Online Privacy Policy

Last Updated: May 2024

IF YOU ARE EXPERIENCING A MEDICAL EMERGENCY, CALL 911

Tactile Medical understands the importance of your privacy and takes our responsibility to protect your information seriously. This Privacy Policy (the “Policy”) describes the types of information we collect from you through your access and use of the Tactile Medical website, distributor portal, or other online pages or apps (collectively referred to as, the “Site”). This Policy also describes how we use and disclose this information, and certain rights and options you have regarding your information.

By providing us with personal information or using the Site, you expressly consent to the information-handling practices described in this Policy. If you do not agree with this Policy, please do not use the Site or provide us with your information.

Patient Records

This Policy is in addition to, and does not replace, any Notice of Privacy Practices that you received from Tactile Medical and that describes how Tactile Medical uses and discloses patients’ protected health information (“PHI”) under the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”). To the extent of a conflict between the terms of this Policy and the Notice of Privacy Practices with respect to PHI, the Notice of Privacy Practices will control how Tactile Medical uses and discloses your PHI. Please review Tactile Medical’s Notice of Privacy Practices for complete information on the use and release of PHI. Speak with Tactile Medical about any concerns you may have regarding your medical records.

Important Information About This Policy

While we always aim to provide complete and transparent information about how we process your personal information, we reserve the right to amend or update this Policy from time to time, or to create additional policies, in order to accurately reflect changed circumstances or new legal requirements. As a result, it is important that you read this Policy closely so that you are fully aware of how and why we use your personal information.

To assist us in ensuring that we can provide the most accurate information possible, we ask that you check this Policy for updates. If we have an ongoing relationship with you and any of the information you have provided is no longer accurate, you keep us informed of this so we can update our records.

Personal Information We May Collect or Receive About You

For the purposes of this Policy, “personal information” is any information that identifies, relates to, or can be used to contact a particular individual.

The types of personal information we may collect includes the following categories:

Contact information – first name, last name, email address (business or personal), mailing address (business or personal), and telephone number (business or personal). If you are a clinician or distributor user, we may also collect your employment information (e.g., job title, supervisor, etc.).
Account information – if you are a user of any of our portals, including distributor portal, your Tactile Medical application username, account password, account number, and other information we may request or you may provide relating to your account.
Marketing information – details of your marketing and communications preferences, including whether or not you have opted out of marketing emails, texts, calls, or similar communications.
Communication information – details of any communications or inquiries you submit to us, including technical or customer support requests, through email, calls, texts, chatbots or similar software tools, or other features available within our Site.
Device and usage information – details regarding how and when you use our Site, including the device used to connect to our application, your internet protocol (“IP”) address and device identifier (including ad ID), the frequency and duration of your usage, the pages you view, and information about your interaction with our Site.

We collect this information when you access, use, or navigate the Site, complete forms when presented to you, request information via our Site, communicate with us or a representative (including by phone, email, text, chat, or otherwise), interact with any chatbot or similar features available within our Site, participate in surveys or sponsored activities, access and use any of our portals, including distributor portals, or otherwise provide us with personal information.

If you are a patient or prospective patient, the collection of PHI, and your rights with respect to such information, is described in further detail in Tactile Medical’s Notice of Privacy Practices. Please contact Tactile Medical with any questions related to its use and disclosure of your PHI.

Please note that we may aggregate or anonymize the foregoing types of data such that they are no longer capable of identifying you, in which case they are no longer considered “personal information” for the purposes of this Policy.

Automatically Collected Usage and Device Information

Like most website operators, we use various technologies to automatically collect the following types of information about you:

Cookies. Cookies are small text files that a website transfers to a visitor’s device for recordkeeping purposes. We use cookies to personalize visitors’ experiences on our website, provide content that we believe may be of interest, track visitor trends and patterns, and otherwise analyze our website traffic. Tactile Medical employs cookies in order for its servers to recognize a return visitor as a unique user. The cookies placed by Tactile Medical cannot access, read, or modify any other data on a computer. Web browsers may offer the option to refuse cookies. If a visitor refuses a Tactile Medical cookie, Tactile Medical does not gather any information on that visitor, but doing so will require you to re-enter certain information at each visit, or prevent us from customizing the website’s features according to your preferences. You may also delete a cookie manually from your hard drive. We may link the information we store in cookies to other personal information we collect or receive about you. For further information about cookies, including how to refuse cookies, please visit www.allaboutcookies.org. Please note that if cookies are disabled, you may not be able to enjoy certain features of our website.
Pixels, tags, and web beacons. Tactile Medical’s website may also use “pixels,” “tags,” or “web beacons.” These technologies are small pieces of code that run when a website/application page or email is loaded. They are used to monitor the behavior of the visitor or email recipient—such as what icons were clicked or whether links in an email were opened—and gather analytics. For example, when you open the Tactile Medical homepage, a pixel may run and generate information based on the visit, and then this information is processed by us or our vendors. Pixels work in conjunction with cookies to let us know what portions of our Site are of interest to you and to help us provide you with tailored information from our Site. If you turn off cookies, pixels, tags, and web beacons may still detect certain information about your interaction with our Site and disregard any cookie-prohibitive markers or signals. Note, the vendors that supply us these pixels, tags, web beacons, cookies, or similar tracking technologies collect your personal information instantaneously and simultaneous to Tactile Medical’s collection of such information.
Log file information. Log file information is automatically collected from your browser or your device each time you access Tactile Medical’s Site. When you use our Site, our servers automatically record certain log file information. These server logs may include anonymous information such as your web request, device type, operating system type, IP address, mobile device identifier provided by your mobile device operating system, browser type, domain name, pages viewed, referring / exit pages and URLs, open and click engagement, as well as the language your system uses and the country and time zone where your device is located. Log file information is used for security purposes (i.e., to prevent fraud) and product improvement purposes.

The information collected through these technologies may be combined with other personal information.

Information from Other Sources

We may obtain both personal and non-personal information about you from our institutional partners, distributors, and service providers, and add it to other information we have collected. For example, if you are a patient using one of our products, we may receive information about you from your healthcare providers or from our distributors. We, and the third parties we engage, may combine information we collect from you over time, and across our website, with information obtained from other sources. This helps us improve the information’s overall accuracy and completeness, and also helps us better tailor our interactions with you.

How We Use Your Information

We (or the service providers acting on our behalf) use the personal information identified above for the following purposes:

Providing our Site, including our distributor portal.
Sending patients and other users of our Site communications about the Site.
Facilitating the ability for providers to provide care to patients, including assisting those providers with creating medical records and administering patient care.
Negotiating, entering into, and managing our business relationship and agreements with our distribution partners and vendors.
Communicating with you, including responding to your inquiries or questions regarding any issues you are experiencing.
Managing customer service issues, including issues relating to the performance of our Site, and product feedback.
Troubleshooting and resolving any technical issues with our Site.
Developing, updating, and improving our Site, patient experience, and otherwise improving our knowledge and insights regarding users.
Preventing and detecting fraud, financial crime, hacking activities, security breaches, and other unlawful activities in connection with the use of our Site.
Enforcing our agreements with you or our distribution partners, complying with our legal or regulatory obligations, and defending or advancing legal claims.
Notifying you about changes to our Site or material changes to this Policy.
Providing you with surveys or otherwise soliciting feedback from you.
Performing other functions as otherwise described to you at the time of collection or to which you otherwise consent.

For more information about your options relating to your personal information and your communication preferences, see “Your Choices About Collection and Use of Your Information” below.

Disclosure of Your Information

When the information we collect is aggregated, anonymized, or otherwise does not identify you, it is no longer considered “personal information.” We may use such information for any purpose or disclose it to third parties, to the extent permitted by applicable law.

In addition, we may disclose your information to the following types of persons:

Those of our affiliates and related entities with whom we partner to provide the Site or who may have services that are of interest to you.
Service providers we use to facilitate our business operations and administer our Site. These third parties have access to your personal information only to perform specific tasks on our behalf. For example, our service providers include (i) IT and system administration providers, (ii) our website developers and consultants, and (iii) data storage providers.
If you are using our Site as a study participant, your healthcare provider or health plan and their personnel, staff, and third-party service providers.
Analytics vendors in order to understand our Site traffic and usage patterns and optimize our Site.
Regulatory and governmental authorities, law enforcement agencies, and courts, as necessary to comply with applicable laws and regulations, respond to a subpoena, search warrant, or other lawful request for information, or to otherwise protect our rights.
Our professional advisors, such as lawyers, accountants, and other similar advisors.
Buyers or other successors prior to or in the event of a merger, acquisition, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as a part of bankruptcy, liquidation, or similar proceeding, where the information is among the assets being transferred.
Other parties for any purpose we disclose at the time you provide the information.

Protection of Personal Information

We use administrative, technical, and physical measures to protect your personal information from loss, theft, or unauthorized use, disclosure, or modification. Please be aware that no data transmission over the Internet is 100% secure. While we strive to protect your personal information, we cannot ensure or warranty the security of any information you transmit to us, and you do so at your own risk.

Your Choices About Collection and Use of Your Information

We respect your right to make choices about the ways we collect, use, and disclose your information, so we try to offer you meaningful choices regarding your personal information. Some choices you have regarding personal information include the following:

Cookies – Depending on your browser or device, you may have the option to set the browser to accept all cookies, reject all cookies, notify you when a cookie is set, or delete cookies. Each browser and device are different, so we recommend you evaluate the tools and settings available in your browser or device, as well as any available instructions for the same. Please note that if you disable or delete cookies, you may not be able to access or use certain features of the Site.
Declining to Provide Information – You can choose not to provide us with information we may request through our Site, but that may result in you being unable to use certain features of our Site, request information about our Site, or initiate other transactions with us.
Marketing preferences – You can opt-out of receiving marketing communications by using the “unsubscribe” or similar link in the email you received, or by replying “STOP” to any text message. You can also contact us at the information below to indicate your marketing preferences.
Do Not Track Mechanisms – Please note that our website does not honor “Do Not Track” signals, and such signals will not impact the operation of the website.

In addition to the above, you may contact us using the details provided at the end of this Policy with any questions about the choices relating to your personal information.

Children’s Privacy

Our Site is a general audience site and is not directed at children under the age of 13. Accordingly, we do not knowingly collect personal information from children under age 13 through our websites or applications. Should we discover that a child under age 13 provided us with personal information, we will use that information only to inform the child that we must have parental consent before receiving such information.

Direct Access to Other Sites

Tactile Medical offers direct links to other websites that are independent of Tactile Medical’s Site. Other websites may not follow the same privacy guidelines as Tactile Medical. We are not responsible for and have no control over the content, acts, or privacy policies of the websites to which Tactile Medical provides direct links. A link to a website does not constitute an endorsement of that website or the entity that controls the website.

Changes to This Privacy Policy

This Policy may be revised from time to time as we add new features and services, as laws change, and as industry privacy and security best practices evolve. If there are changes to our Policy, we will post them here and update the “Last Updated” date at the top of this document. Continued use of the Site after any changes is deemed to be acceptance of those changes. Accordingly, we encourage you to check this Policy periodically for updates.

How to Contact Us

If there are any questions regarding this Privacy Policy, you may contact us using the information below.
Tactile Medical
Phone: 1.833.382.2845 ext. 55211
Email: compliance@tactilemedical.com
Website: https://tactilemedical.com/contact-us/