Privacy Policy

Thank you for visiting this online portal, website or mobile application, which is owned and operated by Aurora Spine, Inc. The Aurora Spine subsidiary or affiliate who owns and operates the online portal, website or mobile application that you are visiting is, where applicable, the data controller responsible for the collection and use of Personal Information. Its contact details can be found in the Contact Us section at the end of this policy. Aurora Spine is a leader in musculoskeletal healthcare. Our purpose is to restore mobility, alleviate pain and improve the quality of life for patients around the world.

This Aurora Spine Website Privacy Policy ("Policy") explains our online practices for the collection and processing of user information collected from or about the users of any online portal, website or mobile application where this Policy is posted (collectively referred to in the Policy as “Websites”). Different Websites may be directed to consumers, healthcare professionals, medical scanning facilities, those seeking employment with us or other users of our services. Please carefully review this Policy.

If you upload or post patient information (for example, health or treatment information including x-rays or medical images that relate to an individual) to one of our Websites (for example, if you are a healthcare professional, hospital, medical scanning facility or similar health care provider or one of their representatives that is a Aurora Spine customer or acting on behalf of a Aurora Spine customer), please note that you are responsible for obtaining any consent required under applicable laws from the relevant individual before uploading or posting the information. In addition, you are responsible for complying with all applicable privacy laws.

To the extent permitted by applicable law, by using the Websites, you are agreeing to this Policy.

Information Collection

PERSONAL INFORMATION

"Personal Information" (also referred to as “Personal Data” in some jurisdictions) is any information that can be used to identify an individual or that we can link directly to an individual, such as name, address, email address, telephone number or credit card number, as applicable. Personal Information, in some jurisdictions, can even include information that indirectly identifies a person – such as a unique number assigned to a patient by a medical facility or healthcare professional, even absent other identifying information. Health and treatment information pertaining to an identified or identifiable individual is a form of Personal Information that in this policy we call Special Personal Information ("Special Personal Information"). We will process any Special Personal Information and Personal Information collected through the Websites in accordance with applicable law and as explained in this Policy. If you do not want to provide us this information, please do not utilize these features of the Websites.

Examples of instances where we collect Personal Information, includes if you:

· register for an account or one of our services or events;

· sign up for newsletters;

· participate in discussion forums;

· ask us a question by contacting us at the information provided in the Contact Us section;

· apply for employment with us; or

· are a customer and provide information about your customer or patients.

The information we collect is typically related to the product or service requested, such as name and contact details, the nature of the product or service requested, and related information so that we may fulfill requests and respond to them. For example, if you apply for a job with Aurora Spine through our website, the information collected will include your qualifications for the position, your education, applicable licenses or certifications, prior job history, references, and any other information that you choose to include about yourself.

We may be required by law to collect certain personal information about you or as a consequence of any contractual relationship we have with you. Failure to provide this information may prevent or delay the fulfillment of these obligations.

Occasionally, Aurora Spine may invite users to participate in a survey or poll, for example, to provide feedback on website content, services, or products. Responses will be anonymous unless users choose to provide contact details so that we can provide a user with additional information regarding the survey.

TECHNICAL INFORMATION

When you visit the Websites, we may also collect certain technical information relating to users, which your web browser automatically sends whenever you visit a website on the Internet or which is collected when you use a mobile application. Our servers automatically record this information, which may include Internet Protocol ("IP") address, browser type, browser language, device type, advertising IDs associated with your device (such as Apple’s Identifier for Advertising (IDFA) or Google’s Ad ID (AAID)), the date and time of your request, and Uniform Resource Locators, or URLs (i.e., website addresses) visited prior to visiting and after leaving our Websites. Depending on a user’s country and the specific information involved, this technical information may or may not be Personal Information.

COOKIES AND SIMILAR TOOLS

Like many websites, we use "cookies," web beacons and other technologies on our Websites to help us serve users better, and to help us evaluate and improve the content or functions of our site. A cookie is a unique numeric code that we transfer to your computer so that we can keep track of your interests and/or preferences and, among other things, recognize you as a return visitor to our Websites. Web beacons are small pieces of code placed on our Websites that allow us to obtain information about website usage.

Common uses for cookies include:

· Identifying visitors who have signed into a protected website to avoid users having to submit a user name and password for every page;

· Keeping track of visitors' preferences regarding the content they would like to see and the format in which they would like to view it so they don't need to resubmit the preferences every time they visit the site;

· Keeping track of which pages visitors request to make improvements to site content and navigation.

· Engaging in analytics about how the Websites are used.

· Collecting information about visitors’ online activities over time and across different websites when they use the Websites.

If you prefer not to receive cookies from this Website set your browser to refuse all cookies from this and other websites that you may visit. This will provide you with more control over the acceptance of cookies on your computer. However, it is possible that some portions of the Websites will not function properly or may perform more slowly if you choose to reject cookies. By using our Websites and not disabling cookies, you consent to their use. We may also provide additional options for your choices regarding cookies on the Websites.

For more information on our use of cookies, please see the Aurora Spine Websites Cookie Policy at www.auroraspine.us/cookies-policy.html.

Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services (including behavioral advertising services) that you do not wish such operators to track certain of your online activities over time and across different websites. While we might engage in such tracking, our Websites do not support Do Not Track requests at this time.

CHILDREN’S INFORMATION

Aurora Spine does not knowingly collect, maintain, disclose or otherwise process Personal Information from minors below the age of 16 in the country where the minor resides without the permission of such minor’s parents or legal guardians. This does not affect medical information about minors that a healthcare professional using one of our Websites may provide in connection with our healthcare professional-directed products or services Websites.

COMBINATION OF DATA

We may combine any of the information we collect, whether Personal Information or not, with Personal Information such as demographic information (for example, age and gender) that we may obtain from third parties. These third parties include healthcare professionals, hospitals, medical scanning facilities or similar health care providers or one of their representatives who may use our Websites for patient-related products and services we make available to them in the course of their or our provision of treatment.

Using and Sharing the Information We Collect

Aurora Spine uses the information we collect: to communicate with users, to provide our products and services to users, to customize or personalize content for users, to identify and authenticate users, to improve our products and services and the content on our Websites, to market to users, and for administrative purposes, system security, product development, and research. We may share the information we collect, including your Personal Information, among our affiliates, subsidiaries, and related companies as well as with third parties that assist us in providing the products or services that you requested or improve our marketing or administration. This includes companies that provide analytics to us about use of our Websites, so that we can evaluate use of our Websites and continue to improve our products, services and the content on our Websites. Because we operate as part of a global business, the recipients referred to above may be located outside the jurisdiction in which you are located (or in which we provide the services).

To the extent that Personal Information and Special Personal Information is transferred out of the country where a user or other individual whose information is provided to us over the Websites lives, such as to Aurora Spine companies in other countries, including in the United States, there may be different standards that apply to how your data may be used and protected. Aurora Spine has put in place appropriate safeguards in accordance with applicable legal requirements to ensure that data is adequately safeguarded and protected irrespective of the country. This includes obtaining written assurances from third parties given access to your data so as to require them to adopt standards that ensure an equivalent level of protection for data as that adopted by Aurora Spine. Should you wish to know more about how Personal Information and Special Personal Information is protected please contact info@auroraspine.us.

From time to time, we will provide aggregate statistics about our customers (including their customers), sales, online traffic patterns and related information to reputable third parties who help us improve our business and services, but these statistics do not include any personally identifying information. Anonymized or aggregated information may also be shared with third parties for other purposes, including the optimization of your web browsing experience and for reports on industry or company trends.

We also may use or disclose information to third parties such as law enforcement agencies and government authorities when we have a good faith belief that it is necessary in order to protect the legal rights, safety, and security of Aurora Spine, our affiliates, or our business partners; to respond to and resolve claims or complaints; to prevent fraud or for risk management purposes; and to comply with or respond to law enforcement or legal process or a request for cooperation by a government or other entity.

In the event that we sell, assign or transfer all or part of the Aurora Spine business or its assets, we may transfer information, including Personal Information, to the buyer. However, the buyer, assignee, or transferee will be required to safeguard Personal Information in a manner that is consistent with the requirements in this Policy. In such situations, your continued use of the Website signifies your agreement to be bound by the privacy policy and other applicable terms of the subsequent owner or operator.

LEGAL BASES FOR USING YOUR PERSONAL INFORMATION

There are different legal bases that we rely on to use Personal Information, namely:

· Performance of a Contract - The use of Personal Information may be necessary to perform the contract that you have with us or to take steps at your request prior to entering into a contract with you. For example, where you work for us either as an employee or a service provider or apply for a job with us your Personal Information will be necessary in connection with your contract of employment or services agreement. If you are a consumer or a user of our services we will use your Personal Information to carry out our obligations under the contract that we have with you. We similarly process patient-related Personal Information from our customers to perform our contracts with them.

· Consent – We will rely on consent, which in some cases may be implied, to use (i) technical information such as cookie data and geolocation data as described in this Policy; and (ii) Personal Information for certain marketing purposes. Where we would like to use Special Personal Information like health information that we collect from an individual, we will only do so with explicit consent if required by law, unless we have an obligation under employment law. You may withdraw your consent at any time by contacting us at the addresses at the end of this Policy. We may obtain certain Personal Information and Special Personal Information about individuals through healthcare professional users (including hospitals, medical scanning facilities or similar health care providers or one of their representatives) of our products and services, in which case they are responsible for obtaining and handling any required consents or for having another legitimate basis for processing such information.

· Legitimate interests – It is in our legitimate interests to process Personal Information in order to improve our products, services, and the content on our Websites, perform administrative tasks, communicate with users, including the delivery of marketing communications with users and patients, customize and personalize content for users, identify and authenticate users, secure our systems and information, conduct research, and develop new products. It is also in our legitimate interests to protect the legal rights, safety, and security of Aurora Spine, our affiliates, or our business partners; to respond to and resolve claims or complaints; to prevent fraud; and to manage risks associated with our business. For more information about the balancing test that we carry out to process your personal information to meet our legitimate interests, please contact us at the details below.

· Legal obligations – We may use Personal Information to comply with legal obligations to which we are subject. For example, we may disclose personal information for medical device regulatory reporting requirements, or to law enforcement in accordance with legal process.

INTERACTIVE FEATURES

To the extent we offer any public or group forums on our Websites, such as newsfeeds, blogs, message boards or similar tools (“interactive features”), the posts or comments you make may be public and viewed by others. You should use care before posting information about yourself, including Personal Information, online. You acknowledge and understand that you have no expectation of privacy or confidentiality in the content you submit to interactive features over the Websites. We assume no obligation to remove Personal Information from postings on our Websites and you disclose any Personal Information in your postings at your own risk.

LINKS TO OTHER WEBSITES

Our Websites may contain links to other websites that are not owned or operated by Aurora Spine, such as social media websites like Facebook, Twitter or through other mechanisms such as email. You should carefully review the privacy policies and practices of other websites, as we cannot control and are not responsible for privacy policies or practices of third-party websites.

SAFEGUARDING INFORMATION

Consistent with applicable laws and requirements, Aurora Spine has put in place physical, electronic, and administrative safeguards to protect Personal Information from loss, misuse, alteration, theft, unauthorized access, or unauthorized disclosure, consistent with legal obligations and industry practices. We evaluate these safeguards on an ongoing basis to help minimize risks from new security threats as they become known. However, as is the case with all websites, we unfortunately are not able to guarantee security for data collected through our Websites.

If you are providing any Special Personal Information or sensitive personal information to us through our Websites, such as credit card details, please be sure that the computer you are using to do so has up-to-date anti-virus software in place, to minimize the risk of any access to the information before it reaches us.

YOUR RIGHTS REGARDING YOUR PERSONAL INFORMATION

Aurora Spine takes reasonable steps to ensure that Personal Data is accurate and up-to-date for the purposes for which it was collected. We encourage you to contact us to update or correct your information if it changes or if you believe that any information that we have collected about you is inaccurate. You can also ask us to erase, restrict or port your Personal Information and you may tell us if you object to our use of your Personal Information. Consistent with legal requirements and limitations, Aurora Spine will comply with reasonable requests to obtain a copy of Personal Information that we hold about you. To exercise your rights, please write to us at info@auroraspine.us or Aurora Spine, Attn: Global Privacy Officer, Global Privacy Officer, 1930 Palomar Point Way, Suite #103., California 92008, USA. Please note that we will likely require additional information from you in order to honor the request.

If you are concerned about how your Personal Information is used, please email us or contact us at the address below. Alternatively you have a right to complain to your local data protection authority (if one exists in your country).

RIGHT TO UNSUBSCRIBE

You may unsubscribe from our marketing or promotional emails. To do so, please email us at info@auroraspine.us. Please note that if you already have requested products or services when you decide to withdraw consent, there may be a short period of time for us to update your preferences and ensure that we honor your request.

HOW LONG YOUR PERSONAL INFORMATION WILL BE RETAINED

We will retain your Personal Information for as long as we maintain a relationship with a user or provide a service for customers that serve individuals and as long as is reasonably necessary thereafter for legitimate business purposes.

OUR DATA PROTECTION OFFICER

If you are using an EU-focused service and have any questions regarding our Data Protection Officer or would like to get in contact with our Data Protection Officer directly please do so at: info@auroraspine.us or write to us at Aurora Spine, Attn: Global Privacy Officer, Global Privacy Officer, 1930 Palomar Point Way, Suite #103., California 92008, USA

CHANGES TO THIS PRIVACY POLICY

We may update this Website Privacy Policy from time to time without notice to users. You should review this Policy periodically. Your continued use of the Online Services constitutes your agreement to this Website Privacy Policy.

If you have any questions, please email us at info@auroraspine.us or write to us at Aurora Spine, Attn: Global Privacy Officer, Global Privacy Officer, 1930 Palomar Point Way, Suite #103., California 92008, USA

Updated: October, 2020