and Ad Impression Security and Fraud Detection Functionality & Debugging Short-Term / Transient Use Services on Our Behalf Advertising and Marketing Services Research & Development Quality Control & Improvement of Products, including Medical Education
Professional and Employment-Information	Security and Fraud Detection Functionality & Debugging Short-Term / Transient Use Services on Our Behalf, Including Employee Purposes Advertising and Marketing Services Research & Development Quality Control & Improvement of Products, including Medical Education
Education Information	Services on Our Behalf, Including Employee Purposes Advertising and Marketing Services Research & Development Quality Control & Improvement of Products, Including Medical Education
Inferences	Auditing and Ad Impression Services on Our Behalf Advertising and Marketing Services Research & Development Quality Control & Improvement of Services
SENSITIVE PERSONAL INFORMATION
Sensitive Personal Identifiers	Employment Purposes
Sensitive Protected Characteristics	Employment Purposes Quality Control & Improvement of Services, Including Medical Education
Health Information	Services on Our Behalf

 

As Necessary:  We may also disclose personal information, as necessary: (a) to comply with any legal process; (b) to respond to requests from public and government authorities; (c) to enforce our terms and conditions; (d) to protect our operations and protect our rights, privacy, safety or property, and/or that of you or others; and (e) to allow us to pursue available remedies or limit the damages that we may sustain.  We may also use personal information in connection with or during negotiation of any reorganization, acquisition, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).

3. Our Retention Policy – How Long We Keep Your Personal Information.

We will keep your personal information while we are providing our products and services to you. Thereafter, we will keep your personal information for one of these reasons: (a) to respond to any questions, complaints or claims made by you or on your behalf; (b) to satisfy any applicable legal, contractual, regulatory, accounting or reporting requirements.  We will not retain your data for longer than necessary for the purposes for which it was collected as set out in this Privacy Policy. In determining data retention periods, we take into consideration local laws, contractual obligations, our reasonable business requirements, and your expectations and requirements.

4. Certain Rights of California Residents and How To Exercise Them. 

     A. Your California Rights.

California consumers have certain rights, which are described below.  Please note that these rights are subject to certain exceptions and certain of these rights are subject to verification mechanisms.

         i. Right to Know Personal Information Collected About You. You have the right to know: (1) the categories of personal information we have collected about you; (2) the categories of sources from which the personal information is collected; (3) the business or commercial purpose for collecting, selling, or sharing personal information; (4) the categories of third parties to whom we disclose personal information; and (5) the specific pieces of personal information we have collected about you.  You also have the right to know the list of all third parties to whom we have disclosed personal information, as defined under California Civil Code Section 1798.83(e) (a/k/a the “Shine the Light Law”), during the preceding year for third party direct marketing purposes.

         ii. Right to Know Personal Information Disclosed, Sold or Shared and to Whom. You have the right to request that we disclose to you: (1) the categories of personal information that we collected about you; (2) the categories of personal information that we sold or shared about you and the categories of third parties to whom the personal information was sold or shared, by category or categories of personal information for each category of third parties to whom the personal information was sold or shared; and (3) the categories of personal information that we disclosed about you for a business purpose and the categories of persons to whom it was disclosed for a business purpose.

         iii. Right to Request Deletion of Your Personal Information. You have the right to request that we delete your personal information. There may be circumstances where we or our service providers cannot delete your personal information. Following receipt of a request, we will let you know what, if any, personal information we can delete from our records.  If we cannot delete all of your personal information, we will let you know the reason.

         iv. Right to Correct Inaccurate Information,If you believe that any of the personal information we maintain about you is inaccurate, you have the right to submit a request for us to correct that information. Upon receipt of a request, we will use commercially reasonable efforts to correct the information as you direct.

         v. Right to Opt-Out of the Sale or Sharing of Your Personal Information.  You may opt-out of the sale or sharing of your personal information by clicking here: Your California Privacy Choices

        vi. Right to Limit the Use of Your Sensitive Personal Information. California residents have the right to limit the use or disclosure of their sensitive personal information under certain circumstances. This right does not apply if the sensitive personal information is used for the following purposes: (1) to that use which is necessary to perform the services or provide the goods reasonably expected by you; (2) to help to ensure security and integrity; (3) to perform services on our behalf; (4) to undertake activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us; and (5) to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us. Given the nature of our use of sensitive personal information, you do not have the right to request that we limit the use of your sensitive personal information.

        vii. Right to Non-Discrimination for Exercising Your Rights. If you choose to exercise any of your rights, you have the right to not receive discriminatory treatment by us.

     B. How to Exercise Your Rights to Know, Correct and Delete

You may submit requests regarding your rights to know, delete and correct, described above, by clicking Your California Privacy Choices, by email to privacy@treace.net or by calling us at 1-877-360-3232. To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with the requests to know, delete and/ or the correct. Our verification procedure may differ depending on whether you have an account with us or not and the request you are making. The following generally describes the verification processes we use:

• • • Password Protected Accounts. If you have a password-protected account with us, we may use existing authentication practices to verify your identity but will require re-authentication before disclosing, correcting or deleting data. If we suspect fraudulent or malicious activity relating to your account, we will require further verification (as described below) before complying with a request to know or delete.
    • Verification for Non-Accountholders. If you do not have, or cannot access, a password-protected account with us, we will generally verify your identity as follows:
    • • For requests to know categories of personal information, we will verify your identity to a reasonable degree of certainty by matching at least two data points provided by you with reliable data points maintained by us.
      • For requests to know specific pieces of personal information, we will verify your identity to a reasonably high degree of certainty by matching at least three data points provided by you with reliable data points maintained by us.  We will also require a declaration, signed under penalty of perjury, that the person requesting the information is the person whose information is the subject of the request or that person’s authorized representative.  We will maintain all signed declarations as part of our records.
      • For requests to correct or delete personal information, we will verify your identity to a reasonable degree or a reasonably high degree of certainty depending on the sensitivity of the personal information and the risk of harm posed by unauthorized deletion.  We will act in good faith when determining the appropriate standard to apply.

If there is no reasonable method by which we can verify your identity, we will state so in response to a request to know or delete personal information, including an explanation of why we have no reasonable method to verify your identity.

If you use an authorized agent to submit a request to know, delete or correct, we may require the authorized agent to provide proof that you gave the agent signed permission to submit the request. We may also require you to do either of the following: (1) verify your own identity directly with us; or (2) directly confirm with us that you provided the authorized agent permission to submit the request. This requirement does not apply if you have provided the authorized agent with power of attorney pursuant to Probate Code sections 4121 to 4130.

We will respond to requests to know, requests to delete and / or delete no later than 45 calendar days. If we cannot verify your request within 45 days, we may deny your request. If necessary, we may take up to an additional 45 days to respond to your request but in such an event will provide you a notice and an explanation of the reason that we will take more than 45 days to respond to your request.

5. Nevada Privacy Notice.

Nevada law provides that Nevada residents may opt-out of the “sale” of “covered information” to third parties, including but not limited to name, address, social security number, and online service activity. Our uses of your personal information are not sales under Nevada law, so no opt-out is required.

6. Opting Out of Communications with Us.

Email or Text Communications.  From time to time, we and our service providers may send you email or text communications marketing our products. You may unsubscribe from our marketing communications by clicking the “unsubscribe” link found in every commercial email or text we send, or by sending us a request to unsubscribe to privacy@treace.net or by replying STOP to a text communication. If you opt-out of receiving our marketing email or text communications, we may still send you non-marketing email or text messages related to your account with us, including specific transactions or interactions with our Services or products.

Opting Out of Commercial Phone and Text Communications.  By choosing to provide us with your mobile phone number, you have provided us, our service providers, and the doctors you select through the “Find a Doctor” tool with express written consent to send you marketing text messages and phone calls.

You may opt-out of receiving marketing text messages and phone calls regarding our products at any time by sending us a text message from your mobile phone with any of the following words: STOP, STOP ALL, END, QUIT, CANCEL or UNSUBSCRIBE. Once you opt-out, you will no longer receive any automated marketing phone calls or text message from us. However, we reserve the right to send you a final text message to confirm that you have unsubscribed. You may also unsubscribe from receiving automated marketing communications by notifying us by email at privacy@treace.net. For more information regarding our text messaging and alerts, please contact us at privacy@treace.net or 1-877-360-3232.

If you opt-out of receiving our marketing calls or text messages, we may still send you text messages or call you for non-marketing purposes, including but not limited to providing you information regarding your account with us, appointment reminders, educational information, and specific transactions or interactions with our Services or products.

7. Children.

Our websites are not intended for children nor targeted to children under the age of 16, and we do not knowingly collect personal information from children under the age of 16. If we learn that we possess information from a child under the age of 16, we will delete such information in accordance with the Children’s Online Privacy Protection Act (“COPPA”) and other applicable laws. If you are a parent or guardian and you believe that your child under the age of 16 has provided us with personal information without your consent, please contact us at privacy@treace.net.

8. Information Security.

We have implemented appropriate and reasonable physical, technical, and administrative safeguards to help prevent unauthorized access to, use of, and disclosure of, your personal information. However, there is no perfect security, and we cannot guarantee the security of your personal information. You are responsible for maintaining the secrecy of any credentials used to access your account with us and you should report suspected unauthorized activity to us immediately.

9. Contact Information.

If you have questions regarding this Privacy Policy, submit your inquiry by email to privacy@treace.net or by calling us at 1-877-360-3232.  Our mailing address is:

Treace Medical Concepts, Inc.
100 Palmetto Park Place
Ponte Vedra, FL 32081

10. Changes to this Privacy Policy.

We reserve the right to amend this Privacy Policy at any time.

 

I understand that https://lapiplasty.com uses cookies to personalize content, provide social media features, assist with promotional and marketing efforts, and to analyze traffic. I consent to allow Treace Medical Concepts, Inc. to use cookies and to allow sharing information about my use of this website with Treace Medical Concepts, Inc.’s social media, advertising, and analytics partners. I acknowledge that I can change my mind and withdraw consent at any time by contacting info@treace.com. View the Privacy Policy.

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