OMPI Privacy Policy

Last updated February 18, 2026

Ortho Molecular Products, Inc. (“Ortho”) and its related brands, divisions, and affiliates (“we,” “us,” or “our,”) are committed to protecting the privacy and security of the personal information of our users in Canada (“you” or “your”). This privacy policy (“Privacy Policy”) governs the websites we and our affiliates, subsidiaries, and related entities operate on which this Privacy Policy is provided and that are made available to individuals in Canada. We have developed this Privacy Policy to describe our practices concerning the collection, use, disclosure, transfer, and storage of your personal information about an identifiable individual as defined under applicable Canadian privacy laws, including the Personal Information Protection and Electronic Documents Act (PIPEDA) and substantially similar provincial laws (“Personal Information”). Our website may contain links to third-party websites, and we are not responsible for and expressly disclaim all liability arising from such third-party websites or their privacy practices. This Privacy Policy does not apply to any information you may provide while on such third-party websites, and we recommend you review and become familiar with their privacy policies as well. By continuing to use the Services (as defined herein) after any update to this Privacy Policy, you acknowledge and agree to the revised Privacy Policy; however, where consent is required under applicable Canadian law for material changes, we will seek your consent. This Privacy Policy includes the following sections:

Notice of Collection, Use and Disclosure

We collect the categories of Personal Information described in the “Information We Obtain” section for the limited business and commercial purposes outlined in the “ Purpose of Collection” column of that same section. We will not collect additional categories of Personal Information or utilize Personal Information for purposes that are materially different, unrelated, or incompatible with the purposes disclosed herein without providing prior notice to you and, where mandated by applicable law, obtaining your consent (express or implied, as appropriate). To learn more about your privacy choices, including consent management and withdrawal, please see the “Exercising Your Privacy Rights” section below.

1. Information We Obtain
2. Collection of Information via Automated Technologies
3. Communications Preferences
4. Disclosure of Personal Information to Third Parties
5. Protection of Personal Information
6. Retaining Personal Information
7. Interest-Based Advertising
8. Canadian Privacy Rights
9. Exercising Your Privacy Rights
10. Complaints Process
11. Transfer of Information
12. Accountability
13. Changes to Our Privacy Notice
14. Contact Us

Information We Obtain

You may be asked to provide certain Personal Information anytime you interact with our organization. Ortho and its affiliates may share this Personal Information with each other and use it consistent with this Privacy Policy. Provision of Personal Information is voluntary; however, refusal to provide requested Personal Information may preclude us from providing our products or services or responding to your inquiries, and we may condition the provision of certain discounts, features, or services on the collection and use of Personal Information as permitted by applicable law and subject to your informed consent. We shall not condition the provision of goods or services on the collection of sensitive Personal Information except where reasonably necessary to provide the requested service or to comply with legal obligations, in accordance with applicable law and proportionality principles. This Privacy Policy describes how your information is collected, used, and shared when you use our services.

We obtain Personal Information about you via various methods, including but not limited to when you interact with our websites or platforms that link to this notice (collectively, the “Services”), interact with us through our social media pages, create or modify your account and profile, request products or services, contact customer support (including recorded calls and stored chat or email transcripts), or otherwise communicate with us, and we collect only what is necessary for identified purposes. Some examples of the types of Personal Information we may collect from you include:

Sensitive Personal Information

Ortho collects certain information that is considered “sensitive” under applicable Canadian privacy laws. Where required by law, we will obtain your express consent before processing your sensitive Personal Information; where consent is not required, we may process such information for the limited purposes described below and as otherwise permitted by law. We shall use your sensitive Personal Information solely for limited purposes, such as to process an application, to comply with legal obligations (e.g., payment processing, fraud prevention), and for other objectives expressly permitted by law. We do not use your sensitive Personal Information to infer characteristics about you. If you have any questions about our handling of sensitive Personal Information or to withdraw your consent, please see the “Contact Us” section below.

We have collected the following categories of sensitive Personal Information about you:

Category	Example(s)	Source(s)	Purpose of Collection
Financial Data	Name, signature, credit card number, bank account number with security code, other financial information, etc.	Directly from consumers/patients, and licensed health care professionals	Maintaining and servicing your account, providing customer service, processing orders/transactions

Collection of Information via Automated Technologies

We, our service providers, and certain third parties use cookies, pixel tags, server or device logs, or similar tracking technologies (“Collection Technologies”) to gather certain information when you use, access, or otherwise interact with our Services, and we obtain your consent for non-essential cookies where required under Canadian law. Below we have described how we use Collection Technologies.

Our use of Collection Technologies generally falls into the following categories:

• Assist with your navigation of our website and remember your information so you do not have to re-enter it;
• Track the number of visitors on our site;
• Remember your site preferences (e.g., account logins);
• To target and deliver ads, subject to your consent where required;
• Authenticate your identity, protect against fraud and provide our products and services; and

Managing Your Cookie Preferences

You can choose how web browser cookies are handled by your device via your browser settings or, where available, our consent management tools. Some devices allow you to control this through your device settings. If you choose not to receive cookies at any time, websites may not function properly, and certain services will not be provided. Each browser and device are different, so check the settings menu of the browser or device to learn how to change your settings and cookie preferences. You can find information on how to manage cookie settings on certain browsers via the following links:

• Cookie settings in Chrome
• Cookie settings in Firefox
• Cookie settings in Internet Explorer
• Cookie settings in Safari

The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs; however, exercising such choices does not opt you out of all advertising and may not affect non-cookie based tracking technologies. You can access these and learn more about targeted advertising and consumer choice and privacy by visiting the Network Advertising Initiative and the Digital Advertising Alliance.

To the extent that our Collection Technologies involve targeted advertising or cross-context behavioral advertising, or otherwise require consent or an opt-out under applicable law, you may exercise your rights and choices as follows (provided, however, that your choices are browser-, app-, and device-specific and may be reset by clearing cookies or changing settings):

Your Privacy Choices
Click on the "Your Privacy Choices " link in the footer of our website and adjust your preferences. Please note that your request to opt-out will be linked to your browser identifier only. If you use a different computer or browser to access our website, you will need to adjust your preferences on those sites.

Browser-Based Preference
Some browsers and extensions may allow you to send preference signals regarding cookies or certain tracking. Where required by applicable law and where technically feasible, we will take reasonable steps to honor such signals for non-essential cookies or similar technologies; you may also manage your preferences through your browser settings and, where available, our consent management tools.

Do Not Track
Some web browsers incorporate a "Do Not Track" feature that signals to websites you visit that you do not want to have your online activity tracked. Most of these features, when turned on, send a signal or preference to the websites you visit indicating that you do not wish to be tracked. Because there is not yet a common understanding of how to interpret the do not track signal, we currently do not respond to the browser do not track signals; however, we will honor applicable opt-out preference signals recognized by Canadian guidance where required by law.

Communications Preferences

You may opt out of receiving text messages or promotional emails from Ortho by following the instructions in those communications, or by contacting us using the methods listed in the “Contact Us” section; we will process such requests without undue delay. If you opt out, we may still send you transactional or relationship messages, such as those about your account, orders, compliance notices, safety communications, recall information, or our ongoing business relations.

Disclosure of Personal Information to Third Parties

We disclose the following categories of Personal Information to our service providers and, where permitted by law, to “contractors” and “third parties” for legitimate business purposes, including maintaining and servicing accounts, providing customer support, processing transactions and payments, verifying customer information, managing marketing and analytics activities, and ensuring the functionality, security, and improvement of our websites and systems, subject to contractual obligations prohibiting use outside our instructions.

Identifiers: We disclose identifiers such as names, contact information, account credentials, and IP addresses to facilitate account management, order fulfillment, communication, fraud prevention, and website security.

Professional Information: We disclose professional details, including business names, job titles, licenses, and clinic affiliations, to verify healthcare professional status, manage practitioner relationships, provide access to professional portals and materials, and process related transactions.

Commercial Information: We disclose commercial information such as purchase history, product preferences, and transaction records to enable order fulfillment, returns, accounting, inventory management, marketing, and analytics that support business operations and product improvement.

Cookie and Tracker Information: We disclose cookie and tracker data, including device identifiers and browsing behavior, to support analytics, advertising, and website optimization that help us understand user engagement, improve performance, and enhance security.

Inferences: We disclose inferences drawn from transaction and browsing activity to personalize user experiences, tailor marketing efforts, and inform product development and service enhancements.

In addition, we may disclose Personal Information for specific purposes such as:

• Fraud Prevention: To investigate, prevent, or address suspected illegal or fraudulent activities, or to protect the safety, rights, or property of us, our users, or others.
• Legal Compliance: To comply with applicable laws, regulations, or lawful requests from government authorities, courts, or regulators.
• Corporate Transactions: To facilitate a merger, acquisition, sale, financing, assignment, or other corporate restructuring involving Ortho Molecular Products, Inc. or its affiliates, including during diligence and integration.

Protection of Personal Information

We take the security of your Personal Information seriously and maintain a comprehensive information security program reasonably designed to protect Personal Information, comprising risk assessments, access controls, encryption in transit and at rest where appropriate, vulnerability management, incident response, and vendor security due diligence. To protect the privacy and security of your Personal Information, we maintain physical, technical, and administrative safeguards. We update and test our security technology on an ongoing basis. Additionally, we train our employees about the importance of confidentiality and maintaining the privacy and security of your information. We commit to taking appropriate disciplinary measures to enforce our employees' privacy responsibilities.

Retaining Personal Information

We retain your Personal Information for as long as is necessary for the purposes described in this Policy, and we apply a retention schedule that limits retention to the shortest period reasonably necessary, after which Personal Information is securely deleted or de-identified and maintained subject to re-identification prohibitions), except where a longer period is required or permitted by law or to establish, exercise, or defend legal claims. This generally means holding the personal information for as long as:

• Your Personal Information is reasonably necessary to manage our operations, to manage your relationship with us, or to satisfy another purpose for which we collected the Personal Information;
• Your Personal Information is reasonably necessary to carry out a disclosed purpose that is reasonably compatible with the context in which the Personal Information was collected; or
• We are otherwise required or permitted to keep your Personal Information by applicable laws or regulations.

Where Personal Information is used for more than one purpose, we will retain it until the purpose with the latest period expires.

Targeted Advertising and Data Sales

We do not sell your Personal Information. We may engage in interest-based advertising and may disclose certain information to advertising and analytics partners, subject to your consent where required by applicable law, and you may manage your choices as described in “Managing Your Cookie Preferences” and “Your Privacy Choices.” Additionally, our Services are intended for a general audience and are not directed to children. We do not knowingly collect Personal Information from children without valid consent from a parent or legal guardian (or other authorized representative, as applicable), and we apply heightened protections to children’s information as required by applicable law. You may observe our advertisements on other websites or mobile applications because we utilize third-party ad services on our Services, which may collect information about your online activities over time and across third-party websites and apps; these third parties may maintain their own privacy policies and controls over which we have no control and for which we disclaim responsibility.

Canadian Privacy Rights

Applicable Canadian privacy laws (including PIPEDA and substantially similar provincial laws) provide individuals in Canada with certain rights regarding their Personal Information. To exercise your rights, please follow the instructions outlined in the “Exercising Your Privacy Rights” section of this policy.

Residents of Canada (including Alberta, British Columbia, and Québec) may have the following privacy rights:

Right of Access: You have the right to request access to your Personal Information and information about how it has been used and disclosed, subject to applicable legal exceptions. You may also request a copy of the Personal Information we have collected about you.

Right to Withdrawal of Consent (and, where applicable, De-Indexing/Cease Dissemination): Subject to legal or contractual restrictions and reasonable notice, you may withdraw your consent to our collection, use, or disclosure of your Personal Information. Where required by applicable law (including in Québec in certain circumstances), you may also request that we cease dissemination or de-index certain information.

Right to Correction: You have the right to request that we correct inaccurate or incomplete Personal Information we maintain about you, and you may request that we annotate unresolved accuracy disputes where required by applicable law.

Right to Withdraw Consent: Subject to legal or contractual restrictions and reasonable notice, you may withdraw your consent to certain collection, use, or disclosure of your Personal Information (including, where applicable, interest-based advertising). If you would like to manage cookies and similar technologies, please see the “Managing Your Cookie Preferences” section above.

Right to Challenge Compliance and Complain: You may challenge our compliance with applicable Canadian privacy laws and our policies and practices, and you may submit a complaint as described in the “Complaints Process” section below.

Exercising Your Privacy Rights

If you are a resident of the applicable jurisdictions listed above and would like to exercise your rights as outlined, please contact us through either of the following options listed below; we may deny or limit requests where an exemption applies or where we cannot verify your identity to the degree required by applicable law. Before we can process your request, we may ask you a series of questions in order to verify your identity and may request additional information reasonably necessary to authenticate you. If permitted or required by applicable law, you may exercise your privacy rights through an authorized agent (which may include a guardian or conservator), or, in Canada, through a representative or mandate holder where recognized by provincial law. If we receive your request from an authorized agent, we may ask for evidence that you have provided such agent with a power of attorney or that the agent otherwise has valid written authority to submit requests to exercise rights on your behalf, and we may require you to verify your identity directly with us to the extent permitted by law. If you are an authorized agent seeking to make a request, please contact us at the email or phone number listed below.

Emailing us at [email protected]
Calling us at 815-337-0089

We will not retaliate against you products treat you unfairly services solely because you exercise rights under applicable Canadian your laws. Unless as permitted law, we will not:

• Deny you goods or services;
• Charge you different prices or rates for goods or services, including granting discounts or other benefits, or imposing penalties;
• Provide you a different level or quality of goods and services; or

Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Complaints Process

Please see the “Exercising Your Privacy Rights” section for details on how to submit a complaint.

Our process for dealing with complaints related to the protection of Personal Information generally includes:

1. Acknowledgement of receipt without reasonable undue delay;
2. Appropriate steps to confirm the identity of the complainant, and to obtain the details of the complaint as well as any relevant documentation;
3. Consideration of applicable law;
4. An appropriate, fair and impartial investigation; and

Communicating the outcome of the investigation to the complainant, including any remediation measures we take (where justified).

Transfer of Information to the United States and Other Countries

Ortho is headquartered in the United States, and we have operations and service providers in the United States and Canada. Therefore, we and our service providers and vendors may transfer your Personal Information to, or store or access it in, jurisdictions that may not provide levels of data protection that are equivalent to those of your home jurisdiction.

If you are located in Quebec, please be advised that your Personal Information may be communicated outside of Quebec. Personal Information transferred or communicated outside of Canada may be accessible to foreign courts, law enforcement and national security entities. We will take steps to ensure that your Personal Information receives an adequate level of protection in the jurisdictions in which we process it.

Accountability

Ortho is accountable for the Personal Information collected from Canadian residents. Your Personal Information may be handled by the following categories of personnel within our organization:

1. Customer Service;
2. Finance;
3. Information Technology;
4. Marketing;
5. Quality; and
6. Sales

Our personnel have the following roles and responsibilities when handling personal data from its collection to its deletion:

The Privacy Officer has ultimate responsibility for ensuring compliance with applicable privacy and data protection legislation, including Quebec’s “Act respecting the protection of personal information in the private sector.”

The privacy team handles everyday tasks relating to Ortho’s privacy and data protection. This includes managing and promoting day-to-day privacy and data protection compliance within the organization, responding to rights requests, developing policies and standards, creating rules and policies, and developing and/or facilitating privacy training.

The security team is responsible for developing, implementing and managing the data security measures deployed in our organization.

All other personnel must perform their duties in compliance with Ortho policies about privacy and data security.

Changes to Our Privacy Notice

We reserve the right to amend the Privacy Policy at any time and for any reason; where a change materially affects how we collect, use, or disclose your Personal Information, we will provide additional notice and seek consent where required by applicable law. Users should check our site to see the current Privacy Policy that is in effect and any changes that may have been made to it; continued use of the Services after any changes constitutes acceptance of the revised Privacy Policy, except where consent is required by Canadian law. The provisions contained herein supersede all previous notices or statements regarding our privacy practices and the terms and conditions that govern them.

How to Contact Us

If you have questions regarding our Privacy Policy or your privacy rights as described above, or to reach our Privacy Officer for Canada, please contact us at [email protected] or 815-337-0089.