CrossRoads Extremity Systems®
Privacy Policy

Effective Date: December 1, 2021

Last Updated: November 15, 2021

1. Introduction

CrossRoads Extremity Systems, LLC (“CrossRoads,” “we,” “us,” or “our”) oversees this the website, minibunion.com (“Site”) and all related services (collectively, our “Services”). We have developed this Privacy Policy to inform all users (“user(s),” “you,” or “your”) about how we collect information in the course of conducting our business, including on the Site, how we use the collected information, and a user’s rights with respect to the collected information.

Please read this Privacy Policy carefully. If you do not agree to be bound by this Privacy Policy, then do not access or use the Services. By accessing and/or using the Services, you accept and agree to be bound by this Privacy Policy. This Privacy Policy is incorporated into our Terms of Use. Your use of our Services and any Personal Information (as hereafter defined) you provide through the Services are subject to this Privacy Policy at all times.

You must be at least EIGHTEEN (18) years old to access the Site and use our services. If you are under eighteen (18) years old, you are not permitted to use any part of the Services for any reason.

If you have any questions about this Privacy Policy, please contact us at patientsupport@crextremity.com or at the contact information below.

2. Information We Collect

When you use the Site, we process certain types of Information, as described below.

a. Personal Information

“Personal Information” means any information that identifies, relates to, describes, or is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal Information that we collect on the Site includes, but is not limited to, first and last names, email address, phone number, and any other information you may choose to provide.

When you access or use the Services, you may provide Personal Information to CrossRoads, such as when you request to receive information, support, or a consultation; communicate with us or our representatives, whether through our website, live chat form, email, telephone, or standard mail.

b. Non-Personal Information

“Non-Personal Information” means information that does not identify you, but provides insights regarding your use of the Site. For example, we collect information about your use of the Site, including but not limited to, the number of visitors to the Site, the time spent on the Site and pages clicked, the types of devices used to access the Site, and the Internet Protocol (IP) addresses of visitors. We may use automated information collection tools, such as cookies and pixels, to collect certain types of Non-Personal Information. You can set your browser to reject cookies, but that may limit your use of some features of the Platform.

Personal Information and Non-Personal Information are collectively referenced as “Information.” Information we collect about you may be aggregated with other users’ Information. It may also be combined with associated Personal Information that you provide to us or that we receive from third parties. If we combine or associate information from other sources with Personal Information that we collect through the Site, we will treat the combined Information as Personal Information in accordance with this Policy.

c. Third-Party Social Networking Service(s)

If you choose to access, visit, and/or use any third-party social networking service(s) that may be integrated with our Site, we may receive your Personal Information and other information about you and your computer, mobile, or other device that you have made available to those social networking services, including information about your contacts through those services. For example, some social networking services allow you to push content from our Site to your contacts or to pull information about your contacts so you can connect with them on or through our Site. Some social networking services also will facilitate registration or enhance or personalize your experience on our Site. Your decision to use a social networking service in connection with our Site is voluntary. However, you should make sure you are comfortable with the information your third-party social networking services may make available by reviewing privacy policies of those providers and/or modifying your privacy settings directly with those networking sites/services.

3. Use of Information

We use Non-Personal Information collected by cookies, web beacons, and other Internet tracking technology to store your preferences, improve website navigation, make personalized features and other services available to you, to generate statistical information, monitor and analyze user traffic and usage patterns, monitor and prevent fraud, investigate complaints and potential violations of our policies, to improve the our content and the products, services, materials, and other content that we describe or make available through the Services, and otherwise help administer and improve the Services.

We may identify you from your Personal Information and merge or co-mingle Personal Information and Non-Personal Information. Except as otherwise stated, CrossRoads may use Information we collect from you for the legitimate business purpose of providing our Services to you, including, but not limited to:

To fulfill or meet the reason you provided the Personal Information. For example, if you share your name and contact information to ask a question about our Services, we will use that Personal Information to respond to your inquiry.
To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
To provide, support, personalize, and develop our Services, including without limitation, to conduct aggregate or research analysis and develop business intelligence that helps us to enhance, improve, evaluate, operate, protect, make informed decisions about, and report on the performance of our Services.
To communicate information and promotional materials to you, where you have not expressed a preference otherwise, and to send you information and updates about the Services.
To notify you of any changes to relevant agreements, policies, or other terms, and to enforce such terms.
To work with our service providers, who perform certain business functions or services on our behalf.
To prevent or investigate fraud, or for risk management purposes, and to help maintain the safety, security, and integrity of our Services, databases and other technology assets, and business.
To comply with legal obligations, court orders, or in order to exercise any legal claim or to defend against any legal claim.
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.
As otherwise described to you when collecting your Personal Information.

In addition, we may use third‐party e‐mail providers to deliver communications to you. This is an opt-in e-mail program. If you no longer want to receive these e-mail communications, you may opt-out of receiving e-mail communications through the “unsubscribe” link or by contacting us patientsupport@crextremity.com.

We may, from time to time, invite you to participate in online surveys. The information requested in these surveys may include, but is not limited to, your opinions, beliefs, insights, ideas, activities, experience, purchase history, and purchase intent regarding products, events, and Services. The information collected by these surveys is used to research market trends, company growth, community needs, etc. Your input will help us to improve customer experience and shape development of our products and Services.

4. How We Share Information

We may share Personal Information with the following parties:

Corporate affiliates, including corporate parents, subsidiaries, other affiliated entities, and associated entities for the purposes described in this Policy which are required to treat the information in accordance with this Privacy Policy;

Service providers that help us administer and provide the Services (for example, a web hosting company whose services we use to host our platform). These third-party services providers have access to your Personal Information only for the purpose of performing services on our behalf.

Physicians with whom we have a relationship.

Authorized third parties, who are parties directly authorized by you to receive the applicable Information. The use of your Information by an authorized third party is subject to the third party’s privacy policy;

Third parties in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings), in which case we will require the recipient to use such information in accordance with this Privacy Policy;

As we believe necessary: (i) under applicable law; (ii) to enforce applicable terms and conditions; (iii) to protect our rights, privacy, safety or property, and/or that of our affiliates, you, or others; (iv) to detect, prevent, or otherwise address fraud, security or technical issues; (v) to respond to claims that contact information (e.g. name, e-mail address, etc.) of a third-party has been posted or transmitted without their consent or as a form of harassment and (vi) to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include authorities outside your country of residence; and

With another party, pursuant to your express consent.

5. Information Security

We take reasonable steps online and offline to safeguard the Personal Information that you provide to us. However, it is common knowledge that transmission of information via the Internet is not wholly secure, and we cannot guarantee or warrant the security of your Personal Information, or any other information, transmitted to or through our Site or Services or otherwise provided to us. We are not responsible for the theft, destruction, or inadvertent disclosure of such information. It is your responsibility to safeguard any passwords, ID numbers, or other special access features associated with your use of the Service(s). Any transmission of information is at your own risk.

If you have any questions about security on our Services, or if you become aware of or suspect a security breach, notify us immediately via email at patientsupport@crextremity.com. If our security system is breached, we will notify you of the breach to the extent required under applicable law.

6. Information Retention

We retain the Personal Information we receive as described in this Privacy Policy for as long as you use our Site or as necessary to fulfill the purpose(s) for which it was collected, provide our products and services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

7. Links to Third Party Sites

The Site may contain links to other sites that are not operated by us. If you click on a link to another site, you will be directed to that third party’s site. Such links do not constitute an endorsement by us of those other websites, their content or services, or the persons or entities associated with those websites. This Privacy Policy does not apply to third-party websites. We have no control over, and assume no responsibility for, the content, privacy policies, or practices of any third-party sites or services. We encourage you to review the privacy policies and terms of all third-party websites or services that you may visit.

8. Children’s Privacy

We do not sell products or services for purchase by anyone under the age of eighteen (18). Furthermore, in accordance with the Children’s Online Privacy Protection Act (“COPPA”), we will never knowingly request or solicit Personal Information from anyone under the age of thirteen (13) without verifiable parental consent. In the event that we receive actual knowledge that we have collected such Personal Information without the requisite and verifiable parental consent, we will delete that information from our database as quickly as is practical. We reserve the right to request proof of age at any stage so that we can verify that minors are not using the Service(s).

9. Your California Privacy Rights

California Civil Code Section 1798.83 permits California residents to request and obtain a list of what Personal Information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year and the names and addresses of those third parties. Requests may be made only once a year and are free of charge. Under Section 1798.83, California residents are entitled to request and obtain such information, by e-mailing a request to patientsupport@crextremity.com. For more information about your rights as a California Resident, please see our Privacy Notice for California Residents.

10. Changes in the Privacy Policy

We reserve the right to modify and update this Privacy Policy at any time by posting an amended version of the statement on our Site. Please refer to this policy regularly. If at any time we decide to use Personal Information in a manner different from that stated at the time it was collected, we will notify you either on the panel home page of our Site or via e-mail.

11. How to Contact Us

Because protecting your privacy is important to us, you may always submit concerns regarding our Privacy Policy on the contact us page. We will attempt to respond to all reasonable concerns and inquiries expeditiously.

If you have any questions or comments about our Privacy Policy, please contact us at:

Telephone number: 1-800-458-1663
Postal address:
Johnson & Johnson Consumer Care Center
P.O. Box 767
Neenah, WI 54957
Contact Title: Customer Service Representative

US Supplemental Privacy Notice

Last Updated December 14, 2022

This US Supplemental Privacy Notice (“Supplemental Notice”) applies only to information collected about California, Colorado, Virginia, Utah, and Connecticut consumers. It provides information required under the following laws, (collectively, “US State Privacy Laws”):

California Consumer Privacy Act of 2018 and California Privacy Rights Act of 2020 (collectively, the “CPRA”)
Colorado Privacy Act of 2021 (the “CPA”)
Connecticut Data Privacy Act (“CTDPA”)
Utah Consumer Privacy Act of 2022 (the “UCPA”)
Virginia Consumer Data Protection Act of 2021 (the “VCDPA”)

We also provide information collected about Nevada consumers under the heading “Privacy Notice for Nevada Residents” at the end of this Supplemental Notice. The other portions of this Supplemental Notice do not apply to Nevada consumers.

This Supplemental Notice describes CrossRoads Extremity Systems (“we,” “us,” “our”) practices regarding the collection, use, and disclosure of Personal Information and provides instructions for submitting data subject requests. This Supplemental Notice is parallel in scope to our Global Privacy Policy and should be read in conjunction with our Global Privacy Policy.

Some portions of this Supplemental Notice apply only to consumers of particular states. In those instances, we have indicated that such language applies only to those consumers.

A. Definitions

“Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal Information includes “personal data” as that term is defined in the applicable US State Privacy Law. Personal Information also includes “Sensitive Personal Information,” as defined below, except where otherwise noted.
“Sensitive Personal Information” means Personal Information that reveals a consumer’s social security, driver’s license, state identification card, or passport number; account log-in, financial account number, debit card number, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; precise geolocation; racial or ethnic origin, religious beliefs, or union membership; contents of email or text messages; and genetic data. Sensitive Personal Information also includes processing of biometric information for the purpose of uniquely identifying a consumer and Personal Information collected and analyzed concerning a consumer’s health, sex life, or sexual orientation. Sensitive Personal Information also includes “sensitive data” as that term is defined in the applicable US State Privacy Law.
“Third Party” has the meanings afforded to it in the applicable US State Privacy Law.
“Vendor” means a service provider, contractor, or processor as those terms are defined in the applicable US State Privacy Law.

To the extent other terms used in this Supplemental Notice are defined terms under the applicable US State Privacy Law, they shall have the meanings afforded to them in those statutes, whether or not capitalized herein. As there are some variations between such definitions in each of the state statutes, the definitions applicable to you are those provided in the statute for the state in which you are a consumer. For example, if you are a Virginia consumer, terms used in this Supplemental Notice that are defined terms in the VCDPA shall have the meanings afforded to them in the VCDPA as this Supplemental Notice applies to you.

B. Collection & Processing of Personal Information

We, and our Vendors, may have collected and processed the following categories of Personal Information about you in the preceding 12 months:

Identifiers, such as name, alias, online identifiers, account name, physical characteristics or description;
Contact and financial information, including phone number, address, email address, financial information, medical information, health insurance information;
Characteristics of protected classifications under state or federal law, such as age, gender, race, physical or mental health conditions, and marital status;
Commercial information, such as transaction information, payment information, tax withholding information and purchase history;
Biometric information;
Internet or other electronic network activity information, such as browsing history, search history and interactions with our websites or advertisements;
Geolocation data, such as device location;
Audio, electronic, visual and similar information, such as call and video recordings;
Professional or employment-related information, such as specialty, education history, professional qualifications, work history and prior employer;
Inferences drawn from any of the Personal Information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics; and
Sensitive personal information, including:
1. Personal Information that reveals:
  1. Social security, driver’s license, state identification card, or passport number;
  2. Account log-in, financial account number, debit card number, or credit card number in combination with any required security or access code, password, or credentials for allowing access to an account;
  3. Precise geolocation;
  4. Racial or ethnic origin, religious or philosophical beliefs, or union membership;
  5. Genetic data.
  6. Biometric data processed for the purpose of uniquely identifying a consumer;
  7. Personal Information collected and analyzed concerning a consumer’s health; and
  8. Personal Information collected and analyzed concerning a consumer’s sex life or sexual orientation.
Retention of Personal Information. We retain your Personal Information for the period reasonably necessary to provide goods and services to you and for the period reasonably necessary to support our business operational purposes listed in Section E.

C. Categories of Personal Information We Disclose to Vendors & Third Parties

We may disclose the following categories of Personal Information to Vendors and Third Parties:

G. Data Subject Rights

Exercising Data Subject Rights. California, Colorado, Virginia Utah, and Connecticut consumers have certain rights with respect to the collection and use of their Personal Information. Those rights vary by state. As required by the CPRA, we provide detailed information below regarding the data subject rights available to California consumers. Colorado, Virginia, Utah, and Connecticut consumers have similar rights and can find more detail by referencing the applicable US State Privacy Law. You may exercise the data subject rights applicable to you under the applicable US State Privacy Law by clicking here or contacting us at 1-800-458-1663. While we will make reasonable efforts to accommodate your request, we reserve the right to impose certain restrictions or requirements on your request, if allowed by or required by applicable law. Consumers in some states may also authorize an agent to make data subject requests on their behalf.
Verification of Data Subject Requests. We may ask you to provide information that will enable us to verify your identity in order to comply with your data subject request. In particular, when a California or Connecticut consumer authorizes an agent to make a request on their behalf, we may require the agent to provide proof of signed permission from the consumer to submit the request, or we may require the consumer to verify their own identity to us or confirm with us that they provided the agent with permission to submit the request. In some instances, we may decline to honor your request if an exception applies under applicable law. We will respond to your request consistent with applicable law.
Non-Discrimination. We will not discriminate against you for exercising your data subject rights. For example, we will not deny goods or services to you, or charge you different prices or rates, or provide a different level of quality for products or services as a result of you exercising your data subject rights.
Appeals To appeal our decision on your data subject requests, you may click here. Please enclose a copy of or otherwise specifically reference our decision on your data subject request, so that we may adequately address your appeal. We will respond to your appeal in accordance with applicable law.
Data Subject Rights Disclosure
- Right to Receive Information on Privacy Practices: You have the right to receive the following information at or before the point of collection:
  - The categories of Personal Information to be collected;
  - The purposes for which the categories of Personal Information are collected or used;
  - Whether or not that Personal Information is sold or shared;
  - If the business collects Sensitive Personal Information, the categories of Sensitive Personal Information to be collected, the purposes for which it is collected or used, and whether that information is sold or shared; and
  - The length of time the business intends to retain each category of Personal Information, or if that is not possible, the criteria used to determine that period.
  We have provided such information in this Supplemental Notice, and you may request further information about our privacy practices by clicking here or contacting us at 1-800-458-1663.
- Right to Deletion: You may request that we delete any Personal Information about you that we collected from you.
- Right to Correction: You may request that we correct any inaccurate Personal Information we maintain about you.
- Right to Know: You may request that we provide you with the following information about how we have handled your Personal Information in the 12 months preceding your request:
  - The categories of Personal Information we collected about you;
  - The categories of sources from which we collected such Personal Information;
  - The business or commercial purpose for collecting Personal Information about you;
  - The categories of Personal Information about you that we shared or disclosed and the categories of Third Parties with whom we shared or disclosed such Personal Information; and
  - The specific pieces of Personal Information we have collected about you.
- Right to Receive Information About Onward Disclosures: You may request that we disclose to you:
  - The categories of Personal Information that we have collected about you;
  - The categories of Personal Information that we have sold or shared about you and the categories of Third Parties to whom the Personal Information was sold or shared; and
  - The categories of Personal Information we have disclosed about you for a business purpose and the categories of persons to whom it was disclosed for a business purpose.
- Right to Non-Discrimination: You have the right not to be discriminated against for exercising your data subject rights. We will not discriminate against you for exercising your data subject rights.
- Right to Restrict or Limit the Use of Sensitive Personal Information: You have the right to restrict the use and disclosure of sensitive personal information to certain purposes related to the offering of goods or services as listed in the CPRA. To exercise this right, you or your authorized representative may submit a request by clicking on the following link: Limit the Use of My Sensitive Personal Information
- Right to Opt Out of Sharing, Disclosure, or Sale of Personal Information: You have the right to direct us to not share, disclose, or sell your personal information. To exercise this right, you or your authorized representative may submit a request by clicking on the following link: Do Not Sell or Share My Personal Information
H. Other Disclosures
- California Residents Under Age 18. If you are a resident of California under the age of 18 and a registered user of our website, you may ask us to remove content or data that you have posted to the website by clicking here or contacting us at1-800-458-1663. Please note that your request does not ensure complete or comprehensive removal of the content or data, as, for example, some of your content or data may have been reposted by another user.
- Disclosure About Direct Marketing for California Residents. California Civil Code § 1798.83 permits California residents to annually request certain information regarding our disclosure of Personal Information to other entities for their direct marketing purposes in the preceding calendar year. We do not distribute your Personal Information to other entities for their own direct marketing purposes.
- Financial Incentives for California Consumers. We offer various types of financial incentives in exchange for your personal information, such as coupons, discounts, promotions, loyalty points, sweepstakes, contests, surveys, and other exclusive offers for California consumers who sign up to receive our marketing emails or join our loyalty program. The amount and terms of such offers will be presented to you at the time of the offer. When you participate in a financial incentive, we collect personal information from you, such as identifiers (like your email address) and commercial information (like your purchase history). Solely for purposes of California privacy law, we reasonably estimate the value of the discount, coupon, or other financial incentive that we offer to you to be equal to or greater than the value we receive from a consumer’s personal information collected in connection with the offer. We reasonably estimate the value of a consumer’s data by estimating the expenses related to the provision of each incentive program per consumer. We incur a variety of expenses for providing financial incentives, such as administrative and technical expenses associated with maintaining a loyalty program and costs associated with discounts on purchases. Participation in our financial incentives is voluntary. You may opt into a financial incentive by following the sign-up or participation instructions provided, and you have the ability to opt out by unsubscribing from our emails or closing your loyalty member account.
- Changes to our Supplemental Notice. We reserve the right to amend this Supplemental Notice at our discretion and at any time. When we make material changes to this Supplemental Notice, we will notify you by posting an updated Supplemental Notice on our website and listing the effective date of such updates.
PRIVACY NOTICE FOR NEVADA RESIDENTS

Effective: December 14, 2022

This Privacy Notice for Nevada Residents adds to the information contained in the Johnson & Johnson Global Privacy Policy, and applies only to Nevada residents (“You,” “your” or “consumer”).

Personal Information Collection and Purposes of Use

We collect certain personal information of Nevada consumers through our Internet websites or other online service. This information includes one or more of the following elements of personally identifiable information:

1. A first and last name.

2. A home or other physical address that includes the name of a street and the name

of a city or town.

3. An electronic mail address.

4. A telephone number.

5. A Social Security Number.

6. An identifier that allows a specific person to be contacted either physically or online.

7. Any other information concerning a person collected from the person through the

Internet website or online service of the operator, and maintained by the operator in combination with an identifier in a form that makes the information personally identifiable.

We collect this personal information for the following purposes:
- to respond to your inquiries and to fulfill your requests;
- to send you important information regarding our relationship with you or regarding this website, changes to our terms, conditions, and policies and/or other administrative information;
- for audits, to verify that our internal processes function as intended and are compliant with legal, regulatory, or contractual requirements;
- for fraud or crime prevention, and for technical security monitoring purposes;
- to facilitate the development of new products and services;
- to enhance, improve or modify our website or products and services;
- for data analysis that will allow us to understand website usage trends;
- to determine the effectiveness of our promotional campaigns, so that we can adapt our campaigns to the needs and interests of our users.
- to better understand you, so that we can personalize our interactions with you and provide you with information and/or offers tailored to your interests.
Your Privacy Rights

Right to access and/or correct your personal information, or opt out of sale of personal information

If you would like to review, correct, or update your personal information, you or your authorized representative may submit your request by clicking here. We will respond to your verified request as soon as reasonably practicable, but no later than sixty (60) days after receipt. If circumstances cause any delay in our response, you will be promptly notified and provided a date for our response.

We generally do not disclose or share personal information for profit. Under Nevada law, you have the right to direct us to not sell or license your personal information to third parties. To exercise this right, if applicable, you or your authorized representative may submit a request by clicking here. We will respond to your verified request as soon as reasonably practicable, but no later than sixty (60) days after receipt. If circumstances cause any delay in our response, you will be promptly notified and provided a date for our response.

Contact Information

Use the contact form to let us know how we can help you!
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HEADQUARTERS

6423 Shelby View Dr. Suite 101,
Memphis, TN 38134

INFORMATION

Phone: (901) 221-8406

CrossRoads Extremity Systems® Privacy Policy