Privacy Policy

Last Revised: April 1, 2024

Hoag Orthopedic Institute, LLC (“HOI” or “we”) is committed to respecting the privacy of your personal information. The following privacy policy (“Privacy Policy”) will inform you of the personal information that we, and our affliates, may collect from you, and how it is used and disclosed. By accessing or using our website, https://www.hoagorthopedicinstitute.com/ (“Website”), or any part thereof, including any products or services provided through the Website, you are acknowledging and accepting the practices described in this Privacy Policy and consent to the collection and use of information as specified below. If you are not willing to accept the terms of this Privacy Policy, please do not use our Website.

This Privacy Policy does not describe how we collect or use your Protected Health Information (as defined by the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”)), which is covered by our Notice of Privacy Practices.

We may modify this Privacy Policy from time to time. If we make changes to this Privacy Policy, we will post those changes on this page next to the “Last Revised” at the top of the page. Please review this page frequently to remain up-to-date with the information we collect, how we use it, and under what circumstances we disclose it. You must review the new Privacy Policy carefully to make sure you understand our practices and procedures. By continuing to access or use the Website after changes to this Privacy Policy become effective, you accept the revised Privacy Policy.

Information Collection

When you visit or access our Website, we may collect some information automatically, such as a domain name and IP Address. The domain name and IP address reveals nothing personal about you other than the IP address from which you have accessed our Website. We may also collect information about the type of Internet browser you are using, operating system, what brought you to our Website, as well as which of our Website pages you have accessed.

Additionally, if you communicate with us regarding our Website, our services, or through the “Contact Us” page of the Website, we will collect any information that you voluntarily provide to us in any such communication, which may include your full name, phone number, email address, or mailing address.

Cookies

We use “cookies” on this Website. A “cookie” is a piece of data stored on a site visitor’s hard drive to help us improve your access to our Website and identify repeat visitors to our Website. For instance, when we use a cookie to identify you, you would not have to log in a password more than once, thereby saving time while on our Website.

Cookies can also enable us to track and target the interests of our users to enhance the experience on our Website. Usage of a cookie is in no way linked to any personally identifiable information on our Website.

From time to time, some third party services providers that we engage may also place their own cookies on your hard drive. Note that this Privacy Policy covers only our use of cookies and does not include use of cookies by such third parties.

Most web browsers automatically accept cookies, but you can usually modify your browser settings to prevent the acceptance of cookies, and cookies may be deleted at any time. Note that rejecting cookies may prevent you from using certain features of our Website. The “help” section located in the toolbar of most web browsers will provide instructions for disabling the acceptance of cookies.

Information Use

We use the collected information primarily for our own internal business purposes, such as providing, maintaining, evaluating, and improving our services and Website, and fulfilling requests for information. We may also use the information to provide you with customer support and respond to your inquiries, to process payment on your behalf, as well as create, maintain, customize and secure your account with HOI.

Security

We strive to follow generally accepted industry standards to protect the information submitted to us, both during transmission and once we receive it. If we collect sensitive information (such as credit card data), that information is encrypted and transmitted to us in a secure way. You can verify this by looking for a closed lock icon at the bottom of your web browser, or looking for “https” at the beginning of the address of the web page. While we use encryption to protect sensitive information transmitted online, we also protect your information o ine. Only employees who need the information to perform a specific job (for example, billing or customer service) are granted access to personally identifiable information. The computers/servers in which we store personally identifiable information are kept in a secure environment.

However, as no electronic transmission or storage of information can be entirely secure, no one can guarantee the absolute security or privacy of your information. If you maintain an account with HOI, you are responsible for keeping your account password secure and your account confidential, and for any and all use of your account. If you have reason to believe that the security of your account has been compromised, please notify us immediately in accordance with our contact information set forth below.

Sharing

We may disclose personal information when required by law or in the good-faith belief that such action is necessary to:

• Cooperate with the investigations of purported unlawful activities and conform to the edicts of the law or comply with legal process served on our company
• Protect and defend the rights or property of our Website and related properties
• Identify persons who may be violating the law, the rights of third parties, or otherwise misusing our Website or its related properties

We may also share information we collect with third parties for quality improvement purposes, including analyzing and optimizing our services, delivering non- personalized ads and content, measuring statistics, and the success of ad campaigns, and to allow sharing of HOI webpages and blog posts to social media sites.

We do not sell or otherwise provide the information we collect to outside third parties for the purpose of direct or indirect mass email marketing.

Please keep in mind that whenever you voluntarily disclose personal information online – for example, through e-mail, discussion board post, or elsewhere – that information can be collected and used by others. In short, if you post personal information online that is accessible to the public, you may receive unsolicited messages from other parties in return. Ultimately, you are solely responsible for maintaining the secrecy of your personal information. Please be careful and responsible whenever you are online.

Do Not Track

“Do Not Track” signals are requests by web browsers to disable a web application’s tracking of website or cross-site traffc. HOI does not track its Website visitors over time and across third party websites to provide targeted advertising and therefore does not respond to Do Not Track signals.

Third-Party Links

This Website may contain links to other sites that are not operated by HOI. Please be aware that we are not responsible for the content or privacy practices of such other sites. We encourage our users to be aware when they leave our Website and to read the privacy statements of any other site that collects personally identifiable information.

Surveys & Contests

From time-to-time our Website may request information from you via surveys or contests. Participation in these surveys or contests is completely voluntary and you may choose whether or not to participate and therefore disclose this information. Information requested may include contact information (such as name and shipping address), and demographic information (such as zip code, age). Contact information will be used to notify the winners and award prizes. Survey information will be used for purposes of monitoring or improving the use and satisfaction of this site.

Children’s Privacy

Our Website is neither directed to nor intended for children under the age of 16 and we do not knowingly collect personal information from such children without parental consent. If we find out that we have inadvertently collected personal information from a child under the age of 16, we will take steps to remove such information from our systems. If you are under the age of 16, please consult a parent or guardian for help.

Questions or Comments

If you have any questions or comments about this Privacy Policy, the ways in which HOI collects and uses your information described here and in any notice, your choices and rights regarding such use, or wish to exercise any applicable privacy you may have, please do not hesitate to contact us at:

Phone: (855) 387-4420
Email: HOICorporateCompliance@hoag.org
Postal Address:
Hoag Orthopedic Institute
Attn: DIRECTOR OF COMPLIANCE
16250 Sand Canyon Ave.
Irvine, CA 92618

If you need to access this Privacy Policy in an alternative format due to having a disability, please email HOICorporateCompliance@hoag.org.

Additional Privacy Disclosures for California Residents

This section supplements the information contained in Hoag Orthopedic Institute, LLC’s Privacy Policy and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this section to comply with the California Consumer Privacy Act of 2018 as set forth in California Civil Code section 1798.100 et seq. (“CCPA”) and any terms defined in the CCPA have the same meaning when used in this section.

This section does not apply to personal information collected from California-based employees, job applicants, offcers or board members, contractors, medical staff members or similar individuals, or business-to-business personal information.

Information We Collect, Use, and Disclose

Hoag Orthopedic Institute, LLC (“HOI” or “we”) collects information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“personal information”). Personal information does not include:

• Publicly available information or lawfully obtained, truthful information that is a matter of public concern.
• Deidentified or aggregated consumer information.
• Information excluded from the CCPA’s scope, like:
  • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA), clinical trial data, or other qualifying research data;
  • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months and disclosed for a business purpose with the following categories of third-party recipients:

We obtain the categories of personal information listed above from the following categories of sources:

• Directly from you. For example, when you submit a form or register for an event.

• Indirectly from you. For example, from observing your actions on our Website and through your browser or device when interacting with our Website.

• Affiliates, service providers and business partners.
• Third-party information providers, including marketing service providers.
• Publicly available sources, such as government or agency records or publicly available websites.

We may use or disclose the personal information we collect for one or more of the following purposes:

• As described to you when collecting your personal information or as otherwise set forth in the CCPA.
• To communicate with you or otherwise fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request more information about our services or products, we will use that personal information to respond to your inquiry and assist with offering you HOI services. If you provide your personal information to make a payment, we will use that information to process your order and payment.
• As needed to carry out HOI’s business activities and operations and allow its Service Providers and Contractors to carry out contracted activities.
• To provide, maintain, develop and improve our website, products, and services, including to perform analytics and non-personalized advertising activities.
• To provide you with customer support, to respond to your inquiries, and to perform audit, quality assurance, and improvement activities, including to investigate and address your concerns and monitor and improve our responses.
• To personalize your HOI website experience and to deliver content and product and service offerings relevant to your interests.
• To help maintain the safety, rights, security, and integrity of our website, products and services, databases and other technology assets, employees, third parties, members of the public and/or business, including at any physical facilities.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• For branding, marketing and community outreach purposes and events (including but not limited HOI class and event registrations).
• To exercise or comply with our legal obligations, rights, and policies, including to provide information to our legal and tax advisors.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our consumers is among the assets transferred.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sale or Sharing of Your Personal Information

In the preceding twelve (12) months, we have not "sold" any personal information for either monetary or other valuable consideration, and we have not "sold" any personal information about minors under the age of 16.

In the preceding twelve (12) months, we have not "shared" personal information for the purpose of cross-context behavioral advertising, and we have not "shared" any personal information about minors under the age of 16

Data Retention

As a general matter, we retain your personal information for as long as necessary for our legitimate business interests and/or as needed or permitted for legal reasons. In certain situations, we will delete your information after it is no longer needed to provide a service.

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. Below we describe your CCPA rights and explain how to exercise those rights.

Right to Know and Data Portability

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months (the “right to know”). Once we receive your request and confirm your identity (see Exercising Your Rights), we will disclose to you:

• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting or selling that personal information.
• The categories of third parties with whom we share that personal information.
• If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
  • sales, identifying the personal information categories that each category of recipient purchased; and
  • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
• The specific pieces of personal information we collected about you.

Right to Delete

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions (the “right to delete”). Once we receive your request and confirm your identity (see Exercising Your Rights), we will review your request. We may deny your deletion request, in whole or in part, if compliance would be impossible or involve disproportionate effort for HOI or if retaining the information is necessary for us or our service provider(s) to:

1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended functionality.
4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
8. Comply with a legal obligation.
9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

We will delete or deidentify personal information not subject to one of these or any other available exception under the CCPA from our records and will direct our service providers to take similar action.

Right to Correct

You have the right to request that any inaccuracies in your personal information be corrected by HOI (“right to correct”), taking into account the nature of the personal information and the purposes of our processing your personal information.

Opt-Out Rights

You have the right to direct us to not sell or share your personal information at any time (the “right to opt-out”). However, HOI does not currently sell or share any personal information as defined in the CCPA.

If you make a request to receive information through the Website by providing an email address or phone number, you may request to discontinue receiving similar messages in the future. Materials sent to you by email or text message contain information on how to opt-out.

The Website may partner with third parties, including Google (Google Analytics), to use cookies, web beacons and other storage technologies to collect or receive information from the Website and elsewhere on the internet. These companies collect information from across the internet and are not controlled or managed by HOI. You can opt-out of having your browsing data collected by these companies by managing your ads preferences or privacy settings on these companies’ websites. If you wish to opt out of these analytics tracking services, visit these websites at the following links:

Google Analytics, Google Analytics Opt-Out Browser Add-on.

YourAdChoices.

Right to Limit Use or Disclosure of “Sensitive” Personal Information

You have the right to limit our use or disclosure of “sensitive” personal information. However, HOI does not currently process “sensitive” personal information for purposes that require a corresponding right to limit our use or disclosure of such information.

Exercising Your Rights

To exercise your rights described above, please submit a request by either:

• Mailing us at Hoag Orthopedic Institute, 16250 Sand Canyon Ave., Irvine, CA 92618, Attn: Director of Compliance
• Emailing us at HOICorporateCompliance@hoag.org
• Calling us at (855) 387-4420
• Visiting https://www.hoagorthopedicinstitute.com/contact-us/.

Only you, or someone legally authorized to act on your behalf, may make a request related to your personal information. To designate an authorized agent, you must provide a written, signed letter to HOI authorizing the agent to act on your behalf.

Your request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

You may only submit a request to know twice within a 12-month period.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. To verify your request, you must provide your name, email address, and phone number. If we believe we need further information to verify your request as required by law, we may ask you to provide additional information to us.

We will only use personal information provided in the request to verify the requestor’s identity or authority to make it.

Response Timing and Format

We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please contact the Director of Compliance at HOIcorporatecompliance@hoag.org.

We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you goods or services.

• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Other California Privacy Rights

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. HOI does not share personal information with third parties for their direct marketing purposes.