Privacy Policy

Effective Date / Updated Date of Privacy Policy: March 15, 2020

 

When you use Strive Orthopedics (to be referred to as Strive) services, you are trusting us with your information. That is a big responsibility and Strive works hard to protect your information and put you in control.

 

This Privacy Policy explains how Strive handles personal information collected online. This information may be gathered through all aspects, such as: online interactions via websites, applications (apps), social media, and through offline interactions with you.  This Privacy Policy does not apply to information collected from residents outside of the United States or to third party websites to which Strive may link. 

 

As part of our commitment to honoring your privacy, this Privacy Notice explains the approach we take in protecting and using the information that we gather from you on our Site. By using the Site, you consent to this Privacy Notice. If you choose to visit our Site, your visit and any disputes over privacy are subject to this Privacy Notice. We reserve the right to change this Privacy Notice at any time without notice except as otherwise provided here. Check back periodically to see if our Privacy Notice has been updated.

INFORMATION STRIVE COLLECTS
Strive may collect the following information, depending on what product and service you use:

  • Contact information and preferences (such as name, email address, mailing address, phone number, and emergency contact information)
  • Biographical and demographic information (such as date of birth, age, gender, ethnicity, marital status, and sexual orientation)
  • Health and medical information (such as medical insurance details, information about physical and non-physical health conditions and diagnoses, treatments for medical conditions, genetic information, family medical history and medications an individual may take, including the dosage, timing, and frequency) we collect in connection with managing clinical trials, conducting research, providing patient support programs, distributing and marketing our products, managing compassionate use and expanded access programs and tracking adverse event reports
  • Payment-related information we need to complete a transaction (such as credit card number and financial account information)
  • Username and password that you may select in connection with establishing an account on our websites or mobile apps
  • Your photograph, social media handle or digital or electronic signature
  • Publicly available information
  • Internet activity, such as your Internet Protocol (“IP”) address, browsing history, your search history and information on your interaction with the Strives Services and our advertisements
  • Device information
  • Geolocation data, e.g., your physical location or movements 
  • If you are accessing the Strive website or app on your mobile device, you may also choose to provide us with location data. To protect your privacy, you should not provide Strive with any information that is not specifically requested
  • Any adverse event information

 

If you are a Health Care Professional, we may also collect:

  • Professional credentials, educational and professional history, institutional and government affiliations, information included on a resume or curriculum vitae, education and work history (such as work experience, education and languages spoken)
  • Information about the Strive programs, products and activities with which you have engaged
  • Details about our interactions with you, your prescribing of our products and the agreements you have executed with us; including remittance or other financial information
  • Any information you choose to provide about yourself or your household
  • Information collected in connection with Strive hosted events or activities you attend or participate in
  • Publicly available information related to your practice, such as license information, disciplinary history, prior litigation and regulatory proceedings, and other due diligence related information

 

We may use the personal information we collect about you with information obtained from other sources, such as public databases, social media platforms and other third parties. We may use public information to confirm contact or financial information, to verify licensure of Health Care Professionals or to better understand your interests by associating demographic information with the information you have provided.

HOW STRIVE USES PERSONAL INFORMATION
How Strive uses your information depends on how you interact with the Strive Services.  Generally, Strive may  use your information to:

  • Provide our products and services to you and make them better
  • Develop new products and services
  • Fulfill your requests
  • Provide customer service
  • Send you administrative communications regarding Strive’s products or Strive Services
  • Notify you about special promotions or offers that may be of interest to you
  • Invite you to participate in surveys about our products or services
  • Better understand the interests of our customers and visitors who use Strive Services
  • Maintain Strive’s online services such as websites and apps
  • Monitor, detect and prevent fraud, improper activity and ensure Strive’s policy compliance
  • Conduct research and follow-up research
  • Process payments
  • Evaluate how you and other users interact with our online services
  • Protect Strive and our users
  • Secure our online services including our network, websites and apps
  • Conduct audits related to our current interactions with you
  • Debug the site and service to identify and repair errors that impair existing intended functionality
  • Defend ourselves in litigation and investigations and to prosecute litigations
  • Comply with our legal and regulatory obligations

 

In addition, some of our applications and mobile-optimized sites may have location-based features. To deliver these features, we may collect and use location data provided by your mobile device. By using such applications, you consent to the collection and use of your mobile device location data for purposes of delivering these location-based features. 

We may use personal information collected from any of the sources listed for our internal business purposes, such as data analysis, audits, developing new products, enhancing our websites and apps, improving our Strive Services, identifying usage trends and determining the effectiveness of our promotional campaigns.

We may aggregate and/or de-identify data about customers and site visitors and use it for any purpose, including product and service development and improvement activities.


We do not sell your personal information. However, we share personal information with our vendors, contractors, business and service partners, or other third parties (collectively, “Service Providers”). Examples of Service Providers include analysis firms, advertisers, payment processing companies, customer service and support providers, email, IT services and SMS vendors, web hosting and development companies and fulfillment companies. Service Providers also include our co-promotion partners for products that we jointly develop and/or market with other companies.

 

Strive may also disclose your personal information as required by law to any competent law enforcement body, regulatory or government agency, court or other third party where we believe the disclosure is necessary or appropriate to comply with a regulatory requirement, judicial proceeding, court order, government request or legal process served on us, or to protect the safety, rights, or property of our customers, the public, Strive or others, and to exercise, establish or defend Strive’s legal rights.

 

Strive may also disclose aggregate or de-identified data that is not personally identifiable to third parties for any purpose.

Cookies and Other Tools

Strive and its Service Providers collect information about you by using cookies, tracking pixels, web beacons and other technologies (collectively, “Tools”). We use this information to better understand, customize and improve user experience with our websites, services and offerings as well as to manage our advertising. This information can make your use of our Strive Services easier and more meaningful by allowing Strive and our Service Providers to provide better service, customize sites based on consumer preferences, compile statistics, provide you with more relevant information based on your interests, analyze trends and otherwise administer and improve our Strive Services. If we have collected your personal information, we may associate this personal data with information gathered through the Tools.

 

Your web browser can be set to allow you to control whether you will accept cookies, reject cookies, or to notify you each time a cookie is sent to your browser. If your browser is set to reject cookies, websites that are cookie-enabled will not recognize you when you return to the website, and some website functionality may be lost. The Help section of your browser may tell you how to prevent your browser from accepting cookies. To find out more about cookies, visit www.aboutcookies.org.

 

Log data: When you use Strive websites and apps, our servers automatically record information (“log data”), including information that your browser sends whenever you visit a website or app or your mobile app sends when you are using it. This log data may include your Internet Protocol address, the address of the webpages you visited that had Strive features, browser type and settings, the date and time of your request, how you used websites and cookie data.

 

Cookie data: Depending on how you are accessing Strive’s online Services, we and our Service Providers may use “cookies” (a small text file sent by your computer each time you visit our sites, unique to your Strive account or your browser) or similar technologies, to record log data. When we use cookies, we may use “session” cookies (that last until you close your browser) or “persistent” cookies (that last until you and/or your browser delete them). For example, we may use cookies to remember your personal preferences, such as sections of the website that you visit frequently, your user ID, or other settings so you do not have to set them up every time you visit.  Some of the cookies we use are associated with your Strive account (including personal information about you, such as the email address you gave us), and other cookies are not.

 

Social media plugins and data. In addition, our websites and apps may use social media plugins (e.g., the Facebook “Like” button, ‘”Share to Twitter”‘ button) to enable you to easily share information with others. When you visit any of our online Strive Services, the operator of the social plugin can place a cookie on your computer, enabling that operator to recognize individuals who have previously visited our websites. If you are logged into the social media website (e.g., Facebook, Twitter, Google+) while browsing on our Strive Services, the social plugins allow that social media website to receive information that you have visited our Strive Services. The social plugins also allow the social media website to share information about your activities on Strive with other users of their social media website. Strive does not control any of the content from the social plugins. For more information about social plugins from other social media websites you should refer to those sites’ privacy and data sharing statements.

 

Device information. In addition to log data, we may also collect information about the device you are using to access our Strive Services, including what type of device it is, what operating system you are using, device settings, unique device identifiers and crash data. Whether we collect some or all of this information often depends on what type of device you are using and its settings.  Different types of information are available depending on whether you are using a Mac or a PC, or an iPhone or an Android phone. To learn more about what information your device may make available to us, please also check the policies of your device manufacturer or software provider.

YOUR PRIVACY CHOICES

You may have certain rights and choices regarding our processing of your personal data.  Depending on your jurisdiction, applicable law may entitle you to additional consumer rights, including the right (with certain limitations and exceptions) to:

  • Know the categories and/or specific pieces of personal information collected about you, including whether your personal information is sold or disclosed, and with whom your personal information was shared
  • Access a copy of the personal information we retain about you
  • Request deletion of your personal information

 

We reserve the right to verify your identity in connection with any requests regarding personal information to help ensure that we provide the information we maintain to the individuals to whom it pertains, and allow only those individuals or their authorized representatives to exercise rights with respect to that information. If you are an authorized agent making a request on behalf of a consumer, we may require and request additional information to verify that you are authorized to make that request.

We reserve the right to deny your request if we cannot verify your identify. Where we deny your request in whole or in part, we will endeavor to inform you of the denial and provide an explanation of our actions and the reasons for the denial.

 

We will not restrict or deny you access to our Strive Services because of choices and requests you make in connection with your personal information. Please note, certain choices may affect our ability to deliver the Strive Services. For example, if you sign up to receive marketing communications by email, then ask Strive to delete all of your information, we will be unable to send you marketing communications.

 

COMMUNICATIONS WITH STRIVE

Communications from Strive: As a Site user, you will be asked if you want to receive marketing materials from Strive and its Business Partners (defined below). If you opt-in we will send you marketing materials. You can decline these communications at any time by simply following the “unsubscribe” link at the bottom of each communication.

Mandatory Communications: Even if you have opted out of email communications, we reserve the right to communicate with you from time to time about important administrative, policy, legal, and financial matters that affect your use of the Site. These communications are mandatory.

 

HOW STRIVE SECURES INFORMATION
It is Strive’s practice to take steps to secure our Strive Services; however, the confidentiality of information transmitted over the Internet cannot be guaranteed. We urge you to exercise caution when transmitting personal information over the Internet, especially personal information related to your health. Email is not a secure form of communication. Please do not send us any personal information via email. Strive cannot guarantee that unauthorized third parties will not gain access to your information; therefore, when submitting personal information to Strive websites or apps, you must weigh both the benefits and the risks. Strive websites or apps may link to third-party websites that are not controlled by Strive or subject to an Strive privacy policy. You should check the privacy policies of such third-party websites before submitting personal information.

Security Measures: We will take reasonable measures which we believe are appropriate to protect your information from loss, misuse, alteration or destruction, and, where possible, will ask that any third parties to whom we may transfer your information take comparable steps to protect that security. Although we will use all reasonable efforts to safeguard the confidentiality of any visitor information collected, we shall have no liability for disclosure of any visitor information obtained due to errors in transmission or the unauthorized acts of third parties

Please note, sending information over the Internet or over mobile networks is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your data transmitted to and from the Site or over mobile networks; any transmission of information is at your own risk. 

If you are located in the EU, your personal data is transferred to the US which is not considered to have the same level of data protection as in the EU. However, Strive ensures all data transfers comply with applicable legal requirements and has implemented safeguards so that personal data receives an adequate level of protection.

THIS WEBSITE IS NOT FOR CHILDREN
Strive does not knowingly collect or use any information from children (we define “children” as minors younger than 13). We do not knowingly allow children to order our products, communicate with us, or use any of our online services. If you are a parent and become aware that your child has provided us with information, please contact us using one of the methods specified below and we will work with you to address this issue.

THIRD PARTY SITES
We may provide links to websites and other third-party content that is not owned or operated by Strive. The websites and third-party content to which we link may have separate privacy notices or policies. Strive is not responsible for the privacy practices of any entity that it does not own or control.

If you provide any personal information through a third-party site, your interaction and your personal information will be collected by, and controlled by the privacy policy of that third party site. We recommend that you familiarize yourself with the privacy policies and practices of any such third parties, which are not governed by this privacy policy.

 

ADDITIONAL INFORMATION FOR CALIFORNIA RESIDENTS

Sale of Personal Information:
Over the past twelve (12) months, we have not sold any categories of personal information. Strive does not sell personal information to third parties.

Your Rights and Choices:
CCPA provides consumers (California residents) with specific rights regarding their personal information. You have the following rights:

Disclosure Rights:
You have the right to request that we disclose the categories of personal information we collect in the 12-month period preceding the request date. Consumer requests of this nature may be made no more than twice in a 12-month period. 

Data Access Request:
You have the right to request that Strive disclose certain information to you about our collection and use of your personal information over the past 12 months. 

Deletion Requests:
You have the right to request that Strive delete any of your personal information that we collected from you and retained, subject to certain exceptions as required by applicable law. Once we receive and confirm your consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

 

  • Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities
  • Identify and repair errors that impair existing intended product functionality
  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent
  • Enable internal-only uses that are reasonably aligned with consumer expectations based on your relationship with us
  • Comply with a legal obligation
  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

 

Exercising Your Data Rights:

To exercise your disclose, access, data portability, and deletion rights described above, submit a request to us through one of the following methods:

 

  • Call us:  1-866-787-4836
  • Email us:    support@striveorthopedics.com 

 

Only you, or a person registered with the California Secretary of State who you authorize to act on your behalf, may make a consumer request related to your personal information. You may also make a consumer request on behalf of your minor child. You may only make a consumer request for access or data portability twice within a 12-month period. The consumer request must:

 

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or proves you are an authorized representative of that person
  • Describe your request with sufficient detail that allows us to properly understand, evaluate and respond to it.

 

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. We will only use personal information provided in a consumer request to authenticate the requestor’s identity or authority to make the request.

Response timing and format
Our intent is to respond to a consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. We will deliver our written response electronically. Any disclosures we provide will only cover the 12-month period preceding the consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data access requests, we will deliver the data in a readily usable format.

Non-discrimination
We will not discriminate against you for exercising any of your CCPA rights. 

Other California privacy rights
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our website who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. We do not disclose personal information to third parties for their direct marketing purposes.