Privacy Policy

OrthoPediatrics Canada ULC dba Pega Medical (“OrthoPediatrics Canada”, “us,” “we,” or “our”) is committed to maintaining the accuracy, confidentiality, and security of any personally identifiable information obtained by our organization. As part of this commitment, this Privacy Policy governs our actions as they relate to the collection, use and disclosure of any Personal Information collected when you visit or contact us through www.pegamedical.com.

In this Policy, the term personally identifiable information is defined as Personal Data and refers to all information about an individual that allows them to be identified alone or in combination with other information, for example, their name, contact information, etc. Personal Data can also refer to more technical information, such as an IP address, web browser settings and a device’s unique ID, but only if this information identifies an individual.

The Purpose of This Privacy Policy

The purpose of this Privacy Policy is to inform users of our website of the Personal Data we may collect as well as the following information, if any:

a. Personal Data we will collect

b. Use of collected Personal Data

c. Who has access to the Personal Data collected

d. The rights of the users of the site as to their Personal Data

Applicable Laws

This Policy complies with the laws of Canada, including the Personal Information Protection and Electronic Documents Act, the Quebec Privacy Act, and the Privacy Act of Canada where applicable.

Consent

Users agree that by using our site, they consent to:

Øthe terms set forth in this Privacy Policy and

Øthe collection, use, and retention of Personal Data as listed in this Policy.

Personal Data We Collect

No Automatic Collection

OrthoPediatrics Canada does not collect Personal Data automatically on www.pegamedical.com.

Manual Collection Through Online Form

OrthoPediatrics Canada may collect the following Personal Data when you perform certain functions on our site:

a. First and last name

b. Email address

c. Telephone number

This Data can be collected using the following methods:

a. If you submit the online form

Please note that we only collect Personal Data that helps us achieve the purpose of communicating with you as set out in this Privacy Policy. We will not collect additional Personal Data without first informing you.

How We Use Personal Data

Personal Data collected on our site will only be used for the purposes specified in this Policy or indicated on the relevant pages of our site. We will not use your Personal Data beyond what we disclose.

The Personal Data we collect when a user of the site performs certain functions may be used for the following purposes:

ØCommunication

Who Has Access to Personal Data

Employees

We may disclose to any member or related affiliate of our organization the user Personal Data that the member or affiliate reasonably needs to fulfill the purposes set out in this Policy.

Restricted Third Parties

Third parties will not be able to access user Personal Data beyond what is reasonably necessary to achieve the given purpose. In order to carry out our operations, we retain certain third-party service providers or agents to provide services to us, including information technology services. To the extent that these service providers have access to your Personal Data, they are obligated by us, including during and following conclusion of a written agreement, to protect your Personal Data to a level of security similar to that which we provide.

Other Disclosures

OrthoPediatrics Canada will not sell your Personal Data. We also will not share your Personal Data with third parties, except in the following cases:

a. if required by law

b. if it is required for any legal proceedings

c. to prove or protect our legal rights

d. to buyers or potential buyers of our company in the event that we seek to sell the company

If you follow hyperlinks from our site to another site, please note that we are not responsible for, and have no control over, their privacy policies and practices.

How Long We Keep Personal Data

We do not retain user Personal Data beyond what is necessary to fulfill the purposes for which it is collected and for the length of time necessary to comply with our contractual and legal obligations, resolve disputes, or enforce our agreements. When the purpose of collecting your Personal Data is achieved, it will be securely destroyed, permanently anonymized, or de-identified to the extent required by applicable privacy laws.

How We Protect Your Personal Data

OrthoPediatrics Canada has established appropriate physical, technical, organizational, and administrative safeguards to protect the Personal Data we collect from or about users of our site, including facility access control and workstation security.

We perform daily backups of all data which is stored using the latest encryption standards and accessible only by authorized employees who must be authenticated using a username and password reinforced by use of two-factor authentication (2FA).

While we take all reasonable precautions to ensure that user Personal Data is secure and that users are protected, there is always a risk of harm. The Internet as a whole can be, at times, insecure and therefore we are unable to guarantee the security of user data beyond what is reasonably practical.

Transfer Outside of Quebec

Data collected in the Province of Quebec has the possibility of being held, communicated, or used outside of the Province of Quebec. Consequently, Personal Data may be subject to the laws of those countries, including any law permitting governmental authorities to access it. Subject to these foreign laws, to the extent Personal Data is transferred outside of the Province of Quebec, we will assess and ensure, to the best of our ability, adequate protections are in place for Personal Data in accordance with generally recognized principals of privacy at least equivalent to those employed in Quebec.

Your Rights as a User

As a user of our site, you have the right to control your Personal Data. This means that you have important rights in relation to your information held by our organization, including:

a. Right of Access: You have the right to know what Personal Data about you has been stored by our company.

b. Right to Change: If the Personal Data we have collected about you is inaccurate or incomplete, you have the right to request that it be amended or updated.

c. Right to Deletion: You also have the right to request the deletion of your Personal Data if you believe that it is no longer necessary for the purposes for which it was collected or if you revoke your consent.

d. Right to anonymization: If you no longer want your Personal Data to be associated with your identity, you can request the anonymization of this Personal Data. This means that your information will be irreversibly anonymized, making it unusable to identify you.

You may choose to withdraw or change your consent to the collection and use of Personal Data at any time, provided that it is legally acceptable to do so and that you have notified us within a reasonable period of time.

How to Change, Delete, or Dispute the Personal Data Collected

If you would like to have your Personal Data deleted or amended in any way, please contact our Privacy Officer:

Enrique Garcia-Belenguer, VP Operations, GM

1111, Autoroute Chomedey, Laval (QC) Canada H7W 5J8

Phone: 1 450 688-5144 ext. 242

Email: egarcia@orthopediatrics.ca

Modifications

This Privacy Policy may be amended from time to time in order to maintain compliance with the law and to reflect any changes to our data collection process. We recommend that users of our site check our policy from time to time to ensure that they are aware of any updates. If necessary, we may notify users by email of changes to this Policy.

Contact

If you have any questions, please do not hesitate to contact us using the following:

OrthoPediatrics Canada ULC.

1111, Autoroute Chomedey, Laval (QC) Canada H7W 5J8

Toll free: 1 877 739-5175

Phone: 1 450 688-5144