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Privacy Policy

Effective January 1, 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.comwww.Lapiplasty.comwww.AlignMyToe.comwww.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” 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: (i) publicly available information or lawfully obtained, truthful information that is a matter of public concern; or (ii) information that is deidentified or aggregated consumer information.

We also collect “sensitive personal information”, as set forth below.  Sensitive personal information is personal information that reveals information such as: (a) social security, driver’s license, state identification card, or passport number; (b) account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; (c) precise geolocation; (d) racial or ethnic origin, religious or philosophical beliefs, or union membership; (e) the contents of a consumer’s mail, email, and text messages unless we are the intended recipient of the communication; and (f) genetic data.  This includes the processing of biometric information for the purpose of uniquely identifying a person, personal information collected and analyzed concerning a person’s health and personal information collected and analyzed concerning a person’s sex life or sexual orientation.  Sensitive personal information that is publicly available is not considered sensitive personal information or personal information.

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

Category of Personal Information Examples Categories of Sources from which Personal Information Collected
PERSONAL INFORMATION
Identifiers Real name

Alias

Postal address

Unique personal identifier

Online identifier

Internet protocol address

Email address

Account name

Cookie information

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 providers

Automatically 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

Protected Characteristics Sex

Age

Directly from you

From your healthcare providers

Commercial Information Records of services purchased, obtained, or considered Directly from you

From your healthcare providers

Biometric information X-rays Directly from you

From your healthcare providers

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 we collect information about you through your use of our services

Automatically from your IP address

Geolocation Data Your general location Directly from you

Automatically when we collect information about you through your use of our services

Automatically from your IP address

Audiovisual Information X-rays

Call recordings

Text messages

Emails

Directly from you

From your healthcare providers

Professional or Employment Information Your prior professional information

Your prior employment information

Directly from you

Consumer reporting agencies

Our service providers

Education information Your education information Directly from you

Consumer reporting agencies

Our service providers

Inferences We may draw inferences from any of the information identified in this chart to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes Automatically
SENSITIVE PERSONAL INFORMATION
Sensitive Personal Identifiers Social security

Driver’s license

State identification card

Passport number

Directly from you

 

Sensitive Protected Characteristics Sex

Age

Directly from you

From your healthcare providers

Contents of Writings The contents of mail, email, and text messages Directly from you

 

Cookies and Tracking Technologies. We and our service providers may use cookies, tracking pixels, or other tracking technologies to collect and store information about your interactions with us. Cookies are small text files that store information on computer or mobile device, and enable websites like ours to capture and remember information about you. We use cookies and other similar technologies to save your website preferences for future visits, allow you to login automatically, and to compile data about your interactions with our website so that we can offer better website experiences and tools in the future.  Tracking pixels are small, often-transparent graphic images that can be embedded in web pages, videos, or emails, and can allow a web server to collect information about you such as whether you have viewed a particular web page or email message.

In general, we and our service providers use cookies, pixels, and other tracking technologies (such as web beacons and HTTP referrers) to optimize the functionality of our sites, to help us understand how the Services are used, and to provide users with interest-based content or advertising based on their browsing activities.

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.

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.

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 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.

We use your personal information for the following business purposes:

Category of Personal Information Business Purposes for Collection
PERSONAL INFORMATION
Identifiers 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

To assist you in arranging appointments with the doctor that you select

To respond to questions, requests, and comments from you

To provide you with downloadable information about our products/services

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

For purposes of hiring and employment with us

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

Protected Characteristics 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

To provide you with downloadable information about our products/services

Commercial Information To respond to questions, requests, and comments from you

To provide you with downloadable information about 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 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

To assist you in arranging appointments with the doctor that you select

To respond to questions, requests, and comments from you

To provide you with downloadable information about our products/services

To report product experience information to the FDA or other regulatory agencies

To assist in providing medical education and training

Internet Information 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 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

To assist you in arranging appointments with the doctor that you select

To respond to questions, requests, and comments from you

To provide you with downloadable information about our products/services

To 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 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

To assist you in 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 and Employment Information For purposes of hiring and employment with us

In connection with patient testimonials or references (with your approval)

For medical education presentations

Education Information For purposes of hiring and employment with us

In connection with patient testimonials or references (with your approval)

For medical education presentations

Inferences 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

To assist you in arranging appointments with the doctor that you select

To respond to questions, requests, and comments from you

To provide you with downloadable information about our products/services

To 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 To recruit employees and perform background screening
Sensitive Protected Characteristics 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

To provide you with downloadable information about our products/services

Contents of Writings 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

To assist you in arranging appointments with the doctor that you select

To respond to questions, requests, and comments from you

To provide you with downloadable information about our products/services

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

For purposes of hiring and employment with us

 

2. Sale, Sharing and Disclosure of Personal Information.

We may share and/or sell, as those terms are defined by the California Consumer Protection Act, as amended by the California Privacy Rights Act, your personal information with third parties that we have collected from you with third parties.  The chart below shows the categories of personal information we have sold and/or shared in the past 12 months, the categories of third parties with whom we have sold and/or shared personal information and the business purpose for the sale or sharing of the personal information.

Categories of Personal Information that We Have Sold or Shared in the Past 12 Months Categories of Third Parties to Whom We Have Sold or Shared Personal Information Business or Commercial Purposes for Sale or Sharing of Personal Information
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 partners

Third parties for marketing purposes

To provide or advertise our products/services to you

To assist with our Online Chat functionality

To assist with our Patient Call Center

To assist us with marketing through video, social media, text and email

To analyze cookie information for marketing purposes

Protected Classes Our business partners and physician network

 

To provide or advertise our products/services to you
Commercial 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 provide or advertise our products/services to you

To fulfill a transaction

Biometric 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 provide or advertise our products/services to you

To report product experience information to the FDA or other regulatory agencies

To assist with medical education and training

Internet Information 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 partners

Third parties for marketing purposes

To assist us with marketing through video, social media, text and email

To analyze cookie information for marketing purposes

Geolocation Data 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 partners

Third parties for marketing purposes

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

To assist you in arranging appointments with the doctor that you select

To respond to questions, requests, and comments from you

To provide you with downloadable information about our products/services

To send educational information about bunions and our products/services

To send promotional offers and advertisements regarding our products/services

Audiovisual Information 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 partners

Third parties for marketing purposes

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

To assist you in arranging appointments with the doctor that you select

To respond to questions, requests, and comments from you

To provide you with downloadable information about our products/services

To send educational information about bunions and our products/services

To send promotional offers and advertisements regarding our products/services

Professional or Employment 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)

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 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 partners

Third parties for marketing purposes

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 Our business partners and physician network

 

To provide or advertise our products/services to you
Contents of Writings Our business partners and physician network

 

To provide or advertise our products/services to you

To assist with our Online Chat functionality

To assist with our Patient Call Center

To assist us with marketing through video, social media, text and email

To analyze cookie information for marketing purposes

1 This may be considered a disclosure rather than a sale or sharing of personal information and is included here as well as in the following chart.

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 https://: https://policies.google.com/technologies/partner-sites. 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 https://tools.google.com/dlpage/gaoptout.

Ads on Third-Party Sites.  We use third party advertising companies to place ads on other sites.  We do this by allowing our advertising and social media partners to place their cookies on a browser of an individual who visits our sites and accepts the use of cookies.  The data received by our third party advertising and social media partners allows them to measure the effectiveness of such advertising and to provide advertisements on other websites about our services which are tailored to your interests.  For more information on how these sites use your personal information to target advertising to you, please visit their websites.

Our Websites Are Not Intended for 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.

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 received services performed on our behalf or obtain employment with us, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on our behalf.
  • 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 services.
  • Medical Education: We use personal information to provide medical education and training to doctors, employees, agents, and consumers.
  • Educational Information:

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

Advertising and Marketing Services

Medical Education

Research & Development

Quality Control &Improvement of Services

Protected Characteristics Security and Fraud Detection

Short-Term / Transient Use

Services on Our Behalf

Medical Education

Quality Control &Improvement of Services

Commercial Information Auditing and Ad Impression

Security and Fraud Detection

Functionality & Debugging

Short-Term / Transient Use

Services on Our Behalf

Advertising and Marketing Services

Medical Education

Research & Development

Quality Control & Improvement of Services

Biometric Information Services on Our Behalf

Medical Education

Research & Development

Quality Control & Improvement of Services

Internet Information Auditing and Ad Impression

Security and Fraud Detection

Functionality & Debugging

Short-Term / Transient Use

Services on Our Behalf

Advertising and Marketing Services

Medical Education

Research & Development

Quality Control & Improvement of Services

Geolocation Data Auditing and Ad Impression

Security and Fraud Detection

Functionality & Debugging

Short-Term / Transient Use

Services on Our Behalf

Advertising and Marketing Services

Medical Education

Research & Development

Quality Control & Improvement of Services

Audiovisual Information Auditing and Ad Impression

Security and Fraud Detection

Functionality & Debugging

Short-Term / Transient Use

Services on Our Behalf

Advertising and Marketing Services

Medical Education

Research & Development

Quality Control & Improvement of Services

Professional and Employment-Information Security and Fraud Detection

Functionality & Debugging

Short-Term / Transient Use

Services on Our Behalf

Advertising and Marketing Services

Medical Education

Research & Development

Quality Control & Improvement of Services

Education Information Services on Our Behalf

Advertising and Marketing Services

Research & Development

Quality Control & Improvement of Services

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 Services on Our Behalf
Sensitive Protected Characteristics Security and Fraud Detection

Short-Term / Transient Use

Services on Our Behalf

Medical Education

Quality Control &Improvement of Services

Contents of Writings Auditing and Ad Impression

Security and Fraud Detection

Functionality & Debugging

Short-Term / Transient Use

Services on Our Behalf

Advertising and Marketing Services

Medical Education

Research & Development

Quality Control & Improvement of Services

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.  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 Sharing of Your Personal Information.  You may opt-out of the sale or sharing of your personal information by clicking here: California Consumer Privacy Act

        vi. Right to Limit the Use of Your Sensitive Personal Information. You may request that we limit the use or disclosure of your sensitive personal information: (i) to that use which is necessary to perform the services or provide the goods reasonably expected by you; (ii) to help to ensure security and integrity; (iii) to perform services on our behalf; (iv) 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 (v) to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us.  You may exercise this right by clicking here: California Consumer Privacy Act.

        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.  This includes the right not to be retaliated against for the exercise of your rights.

     B. How to Exercise Your Rights And Related Issues.

You may submit requests regarding your rights to know, delete and correct, described above, by clicking 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:

    • 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: (a) verify your own identity directly with us; or (b) 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.

Regarding your rights to opt-out of the sharing of personal information and to limit the use of your sensitive personal information, you can exercise those rights by clicking on California Consumer Privacy Act.

5. Your Rights If You Are a Resident of Colorado, Connecticut, Utah or Virginia.

If you are a resident of Colorado, Connecticut, Utah or Virginia (except as noted), you have certain additional rights set forth below.  Please note that these rights are subject to certain exceptions and certain of these rights are subject to verification mechanisms.

The Right to Know:  You have the right to know whether we are processing your personal information.

The Right of Access: You have the right to access your personal information, and to obtain a copy of it in a readily usable format, if feasible.

The Right to Correct Inaccuracies: You may request that inaccuracies in your personal information be corrected.  Utah law does not provide for this right.

The Right to Data Portability: You have the right to obtain a copy of your data in a portable and, if feasible, readily usable format.

The Right to Opt-Out: You may elect to prevent your personal information from being:

  1. Used in targeted advertising;
  2. Sold; or
  3. *Used for profiling purposes that may produce legal or similarly significant effects.

* Utah law does not provide for this right.

Furthermore, in connection with your sensitive personal data: (a) if you are a resident of Utah, we will not process that information without first presenting you with clear notice and an opportunity to opt out of the processing; and (b) if you are a resident of Colorado, Connecticut or Virginia, we will not process sensitive personal data without obtaining your consent.

You may submit a request by emailing us at privacy@treace.net or by calling us at 1-877-360-3232.  Information requests under “Right of Access” will be transmitted securely. If we cannot fulfill your request, we will notify you of that decision and the reasons why within 45 days. At that point if you believe our decision was in error, you can submit an appeal using the method(s) above. If the result is the same, you can also seek assistance and/or redress from your state attorney general.

6. 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.

7. 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 Services. 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. 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.

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 the Lapiplasty® procedure 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.

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.  When we make changes, we will notify employees through an email notice and reflect the date it was updated.

 

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