California Privacy Statement

Effective Date: TBD

Introduction

This Privacy Notice for California Residents (“Notice”) explains the privacy practices of VB Spine and its affiliates and subsidiaries (collectively, “VB Spine,” “we,” “our,” or “us”) in connection with the personal information we collect about California residents and households (“you” or “Consumers”).

This Notice applies to all personal information VB Spine collects when you interact with us—for example, when you visit our websites, use or purchase our products or services, contact customer service, or interact with us as a business customer, supplier, or partner (collectively, the “Services”).

This Notice supplements our general Privacy Statement, except where noted in the rights section below.

Overview

We want to help you understand how we handle your information. Here’s a high-level summary:

What personal information do we collect?
We collect categories such as identifiers, inferences, customer records, protected characteristics, online activity, geolocation data, biometric information, professional details, sensory data, and sensitive personal information. More detail is provided below.

How do we use your information?
We use your information to communicate with you, operate and improve our business and Services, and meet legal requirements.

Do we sell or share your information?
We may “sell” or “share” information as defined under California law in limited situations. For example, if you opt in to targeting cookies, partners may collect limited data to provide more relevant advertising.

How long do we keep your information?
We retain information based on our retention policies unless a longer period is required by law or contract.

Collection and Use of Information

We collect information that identifies, relates to, describes, or could reasonably be linked to you (“personal information”).

In the last 12 months, VB Spine collected the following categories:

Identifiers: such as name, contact details, income level, government ID, and demographic information
Inferences: insights based on your preferences or behavior
Customer Records: contact details, transaction history, payment information, and government ID
Protected Characteristics: such as age or criminal background history
Online Activity: browsing history and interaction with our systems and websites
Geolocation Data: general location information
Professional Information: employer, work history, qualifications
Sensory Data: photos, videos, and audio recordings
Sensitive Personal Information: health data, login credentials, payment details, and precise location

Sources of Information

We collect personal information from:

From you:
Information you provide directly, such as when you register, contact us, or submit forms, emails, or content.

From your devices:
Information collected automatically when you use our services, including IP address, device type, browser type, operating system, and usage behavior. We use cookies and similar technologies. See our Cookie Disclosure for more details.

From third parties:
We may receive information from vendors, analytics providers, advertisers, and social media platforms, depending on your privacy settings with those services.

How We Use Information

We may use your personal information to:

Deliver products and services
Activate or register products and services
Send product and service information
Customize content and advertising
Support online communities and social media engagement
Store preferences for future interactions
Improve products, services, and websites
Develop new offerings and customer experiences
Resolve issues and provide support
Register visitors at events or facilities
Fulfill contracts and agreements
Send personalized offers and marketing messages
Comply with legal and regulatory obligations

We do not use sensitive personal information for purposes outside those permitted under California law.

Disclosure of Information

We have not disclosed personal information to third parties for business purposes in the last 12 months as defined by California law. However, we may share information in the following situations:

With your consent: when you authorize it
Within our corporate group: affiliates and subsidiaries for operations and service delivery
With service providers: such as hosting, customer support, fulfillment, and communications providers
To comply with law or protect rights: including legal requests or safety concerns
Business transfers: in mergers, acquisitions, reorganizations, or asset sales
De-identified or aggregated data: information that cannot identify you
Advertising partners: for personalized advertising based on your activity

We do not sell personal information for money. However, we may “share” information for targeted advertising if you opt in to cookies. In the last 12 months, this involved internet or electronic activity data.

You may opt out of this sharing, including through browser-based opt-out preference signals. We honor recognized signals for the browser where they are enabled.

We do not knowingly sell or share personal information of individuals under 16 years old.

Your Rights and Choices

California residents have the following rights:

Right to know: request details about personal information we collect and use
Right to opt out: request that we do not sell or share your personal information
Right to correct: request correction of inaccurate information
Right to delete: request deletion of personal information, subject to exceptions
Right to non-discrimination: you will not be treated unfairly for exercising your rights

To exercise these rights, contact us at globalprivacy@vbspineco.com . Authorized agents may also submit requests with proper verification.

We will verify requests by confirming identity using information we already have on file. If needed, we may request additional details.

Updates to This Notice

VB Spine may update this Notice at any time. When changes are made, we will post the revised version and update the effective date. Continued use of our Services means you accept the updated Notice.

Last updated: TBD