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Privacy Policy

Effective September 25, 2025

This Privacy Policy (the “Privacy Policy”) describes how Treace Medical Concepts, Inc. (“we,” “us,” or “our”) collect, use, disclose and process your personal information. This Privacy Policy applies to your use of our websites (including www.treace.comwww.Lapiplasty.comwww.AlignMyToe.comhttps://litcentral.treace.netwww.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 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. By visiting this website, you acknowledge and consent to the privacy practices described in this Privacy Policy, including any revisions to this Privacy Policy that we post. 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 for a variety of business reasons as indicated in the chart below. Please note the specific pieces of personal information we may collect 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 in this Privacy Policy, “personal information” is information that identifies, relates to, or could reasonably be linked directly or indirectly with you. Personal information does not include: (1) information that is lawfully made available from federal, state, or local government records; (2) information that we have a reasonable basis to believe is lawfully made available to the general public by you from widely distributed media; or (3) information that is deidentified or aggregated consumer information. We also collect “sensitive personal information,” which is a subset of personal information, as set forth below. Please note that various jurisdictions may use different terms. For example, some jurisdictions use the terms “personal data” or “sensitive personal data”. As used in this Privacy Policy, the terms “personal information” and “sensitive personal information” are construed to include these different terms.

Set forth 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. Please note that we may not collect all of the information referenced below regarding you and we may not use your personal information for all purposes set forth in this Privacy Policy.

Category of Personal Information What We Collect Categories of Sources from which Personal Information Collected Business or Commercial Purposes for Collection
PERSONAL INFORMATION
Identifiers

Real name

Alias

Postal address

Email address

Phone number

Signature

Date of birth

Unique personal

identifier

Online identifier

Social media

handles

Internet protocol

address

Account name

Cookie information

Social security

number**

Driver’s license

number**

Passport number**

Directly from you*

Automatically when you visit our website

From your healthcare providers

From surveys and promotions

From content you post or share publicly on forums or social media pages

Other 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 other foot conditions and our products/services

To send promotional offers and advertisements regarding our products/services

To engage in marketing, including in connection with our Influencer and Ambassador Programs (described below)****

To include you in our email newsletter and messaging campaigns

To operate and improve our websites and Services

To design, order and manufacture patient-specific products for you

To assist your doctor with explaining your foot condition or planning your surgery

To provide customer service, security, and detect, prevent and mitigate fraudulent, harmful or illegal activities

To assist us with product experience and compliance-related activities

To assist with medical and patient education

To arrange travel for our surgeons, to provide them with reimbursement for that travel and to learn their travel preferences

For purposes of hiring and employment with us

As necessary to make disclosures to governmental and/or regulatory agencies

Protected Characteristics

Sex/gender

Medical Condition (genetic characteristics, cancer or a record or history of cancer)

Disability (mental and physical including HIV/AIDS, cancer, and genetic characteristics)

Age (over 40)

Directly from you

From your healthcare providers

From content you post or share publicly

on forums or social media pages

To engage in quality improvement activities

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

For customer service

As necessary to make disclosures to governmental and/or regulatory agencies

Commercial Information

Records of products purchased, obtained, or considered, or other purchasing or consuming histories or tendencies

Directly from you

From your healthcare providers

From content you post or share publicly

on forums or social media pages

To respond to questions, requests, and comments from you

To provide and send educational information about bunions and other foot conditions and our products/services

To send promotional offers and advertisements regarding our products/services

To include you in our email newsletter and messaging campaigns

To operate and improve our websites and Services

To provide customer service, security, and detect, prevent and mitigate fraudulent, harmful or illegal activities

To arrange travel for our surgeons, to provide them with reimbursement for that travel and to learn their travel preferences

To assist us with product experience and compliance-related activities

As necessary to make disclosures to governmental and/or regulatory agencies

Biometric information

X-rays

CT scans

Other medical images

Weight

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 respond to questions, requests, and comments from you

To provide and send educational information about bunions and other foot conditions and our products/services

To design and manufacture patient-specific products for you

To assist your doctor with explaining your foot condition or planning your surgery

To engage in quality improvement activities

For customer service

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

To assist in providing medical education and training

As necessary to make disclosures to governmental and/or regulatory agencies

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 (see disclosures below)

Content performance metrics

Directly from you

Automatically when you visit our website

To send educational information about bunions and other foot conditions and our products/services

To send promotional offers and advertisements regarding our products/services

To engage in marketing, including in connection with our Influencer and Ambassador Programs (described below)****

To include you in our email newsletter and messaging campaigns

To operate, evaluate and improve our websites and Services

To identify businesses that come to our website

To track your time on our website and pages visit

To monitor investors

To provide customer service, security, and detect, prevent and mitigate fraudulent, harmful or illegal activities

To assist us with product experience and compliance-related activities

To locate, track and contact potential investors

To identify consumers, competitors, and law firms visiting our website

As necessary to make disclosures to governmental and/or regulatory agencies

Geolocation Data

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 other foot conditions 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

To customize our website experience based on your location

As necessary to make disclosures to governmental and/or regulatory agencies

Audiovisual Information

X-rays

CT scans

Other medical images

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

From content you post or share publicly on forums or social media pages

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 design and manufacture patient-specific products for you

To assist your doctor with explaining your foot condition or planning your surgery

To send promotional offers and advertisements regarding our products/services

To provide customer service, security, and 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

To assist us with product experience and compliance-related activities

As necessary to make disclosures to governmental and/or regulatory agencies

We may also disclose non-personally identifiable x-rays to our social media provider and post them on social media

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

As necessary to make disclosures to governmental and/or regulatory agencies

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

As necessary to make disclosures to governmental and/or regulatory agencies

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 other foot conditions and our products/services

To send promotional offers and advertisements regarding our products/services

To provide customer service, security, and detect, prevent and mitigate fraudulent, harmful or illegal activities

As necessary to make disclosures to governmental and/or regulatory agencies



Category of Personal Information What We Collect Categories of Sources from which Personal Information Collected Business or Commercial Purposes for Collection
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

As necessary to make disclosures to governmental and/or regulatory agencies

Sensitive Geolocation

Your location

Automatically

To engage in quality improvement activities

For customer service

As necessary to make disclosures to governmental and/or regulatory agencies

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 information about our products/services

To design, order and manufacture patient-specific products for you

To assist your doctor with explaining your foot condition or planning your surgery

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

As necessary to make disclosures to governmental and/or regulatory agencies

Health Information

Medications taken

Information regarding foot conditions

X-rays

CT scans

Other medical images

Other health or medical information

Health insurance information

Direct from you

Our service providers

From your healthcare providers

To treat foot conditions

To engage in quality improvement activities

To provide us and/or healthcare professionals with health information for:

  • Creating a custom-cut guide for patients;
  • Ordering and manufacturing patient-specific products;
  • Uploading radiological images relating to the products and services you are seeking;
  • Approving custom surgical instruments and other products;
  • Preoperative planning;
  • Tracking the status of surgical case and patient-specific products; and
  • Directing collaboration between us and healthcare professionals

To create 3D models in connection with treatment and patient education purposes

To train artificial intelligence software with your express consent (to the extent authorized by law)

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

For customer service

As necessary to make disclosures to governmental and/or regulatory agencies


* This includes, but is not limited to, information you submit on our website (such as our request an appointment form, the Am I a Candidate Questionnaire, or the Questions form near the bottom of the Lapiplasty.com 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).

** This only applies to job applicants.

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

**** Influencer and Ambassador Programs. If you participate in one of our sponsored influencer or ambassador programs, we may collect certain personal information such as your name, contact details, social media handles, and content performance metrics. We may also request limited rights to use and disclose influencer-generated content for marketing purposes. All influencer and ambassador partnerships are expected to comply with Federal Trade Commission (FTC) endorsement guidelines, including appropriate disclosure of sponsorships.

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 and our service providers and other collaborators 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 and to provide marketing. 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.

Our website has the following cookies:

  • Strictly necessary cookies. These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of this site will not then work. These cookies do not store any personally identifiable information.
  • Functional cookies. These cookies enable the website to provide enhanced functionality and personalization. They may be set by us or by third-party providers whose services we have added to our pages. If you do not allow these cookies, then some or all of these services may not function correctly.
  • Performance cookies. These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular and see how visitors move around the site. All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies, we will not know when you have visited out site and will not be able to monitor its performance.
  • Targeting cookies. These cookies may be set through our site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant advertisements on other sites. They do not store directly personal information but are based on uniquely identifying your browser and internet device. If you do not allow these cookies, you will experience less targeted advertising.
  • Social media party cookies. These cookies are set by a range of social media services that we have added to the site to enable you to share our content with your friends and networks. They are capable of tracking your browser across other sites and building up a profile of your interests. This may impact the content and messages you see on other websites you visit. If you do not allow these cookies, you may not be able to use or see the sharing tools.

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.

Other than for strictly necessary cookies, we do not collect this type of information from non-US visitors to our website.

By using our 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.

Social Media Mentions and User-Generated Content. From time to time, we may monitor and review public content that individuals choose to share on social media platforms in connection with our products or services (for example, tagged posts, hashtags, or mentions of our brand). If we wish to share or repost your content, we will only do so with your express written consent. We encourage patients not to disclose sensitive health information in public posts, comments, or direct messages on social media, as these channels are not secure.

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.

Social Media Interactions. While we strive to protect patient information, please be aware that any health-related details you voluntarily disclose on social media platforms (such as comments, reviews, or direct messages) are outside of our control and may be visible to others. For your privacy, we strongly encourage you not to share sensitive medical information through social media. If you contact us in this way, we may redirect you to a secure communication channel.

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. Personal Information We Disclose, Share for Targeted Advertising or Sell and the Purpose for It.

Disclosure of Personal Information to Service Providers

We disclose and have disclosed in the preceding 12 months personal information to our service providers and contractors for the following business purposes.

  • Auditing and Ad Impression: We disclose 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 disclose 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 disclose personal information to engage in debugging to identify and repair errors that impair existing intended functionality.
  • Short-Term / Transient Use: We disclose 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 described in this Privacy Policy, 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, arranging travel and making reimbursements in connection with such travel, providing financing, providing analytic services, providing storage, assisting with product experience and compliance-related activities 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 disclose personal information to provide advertising or marketing services on our own behalf, including in connection with our Influencer and Ambassador Programs described above.
  • Research & Development: We disclose personal information for our internal research related to technological and product development and demonstration.
  • Quality Control & Improvement of Products: We disclose 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").

The following chart sets forth the categories of personal information we have disclosed to our service providers for a business purpose over the past 12 months.

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, Including 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 Education

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, Including Employment Purposes

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 Employment Purposes

Advertising and Marketing Services

Research & Development

Quality Control & Improvement of Products, Including Medical Education

Education Information

Services on Our Behalf, Including Employment Purposes

Advertising and Marketing Services

Research & Development

Quality Control & Improvement of Products

Inferences

Auditing and Ad Impression

Services on Our Behalf

Advertising and Marketing Services

Research & Development

Quality Control & Improvement of Products



Categories of Personal Information that We Disclose Business Purposes for the Disclosure of Personal Information
SENSITIVE PERSONAL INFORMATION

Sensitive Personal Identifiers

Employment Purposes

Sensitive Geolocation

Quality Control & Improvement of Products, Including Medical Education

Sensitive Protected Characteristics

Employment Purposes

Quality Control & Improvement of Products, Including Medical Education

Health Information

Services on Our Behalf


Selling and Sharing (for Targeted Advertisement) 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 from our website. This access and certain other functions described in this Privacy Policy 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, as well as certain other data privacy laws. 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 that may be deemed sales or sharing of personal information for cross-context behavioral advertising under California law 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 (as Defined by the CCPA) Categories of Third Parties Business or Commercial Purposes
PERSONAL INFORMATION

Identifiers

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 analyze cookie and online tracking technology information for marketing purposes

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 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 other foot conditions 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-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 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 other foot conditions 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

Third-party advertising and marketing companies

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)

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 other foot conditions and our products/services

To send promotional offers and advertisements regarding our products/services



Categories of Personal Information Sold or Shared (as Defined by the CCPA) Categories of Third Parties Business or Commercial Purposes
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

Third-party advertising and marketing companies

To connect patients with doctors for treatment of foot conditions

To assist with tasks related to surgical 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 disclosed to 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.

Call Forwarding Technology. We use certain call forwarding technology to capture information regarding telephone calls placed to numbers on the website, including the duration, originating and receiving number, and time to answer. This information will be collected by us and our vendor and will be used for both quality assurance and marketing purposes. At this time, we are not recording the contents of the call itself although we have that functionality and may do so in the future. By dialing telephone numbers listed to the website, you consent to the capture, use and sharing of this information.

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://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. For example, we share personal information with third-party platforms (such as Google, Facebook, Instagram, LinkedIn, YouTube, and X) to market our products and services to you while you are browsing the internet or using social media. This means that if you visit our website, you may later see our ads on third-party platforms. This process is known as “retargeting.” You may opt out of these targeted advertisements by adjusting your cookie settings, changing your browser or device ad preferences, or by clicking Your Privacy Choices. 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.

Other Disclosures

Artificial Intelligence Training. We may use certain health information to train artificial intelligence software, but only with your express consent and only as authorized by law. We do not use information collected from social media platforms (including posts, comments, or testimonials) for this purpose unless we have obtained your express written consent.

As Necessary: We may also use and/or disclose Personal Information, as necessary: (a) to comply with any law, regulation and/or legal process and/or exercise or defend legal claims; (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 and disclose your 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). You acknowledge that such transfers may occur and that any acquirer of or successor to us may continue to use your Personal Information as set forth in this Privacy Policy.

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: (1) to respond to any questions, complaints or claims made by you or on your behalf; and (2) 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. Video Content.

Our website may include content, such as clips, that may be governed by the Video Privacy Protection Act (“VPPA”). Some of the cookies and other tracking technologies that we have disclosed above may provide to others access to your personal information (or personally identifiable information as that term is used under the VPPA). To the extent that the VPPA applies to our website, or any content on our website, by using our website, you explicitly consent to our practices, including those that relate to video contents or otherwise governed by the VPPA. If you would like to withdraw your consent, please call us at 1-877-360-3232 or email us at privacy@treace.net.

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

  1. 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.

    1. 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.

    2. 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.

    3. Right to Request Deletion of Your Personal Information. You have the right to request that we delete your personal information. However, there are number of situations where you do not have the right to require us to delete your personal information. For example, you cannot request that we delete your personal information if it is reasonably necessary for us to comply with a legal obligation, complete the transaction for which the personal information is collected or provide the Services that you have requested or reasonably anticipated by you within the context of our ongoing business relationship, or to otherwise perform a contract between us. We also will not delete your personal information from our backup systems to the extent permitted by the CCPA. Following receipt of a request, we will let you know what, if any, personal information we can delete. If we cannot delete all of your personal information, we will let you know the reason.

    4. 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.

    5. 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 Your Privacy Choices. You can also exercise this right to opt-out by using a browser that supports an opt-out preference signal (also known as a Global Privacy Control (GPC)). If you choose to use this signal, you will need to turn it on for each browser you use.

    6. 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 in various circumstances. 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.

    7. 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.

  2. Your Rights If You Are a Resident of Texas or Nebraska.

    If you are a resident of Texas or Nebraska, you may have certain rights related to your personal information.

    Please note that not all of these rights may be applicable to you, these rights are subject to certain exceptions and certain of these rights are subject to verification mechanisms.

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

    2. 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.

    3. The Right to Correct Inaccuracies. You may request that inaccuracies in your personal information be corrected.

    4. The Right to Delete. You have the right to request that your personal information be deleted, except in cases where retention is required, for example by law or contractual obligation.

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

    6. The Right to Opt-Out. You may elect to prevent your personal information, to the extent applicable, from being:

      1. Used in targeted advertising;

      2. Sold;

      3. Used for automated decision making or profiling purposes that may produce legal or similarly significant effects.

    7. The 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.

    8. Rights Regarding Sensitive Personal Information. We will not process your sensitive personal information without obtaining your consent. You have the right to withdraw your previous consent and opt out of further processing of your sensitive personal information.

    Furthermore, if we have actual knowledge that you are 13 years of age and not older than 18 years of age, we will not without your consent process your personal information for the purposes of targeted advertising, profile you in furtherance of decisions that produce legal effects or effects of similar significance, or sell your Personal Information.

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

    .

    For California residents: (1) you can exercise your rights by clicking on Your Privacy Choices; and (2) for requests to know, correct and/or delete (to the extent applicable to you), you can also make a request by sending an email to privacy@treace.net or by calling us at 1-877-360-3232.

    For residents of Texas and Nebraska, you can exercise your rights by (to the extent applicable to you), by clicking on Your Privacy Choices, sending an 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 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, correct, 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 valid 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 valid 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, correct 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.

There may be situations where we cannot grant your request. For example, if you ask us to delete Personal Information that we are obligated to keep to comply with applicable law, we may not be able to fulfill some or all of your request. We may also decline to grant your request where our use of your Personal Information serves a legitimate purpose such as for security purposes. Your request may also be denied if it compromises the privacy of others, is overly repetitive, or extremely burdensome to fulfill.

We will respond to valid requests to know, requests to correct 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.

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 right applies.

7. Opting Out of Communications with Us.

Social Media Advertising Transparency. If you see our ad on social media, it's because you visited our website or engaged with our content. These ads are delivered through common online advertising practices such as retargeting. You can opt out of these advertisements by adjusting your cookie settings, browser ad preferences, or by clicking Your Privacy Choices.

Email and 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 submitting a request to unsubscribe to our email address or by replying with the text communication. If you opt out of receiving our marketing email or text communications, we may still send you non-marketing communications relating to your account with us, including specific transactions or interactions with our Services or products.

Opting Out of Personal Phone and Text Communications. By choosing to provide us with your mobile phone number, you have provided us our 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, we will no longer send you marketing text messages or make marketing phone calls. 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@terence.net. For more information regarding our text messaging and alerts, please contact us at privacy@terence.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.

8. Children.

We do not direct our websites or applications to children under 18 years of age. However, we may collect, use and disclose information regarding individuals aged 17 to 17 for therapeutic/rehab purposes and as required by law when such individuals are treated with our products. For any person under the age of 13, we will obtain verifiable parental consent before any such collection, use and/or disclosure. We do not allow persons known to be under 18 years of age to receive direct marketing communications from us. No information should be submitted to our websites or applications by persons under 18 years of age. When appropriate, we may ask you to indicate proof of age or limit to verify compliance with the age requirements set forth in this Privacy Policy. We do not knowingly collect personal information from individuals under 18 years of age through our social media channels. If you are a parent or guardian and you believe that your child has provided us with personal information without your consent, please contact us at 1-877-360-3232 or privacy@terence.net.

9. 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.

10. 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

11. Changes to this Privacy Policy.

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