Privacy Notice and Policies
Zimmer Biomet values your privacy and the protection of your Personal Data. This Zimmer Biomet Privacy Notice (“Notice”) explains how we collect, use, share, transfer, and process information collected from or about you (“Personal Data”) by any subsidiary or affiliate of Zimmer Biomet Holdings, Inc. (collectively “Zimmer Biomet,” “we,” “our,” or “us”).
This Notice describes the types of Personal Data that Zimmer Biomet may collect or process, how we may use and disclose that Personal Data, and how you may exercise any rights you may have regarding the processing of your Personal Data. This Notice applies to Personal Data collected or processed by us online (through websites, applications, and otherwise), when we provide products or services to you, your doctor, hospital, medical treatment or scanning facility, or other healthcare provider (collectively, “Healthcare Provider,” which refers both to the Healthcare Provider institution, organization, or company, and individuals employed by or working for or with such organization), or your patients, and in other situations where you interact with us, including anywhere this Notice is posted or referenced (products, services, websites, and other systems will be referred to in this Notice as “Products and Services”). This Notice also applies to Personal Data that is collected or processed when you interact with us in-person, by telephone, or by mail.
Zimmer Biomet may have other unique privacy notices that apply to certain specific situations, such as privacy notices for specific Products and Services in various specific circumstances. To the extent you were provided with a different privacy notice or policy and those policies or notices apply, those policies or notices will govern our interactions with you, not this one.
If you provide Personal Data of anyone other than yourself, please note that you are responsible for complying with all applicable privacy and data protection laws prior to providing that information to Zimmer Biomet (including obtaining consent, if necessary and required).
Please carefully review this Notice. To the extent permitted by applicable law, by providing us your Personal Data or otherwise interacting with us, you are agreeing to this Notice.
The Zimmer Biomet subsidiary or affiliate with whom you, your Healthcare Provider, or your patient is interacting or who owns and operates the Product or Service is, where applicable, the entity responsible for the collection and use of your Personal Data (known in some jurisdictions as the data controller). A list of the data controllers and contact details can be found in Appendix 1 to this Notice.
Contact Us
If you have any questions, including how to access this Notice in an alternative format or to obtain further information about the security measures described in “Safeguarding Information”, please email us at privacy.nam@zimmerbiomet.com or write to us at Zimmer Biomet, Attn: Global Privacy Officer, P.O. Box 708 1800, West Center Street, Warsaw, Indiana 46581-0708.
For more contact details for your country of residence, please refer to Appendix 1 to this Notice.
Updated: September 2023Personal Data Collection and Your Rights
Personal Data Collection
“Personal Data” is any information that can be used to identify an individual or that we can link directly to an individual, such as name, address, email address, telephone number, credit card number, or health or treatment information, as applicable. Personal Data in some jurisdictions can include information that indirectly identifies a person – such as a unique number assigned to a patient by a Healthcare Provider, even absent other identifying information. Please note that, for patients, as described below, we often receive information about you from your Healthcare Provider.
Some examples of instances where we collect Personal Data include if you:
register for an account for one of our Products or Services;
sign up for newsletters or other informational or marketing materials;
participate in our events, conferences, or trainings, including surgery trainings and Product and Service demonstrations;
ask us a question by contacting us;
apply for employment with us;
interact with us as a customer, vendor, supplier, or business partner or an employee or representative of same, including if you provide information about your customers or patients;
respond to our surveys or questionnaires;
make a complaint to us or to our customers about us; or
purchase, use, or receive our Products or Services.
We will process any Personal Data we collect in accordance with applicable law and as explained in this Notice (unless, as explained above, one of our other policies or notices governs). In some circumstances, if you do not want to provide us with your information, certain Products and Services may be unavailable to you.
Your Rights Regarding Your Personal Information
Under your jurisdiction’s data protection law, you may exercise the following rights with respect to some or all of your Personal Data:
to request access to your Personal Data (including under GDPR Article 15);
to request that we rectify or erase your Personal Data (including under GDPR Articles 16 and 17);
to request that we restrict or block the processing of your Personal Data (including under GDPR Articles 18, 21 and 22);
to provide your Personal Data directly to another, i.e., a right to data portability (including under GDPR Article 20); and
when we previously obtained your consent, to withdraw consent to processing (including under GDPR Article 21).
Zimmer Biomet will not discriminate against you for exercising your rights.
To exercise these rights, please submit a request using the Privacy Request Form, write at privacy.nam@zimmerbiomet.com or for the US only, call us at 1-844-922-2721. Alternatively, you can find the relevant contact details for your country of residence in Appendix 1 to this Notice.
Please note that we may require additional information from you or your authorized agent to honour your request and may deny your request if we cannot verify your identity or status.
If you are concerned about how your Personal Data is used, please email us or contact us. You may also have the right to lodge a complaint against us. To do so, contact your local data protection authority (if one exists in your country).
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
Below is a summary of how we may collect, process, and use Personal Data and the potential recipients of your Personal Data, now and over the past twelve months. Some jurisdictions require us to state the legal bases for processing your Personal Data, which is included below, but please note that not all jurisdictions may recognize all legal bases.
This section is for users of Online Services and Visitors of our Websites and Physical Locations:
We may process your Personal Data when you visit our websites, our physical locations, or when you submit inquiries to us both online (e.g., via email) or offline (e.g., by written letters).
We process identity & contact information, such as: | · first and last name · email address · postal address · phone number |
We process other personal information, such as: | · age · gender · marital status · disability · date of birth |
We process visual information, such as: | · still images · video (incl. via CCTV) |
We process technical Information, such as: | · Internet Protocol (IP) addresses · browser type · browser language · device type · date and time you use our Products and Services · Uniform Resource Locators, or URLs (i.e., website addresses) visited prior to arriving and after leaving our Products and Services · activity on our Products and Services and referring websites or applications · data collected from cookies or other similar technologies** · geolocation information**** |
Anonymized / De‑identified Data: | Anonymized data is data for which your individual personal characteristics have been removed such that you are not identified and the information is no longer considered Personal Data under data protection laws*** |
We obtain this Personal Data from: | · you directly · your devices · our security systems (including CCTV) |
We process this Personal Data for the following purposes: | · to provide you with our Products and Services · to communicate with you · to identify and authenticate you · to customize content for you · to detect security incidents · to protect against malicious or illegal activity · to ensure the appropriate use of our Products and Services · to improve our Products and Services · for short-term, transient use · for administrative purposes · for marketing, internal research, and development · for quality assurance |
We process this Personal Data under the following legal bases: | · for the purposes of our legitimate interests · in preparation for or to perform a contract with you · in circumstances where we have requested and received consent and for other purposes that may be required or allowed by law* |
We may share this Personal Data with: | · Zimmer Biomet, our affiliates, subsidiaries, and related companies · partners that assist us in providing the Products or Services or help us improve our marketing or administration** |
*The legal bases relied upon by Zimmer Biomet under the European Union’s General Data Protection Regulation (“GDPR”) include those enumerated in Articles 6 and 9, depending on the type of Personal Data.
**In limited circumstances, recipients may include, (1) in the event of a sale, assignment, or transfer, to the buyer, assignee, or transferee; and, (2) government officials, law enforcement, or others when permitted by this Notice or required by law.
***This includes in the United States the removal of identifiers from protected health information required under the Health Insurance Portability and Accountability Act (HIPAA), 45 CFR § 164.514(b)(2), for such data to be considered deidentified.
Below is a summary of how we may collect, process, and use Personal Data and the potential recipients of your Personal Data, now and over the past twelve months. Some jurisdictions require us to state the legal bases for processing your Personal Data, which is included below, but please note that not all jurisdictions may recognize all legal bases.
This section is for Patients and Users of Medical Devices.
We may process your Personal Data when you are the existing or prospective patient of a Healthcare Provider who is a Zimmer Biomet customer and/or when you receive or use a Zimmer Biomet medical device (including, where applicable, mobile apps).
We process identity & contact information, such as: | · first and last name · email address · postal address · phone number |
We process other personal information, such as: | · age · gender · marital status · disability · date of birth |
We process visual information, such as: | · pictures and videos of treatment activities |
We process technical Information, such as: | · Internet Protocol (IP) addresses · browser type and browser language · device type · advertising IDs associated with your device (such as Apple’s Identifier for Advertising (IDFA) or Android’s Advertising ID (AAID)) · date and time you use our Products and Services · Uniform Resource Locators, or URLs (i.e., website addresses) visited prior to arriving and after leaving our Products and Services · activity on our Products and Services and referring websites or applications · data collected from cookies or other similar technologies** · geolocation information**** |
We process information regarding your treatment, such as: | · date of birth · sex/gender · treatment dates · medical history and treatment information · patient-reported outcome measures (e.g., responses to questionnaires and surveys) · X-rays, magnetic resonance imaging, and medical scans · user activity · therapy completion and use details · communications with your Healthcare Provider , including audio and/or video from telehealth sessions; Commercial and financial information, such as: · Products and Services purchased, obtained, or considered · request documentation · customer service records · financial transaction history · financial account number |
Anonymized / De‑identified Data: | Anonymized data is data for which your individual personal characteristics have been removed such that you are not identified and the information is no longer considered Personal Data under data protection laws*** |
We obtain this Personal Data from: | · you directly · your Healthcare Provider · your devices · our business partners |
We process this Personal Data for the following purposes: | · to provide you with our Products and Services · to communicate with you · to identify and authenticate you · to detect security incidents · to protect against malicious or illegal activity · to ensure the appropriate use of our Products and Services · to improve our Products and Services · for short-term, transient use · for administrative purposes · for quality assurance |
We process this Personal Data under the following legal bases: | · for the purposes of our legitimate interests · for medical diagnosis and the provision of healthcare and treatment · in the public interest · to comply with a legal obligation · in preparation for or to perform a contract · to protect vital interests · to ensure high standards of quality and safety of healthcare and medical devices · in circumstances where we have requested and received consent and for other purposes that may be required or allowed by law* |
We may share this Personal Data with: | · Zimmer Biomet, our affiliates, subsidiaries, and related companies · Healthcare Providers · partners that assist us in providing the Products or Services or help us improve our marketing or administration** |
*The legal bases relied upon by Zimmer Biomet under the European Union’s General Data Protection Regulation (“GDPR”) include those enumerated in Articles 6 and 9, depending on the type of Personal Data.
**In limited circumstances, recipients may include, (1) in the event of a sale, assignment, or transfer, to the buyer, assignee, or transferee; and, (2) government officials, law enforcement, or others when permitted by this Notice or required by law.
***This includes in the United States the removal of identifiers from protected health information required under the Health Insurance Portability and Accountability Act (HIPAA), 45 CFR § 164.514(b)(2), for such data to be considered deidentified.
Below is a summary of how we may collect, process, and use Personal Data and the potential recipients of your Personal Data, now and over the past twelve months. Some jurisdictions require us to state the legal bases for processing your Personal Data, which is included below, but please note that not all jurisdictions may recognize all legal bases.
This section is for Healthcare Providers.
We may process your Personal Data when you are a Healthcare Provider who is a current or prospective Zimmer Biomet customer, uses Zimmer Biomet Products and Services, or treats patients with Zimmer Biomet Products and Services, including use of Zimmer Biomet’s online portals.
We process identity & contact information, such as: | · first and last name · email address · postal address · phone number |
We process other personal information, such as: | · age · gender · marital status · disability · date of birth |
We process technical Information, such as: | · Internet Protocol (IP) addresses · browser type and browser language · device type · advertising IDs associated with your device (such as Apple’s Identifier for Advertising (IDFA) or Android’s Advertising ID (AAID)) · date and time you use our Products and Services · Uniform Resource Locators, or URLs (i.e., website addresses) visited prior to arriving and after leaving our Products and Services · activity on our Products and Services and referring websites or applications · data collected from cookies or other similar technologies** · geolocation information**** |
We process commercial and financial information, such as: | · Products and Services purchased, obtained, or considered · request documentation · customer service records · financial transaction history · financial account number |
We process professional and educational information, such as: | · job title or position · employer · National Provider Identifier number · state medical license number · work skills · employment history · graduate degrees · certifications · specialized training · responses to surveys and questionnaires · enrolment history for our education and training events |
Anonymized / De‑identified Data: | Anonymized data is data for which your individual personal characteristics have been removed such that you are not identified and the information is no longer considered Personal Data under data protection laws*** |
We obtain this Personal Data from: | · you directly · your devices · our business partners · your employer or principal · your patients · other Healthcare Providers |
We process this Personal Data for the following purposes: | · to provide you with our Products and Services · to communicate with you · to identify and authenticate you · to detect security incidents · to protect against malicious or illegal activity · to ensure the appropriate use of our Products and Services · to improve our Products and Services · for short-term, transient use · for administrative purposes · for quality assurance · for marketing, internal research, and development · for quality assurance · to customize content for you |
We process this Personal Data under the following legal bases: | · for the purposes of medical diagnosis and the provision of healthcare and treatment · for scientific or historical research or statistical purposes · to ensure high standards of quality and safety of healthcare and medical devices · for the purposes of our legitimate interests · to comply with a legal obligation · in preparation for or to perform a contract · to protect vital interests · in circumstances where we have requested and received consent and for other purposes that may be required or allowed by law* |
We may share this Personal Data with: | · Zimmer Biomet, our affiliates, subsidiaries, and related companies · other Healthcare Providers · your patients · partners that assist us in providing the Products or Services or help us improve our marketing or administration** |
*The legal bases relied upon by Zimmer Biomet under the European Union’s General Data Protection Regulation (“GDPR”) include those enumerated in Articles 6 and 9, depending on the type of Personal Data.
**In limited circumstances, recipients may include, (1) in the event of a sale, assignment, or transfer, to the buyer, assignee, or transferee; and, (2) government officials, law enforcement, or others when permitted by this Notice or required by law.
***This includes in the United States the removal of identifiers from protected health information required under the Health Insurance Portability and Accountability Act (HIPAA), 45 CFR § 164.514(b)(2), for such data to be considered deidentified.
Below is a summary of how we may collect, process, and use Personal Data and the potential recipients of your Personal Data, now and over the past twelve months. Some jurisdictions require us to state the legal bases for processing your Personal Data, which is included below, but please note that not all jurisdictions may recognize all legal bases.
This section is for Employment and Apprenticeship Candidates.
We may process your Personal Data when you apply or are a candidate for employment or apprenticeship at Zimmer Biomet.
We process identity & contact information, such as: | · first and last name · email address · postal address · phone number |
We process other personal information, such as: | · age · gender · marital status · disability · date of birth |
We process technical Information, such as: | · Internet Protocol (IP) addresses · browser type and browser language · device type · advertising IDs associated with your device (such as Apple’s Identifier for Advertising (IDFA) or Android’s Advertising ID (AAID)) · date and time you use our Products and Services · Uniform Resource Locators, or URLs (i.e., website addresses) visited prior to arriving and after leaving our Products and Services · activity on our Products and Services and referring websites or applications · data collected from cookies or other similar technologies** · geolocation information**** |
We process professional and educational information, such as: | · job title or position · employer · work skills · employment history · graduate degrees · certifications · specialized training · responses to surveys and questionnaires |
Anonymized / De‑identified Data: | Anonymized data is data for which your individual personal characteristics have been removed such that you are not identified and the information is no longer considered Personal Data under data protection laws*** |
We obtain this Personal Data from: | · you directly · your employer or principal · your devices · our business partners |
We process this Personal Data for the following purposes: | · to communicate with you · to identify and authenticate you · to detect security incidents · to protect against malicious or illegal activity · for short-term, transient use · for administrative purposes · for marketing, internal research, and development |
We process this Personal Data under the following legal bases: | · for the purposes of our legitimate interests · in preparation for or to perform a contract · to comply with a legal obligation · in circumstances where we have requested and received consent and for other purposes that may be required or allowed by law* |
We may share this Personal Data with: | · Zimmer Biomet, our affiliates, subsidiaries, and related companies · partners that assist us in providing the Products or Services or help us improve our marketing or administration** |
*The legal bases relied upon by Zimmer Biomet under the European Union’s General Data Protection Regulation (“GDPR”) include those enumerated in Articles 6 and 9, depending on the type of Personal Data.
**In limited circumstances, recipients may include, (1) in the event of a sale, assignment, or transfer, to the buyer, assignee, or transferee; and, (2) government officials, law enforcement, or others when permitted by this Notice or required by law.
***This includes in the United States the removal of identifiers from protected health information required under the Health Insurance Portability and Accountability Act (HIPAA), 45 CFR § 164.514(b)(2), for such data to be considered deidentified.
Below is a summary of how we may collect, process, and use Personal Data and the potential recipients of your Personal Data, now and over the past twelve months. Some jurisdictions require us to state the legal bases for processing your Personal Data, which is included below, but please note that not all jurisdictions may recognize all legal bases.
This section is for Business Partners and Their Employees, Agents, and Contractors
We may process your Personal Data when you act as a business partner such as a vendor, supplier, distributor, retailer, or service provider.
We process identity & contact information, such as: | · first and last name · email address · postal address · phone number |
We process other personal information, such as: | · age · gender · marital status · disability · date of birth |
We process technical Information, such as: | · Internet Protocol (IP) addresses · browser type and browser language · device type · advertising IDs associated with your device (such as Apple’s Identifier for Advertising (IDFA) or Android’s Advertising ID (AAID)) · date and time you use our Products and Services · Uniform Resource Locators, or URLs (i.e., website addresses) visited prior to arriving and after leaving our Products and Services · activity on our Products and Services and referring websites or applications · data collected from cookies or other similar technologies** · geolocation information**** |
We process commercial and financial information, such as: | · Products and Services purchased, obtained, or considered · request documentation · customer service records · financial transaction history · financial account number |
Anonymized / De‑identified Data: | Anonymized data is data for which your individual personal characteristics have been removed such that you are not identified and the information is no longer considered Personal Data under data protection laws*** |
We obtain this Personal Data from: | · you directly · our business partners · your employer or principal · your devices |
We process this Personal Data for the following purposes: | · to communicate with you · to identify and authenticate you · to detect security incidents · to protect against malicious or illegal activity · for short-term, transient use · for administrative purposes · for marketing, internal research, and development · to provide you with our Products and Services · to communicate with you · to identify and authenticate you |
We process this Personal Data under the following legal bases: | · for the purposes of our legitimate interests · for medical diagnosis and the provision of healthcare and treatment · in the public interest · to comply with a legal obligation · in preparation for or to perform a contract · to protect vital interests · to ensure high standards of quality and safety of healthcare and medical devices · in circumstances where we have requested and received consent and for other purposes that may be required or allowed by law* |
We may share this Personal Data with: | · Zimmer Biomet, our affiliates, subsidiaries, and related companies · Healthcare Providers · patients · partners that assist us in providing the Products or Services or help us improve our marketing or administration** |
*The legal bases relied upon by Zimmer Biomet under the European Union’s General Data Protection Regulation (“GDPR”) include those enumerated in Articles 6 and 9, depending on the type of Personal Data.
**In limited circumstances, recipients may include, (1) in the event of a sale, assignment, or transfer, to the buyer, assignee, or transferee; and, (2) government officials, law enforcement, or others when permitted by this Notice or required by law.
***This includes in the United States the removal of identifiers from protected health information required under the Health Insurance Portability and Accountability Act (HIPAA), 45 CFR § 164.514(b)(2), for such data to be considered deidentified.
Below is a summary of how we may collect, process, and use Personal Data and the potential recipients of your Personal Data, now and over the past twelve months. Some jurisdictions require us to state the legal bases for processing your Personal Data, which is included below, but please note that not all jurisdictions may recognize all legal bases.
This section is for Attendees and Participants at Zimmer Biomet Events.
We may process your Personal Data when you attend or participate in professional and educational events we sponsor or hold.
We process identity & contact information, such as: | · first and last name · email address · postal address · phone number |
We process other personal information, such as: | · age · gender · marital status · disability · date of birth |
We process technical Information, such as: | · Internet Protocol (IP) addresses · browser type and browser language · device type · advertising IDs associated with your device (such as Apple’s Identifier for Advertising (IDFA) or Android’s Advertising ID (AAID)) · date and time you use our Products and Services · Uniform Resource Locators, or URLs (i.e., website addresses) visited prior to arriving and after leaving our Products and Services · activity on our Products and Services and referring websites or applications · data collected from cookies or other similar technologies** · geolocation information**** |
We process professional and educational information, such as: | · job title or position · employer · work skills · employment history · graduate degrees · certifications · specialized training · responses to surveys and questionnaires |
We process visual information, such as: | · still images · video (including via CCTV) |
Anonymized / De‑identified Data: | Anonymized data is data for which your individual personal characteristics have been removed such that you are not identified and the information is no longer considered Personal Data under data protection laws*** |
We obtain this Personal Data from: | · you directly · your employer or principal · your devices · our business partners |
We process this Personal Data for the following purposes: | · to communicate with you · to identify and authenticate you · to detect security incidents · to protect against malicious or illegal activity · for short-term, transient use · for administrative purposes · for marketing, internal research, and development |
We process this Personal Data under the following legal bases: | · for the purposes of our legitimate interests · in preparation for or to perform a contract · to comply with a legal obligation · in circumstances where we have requested and received consent and for other purposes that may be required or allowed by law* |
We may share this Personal Data with: | · Zimmer Biomet, our affiliates, subsidiaries, and related companies · other event attendees and participants · partners that assist us in providing the Products or Services or help us improve our marketing or administration** |
*The legal bases relied upon by Zimmer Biomet under the European Union’s General Data Protection Regulation (“GDPR”) include those enumerated in Articles 6 and 9, depending on the type of Personal Data.
**In limited circumstances, recipients may include, (1) in the event of a sale, assignment, or transfer, to the buyer, assignee, or transferee; and, (2) government officials, law enforcement, or others when permitted by this Notice or required by law.
***This includes in the United States the removal of identifiers from protected health information required under the Health Insurance Portability and Accountability Act (HIPAA), 45 CFR § 164.514(b)(2), for such data to be considered deidentified.
Cookies and Similar Tools
When you visit Zimmer Biomet websites or applications, we may use “cookies,” web beacons, and other technologies to help us serve users better and to help us evaluate and improve the content or functions of the Products or Services. A cookie is a small piece of data (a unique numeric code) sent from a website or application and stored on a user’s device while the user is browsing the website or using the application. Cookies do lots of different jobs, like identifying previous activity so that your use of the Product or Service is more efficient and enjoyable, remembering your preferences (like language choices), and authenticating you.
****Geolocation information may be either provided by you or collected automatically for the legitimate business interest of running and maintain the website. This information may include your IP address and/or geographic location (such as longitude, latitude, city, state, and/or zip code).
Common uses for cookies include:
identifying users who have signed into a Product or Service to avoid users having to submit a user name and password repeatedly;
keeping track of users' preferences regarding the content they would like to see and the format in which they would like to view it so they do not need to resubmit preferences;
keeping track of which pages users’ request to make improvements to site content and navigation;
engaging in analytics about how the Products or Services are used; and
collecting information about users’ activities over time and across different websites or applications while using the website or application.
Web beacons (also known as internet tags, pixel tags, and clear GIFs) are small pieces of code that may be placed on our websites or other Products and Services that allow us to obtain information about usage. Web beacons cannot identify you as an individual and are used to help display content to visitors and to generate statistics regarding web traffic and trends.
If you would like to opt-out or withdraw consent to use non-essential cookies and related technologies, you can set your web browser to prevent the use of cookies from Zimmer Biomet websites, as well as other websites that you may visit (see www.aboutcookies.org for more information on how to do this. If you do so, you can still use Zimmer Biomet Products and Services, but it is possible that some portions of the Products and Services will not function properly or may perform more slowly. You may also be able to opt-out / withdraw consent to use non-essential cookies and related technologies by clicking the “Preferences” button at the bottom of this Product or Service. Except where prohibited by law, by using our Products and Services and not disabling cookies, you consent to their use.
For more information on our use of cookies, web beacons, and similar technologies, visit the Zimmer Biomet Cookie Notice page.
Children’s Information
Zimmer Biomet does not knowingly collect, maintain, disclose, or otherwise process Personal Data from minors below the age of 16 without the permission of such minor’s parents or legal guardians.
Combination of Data
We may combine information we collect, whether Personal Data or not, with Personal Data that we may obtain from third parties, including Healthcare Providers.