This website and Privacy Statement are intended for a U.S. audience.

By using this website, you agree to the terms of the most recent version of this Privacy Statement.

This website may collect personal information. Personal information is information that can be used to identify you.

You may send us your personal information when you elect to receive information from us or participate in an activity. For example, you may complete a request for information or register for an event.

We may keep and use your personal information:

  • to respond to your requests
  • to enforce this Privacy Statement and other rules about your use of this website
  • to protect someone’s health, safety or welfare
  • to protect our rights or property
  • to comply with a law or regulation, court order or other legal process

Spineology may be required by a court of law, law, or regulation to release your personal information. We may disclose your personal information to third parties if the disclosure is necessary to:

  • enforce this Privacy Policy and the other rules about your use of this website
  • protect our rights or property
  • protect someone’s health, safety or welfare
  • fulfill obligations relating to a corporate sale, merger, dissolution, or acquisition
  • comply with a law or regulation, court order or other legal process

If you visit our website to read or download information, we may collect certain information about you from your computer. This information may include:

  • The name of the domain from which you access the Internet
  • The Internet Protocol address (“IP Address”) of the computer you are using
  • The type of browser and operating system you are using
  • The date and time you access our website
  • The internet address of the site from which you linked directly to our website
  • Which pages you have visited on our website
  • The search terms you use
  • The links on which you click

Non-personal information is information that cannot identify you or be tied to you. We may use non-personal information or aggregate non- personal information to:

  • create reports for internal use to develop programs, products, services or content
  • share it with third parties
  • provide aggregated information on how visitors use our site, such as ‘traffic statistics’ and ‘response rates, ‘ to third parties

If we decide to make a significant change to our Privacy Statement, we will post a notice on the homepage of our website for a period of time after the change is made.

This website may contain links to other websites. The links are provided for your convenience. Spineology does not review, control, or monitor the privacy practices of websites operated by others. This Privacy Policy does not apply to any other website. We are not responsible for the performance of websites operated by third parties or for your business dealings with them.

This website allows you to communicate with us using an online form. If your communication requests a response from us, we will send you a response via email. The email response or confirmation may include your personal information, including your name, address, etc. We cannot guarantee that our emails to you will be secure from unauthorized interception.

Spineology takes reasonable steps to protect your personal information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet transmission is ever 100% secure.

If you have questions or comments about this Privacy Statement, please contact us at marketing@spineology.com.

State-Specific Privacy Notices

California

Supplemental Privacy Notice for California Residents This notice for California residents supplements the information contained in our Privacy Statement and applies solely to residents of the State of California. We adopt this Supplemental Notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this Supplemental Notice. Under the California Consumer Privacy Act (“CCPA”), you have certain rights in relation to some of your personal data, including the right to certain disclosures and explanations of rights. This section explains your rights under California law.

California ‘Do Not Track’ Disclosures

California law (CalOPPA) requires Spineology to inform you of how we respond to web browser ‘Do Not Track (DNT) signals’ . Because there currently is not an industry or legal standard for recognizing or honoring DNT signals, we do not honor Do Not Track requests at this time.

California Consumer Privacy Act of 2018

Categories of Personal Information We Collect

Spineology collects information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California consumer or household (“personal information”). We may have collected the following categories of personal information from consumers through our website within the twelve (12) months preceding the effective date of this Privacy Policy:

  • Identifiers such as: Name, Address, Unique personal identifier (e.g., device ID, online identifier), Internet Protocol address, Email address
  • Internet or other electronic network activity information (e.g., browsing history, interaction with our website, etc.)
  • Geolocation data
  • Professional, employment-related, or other similar information

“Personal information” under the California Consumer Privacy Act does not include information that is:

  • publicly available from government records,
  • de-identified or aggregated consumer information,
  • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data, or
  • certain personal or financial information covered under certain sector-specific privacy laws.
Categories of Sources of Personal Information

We obtain the categories of personal information listed above from the following categories of sources:

  • Directly from consumers’ interactions with us, including with our websites, services, and representatives
  • Publicly available sources
  • Customers, including health care providers and insurance providers
Use or Disclosure of Personal Information

In the past 12 months, we have used or disclosed the personal information we collect for our operational purposes and for one or more of the following business purposes:

  • To respond to consumer requests
  • For analytical purposes and to research, develop, and improve programs, products, services, and content
  • For activities to monitor and maintain the quality or safety of our products and services
  • For activities described to consumers when collecting their personal information or as otherwise permitted under CCPA
  • For U.S. healthcare providers, to link name, National Provider Identifier (NPI), state license number, and/or IP address to web pages they visit, for compliance, marketing, and sales activities
  • To conduct audits and perform troubleshooting activities of our websites, products, and services
  • To detect and protect against security incidents and deceptive, malicious, or fraudulent activity
  • To ensure our website, products, apps, and services function as intended, including debugging and repairing
  • To comply with a law or regulation, court order or other legal process
How We Share Personal Information

Spineology will not share consumers’ personal information with an unrelated third party without permission, except:

In the ordinary course of business, Spineology may share some personal information with companies that we hire to perform services or functions on our behalf. In all cases in which we share consumers’ personal information with a third party, we will only allow them to keep, disclose, or use consumers’ information to provide the services we asked them to provide.

Spineology may be required by a court of law, law or regulation to release your personal information. We may disclose your personal information to third parties if the disclosure is necessary to:

  • enforce this Privacy Statement and the other rules about your use of this website
  • protect our rights or property
  • protect someone’s health, safety or welfare
  • fulfill obligations relating to a corporate sale, merger, dissolution, or acquisition
Categories of Personal Information We Sell

We do not sell personal information of California consumers.

Personal Information on Minors

We do not sell personal information of California consumers, including minors.

Rights under California Law

  1. Right to Access. If you are a California consumer, you have the right to ask us to send you the following information up to two times in a twelve-month period:
    • The categories of personal data we have collected about you.
    • The categories of sources from which we collected the personal data.
    • Our business or commercial purpose for collecting personal data.
    • The categories of third parties with whom we share personal data.
    • What categories of personal data we disclose about you for business purposes.
    • What categories of personal data we sell or exchange for consideration about you.
    • The specific pieces of personal information we have collected about you.
  2. Right to Delete. If you are a California consumer, you have the right to ask us to delete the personal data about you we have collected. We may deny the request if the information is necessary to:
    • complete a transaction, including providing a requested or reasonably anticipated good or service, or fulfill a contract between the consumer and Spineology;
    • detect and protect against security incidents, malicious, deceptive, fraudulent, or illegal activity, or take against those responsible for such activity;
    • debug to identify and repair errors impairing intended functionality;
    • exercise free speech or another right provided for by law;
    • comply with the California Electronic Communications Privacy Act;
    • engage in research in the public interest adhering to applicable ethics and privacy laws where the consumer has provided informed consent;
    • enable solely internal uses reasonably aligned with the consumer’s expectations based on the consumer’s relationship with Spineology;
    • comply with a legal obligation; or
    • otherwise use the information internally in a lawful manner compatible with the context in which the consumer provided the information
  3. Right to Opt Out. If a business sells personal information to third parties, California consumers have the right, at any time, to opt out of the sale or disclosure of their personal information to third parties. Spineology does not sell personal information to third parties.

Submitting a Request or Inquiry

If you are a California resident and you want to submit a request or inquiry to us regarding your California rights, you or your authorized agent can contact us at marketing@spineology.com.

Your request will be confirmed within ten days of receipt and we will respond within 45 days. If we need more than 45 days, we will notify you that your request is being delayed.

We can only respond to your request if it is verifiable. This means we are obligated to take reasonable steps to verify your identity or your authorized agent’s authority and your right to access the information you request. We may ask for additional information that will help us do so. We will only use that additional information in the verification process, and not for any other purpose.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate 9/23/24, 3:58 PM Spineology : Privacy Policy https://web.archive.org/web/20240814102713/https://www.spineology.com/privacy-policy 7/8 ©2023 Spineology Inc. Phone: 651-256-8500 Privacy Policy before completing your request.

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