Ortholive Privacy Policy
Effective Date: January 30, 2025
THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU MAY BE USED AND
DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION. PLEASE REVIEW IT
CAREFULLY.
WHO WILL FOLLOW THIS NOTICE
NOTICE: This Notice of Privacy Practices (the “Notice”) describes OrthoLive Medical Group, Inc. and its
subscribers (the “Company”) practices and those of Company employees, staff, volunteers, and other personnel who
are involved in your care. The Company and these individuals will follow the terms of this Notice, and may use or
disclose medical information about you to carry out treatment, payment or health care operations, or for other
purposes as permitted or required by law. This Notice describes your rights to access and control medical
information about you, including information that may identify you and that relates to your past, present, or future
physical, medical, or mental condition and medical care and related health care services. Your personal physician
may have other policies that he or she follows if he or she sees you outside of the Company and may use his or her
own Notice of Privacy Practices.
THE COMPANY’S PLEDGE REGARDING MEDICAL INFORMATION
The Company understands that medical information about you and your health is personal. The Company is
committed to protecting medical information about you. Health information that the Company receives and/or
creates about you, personally, relating to your past, present, or future health, treatment, or payment for health care
services, is “protected health information” under the federal law known as the Health Insurance Portability and
Accountability Act of 1996 (HIPAA), 45 C.F.R. Parts 160 and 164. In order to provide you with quality care and to
comply with certain state and federal legal requirements, the Company creates a record of the services you receive at
the Company. This Notice applies to all of the records of your care generated by the Company. This Notice will tell
you about the ways in which the Company may use and disclose medical information about you. It also describes
your rights and certain obligations the Company has regarding the use and disclosure of medical information. The
Company is required by law to: (1) Make sure that medical information that identifies you is kept private; (2) Give
you this Notice of its legal duties and privacy practices concerning medical information about you; (3) Follow the
terms of the Notice that are currently in effect, and (4) Notify you in case there is an unauthorized use or disclosure
of your unsecured medical information.
HOW THE COMPANY MAY USE AND DISCLOSE MEDICAL INFORMATION ABOUT YOU
The following categories describe different ways that the Company may use or disclose protected medical
information. For each category of uses and disclosures, the Company will explain what is meant and may give some
examples. Not every use or disclosure in a category will be listed. However, all of the ways the Company is
permitted to use and disclose information will fall within one of the categories. Some information such as
psychotherapy notes, certain drug and alcohol information, HIV, or mental health information is entitled to special
restrictions.
The Company may disclose medical information about you to researchers when the information does not directly
identify you as the source of the information or when a waiver has been issued by an institutional review board or a
privacy board that has reviewed the research proposal and protocols for compliance with standards to ensure the
privacy of your health information.
For Payment
The Company may use and disclose medical information about you so that the Company can get paid for the
treatment and services you receive at the Company. For example, the Company may need to give information to
your health plan or to the Medicare program about treatment you receive at the Company so that they will pay the
Company or reimburse you for your care. The Company may also tell your health plan about a proposed treatment
to determine whether your plan will cover the treatment.
For Health Care Operations
The Company may use and disclose medical information about you to carry out activities that are necessary for
Company operations. These uses or disclosures are made for quality of care, compliance activities, administrative
purposes, contractual obligations, grievances or lawsuits. For example, the Company may use medical information
to review treatment and services provided at the Company or to evaluate the performance of its staff and contractors
in caring for you.
To Individuals or Family Members Involved in Your Health Care
Unless you object, the Company may disclose medical information about you to a member of your family, a relative,
close friend or any other person that you identify who is involved in your care. The Company may also tell your
family or friends, personal representative, or any other person who is responsible for your care, of your location,
general condition or death, unless you object.
Emergencies
The Company may disclose medical information about you to a public or private entity assisting in disaster relief so
that your family can be notified about your condition, status, or location. You may object to this disclosure with a
written request. However, if you are not available or are unable to agree or object, or in some emergency
circumstances, the Company will use its professional judgment to decide whether this disclosure is in your best
interest.
For Fundraising Activities
The Company may use medical information about you to contact you about Company sponsored activities including
fundraising events. We will only use contact information such as your name, address, and phone number.
As Required By Law
The Company will disclose your health information when required to do so by federal, state or local law.
Workers Compensation
The Company may release medical information about you for workers’ compensation or similar programs. These
programs provide benefits for work-related Episodes or illness.
For Public Health Activities
The Company may disclose medical information about you for public health activities. These purposes generally
include the following: (1) To prevent or control disease, injury, or disability; (2) To report deaths; (3) To report abuse
or neglect of children, elders and dependent adults; (4) To report reactions to medications or problems with
products; (5)To notify people of recalls of products they may be using; and (6) To notify a person who may have
been exposed to a disease or who may be at risk for contracting or spreading a disease or condition.
For Health Oversight Activities
The Company may disclose medical information about you to a health oversight agency for activities authorized by
law.
For Lawsuits and Disputes
The Company may disclose medical information about you in response to a court or administrative order, subpoena,
discovery request, or other lawful process.
Disclosure to Law Enforcement
If asked to do so by law enforcement and as authorized or required by law, the Company may release medical
information: (1) To identify or locate a suspect, fugitive, material witness, or missing person; (2) About a suspected
victim of a crime if, under certain limited circumstances, we are unable to obtain the person’s agreement; (3) About
a death suspected to be the result of criminal conduct; (4) About criminal conduct at the Company; and (5) In case of
a medical emergency, to report a crime, the location of the crime or victims, or the identity, description or location of
the person who committed the crime.
Decedents
The Company may release medical information about you to a coroner or medical examiner. This may be necessary,
for example, to identify a deceased person or determine the cause of death. The Company may also release medical
information about you to funeral directors. The Company may also release information to any individual known to
the Company as a family member, close personal friend of the family, or any other person identified, who was
involved in your care or the payment for your care prior to your death, unless you indicate otherwise. Your medical
information may be used or disclosed to others without your authorization after fifty (50) years from the date of your
death.
For Specialized Government Functions
The Company may disclose medical information about you to authorized federal officials for intelligence, counter
intelligence, and other national security activities.
Information About Inmates/Individuals in Custody
If you are an inmate or under the custody of a law enforcement official, the Company may release medical
information about you to the correctional institution or law enforcement official responsible for you as authorized or
required by law.
Disclosure For Threats to Health and Safety
In certain circumstances, the Company may be required to disclose medical information to avert a serious threat to
your health and safety or the health and safety of another person as required by law enforcement. The use or
disclosure will be made in compliance with the law and will be limited to the relevant requirements of the law.
Marketing
The Company will not release your medical information for marketing purposes without an authorization from you.
Sale of Medical Information
The Company will not sell your medical information without an authorization from you.
YOUR RIGHTS
You have the following rights regarding your medical information. In order to exercise these rights, you must
contact The HIPAA Privacy Officer at the Company.
Right to Inspect and Copy
With certain exceptions, you have the right to inspect and receive copies of your medical information.
Amendment
If you feel that medical information about you is incorrect or incomplete, you may ask the Company to amend the
information.
Right to an Accounting of Disclosures
You have the right to receive a list of certain disclosures that we may have made of your medical information.
Right to Request Restrictions
You have the right to request a restriction or limitation on medical information that the Company uses or discloses
about you for treatment, payment or health care operations, and to request a limit on the medical information that the
Company may disclose to family members or friends involved in your care.
Request Confidential Communications
You have the right to request that the Company communicate with you about your appointments or other matters
related to your treatment in a specific way or at a specific location.
Receive a Copy
You have the right to obtain a copy of this notice.
CHANGES TO THIS NOTICE
The Company reserves the right to change the terms of this Notice at any time. The Company reserves the right to
make the revised or changed notice effective for medical information the Company already has about you as well as
any information the Company receives in the future. The Company will post a copy of the current Notice. The
Notice will contain an effective date.
QUESTIONS AND COMPLAINTS
If you have any questions or believe that your privacy rights have been violated, you may contact the Company’s
HIPAA Privacy Officer in person or mail a written summary of your concern to the address listed above.
You may also file a written complaint with the Department of Health and Human Services at the following address:
Michael Leoz, Regional Manager Office for Civil Rights
U.S. Department of Health and Human Services 90 7th Street, Suite 4-100
San Francisco, CA 94103
Customer Response Center: (800) 368-1019
Fax: (202) 619-3818
TDD: (800) 537-7697
Email: ocrmail@hhs.gov
Customer Response Center: (800) 368-1019
Fax: (202) 619-3818
TDD: (800) 537-7697
Email: ocrmail@hhs.gov
You will not be penalized or retaliated against for filing a complaint.
OTHER USES OF MEDICAL INFORMATION
Other uses of disclosures of medical information not covered by this Notice or the laws that apply to use will be
made only with your written permission. If you provide the Company permission to use or disclose medical
information about you, you may revoke that permission in writing at any time by submitting your request here. If
you revoke your permission the Company will stop any further use or disclosure of your medical information for the
purposes covered by your written authorization, except if the Company has already acted in reliance on your
permission. You understand that the Company is unable to take back any disclosure the Company has already made
with your permission and that the Company is required to retain its records of the care that the Company provided to
you.
Ortholive Privacy Policy
OrthoLive, Inc. (“OrthoLive”, “we”, “us”, or “our”) recognizes the importance of protecting the privacy of your
Personal Information, and we have prepared this Privacy Policy to provide you with important information about the
privacy practices applicable to the OrthoLive platform and any website or service that links to or refers to this
Privacy Policy.
Introduction. By using OrthoLive.com, or any other OrthoLive website, app or service on which this policy
appears, you are consenting to have your Personal Information (defined below) and non-personally
identifiable data transferred to and/or processed in the United States in accordance with the terms of this
Privacy Policy. Please do not use the OrthoLive Services if you do not agree with this policy and any other
policies listed on or within the OrthoLive Services.
Personal Information
means information that alone or when in combination with other information may be used to readily identify,
contact, or locate you, such as: name, address, e-mail address, phone number, social security number, and insurance-
issued ID numbers. Personal Information also includes identifiable health information collected about you.
However, Personal Information does not include any information or data which has been anonymized so that it does
not allow a third-party to identify a specific individual.
HIPAA. The Health Insurance Portability and Accountability Act protects your individually identifiable
information that you provide to us for purposes of obtaining medical care, or Protected Health Information.
The HIPAA Notice describes how we can use and share your PHI and also describes your rights with respect
to your PHI. You can access it here.
Collection. Information you provide directly to us:
Contact information, such as your full name, email address, mobile phone number, and address
Username and password
Health insurance
Payment information, such as your credit card number, expiration date, and credit card security code
For health care providers, information about your employment, such as your job title, practice area, primary
specialty, and medical license status, gender, date of birth, languages spoken, educational background, address,
photograph, social security number, Tax ID, NPI number, professional license information and bank account
information
Personal health information, including information about your diagnosis, previous treatments, general health, and
health insurance
Any other information you provide to us
Use of Information. Information and data collected is primarily used for these purposes:
Provide telehealth service
Care Navigation
To create aggregate statistics relating to the use of OrthoLive
To notify you when website updates are available
To market and promote OrthoLive services offered to you through the website
To fulfill any other purpose for which you provide us Personal Information
For any other purpose for which you give us authorization
Sharing. Whom we may share your information with:
Healthcare providers, insurance companies, and other healthcare-related entities: We may share your information with other health care providers, laboratories, government agencies, insurance companies, medical
examiners, and other entities relevant to providing you with treatment options and support.
Authorized third-party vendors: We may share your information with third-party vendors and service-providers that help us with specialized services, including billing, payment processing, customer service, business analytics,
marketing (including but not limited to advertising, attribution, deep-linking, mobile marketing, optimization and
retargeting), performance monitoring, hosting, and data processing. These third-party vendors and service providers
may not use your information for purposes other than those related to the services they are providing to us.
Legal: We may disclose information to respond to subpoenas, court orders, legal process, law enforcement requests, legal claims or government inquiries, and to protect the rights, interests, health, safety, and security of OrthoLive,
our affiliates, users, or the public. We will attempt to notify you by sending an email to the email address in our
records unless doing so would violate the law or unless you have not provided your email address to us if compelled
to do so by a third-party.
At your direction: We may share information for any other purposes disclosed to you at the time we collect the information or pursuant to your consent or direction
Security. We use our best efforts to help protect information from loss, theft, misuse and unauthorized access,
disclosure, alteration and destruction. You should understand that data storage system or transmission of
data over the Internet or any other public network can never be guaranteed to be 100 percent secure.
Children. We will never knowingly collect the information from anyone under the age of 18. If we are made
aware that we have received information from anyone under the age of 18, we will promptly remove that
information from our records.
California Residents. California residents have the right to request and receive free of charge, once per calendar year, information from us regarding categories of Personal Information we shared with third-parties
for their direct marketing purposes during the previous calendar year, if any. To request this information please email privacy@ortholive.com with the subject line Request for California Privacy Information. We
will respond to such written requests within 30 days following receipt at the e-mail or mailing address stated
above
Changes to Privacy Policy. We may modify this Privacy Policy from time to time, and the revised version will
be effective when posted. We recommend that you review the Privacy Policy each time you use the OrthoLive
website to stay informed of our privacy practices.
OrthoLive Privacy Policy – Revised January 2025
OrthoLive, Inc. (“OrthoLive”, “we”, “us”, or “our”) recognizes the importance of protecting the privacy of your
Personal Information, and we have prepared this Privacy Policy to provide you with important information about the privacy practices applicable to the OrthoLive platform and any website or service that links to or refers to this
Privacy Policy.
Introduction. By using OrthoLive.com, or any other OrthoLive website, app or service on which this policy
appears, you are consenting to have your Personal Information (defined below) and non-personally
identifiable data transferred to and/or processed in the United States in accordance with the terms of this
Privacy Policy. Please do not use the OrthoLive Services if you do not agree with this policy and any other
policies listed on or within the OrthoLive Services.
Personal Information
means information that alone or when in combination with other information may be used to readily identify,
contact, or locate you, such as: name, address, e-mail address, phone number, social security number, and insurance-
issued ID numbers. Personal Information also includes identifiable health information collected about you.
However, Personal Information does not include any information or data which has been anonymized so that it does
not allow a third-party to identify a specific individual.
HIPAA. The Health Insurance Portability and Accountability Act protects your individually identifiable
information that you provide to us for purposes of obtaining medical care, or Protected Health Information.
The HIPAA Notice describes how we can use and share your PHI and also describes your rights with respect
to your PHI. You can access it here.
Collection. Information you provide directly to us:
Contact information, such as your full name, email address, mobile phone number, and address
Username and password
Health insurance
Payment information, such as your credit card number, expiration date, and credit card security code
For health care providers, information about your employment, such as your job title, practice area, primary
specialty, and medical license status, gender, date of birth, languages spoken, educational background, address,
photograph, social security number, Tax ID, NPI number, professional license information and bank account
information
Personal health information, including information about your diagnosis, previous treatments, general health, and
health insurance
Any other information you provide to us
Use of Information. Information and data collected is primarily used for these purposes:
Provide telehealth service
To create aggregate statistics relating to the use of OrthoLive
To notify you when website updates are available
To market and promote OrthoLive services offered to you through the website
To fulfill any other purpose for which you provide us Personal Information
For any other purpose for which you give us authorization
Sharing. Whom we may share your information with:
Healthcare providers, insurance companies, and other healthcare-related entities: We may share your information with other health care providers, laboratories, government agencies, insurance companies, medical
examiners, and other entities relevant to providing you with treatment options and support.
Authorized third-party vendors: We may share your information with third-party vendors and service-providers that help us with specialized services, including billing, payment processing, customer service, business analytics,
marketing (including but not limited to advertising, attribution, deep-linking, mobile marketing, optimization and
retargeting), performance monitoring, hosting, and data processing. These third-party vendors and service providers
may not use your information for purposes other than those related to the services they are providing to us.
Legal: We may disclose information to respond to subpoenas, court orders, legal process, law enforcement requests, legal claims or government inquiries, and to protect the rights, interests, health, safety, and security of OrthoLive,
our affiliates, users, or the public. We will attempt to notify you by sending an email to the email address in our
records unless doing so would violate the law or unless you have not provided your email address to us if compelled
to do so by a third-party.
At your direction: We may share information for any other purposes disclosed to you at the time we collect the information or pursuant to your consent or direction
Security. We use our best efforts to help protect information from loss, theft, misuse and unauthorized access,
disclosure, alteration and destruction. You should understand that data storage system or transmission of
data over the Internet or any other public network can never be guaranteed to be 100 percent secure.
Children. We will never knowingly collect the information from anyone under the age of 18. If we are made
aware that we have received information from anyone under the age of 18, we will promptly remove that
information from our records.
California Residents. California residents have the right to request and receive free of charge, once per calendar year, information from us regarding categories of Personal Information we shared with third-parties
for their direct marketing purposes during the previous calendar year, if any. To request this information
please email privacy@ortholive.com with the subject line Request for California Privacy Information. We
will respond to such written requests within 30 days following receipt at the e-mail or mailing address stated
above
Changes to Privacy Policy. We may modify this Privacy Policy from time to time, and the revised version will
be effective when posted. We recommend that you review the Privacy Policy each time you use the OrthoLive
website to stay informed of our privacy practices.
Questions. If you have any questions about this Privacy Policy, please email us at
privacy@ortholive.com.