PARAGON 28 PRIVACY POLICY
Last Updated: December 2024
Paragon 28, Incorporated, its subsidiaries and its affiliates (“Paragon 28”, “we”, “us” and “our”) respect the privacy and confidentiality of the individuals whose personal information we collect, including users of our online services and healthcare professionals. This Privacy Policy (“Privacy Policy”) was created to inform you of our practices regarding the collection, use and disclosure of personal information and the choices you have related to that information.
Please note that we may update this Privacy Policy from time to time.
If you are a California resident and would like to exercise your California privacy rights, please see the California Privacy Rights section below.
If you reside in the European Union, please see the Additional Information Regarding the EEA section below.
1. SCOPE
This Privacy Policy applies to all personal information collected about you by Paragon 28, when you:
Collectively, we refer to the Websites, Social Media Pages, e-mails, other communications, and offline business interactions as the “Services.”
2. PERSONAL INFORMATION WE COLLECT
We collect personal information when you use our Services and when we communicate with you. As used throughout this Privacy Policy, “Personal Information” means any information that relates to, identifies or could be used to identify a specific individual, such as their name, email address or telephone number. Personal information does not include anonymous data. The types of personal information that we may collect about you through the Services include:
If you are a healthcare provider, we may also collect:
Collection of Personal Information
We and our service providers collect Personal Information in a variety of ways, including:
From You Directly Through the Services. We collect Personal Information through the Services, for example:
From Other Sources. In some instances, we receive Personal Information from other sources, for example:
We need to collect Personal Information to provide the requested Services to you. If you choose not to provide the information requested, we may not be able to provide the Services. If you disclose any Personal Information relating to other people to us or to our service providers in connection with the Services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.
3. HOW WE USE PERSONAL INFORMATION
We and our authorized third-party service providers process Personal Information for the following purposes:
We will engage in these activities to manage our contractual relationship with you and/or to comply with a legal obligation.
We use this information to manage our contractual relationship with you.
We use this information to manage our contractual relationship with you and/or to comply with a legal obligation.
We engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, and/or based on our legitimate interest.
For any other purposes disclosed to you at the time we collect your Personal Information or with your consent.
4. WHEN WE DISCLOSE PERSONAL INFORMATION
We disclose Personal Information:
Other Uses and Disclosures
We also use and disclose your Personal Information as necessary or appropriate, in particular when we have a legal obligation or legitimate interest to do so:
5. OTHER INFORMATION
“Other Information” is any information that does not reveal your specific identity or does not directly relate to an identifiable individual. The Services collect Other Information such as:
Collection of Other Information
We and our service providers collect Other Information in a variety of ways, including:
Uses and Disclosures of Other Information
We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. If we are required to treat Other Information as Personal Information under applicable law, we may use and disclose it for the purposes for which we use and disclose Personal Information as detailed in this Policy. In some instances, we may combine Other Information with Personal Information. If we do, we will treat the combined information as Personal Information as long as it is combined.
6. THIRD-PARTY LINKS
This Privacy Policy does not address, and we are not responsible for, the privacy, information, or other practices of any third parties, including any third party operating any website or service to which the Services link. The inclusion of a link on the Services does not imply endorsement of the linked site or service by us or by our affiliates. We encourage you to read the privacy statements of every website you visit.
In addition, we are not responsible for the information collection, use, disclosure, or security policies or practices of other organizations, such as Facebook, Apple, Google, Microsoft, RIM, or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider, or device manufacturer, including with respect to any Personal Information you disclose to other organizations through or in connection with our Social Media Pages.
7. SENSITIVE INFORMATION
Unless we request it, we ask that you not send us, and you not disclose, any sensitive Personal Information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background, or trade union membership) on or through the Services or otherwise to us.
8. DATA SECURITY
We seek to use reasonable and appropriate organizational, technical and administrative safeguards to protect the integrity and security of Personal Information within our organization. However, no data storage system or transmission of data over the internet or any other public network can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contact Us” section below.
9. DATA RETENTION
We retain Personal Information for as long as is reasonably necessary and relevant for the specific business purpose or purposes for which it was collected and the duration of your use of our Services. In addition, we retain personal information to comply with applicable law, prevent fraud, resolve disputes, troubleshoot problems, assist with investigations, enforce our Terms of Use and other reasons permitted by law. The criteria used to determine our retention periods include:
10. JURISDICTION AND INTERNATIONAL TRANSFERS
Paragon 28 is based in the United States and, regardless of where you use our Services, your Personal Information may be transferred to servers located in the U.S. and other territories as necessary for the purposes described above, including to territories that may not provide the same level of data protection as your home country. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Information.
11. YOUR PRIVACY CHOICES
Your choices regarding our use and disclosure of your Personal Information
We give you choices regarding our use and disclosure of your Personal Information for marketing purposes, including the following:
Please note that “opt-out” and “unsubscribe” requests may not take effect immediately and may require a reasonable amount of time to process and apply. If you opt-out of receiving marketing communication, we will still send you non-marketing emails for our business purposes, such as for responses to your requests or communications about your account. Additionally, you should be aware that any information provided to us prior to your election to opt-out or unsubscribe will not be retrieved or rescinded, unless required by law.
How you can access, change, or delete your Personal Information
If you would like to request to access, correct, update, suppress, restrict, or delete Personal Information that you have provided to us, withdraw your consent, object to or opt out of the processing of Personal Information, or if you would like to request to receive a copy of your Personal Information for purposes of transmitting it to another company (to the extent these rights are provided to you by applicable law), you may contact us in accordance with the “Contact Us” section below. We will respond to your request consistent with applicable law. If you are a California resident, please refer to the “California Privacy Rights” section at the end of this Policy for more information about the requests you may make under the CCPA.
In your request, please make clear what Personal Information you would like to have changed or whether you would like to have your Personal Information suppressed from our database.
For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to respond to your request without undue delay. Please note that we may need to retain certain information for recordkeeping purposes.
12. CALIFORNIA PRIVACY RIGHTS
Pursuant to the California Consumer Privacy Act of 2018 (CCPA), we are providing the following additional details regarding the categories of Personal Information that we collect, use, and disclose about California residents. This section supplements the information provided in this Privacy Policy and applies only to California residents.
Collection and Disclosure of Personal Information: For purposes of this section, Personal Information means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to a particular consumer or household. Personal Information does not include:
While the information we may collect from you depends on your relationship and interactions with Paragon 28, the chart below is a summary of (1) the categories of Personal Information, as identified and defined by the CCPA, that we plan to collect and have collected and disclosed within the last twelve (12) months; and (2) the categories of third parties to which we disclosed Personal Information for our operational business purposes within the last twelve (12) months:
Categories of Personal Information | Disclosed to Which Categories of Third Parties for Operational Business Purposes |
identifiers such as a name, address, unique personal identifier, email, phone number, your device’s IP address and software and identification numbers associated with your devices | authorized service providers and vendors and affiliates; marketing and advertising service providers; co-branding partners; legal authorities |
characteristics of protected classifications including medical information such as your medical history, mental or physical condition or treatment | authorized service providers and vendors and affiliates; legal authorities |
commercial information such as records of products or services purchased, obtained or considered by you | authorized service providers and vendors and affiliates; co-branding partners; legal authorities |
internet or other electronic information regarding you browsing history, search history, the webpage visited before you came to our website, length of visit and number of page views, click-stream data, locale preferences, your mobile carrier, date and time stamps associated with transactions and system configuration information | authorized service providers and vendors and affiliates; marketing and advertising service providers; co-branding partners; legal authorities |
your geolocation, to the extent you have configured your device to permit us to collect such information | authorized service providers and vendors and affiliates; marketing and advertising service providers; co-branding partners; legal authorities |
audio recordings of your voice to the extent you call us, as permitted under applicable law | authorized service providers and vendors and affiliates; legal authorities |
professional or employment-related information | authorized service providers and vendors and affiliates; legal authorities |
education-related information | authorized service providers and vendors and affiliates; legal authorities |
inferences about your preferences, characteristics, behavior and attitudes | authorized service providers and vendors and affiliates; marketing and advertising service providers; co-branding partners; legal authorities |
Sensitive Personal Information, such as social security number, passport number, personal information collected or analyzed concerning an individual’s health | authorized service providers and vendors and affiliates; legal authorities |
We may also disclose your Personal Information to a third party in the event of any reorganization, financing transaction, merger, sale, joint venture, partnership, 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).
To learn more about the Personal Information we collect and how we collect it, please refer to Personal Information We Collect above.
Sources of Personal Information: As described above, we collect Personal Information from the following sources:
To learn more about the sources from which the Personal Information is collected, please refer to Personal Information We Collect above.
Purposes for the Collection, Use and Disclosure of Personal Information: We collect Personal Information for the business purposes described above in How We Use Personal Information. We disclose Personal Information as described in When Paragon 28 Discloses Personal Information.
Purposes of Use of Sensitive Personal Information: We may collect, use, and disclose Sensitive Personal Information for purposes of performing services for our business, providing goods or services as requested by you, ensuring security and integrity, short term transient use such as displaying first party, non-personalized advertising, order processing and fulfillment, servicing accounts, providing customer service, verifying customer information, processing payments, providing financing, and activities relating to quality and safety control or product improvement.
CCPA Privacy Rights and Requests:
If you are a California resident, you may make the following requests:
How to Exercise Your California Privacy Rights: To make a request to know or delete, please contact us at [email protected].
13. NOTICE TO NEVADA RESIDENTS
Nevada Residents as Covered by Nevada Privacy Law: Paragon 28 does not sell Covered Information as defined under Nevada law. If you would like to make a further inquiry regarding the selling of your Covered Information, as defined under Nevada law, please contact us using the contact information in the Contact Us section below.
14. ADDITIONAL INFORMATION REGARDING THE EEA
You may also:
15. CHANGES TO THIS PRIVACY POLICY
We may update this Privacy Policy from time to time. When we update the Privacy Policy, we will revise the “last updated” legend above and post a link to the new Privacy Policy on our website. If we make any material changes, we will provide you with notice as required under applicable law. Changes to this Privacy Policy are effective when they are posted on the Services.
16. CONTACT US
To contact Paragon 28 with any questions or comments about this Privacy Policy, obtain access to your information or withdraw consent, please contact us at [email protected].