How we handle your personal information.

This website and the e-mails sent from it are published by MedTechInvest Canada Corp. ("MedTechInvest Canada"), 4789 Yonge St., Suite 805, Toronto, ON M2N 0G3, Canada, the Canadian distributor and importer of FixNip NRI, on behalf of the manufacturer FixNip Ltd., 13 Bareket St., Caesarea Industrial Park, Caesarea 3079544, Israel (company no. 515256428). FixNip Ltd. decides on the purposes of the processing described in this policy; MedTechInvest Canada operates the website and manages the personal information collected through it for all of Canada.

Together they are responsible for this personal information under the Personal Information Protection and Electronic Documents Act (PIPEDA), under the Act respecting the protection of personal information in the private sector of Quebec (Law 25) and under any other privacy law of a Canadian province that applies. In this policy, "we" and "us" refer to both. MedTechInvest Canada is your single point of contact: its Privacy Officer (section 2) handles every question and request, including those concerning FixNip Ltd.

The website is built and operated on our behalf by Huber & Zipse GmbH, Blücherstraße 32, 75177 Pforzheim, Germany, which acts as our service provider and processes personal information only on our documented instructions.

We have designated a person in charge of the protection of personal information (Privacy Officer). You can contact the Privacy Officer for any question, request or complaint about your personal information:

• Title: Privacy Officer, MedTechInvest Canada Corp.
• E-mail: privacy@fixnip.ca
• Mail: MedTechInvest Canada, attention Privacy Officer, 4789 Yonge St., Suite 805, Toronto, ON M2N 0G3, Canada

We answer in writing within 30 days of receiving your request. How we govern personal information internally (roles, retention, complaints, incidents) is described in our privacy governance policy.

This policy applies to personal information collected through this website, its forms, the professional area (surgeon portal, online ordering and FixNip Academy), the e-mails we send and your messages to us. It does not apply to information that your surgeon or clinic collects in the course of your care, to the websites of third parties we link to, or to social media platforms, which have their own policies. It does apply to sign-up forms we hand out on paper at events: they carry the same consent wording, are entered into the same system and are then shredded. It does not cover our own employees or job applicants.

"Personal information" means any information that concerns a natural person and allows that person to be identified, directly or indirectly.

• Accountability: a named Privacy Officer is responsible for compliance, and our service providers are bound by written agreements.
• Purposes first: we state why we collect information before or when we collect it, and we do not use it for other purposes without new consent, unless the law permits or requires it.
• Consent: we ask for express consent whenever information is sensitive or the use would not be expected, and you can withdraw it at any time.
• Minimum collection: each form asks only for what its purpose needs; optional fields are marked.
• Limited use, disclosure and retention: information is used only for its purpose, shared only as described in section 10 and deleted or anonymized when its retention period ends.
• Accuracy: you can correct your information at any time.
• Security: protection measures match the sensitivity of the information (section 13).
• Openness, access and recourse: this policy is public, and you can access your information and challenge our practices (sections 15 and 16).

We collect personal information directly from you through the forms of this site, automatically when you use the site (as described below), and from public registers of the provincial medical colleges when we verify a surgeon's licence. We do not buy personal information and do not collect it from data brokers.

Fields marked as optional can be left empty without any consequence. If you do not provide a required field, the corresponding function (for example the sign-up or the professional account) cannot be provided. No law obliges you to provide personal information to us.

Social media platforms: if you write to us through a social media platform or submit a form offered in an advertisement on such a platform, the platform passes on to us the information you entered there, and we handle it as described for e-mail sign-ups. What the platform itself collects is governed by its own privacy policy. Personal information we hold is never uploaded to a platform to build advertising audiences.

Professional contact details: the work details of surgeons and tattoo artists (name, practice or studio, work address, work phone and e-mail) count as personal information in our hands, because we use them for more than contacting you: verification, orders, certification and, with your consent, the public listing. Licence and certificate numbers are never treated as mere business contact details.

Health information is sensitive. We treat it with the highest level of protection and use it only with express consent or where the law requires it.

• Patients: our forms never ask for medical details, diagnoses or photos. Because the simple fact that you sign up for information about nipple reconstruction could suggest a health context, we treat every patient sign-up as sensitive: it is used only to send you what you asked for, it is never shared with advertising platforms and never used to target advertising. Please do not send us medical details by e-mail; your surgeon is the right person for them.
• Orders placed by surgeons: an order can contain a patient identifier (initials or a code) so that the implant can be traced. This information is encrypted, accessible only to the staff who process orders, used only to process the order and to meet the record-keeping and safety obligations of the Medical Devices Regulations, and shared only with the parties listed in section 10 who need it for those purposes. Where the identifier comes from a health information custodian in Ontario, we are bound by section 49 of the Personal Health Information Protection Act, 2004: we use and disclose it only for the purpose for which your surgeon was permitted to disclose it or to carry out a legal duty, and never more than is reasonably necessary. Equivalent limits apply under the health information laws of other provinces. E-mails travel encrypted between mail servers but are not encrypted end to end, and our delivery provider keeps a copy of each e-mail for 30 days in the United States; for this reason, order e-mails do not contain the patient identifier, which is shown only in the secure staff area.

Where we rely on your consent, we ask for it in clear terms and separately from any other request, and we never pre-tick a checkbox. Consent to e-mails is confirmed by a link we send to your address (double opt-in).

To keep automated and mistyped requests out, every form checks whether the domain of the address can receive e-mail and whether it belongs to a disposable-address service; only the domain is looked up, and nothing is sent to it. We also count each request with its result (for example accepted or filtered), the form, the page and the campaign parameters, without your name, address or message.

You can withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice: use the unsubscribe link in any e-mail, withdraw a locator listing in the portal, or write to the Privacy Officer. Withdrawal does not affect processing that took place before it. If you withdraw consent, we can no longer provide the corresponding function; for example, we stop sending e-mails, or close the professional account. Order records that the law requires us to keep are kept for the required period.

This site loads an advertising pixel and an advertising tag only after you have accepted them in the consent window shown on its public pages, never in the professional or staff area; it uses no third-party analytics and no other technology that identifies you, locates you or builds a profile of you. Otherwise it only stores what the site needs to work: your language choice, your accessibility settings, the campaign parameters of the link you arrived through (for the visit, and for 90 days in your browser so that a later sign-up can be attributed) and, in the professional area, the sign-in session. The full list, with durations, is on the cookies and tracking page.

The advertising measurement (Meta Pixel and Google Ads tag) is switched off by default, is activated only after you have actively accepted it, can be withdrawn at any time through Cookie settings in the footer, and never receives health information, your name or your e-mail address. With your acceptance, our server also sends the same signals (an action such as a sign-up, the page, your connection address, browser information and Meta's browser identifiers) directly to Meta, so that each action is counted once. When you send a form, we record with it whether the consent window was accepted at that moment, so we can show that the tags ran only with your agreement.

Every commercial e-mail identifies the sender, MedTechInvest Canada Corp. on behalf of FixNip Ltd., with a mailing address and a way to contact us, and contains an unsubscribe link that works with one click, without a login or a reply. Unsubscribe requests take effect immediately and in any case within 10 business days. E-mails that only confirm a request you made (for example the confirmation link or a sign-in code) are sent without marketing content. The unsubscribe link in an e-mail stays valid for at least 60 days after the e-mail was sent.

Professional contacts. We may write to surgeons, clinics and tattoo studios at a business address they have published themselves (for example on their website or in a professional directory) or given to us, without a notice that they do not wish to receive commercial messages, and only about matters that concern their professional role. These messages identify us and contain the same unsubscribe link as any other e-mail. We keep a record of where and when we found each address. We do not buy contact lists.

We do not sell, rent or trade personal information, and we do not share it with advertisers or data brokers. We share it only with:

• Service providers that host, operate or send e-mails for this site. They may use the information only to provide their service to us, under written agreements that require confidentiality and security measures at least equivalent to ours. They are listed in the table below.
• FixNip Ltd. (manufacturer, Israel), only the information it needs for order fulfilment, product traceability, complaint handling, incident reporting and recalls, and aggregated statistics that identify no one.
• Health Canada and other authorities where the law requires it, for example for mandatory incident reports or a recall, and to comply with a court order or other legal obligation.
• Without consent, where the law permits it, for example to establish, exercise or defend legal claims, to detect or prevent fraud, or in an emergency that threatens the life, health or security of a person. If we disclose your information in such an emergency, we inform you in writing without delay.
• A successor in the event of a sale, merger or reorganization of our business, including in insolvency proceedings, under an agreement that the information will only be used for the purposes of this policy; you will be informed within a reasonable time after the transaction that it has been completed and that your information was transferred.

Our servers are located in Germany, in the European Union. Personal information may also be processed in Ireland (e-mail sending), in Israel (FixNip Ltd.) and in the United States (e-mail delivery logs; address suggestions if switched on; advertising measurement on our advertising landing page, only after you accept). Our database is hosted in Frankfurt on servers of Amazon Web Services, Inc. and supported by Supabase Pte. Ltd. (Singapore) and Supabase, Inc. (United States); support access may occur from Singapore and the United States, and providers established in the United States may be required by United States authorities to disclose information, wherever it is stored. Information stored outside Canada is subject to the laws of the country where it is held and may be accessible to the courts, law enforcement and national security authorities of that country.

Before personal information of Quebec residents is communicated outside Quebec, we assess whether it will receive adequate protection, in particular in light of generally recognized privacy principles, and we put in place a written agreement that takes the results of that assessment into account.

We keep personal information only as long as its purpose requires or the law obliges us to, then destroy it or anonymize it irreversibly. An automated daily routine applies the short periods; long-term records such as orders are reviewed and deleted in a documented annual review.

Information that has been anonymized irreversibly, so that it no longer allows anyone to be identified directly or indirectly, is no longer personal information. We may use it for serious and legitimate purposes such as improving the site and aggregated reporting to FixNip Ltd., in accordance with generally accepted best practices and with the criteria of Quebec's Regulation respecting the anonymization of personal information: the process is supervised by a competent person, preceded and followed by an analysis of the risk of re-identification, re-assessed periodically and recorded in a register.

• All connections to the site are encrypted (HTTPS with HSTS).
• Licence numbers and patient identifiers are stored encrypted; comparisons use keyed hashes, so the clear value is not needed. Order e-mails do not contain the patient identifier.
• Staff access requires a personal account with a second authentication factor and is limited to the roles that need it.
• Every view, export and change of personal information is written to an access log that cannot be edited.
• The site applies a strict content security policy and loads no third-party scripts for tracking.
• Our service providers are bound by confidentiality and security obligations, and backups are encrypted.

No method of transmission or storage is completely free of risk. We review our measures regularly and adapt them to the sensitivity of the information.

If personal information is lost, accessed or disclosed without authorization, we take reasonable measures to reduce the risk of harm and prevent a recurrence, record the incident in our register, and, where the incident presents a real risk of significant harm (PIPEDA) or a risk of serious injury (Law 25), notify the persons concerned, the Office of the Privacy Commissioner of Canada and, where their law applies, the Commission d'accès à l'information du Québec or another provincial commissioner, as soon as feasible.

Subject to the exceptions provided by law, you have the right to:

• be informed whether we hold personal information about you, and access it;
• have it corrected if it is inaccurate, incomplete or ambiguous;
• withdraw your consent (section 7);
• ask us to delete it, or to stop disseminating it, where its use no longer complies with the law;
• in Quebec, ask that a hyperlink attached to your name that gives access to information about you be de-indexed where the conditions of the law are met;
• in Quebec, receive computerized personal information you provided in a structured, commonly used technological format, or have it communicated to a person you designate;
• know the categories of persons within our organization who have access to your information, the retention period and the contact details of our Privacy Officer;
• file a complaint (section 16).

Send your request in writing to the Privacy Officer (section 2). We may ask you to confirm your identity before answering, and we never ask for more information than that requires. We answer within 30 days. In exceptional cases the law allows us to take up to 30 more days, for example when we must consult others; we then tell you within the first 30 days why, when you will receive our answer and that you may complain to the Privacy Commissioner about the extension. Access is free of charge; a reasonable fee may apply only for transcription, reproduction or transmission: we tell you the approximate amount in advance and proceed only if you confirm your request. If we refuse a request, we give you the reasons in writing and tell you how to challenge the decision.

If the person concerned has died, the rights in this section may be exercised by the person authorized to administer the estate (executor, administrator or, in Quebec, liquidator of the succession) on proof of that authority, and by any other person that the applicable provincial law allows, for the purposes that law permits. A person acting for someone else, for example under a power of attorney or as the holder of parental authority, must show us proof of that authority; we then deal with the representative as we would with the person.

Please contact our Privacy Officer first; we examine every complaint and answer in writing. You also have the right to complain to a privacy authority:

• Office of the Privacy Commissioner of Canada
• Commission d'accès à l'information du Québec (residents of Quebec)
• Office of the Information and Privacy Commissioner of Alberta or of British Columbia, where their law applies

We make no decision about you based exclusively on automated processing. The verification of a surgeon's licence is reviewed by a person before access is granted or refused.

This site is directed at adults. We do not knowingly collect personal information from persons under 18 years of age, and never from a child under 14 without the consent of the person having parental authority. If you believe we hold such information, contact the Privacy Officer and we will delete it.

This site is intended for residents of Canada. If you use it from elsewhere, your information is handled in accordance with this policy, and we answer access, correction and deletion requests from anyone. MedTechInvest Canada and FixNip Ltd. do not offer their products or services to persons in the European Union and have not designated a representative there.

Huber & Zipse GmbH processes personal information in the European Union as our service provider (processor within the meaning of Article 28 of the EU General Data Protection Regulation) and is bound by the obligations of that regulation that apply to processors.

Where FixNip Ltd. holds personal information in Israel, it is the controller of that database under the Israeli Protection of Privacy Law, 5741-1981, in addition to the Canadian laws named above. Its name and address are in section 1; you can reach it for any privacy matter through our Privacy Officer (section 2), who acts as its point of contact and forwards requests to it. Under that law you have the right to access the personal information about you, yourself or through a representative you authorize in writing, and to ask that information that is incorrect, incomplete, unclear or out of date be corrected or deleted. If a request is refused, we tell you why. Providing personal information to us is voluntary, as explained in section 5.

We update this policy when our practices or the law change. The date at the top shows the current version, and every change is published on this page and announced by a notice on the site. Before a substantial change to how we use information you gave us takes effect, we inform you by e-mail or by a notice on the site and, where required, ask for your consent again. Previous versions are available from the Privacy Officer.

This policy is available in English and French; both versions have the same value.