PRIVACY & NON-DISCRIMINATION POLICIES

April 30, 2025

The Orthopaedic & Fracture Clinic (OFC) values its users' privacy. This Privacy Policy ("Policy") will help you understand how we collect and use information from those who visit our website or make use of our online facilities and services and what we will and will not do with the information we collect. Our Policy has been designed and created to ensure those affiliated with the Orthopaedic & Fracture Clinic of our commitment and realization of our obligation to meet privacy standards.

This Privacy Policy supplements our Notice of Privacy Practices, which is made available to patients under HIPAA. If you have a request about your protected health information, please contact us at (507) 386-6600.

We reserve the right to change this Policy at any given time. If you want to ensure you are up to date with the latest changes, we advise you to visit this page frequently. Use of our website after the “Last Updated” date above will constitute your consent to this Policy.

This Policy applies to the Orthopaedic & Fracture Clinic and governs any and all online data collection and usage by us. Using our website, you consent to the data collection procedures expressed in this Policy.

Please note that this Policy does not govern the collection and use of information by companies that the Orthopaedic & Fracture Clinic does not control nor by individuals not employed or managed by us. If you visit a website that we mention or link to, be sure to review its privacy policy before providing the site with information.

It is highly recommended that you review the privacy policies and statements of any website you choose to use to understand better how websites gather, use, and share the information collected.

Specifically, this Policy will inform you:

• About the personal information collected from you through our website.

• Of the reasons we collect information and the legal basis for such collection.

• How we use the collected information.

• About the choices available to you regarding the use of your data.

• About the security procedures in place to protect your information.

Personal Information We Collect

For the purposes of this Policy, “personal information” is any information that identifies, relates to, or can be used to contact a particular individual. This section does not describe the PHI we collect from or about patients; please review our Notice of Privacy Practices to learn more.

A. Information You Provide

The personal information we collect from you can be categorized as follows:

• Contact Information: First name, last name, email address (personal or business), mailing address (personal or business), telephone number (personal or business).

• Transactional Information: Details about your transactions with us, including method of payment, payments received, payment details, transaction history, and other information relating to any payments transmitted to us by you.

• Marketing Information: Details about informational and promotional materials you may have requested or received from us, the services in which you are interested, your receipt of promotional communications, and information on our marketing or communication preferences.

• Communication Information: Copies of the communication and inquiries you have submitted to us, including through emails, calls, chatbots, and features available on our website.

• Device and Usage Information: Details regarding how and when you use our website, including the device used to connect to our website, your IP address and device identifier, the frequency and duration of your usage, the pages you view, what websites or search terms referred you to our website, and information about your interaction with our website.

We collect this information when you use, visit, or navigate our website, fill in forms through the use of our website, submit applications or inquiries to us, submit payments to us, communicate with us (including by phone, email, or otherwise), visit or engage with our social media pages, participate in surveys or sponsored activities, or otherwise provide us with personal information.

Please note that we may aggregate or anonymize the foregoing types of information so that they are no longer capable of identifying you, in which case they are no longer considered “personal information.” We may also collect information about you from third-party and publicly available sources.

B. Automatically Collected Usage and Device Information

Like most website operators, we use various technologies to automatically collect information about visitors and users in general audience areas of our website that are available to the public. Those technologies include:

• Cookies: Cookies are small text files that a website transfers to a visitor’s browser or device for record-keeping purposes. We use cookies to personalize visitors’ experiences on our website, provide content that we believe may be of interest, track visitor trends and patterns, engage in marketing and advertising, and otherwise analyze our website traffic. For further information about cookies, including how to refuse cookies, please visit allaboutcookies.org. Please note that if cookies are disabled, you may not be able to enjoy certain features of our website.

• Log Files and Device Identifiers: We use log files to track actions occurring on the website and collect data about visitors, including IP address, browser type, internet service provider, referring/exit pages, date/time stamps, and device identifiers. This information is used for security purposes and to detect and prevent fraud.

• Pixels, Tags, and Web Beacons: Our website may also use “pixels,” tags,” or “web beacons.” When we refer to “pixels,” we are generally referring to all of these types of technologies. These technologies are small pieces of code that run when a page or email is loaded. They are used to monitor the behavior of the visitor of email recipient – such as what icons were clicked or whether links in an email were opened – and gather analytics. For example, when you open our homepage, a pixel may run and generate information based on the visit, and then this information is processed by us and our vendors. Pixels work in conjunction with cookies to let us know what portions of our website interest you and to help us provide you with tailored information from our website. If you turn off cookies, the pixels, tags, and web beacons we use may still detect certain information about your interaction with our website and disregard any cookie-prohibitive markers or signals. Note that the vendors that supply us with these pixels, tags, web beacons, or similar tracking technologies collect your personal information instantaneously and simultaneously to our collection of your information; in some cases, they may use the information for their own or others’ purposes.

• Analytics: Our website may also use third-party tools like Google Analytics. You can find more information about how data is collected and processed in connection with the Google Analytics service here. You can also read Google’s privacy policy here.

The information collected through these technologies may be combined with personal information or aggregated with other information we technologically or manually collect about or from you. We may disclose information about your use of our website to our advertising and analytics partners, who may combine it with other information you previously provided.

Use of Your Personal Information

We (or service providers acting on our behalf) use the personal information identified above for one or more of the following purposes:

• Making our website available to our users and patients.

• Negotiating, entering into, and managing our relationship agreements with you.

• Processing requests or inquiries regarding our services, and to otherwise make information about our services available to prospective and existing patients and users.

• Providing and optimizing your experience on our website and ensuring that our content is presented to you most effectively.

• Communicating with you regarding our website, our agreements with you, and other issues.

• Sending you promotional or informational communications and solicitations, tracking your marketing preferences, and for our internal marketing purposes.

• Managing customer service issues, including issues relating to the performance of our website.

• Developing, updating, and improving our website, including our user experience and our knowledge and insights regarding potential operational partners and other website users.

• Preventing and detecting fraud, financial crime, hacking activities, security breaches, and other unlawful activities in connection with our website.

• Enforcing our agreements with users or operational partners, complying with our legal or regulatory obligations, and defending or advancing legal claims.

• Notifying you about changes to our website or material changes to this Policy.

• Providing you with surveys or otherwise soliciting feedback from you.

• Performing other functions as otherwise described to you at the time of collection or to which you otherwise consent.

See below for more information about your options relating to your personal information and communication preferences.

Disclosure of Personal Information

When the information we collect about you is aggregated, anonymized, or otherwise does not identify you, we may use that information for any purpose or disclose it to third parties to the extent permitted by applicable law.

The Orthopaedic & Fracture Clinic may disclose your personal information to the following types of entities or individuals:

• Service providers we use to facilitate our business operations and administer our technology solutions. For example, our service providers include (1) IT and system administration providers, (2) data storage providers, (3) vendors to facilitate payments and payment processing, (4) vendors that verify relevant details about you, (5) vendors that ensure our software applications are available for use.

• Insurance companies and other operational partners with whom you have a relationship and to whom you choose to direct us to make your information available.

• Marketing and advertising vendors that may assist with lead generation, hosting information relating to partners and users, marketing automation, advertisement placement and targeting, and marketing campaigns and communications.

• Analytics vendors to understand our website traffic and usage patterns and optimize our website. Note that the technologies we use on our website to automatically collect information about you and your interaction with our website may be supplied by third-party vendors that collect your information instantaneously and simultaneously to our collection of your information.

• Our affiliated or related entities may use your information to provide you with the details of their services.

• Regulatory and governmental authorities, law enforcement agencies, and courts, as necessary to comply with applicable laws and regulations, respond to a subpoena, search warrant, or other lawful request for information, or to otherwise protect our rights.

• Our professional advisors, such as lawyers, accountants, and other similar advisors.

• Buyers or other successors prior to or in the event of a merger, acquisition, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a growing concern or as a part of bankruptcy, liquidation, or similar proceeding, where the information is among the assets being transferred.

• Other parties for any purpose we disclose when you provide the information.

We further reserve the right to refer or disclose your information to law enforcement or regulatory authorities if we believe you, other individuals, our partners or service providers, or anyone else is in danger, at risk of harm, in violation of applicable laws, or representing a safety concern.

Non-Marketing Purposes

The Orthopaedic & Fracture Clinic greatly respects your privacy. We maintain and reserve the right to contact you if needed for non-marketing purposes (such as bug alerts, security breaches, account issues, and/or changes in OFC services). In certain circumstances, we may post a notice on our website, in newspapers, or by other public means.

Children under the age of 13

The Orthopaedic & Fracture Clinic’s website is not directed to and does not knowingly collect personally identifiable information from children under thirteen (13). If it is determined that such information has been inadvertently collected on anyone under the age of thirteen (13), we shall immediately take the necessary steps to ensure that such information is deleted from our system's database, or in the alternative, that verifiable parental consent is obtained for the use and storage of such information. Anyone under thirteen (13) must seek and obtain parent or guardian permission to use this website.

Unsubscribe or Opt-Out

All users and visitors to our website have the option to discontinue receiving marketing communications from us via email or newsletters. To unsubscribe, please use the “unsubscribe” or similar button presented to you in the communication, contact us at ofc@ofc-clinic.com, or call 507-386-6600.

Links to Other Websites

The Orthopaedic & Fracture Clinic does not claim or accept responsibility for non-OFC websites' privacy policies, practices, and/or procedures. Therefore, we encourage all users and visitors to be aware when they leave our website and to read the privacy statements of every website that collects personally identifiable information. This Privacy Policy Agreement applies only and solely to the information collected by our website.

Notice to European Union Users

The Orthopaedic & Fracture Clinic’s operations are located primarily in the United States. If you provide information to us, the information will be transferred out of the European Union (EU) and sent to the United States. By providing us with personal information, you consent to its storage and use as described in this Policy.

Security

The Orthopaedic & Fracture Clinic takes precautions to protect your information. Nonetheless, transmission of information over the Internet cannot be and is not 100% secure. We make no warranties regarding the security of your information when it is submitted to us via our website or in an online fashion.

How to Contact Us

If you have any questions or concerns regarding the Privacy Policy Agreement related to our website, please feel free to contact us at the following telephone number, email address, or mailing address.

• Telephone Number: 507-386-6600

• Email Address: ofc@ofc-clinic.com

• Mailing Address:

  Orthopaedic & Fracture Clinic

  1431 Premier Drive

  Mankato, MN 56001