Privacy Statement

• • PRIVACY AND SECURITY
    • Overview. At Modernizing Medicine Podiatry Systems, Inc. (“Modernizing Medicine”, “we”, “our”, or “us”), our mission is to transform how healthcare information is created, consumed, and utilized to increase practice efficiency and improve patient outcomes. As such, we understand the importance of privacy and security.
    • Security. We use reasonable safeguards aimed to protect against unauthorized use, disclosure, alteration, or destruction of the personal information we collect and maintain. Although we strive to protect your personal information, we can’t guarantee the security of any information or that unauthorized use, disclosure, alteration, or destruction or some other data breach will not occur. Please keep in mind that no data transmitted over the Internet is 100% secure and any information disclosed online can potentially be collected and used by parties other than the intended recipient.
    • Children’s Information. We do not expect to collect information, including personal information as defined by the Children’s Online Privacy Protection Act, from children under the age of 13. If you are a parent or guardian of a child under the age of 13 and believe he or she has disclosed personal information to us, you may contact us at privacy@modmed.com to request that we delete and stop use of that information. If we learn that we have received any information directly from a child under age 13 without first receiving his or her parent’s verified consent, we will use that information only to respond directly to that child (or his or her parent or legal guardian) to inform the child that he or she cannot use our products or services. We will then subsequently delete that child’s information.
    • Links to Other Sites. Our products and services may contain links to other sites and other products and services that are not owned or controlled by us. Please be aware that we are not responsible for the privacy practices or content of such other sites, products, and services.
  • CALIFORNIA RESIDENTS
    • Applicability. If you are a California resident, then this section 2 may apply to you.
    • CCPA.
      • Scope.
        • This section 2 is intended to describe your rights under the California Consumer Privacy Act of 2018 (“CCPA”). This section 2 provides rights and other terms relating to CCPA Personal Information (defined below). These rights and other terms are only available to California residents about whom we collect CCPA Personal Information
        • In this section 2, when we talk about “CCPA Personal Information”, we mean information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household as set forth in the CCPA.
        • You should be aware that CCPA Personal Information doesn’t include:
          • Publicly available information from government records,
          • De-identified or aggregated consumer information, and
          • Information excluded from the CCPA’s scope, such as:
            • Protected Health Information (which is personally identifiable health information that is protected by the Health Insurance Portability and Accountability Act of 1996 and its implementing regulations), information subject to the California Confidentiality of Medical Information Act, or clinical trial data; or
            • “Business to business” information, which is information related to communications or transactions between a business collecting the information and a consumer who is acting on behalf of another business where the communications or transaction relate solely to an exchange of products or services between the two businesses.
      • Your Rights and Choices under the CCPA. Below please find a description of key rights California consumers have under the CCPA and an explanation of how to exercise those rights with us.
        • The Right to Know. You have the right to request that we disclose certain information to you about our collection and use of your CCPA Personal Information over the past 12 months. Once we receive and verify your request, we will disclose to you:
          • The categories of CCPA Personal Information we collected about you.
          • The categories of sources for the CCPA Personal Information we collected about you.
          • Our business or commercial purpose for collecting or selling that CCPA Personal Information.
          • The categories of third parties with whom we share that CCPA Personal Information.
          • The specific pieces of CCPA Personal Information we collected about you (also called a data portability request).
          • If we sold or disclosed your CCPA Personal Information for a business purpose, two separate lists setting out:
            • sales, identifying the CCPA Personal Information categories that each category of recipient purchased; and
            • disclosures for a business purpose, identifying the CCPA Personal Information categories that each category of recipient obtained.
        • The Right to Deletion.
          • You have the right to request that we delete any of your CCPA Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and verify your request, we will delete (and direct our service providers to delete) your CCPA Personal Information from our records, unless an exception under the CCPA applies.
          • We may deny your deletion request for reasons permitted by the CCPA. For example, if the information is excluded from the CCPA or does not constitute CCPA Personal Information, such as Protected Health Information held on behalf of a healthcare provider who uses our products or services. Please submit all requests related to your Protected Health Information directly to your healthcare provider. We may also deny your deletion request if the information is required to complete the transaction for which the information was collected or for us or your provider (as applicable) to provide you with requested goods or services.
        • Exercising Your Right to Know and Right to Deletion.
          • To exercise your Right to Know and Right to Deletion, please submit a request to us at the Contact Information below.
          • Only you or an authorized representative may make a request related to your CCPA Personal Information. You may also make a request on behalf of your minor child.
          • You may
          • only make a Right to Know or Right to Delete request twice within a 12-month period. The request must:
            • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected CCPA Personal Information or an authorized representative.
            • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
          • We will take steps to verify your identity before processing your Right to Know or Right to Delete request. If you have an account with us, we will use our existing account authentication practices to verify your identity. If you do not have an account with us, we may request additional information about you so that we can verify your identity. We will only use the CCPA Personal Information you provide to us in response to this request to verify your identity and to process your request, unless you initially provided the information for another purpose.
          • You may use an authorized agent to submit a Right to Know or Right to Deletion request. When we verify your agent’s request, we may verify both your and your agent’s identity and request a signed document from you that authorizes your agent to make the request for you. To protect your CCPA Personal Information, we reserve the right to deny a request from an agent that does not submit adequate proof that you authorized them to act for you.
          • We cannot respond to your request or provide you with CCPA Personal Information if we cannot verify your identity or authority to make the request and confirm the CCPA Personal Information relates to you.
        • Response Timing and Format. Once we have verified a request from a California consumer, we will try to respond within 45 days. If we need more time, we will tell you in writing why and how much longer we need, either by mail or electronically (based on your choice). Our responses will include the CCPA-required information.
        • CCPA Personal Information Sales Opt-Out Rights. You have the right to opt out of the sale of your CCPA Personal Information. If you do not affirmatively opt out, and you are not a minor (less than 16 years of age), your CCPA Personal Information may be sold. You (or your authorized representative) may submit your request to opt out of the sale of your CCPA Personal Information by clicking here or by emailing privacy@modmed.com.
        • Non-Discrimination. We will not discriminate against you for choosing to exercise any of your CCPA rights, including with respect to the pricing of any Services. If you exercise certain CCPA rights, understand that you may be unable to use or access certain features of our products or services. Additionally, please note that we may still charge you a different price or rate for our products or services, including through granting of discounts or other benefits, for reasons unrelated to your exercise of these rights, unless prohibited by the CCPA.
    • Shine the Light. California Civil Code Section 1798.83 gives California residents the rights to request certain information regarding our disclosure of their personal information to third parties for those third parties’ direct marketing purposes. We may share your personal information with affiliated third parties, some of which do not share the name of Modernizing Medicine, for their own direct marketing purposes. You may request information regarding the disclosure of your personal information to third parties for those third parties’ direct marketing purposes by contacting us at the Contact Information below.
  • CHANGES TO THIS PRIVACY STATEMENT

We may change this Privacy Statement at any time. Unless we say otherwise, changes will be effective upon the last updated date at the top of this Privacy Statement. Please check this Privacy Statement regularly to ensure that you are aware of any changes.

• • CONTACTING US

If you have any questions or comments about this Privacy Statement, or if you wish to exercise your rights under California law, please contact us by either:

• • Calling us at 1-866-799-2146 and asking to speak with the Privacy Officer;
  • Emailing privacy@modmed.com; or
  • Writing us at:
    Modernizing Medicine Podiatry Systems, Inc.
    4850 T-Rex Avenue, Suite 200
    Boca Raton, Florida 33431
    Attention: Privacy Officer
    1-866-799-2146