Privacy and Security Policy:

Effective Date: March 17, 2022

Welcome to OrthoRPM Inc (“OrthoRPM”). OrthoRPM (hereinafter referred to as “we,” “us” or “our”) is a medical technology company that develops and commercializes innovative medical solutions targeting muscle atrophy – a frequent complication associated with joint surgery – by utilizing its patented neuromuscular electrical stimulation (NMES) technology platform. This website is intended to provide patients and physicians with basic information about our products and services, and is not intended for the diagnosis or assessment of any disease or condition, nor is it intended to be used as medical advice. Please be aware that there are two policies that govern your use of the OrthoRPM website and products:

• This Privacy and Security Policy describes how we gather and use information when you access OrthoRPMOrtho.com (the “Site”), and/or when you use or register any OrthoRPM products, (referred to hereinafter as the “Product(s)”); and
• Our Terms of Use which governs the way you use the Site and our Products

Please read this Privacy Policy and the Terms of Use carefully. By visiting this Site or using any of our Products, you are agreeing to them. If you cannot agree, please do not use the Site or Products.

Information OrthoRPM Collects and how it is Used

OrthoRPM currently only collects information that assists us in providing you with information on Products and services we provide, or information you choose to enter voluntarily. OrthoRPM does not automatically collect Personally Identifying Information (“PII”), which is information that can be used on its own or with other data to identify you personally. OrthoRPM may collect PII when you choose to enter information into the Patient Survey page or to request more information on our products, and when you choose to purchase accessories through the   e-commerce page. Examples of PII include: name, address, email address, phone number, social security number or credit card number. We may use an IP address to identify the general geographic area from which you are accessing our website, but we do not combine that information with other information you provide in order to attempt to identify you. At this time, we do not collect Protected Health Information (“PHI”), which is information that indicates the past, present or future health status of an individual. Examples of PHI can include your name associated with your family medical history. If you choose to enter information regarding your surgery date, surgeon, or other information we collect on out Patient Survey Page, we will not use that information in conjunction with any other information in an attempt to identify you. We take the protection of any information you provide to us seriously. We employ rigorous technical and organizational safeguards against unauthorized disclosure or access to all information.

Here is an explanation of the types of information we do and do not collect, and why we collect it:

1. In order to give you access to our website and services via the internet, we collect industry standard log data that includes the type of browser and operating system you are using, the address of the external or internal page that referred you, (such as search engines) and your IP address. This information is collected from every visitor and is used to diagnose Site performance and usability. This information is not combined with any other information you may choose to provide to us, such as information entered into the Patient Survey.
2. When you purchase accessories through the e-commerce Site, we may ask you for credit card information in order to properly process your transaction.
3. On our Patient Survey page, we may ask for your physician’s name and location, surgery date, and questions about your satisfaction with our products. Information you supply on the Patient Survey is completely voluntary; you do not have to complete the survey to use our products. We do not ask for your name, address, or other identifying information, nor do we ask for personal or family medical history. We ask for your physician’s name and location so that we may ensure our devices are being prescribed and used in accordance with our physician agreements, and will not be used in any way in any attempt to identify you.
4. If you contact us via a form on the Site, for example, to request more information or an additional copy of the user manual, we will require you to enter contact information such as your name, address, and phone number because they are relevant to providing you with the assistance that you are requesting. We will only use this information in relation to the purpose for which you are providing it.
5. Any information we do collect may be used for internal business purposes or research and development, which may include improvements to the medical products and devices we offer to our patients, or the OrthoRPM website. We may use the information we collect for internal data analysis, studying how the OrthoRPM Website is used, identifying usage trends and determining the effectiveness of promotional campaigns.
6. OrthoRPM will internally analyze Patient Survey results to make discoveries in the study of orthopedic medicine, pain management, and other medical topics. In addition, we may use the information you provide in the Patient Survey and other information for the purposes of collaborative research and publication in these areas.

How OrthoRPM Secures Your Information

We understand how important your privacy is, which is why we take great care in safeguarding your personal information. OrthoRPM employs a range of physical, technical and administrative safeguards to secure the information you entrust to us and protect it from loss, misuse and unauthorized access, disclosure, alteration or destruction. Information you provide to OrthoRPM through our website is encrypted using industry standard Secure Socket Layer (SSL) technology, and information you may provide on our Patient Survey page is processed and stored behind firewalls on controlled servers with restricted access. We do not sell, rent, trade or otherwise provide information to third parties for any purpose. OrthoRPM does not store any credit card information, unless you voluntarily select a subscription order on the e-commerce page.

How OrthoRPM Shares Your Information

We will keep your information private and will never sell your information. We will only share your information if we receive your consent, or in the following circumstances:

1. If we contract with third-party vendors to provide services that are necessary to the Site. These vendors are required by contract and in some cases, state and/or federal law, to protect the information we share with them and may only use it for that purpose.
2. When you purchase accessories through the Site, we will share information about the transaction with your credit card company to facilitate your payment.
3. We may disclose your information if that doing so is reasonably necessary to comply with a law, regulation, or valid legal process. If we are going to release your information, we will do our best to provide you with notice in advance, unless we are prohibited by court order from doing so.
4. We may also disclose your information to address fraud, security, or spam, or to comply with a legal duty to inform others, such as if we believe it’s necessary to prevent imminent and serious bodily harm to a person, or to protect our rights or property.
5. Even if we are acquired by or merged with another company, this Privacy Statement will continue to apply to information collected while it was in place.
6. We may disclose information you provide in the Patient Survey to our partners for our marketing or research and development purposes, or to our partners who are conducting research on various health issues.

Cookies

Cookies are small files, typically of letters and numbers, downloaded onto your computer or mobile device when you visit certain websites. When you return to these websites — or visit other websites that use the same cookies — they recognize these cookies and therefore your browsing device.

The cookies on our website do lots of different jobs, including:

• Making the website work properly for you and enabling you to make use of the secure online services that we provide.
• Collecting data about your use of the website which is then anonymized and used to help us improve our online services.
• Remembering your preferences and making the site easier for you to use.

In addition, our website includes cookies that are placed by third party services we make use of to enhance the information we present online. We have no control over these third-party cookies. You can learn about the cookies we use and how to manage them below.

What Types of Cookies OrthoRPM Uses

Strictly Necessary Cookies
These cookies are essential, as they enable you to move around the website and use its features, such as accessing secure areas. Without these cookies, services you’ve asked for can’t be provided, as this category of cookie is essential for OrthoRPM to work it cannot be disabled. These cookies don’t gather information about you that is used for marketing or remembering where you’ve been on the internet.

As this category of cookie is essential for OrthoRPM to work it cannot be disabled.

Strictly Necessary Cookies
These cookies collect information about how you use a website, for example which pages you go to most often and if you get error messages from certain pages. These cookies don’t gather information that identifies you. All information these cookies collect is anonymous and is only used to improve how a website works.

These cookies are not used to target you with online marketing. Without these cookies we can’t learn how our website is performing and make relevant improvements that could better your browsing experience. Examples of third-party cookies: Optimizely, Google Analytics.

How to Manage Cookies from this Website

Our Cookies (first party cookies)
You can use the browser that you are viewing this website with to enable, disable or delete cookies. To do this, follow the instructions provided by your browser (usually located within the “Help”, “Tools” or “Edit” settings). Please note that if you set your browser to disable cookies, you may not be able to access secure areas of the website and other parts of the website may also not work properly. You can find out more information about how to change your browser cookie settings at http://www.allaboutcookies.org.

Do Not Track

The Site does not currently respond to a Do Not Track (“DNT”) or similar signal as it awaits the results of efforts by the policy and legal community to determine the meaning of DNT and the proper way to respond. Since OrthoRPM does not collect personally identifiable information, does not track your online behavior for marketing or advertising purposes, and does not share your information with third parties, we do not at this time believe that DNT is applicable to the services and information we provide.

Information Retention

At this time, OrthoRPM retains non-PII indefinitely, and only for the purposes set forth above. We do not collect or retain PII, PHI or other data that requires additional protections under various state and federal laws and regulations.

A Note about Children

OrthoRPM is a general audience website that is not directed to children, but children under the age of 13 may use this Site. Since OrthoRPM does not collect PII from any of its users, we also aver that we do not knowingly collect PII from anyone under the age of thirteen. OrthoRPM is not responsible for independently verifying the age of each of its users.

Changes to this Policy

We may change our policies at any time and the changes will apply to any information we already hold, as well as new information after the change occurs. Before we make a significant change, we will post the new notice on our website at www.Ortho-RPM.com. The new policy will be available upon request. If this Privacy Policy changes, the revised policy will be posted on this site. Please check back periodically, and especially before you provide any Personal Information.

Acceptance of Privacy Policy Terms & Conditions

By using our website, you consent to the collection and use of this information by OrthoRPM Inc. If we decide to change our privacy policy, we will post those changes on this page so that you are always aware of our policies.

How Do I Contact OrthoRPM Inc?

We invite you to contact us as follows:
Email: info@Ortho-RPM.com

Postal Address:
OrthoRPM, Inc.
674 2^nd Street
Encinitas CA 92024
Phone: (760) 420.9866
OM-0800-001 Rev. A