Clinician Privacy Policy

Australia/Ireland/India/New Zealand/Singapore/South Africa/United Kingdom
Kingdom of Saudi Arabia/United Arab Emirates

Australia/Ireland/India/New Zealand/Singapore/South Africa/United Kingdom

Welcome

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’) (as defined further below) by any subsidiary or affiliate of Zimmer Biomet Holdings, Inc. (collectively ‘Zimmer Biomet’, ‘we’, ‘our’, or ‘us’).

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 the section ‘Contact Us’ and in Appendix 1 to this Notice.

Please carefully review this Notice. We will process any Personal Data we collect in accordance with applicable law and as explained in this Notice (unless, as explained below, a separate policy or notice governs). In some circumstances, if you do not want to provide us with your information, certain Products and Services may be unavailable to you. To the extent permitted by applicable law, by providing us your Personal Data or otherwise interacting with us, you are agreeing to this Notice. If you do not agree with our policies and practices, it is your choice not to use our Products and Services or otherwise engage with us.

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).

Purpose of this Privacy Notice

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.

Some examples of instances where we collect Personal Data include:

Through online activities and services we offer (through this and other websites, web surveys, newsletters, applications, online messaging services or channels, including online ‘chats’ with live individuals and artificial intelligence, social media, our telephone customer service centres, email or SMS/text messages and otherwise) (‘Online Services’).
Through your account and our products or services, whether provided directly to you or your patient, or if you are a patient, through your doctor, hospital, medical treatment or scanning facility, or other healthcare provider (collectively, ‘Healthcare Provider’, which refers both to the Healthcare Provider institution, organisation, or company and individuals employed by or working for or with such organisation).
In other situations where you interact with us, including but not limited to interacting with us by visiting our sites, offices, or our events (such as trade fairs and conferences) (‘Events’) (our Online Service, Events and other products and services are collectively referred to in this Notice as ‘Products and Services’).
Related to activities we undertake in recruiting participants for participation in clinical trials or activities related to identifying and contracting with study investigators and their staff.
In connection with adverse events, complaints and reports.
When you interact with us in a professional capacity, for example, if you are a Healthcare Provider or an employee of a company we do business with or provide Products and Services to.
When we undertake employment recruiting activities, or
Anywhere this Notice is posted or referenced.

Zimmer Biomet may have other unique privacy notices that apply to certain specific situations, such as privacy notices for specific Products and Services. To the extent you were provided with a different privacy notice or policy that applies, those policies or notices will govern our interactions with you, not this one.

Personal Data, Collection, Purposes, Source and Recipients

Personal Data

‘Personal Data’ is any information – as electronically or otherwise recorded – that can be used to identify a specific 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.

Personal Data may include information considered sensitive in some jurisdictions, such as biometric information, genetic information, health information, financial account information, specific geolocation, ethnic or racial origin, information concerning your sex life or your sexual orientation, social security number, driver’s license number, state identification card number, passport number and other similar information. Personal Data that could be considered sensitive Personal Data under applicable law is indicated with a caret (^) in the chart below.

The below table is a high-level summary of the types of Personal Data we may collect from you. Following that high-level summary is additional detail and information on how we collect, process and use Personal Data and the potential sources and 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 recognise all legal bases. The types of Personal Data we collect and disclose depends on your relationship with Zimmer Biomet. Not all the categories listed in the following charts may apply to you. If the nature of your relationship with Zimmer Biomet changes, additional categories of Personal Data may also apply.

	Identity and Contact Information	Age, Gender and Other Characteristics	Video, Audio and Recorded Information	Technical Information	Health Information	Commercial and Financial Information	Professional and Educational Information	Anonymised / De-Identified Data
Users of Online Services, Visitors to Our Websites and Physical Locations, and Senders of Enquiries	X^	X^	X	X	X^			X
Patients and Users of Medical Devices	X^	X^	X^	X^	X^	X^		X
Healthcare Providers	X^	X^	X	X		X^	X^	X
Employment and Apprenticeship Candidates	X^	X^	X	X			X^	X
Business Partners and Their Employees, Agents and Contractors	X^	X^	X	X		X^	X^	X
Attendees and Participants at Zimmer Biomet Events	X^	X^	X	X	X^	X^	X	X
Clinical Investigators and Members of Investigator Teams	X^	X^	X	X		X^	X^	X
Clinical Study Candidates	X^	X^	X	X^	X^	X^	X	X
Children⁺	X^	X^	X^	X^	X^	X		X

Personal Data that may be considered sensitive is noted with a ‘^’.

⁺ Zimmer Biomet may process Personal Data of minors who are users of a Zimmer Biomet product. In those instances, Zimmer Biomet seeks consent from the minor’s parents or legal guardians to process their Personal Data. Zimmer Biomet does not knowingly collect, maintain, disclose, or otherwise process Personal Data from minors below the age of 16 in other circumstances, including through Online Services.

Users of Online Services, Visitors to Our Websites and Physical Locations, and Senders of Enquiries We may process your Personal Data when you (1) visit, use, register for and/or engage with our Online Services; (2) sign up for our newsletters or other informational or marketing materials; (3) submit enquiries to us both online (e.g. via email, via chatbot) or offline (e.g. by written letters); (4) contact our customer service centres through phone, email, SMS/text messages, chats, or otherwise; (5) complete a survey or other online questionnaire or form; and/or (6) participate in Events.
We process these types of Personal Data:	We obtain this Personal Data from:	We process this Personal Data for the following purposes:	We process this Personal Data under the following legal bases:	We may share this Personal Data with**:
Identity and Contact Information, such as: name and surname or unique pseudonym honorifics and titles, preferred form of address employer/company email address postal address phone number username or code and password^, security answers^ and user preferences contact information for related persons, such as authorised users of your account or designated representatives customer number company ID number such as account number National Provider Identifier (NPI) number Other Personal Information, such as: age gender preferred language marital status disability^ date of birth Video, Audio and Recorded Information, such as: still images video (including via CCTV) voicemails recordings of your interactions with our Online Services, including with our customer service, whether through phone, email, SMS/text message, or chat Technical Information, such as: Internet Protocol (IP) addresses (which may identify your general geographic location or company) 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 and online behaviour while on our Products and Services and referring websites or applications, including forms and other information submitted, videos watched, your clicks on our site pages and product descriptions read data collected from cookies or other similar technologies geolocation information**** Anonymised / De identified Data Anonymised 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***	you directly those authorised to provide on your behalf such as your carer or authorised representative your devices our security systems (including CCTV) third parties that provide access to information you make publicly available, such as social media companies conducting non-clinical research such as market research companies business partners and other third parties that assist us in providing and improving our Products and Services	to provide you with our Products and Services to communicate with you to administer our relationship with your organisation to send you updates to identify and authenticate you to customise content for you and tailor your experience when using our Products and Services to detect security incidents to protect against malicious, fraudulent 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 internal research and development to evaluate the effectiveness of and improve our Products and Services, and to develop new products and services for quality assurance and to assist in training and development of our representatives to determine and verify Products and Services eligibility and coverage in connection with adverse event and complaint tracking and reporting to procure third-party products and services, including to manage and satisfy related third- party contractual obligations for marketing, advertising and promotion, including to contact you regrading programmes, Products and Services and topics that may be of interest or useful to you to comply with legal and regulatory obligations	for the purposes of our legitimate interests in preparation for or to perform a contract with you to comply with legal and regulatory obligations and to establish, exercise, or defend our legal claims and rights to facilitate the provision of healthcare or treatment for reasons of public health, including ensuring 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*	Zimmer Biomet, our affiliates, subsidiaries and related companies Healthcare Providers your company / employer individuals or entities that you designate or instruct us to share your Personal Data with authorised representatives, family members and carers third parties who assist with fraud prevention, detection and mitigation third parties who assist with our information technology and security programmes and our loss prevention programmes Zimmer Biomet’s lawyers, auditors and consultants partners that assist us in providing the Products or Services or help us improve our marketing or administration
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 these types of Personal Data:	We obtain this Personal Data from:	We process this Personal Data for the following purposes:	We process this Personal Data under the following legal bases:	We may share this Personal Data with**:
Identity and Contact Information, such as: name and surname or a unique pseudonym honorifics and titles, preferred form of address employer / company email address postal address phone number username or code and password,^ security answers^ and user preferences contact information for related persons, such as authorised users of your account or designated representatives Other Personal Information, such as: age gender preferred language marital status disability^ ethnicity^ date of birth Video, Audio and Recorded Information, such as: still images video (including via CCTV) recordings of your calls with our customer service representatives voicemails recordings of your interactions with our Online Services, whether through email, SMS/text message, or chat pictures and videos of diagnosis and treatment activities^ Technical Information, such as: Internet Protocol (IP) addresses (which may identify your general geographic location or company) 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 and online behaviour while on our Products and Services and referring websites or applications, including forms and other information submitted, videos watched, your clicks on our site pages and product descriptions read^ data collected from cookies or other similar technologies geolocation information**** Health Information, such as: identification of pathologies/diseases^ identification number associated with your Products^ areas of interest in medical research^ treatment and surgery dates^ medical history and treatment information^ patient-reported outcome measures (e.g. responses to questionnaires and surveys about your health or treatment)^ DICOM images, X-rays, magnetic resonance imaging and medical scans^ user activity^ therapy completion and use details^ communications with your Healthcare Provider, including audio video, or other recordings from telehealth sessions^ drug allergies, prescriptions and dosing ^ health values taken, such as heart rate and blood pressure, gait patterns or rhythms ^ adverse event information^ health insurance information and other information on payment for healthcare services^ pregnancy status^ contact information for designated recipients of your health information location data^ pictures and videos of diagnosis and treatment activities ^ patient ID number^ Commercial and Financial Information, such as: Products and Services purchased, obtained, or considered bank account number and details^ request documentation customer service records financial transaction history financial account number^ other payment information Anonymised / De identified Data Anonymised 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***	you directly Healthcare Providers those authorised to provide Personal Data on your behalf, such as your carer or authorised representative your devices our security systems (including CCTV) third parties that provide access to information you make available, such as social media companies conducting non-clinical research such as market research companies our business partners or other third parties that assist us in providing and improving our Products and Services Your use of Zimmer Biomet Products or Services	to provide you with our Products and Services to communicate with you to administer our relationship with you to send you updates to identify and authenticate you to detect security incidents to protect against malicious, fraudulent 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 to generate surgeon- specific performance analytics relating to their patients’ pre-operative, intra-operative and post-operative insights and to further enable Healthcare Providers to compare aggregated, de-identified performance analytics across other Healthcare Providers – either regionally or globally. for internal research and development to evaluate the effectiveness of and improve our Products and Services and to develop new products and services to determine and verify Products and Services eligibility and coverage in connection with adverse event and complaint tracking and reporting to procure third-party products and services, including to manage and satisfy related third-party contractual obligations for marketing, advertising and product promotion, including to contact you regarding programmes, Products and Services and topics that may be of interest or useful to you to comply with legal and regulatory obligations	for the purposes of our legitimate interests for medical diagnosis and the provision of healthcare or treatment to comply with legal and regulatory obligations and to establish, exercise or defend our legal claims or rights. in preparation for or to perform a contract to protect vital interests or in the public interest for reasons of public health, including ensuring high standards of quality and safety of healthcare and medical devices for scientific or historical research or statistical purposes in circumstances where we have requested and received consent, including from Patients directly for their use of certain Products or Services, and for other purposes that may be required or allowed by law*	Zimmer Biomet, our affiliates, subsidiaries and related companies Healthcare Providers individuals or entities that you designate or instruct us to share your Personal Data with authorised representatives, family members and carers third parties who assist with fraud prevention, detection and mitigation third parties who assist with our information technology and security programmes and our loss prevention programmes Zimmer Biomet’s lawyers, auditors and consultants third parties with your consent partners that assist us in providing the Products or Services or help us improve our marketing or administration
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 these types of Personal Data:	We obtain this Personal Data from:	We process this Personal Data for the following purposes:	We process this Personal Data under the following legal bases:	We may share this Personal Data with**:
Identity and Contact Information, such as: name and surname or unique pseudonym honorifics and titles, preferred form of address employer / company email address postal address phone number username or code and password^, security answers^ and user preferences contact information for related persons, such as authorised users of your account or designated representatives customer number company ID number such as account number National Provider Identifier (NPI) number unique personal identifier signature Other Personal Information, such as: age gender preferred language marital status disability^ date of birth Video, Audio and Recorded Information, such as: still images video (including via CCTV) recordings of your calls with our customer service representatives voicemails recordings of your interactions with our Online Services, whether through email, SMS/text message, or chat pictures and videos of treatment activities or training activities Technical Information, such as: Internet Protocol (IP) addresses (which may identify your general geographic location or company) 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)) Uniform Resource Locators, or URLs (i.e. website addresses) visited prior to arriving and after leaving our Products and Services activity and online behaviour while on our Products and Services and referring websites or applications including forms and other information submitted, videos watched, your clicks on our site pages, browsing time and product descriptions read data collected from cookies or other similar technologies geolocation information**** Commercial and Financial Information, such as: Products and Services purchased, obtained, or considered Bank account number and details^ request documentation customer service records financial transaction history financial account number^ other payment information tax identification number^ Professional and Educational Information, such as: job title or position your employer, company with which you are associated, or principal working location National Provider Identifier (NPI)number state medical license number work skills employment history graduate degrees certifications professional memberships specialised training responses to surveys and questionnaires enrolment and attendance history for our education and training events records of collaborations with Zimmer Biomet, such as consulting and other engagements information from references background checks Product Usage Information, such as: technical and surgical data (pre-, intra- and post-operative) and performance metrics derived from your use of certain Products or Services date and time you use our Products and Services, including the Products and Services used user preferences purchasing tendencies Anonymised / De identified Data Anonymised 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***	you directly Healthcare Providers your employer, company with which you are associated, or principal third-party data repositories your devices your references and third parties that assist us in conducting background checks our security systems (including CCTV) third parties that provide access to information you make available, such as social media companies companies conducting non-clinical research such as market research companies your patients clinical investigators and/or members of investigator teams the use of Zimmer Biomet Products or Services sales representatives imaging centres	to provide you with our Products and Services to communicate with you to administer our relationship with your organisation to send you updates to identify and authenticate you to customise content for you and tailor your experience when using our Products and Services to detect security incidents to protect against malicious, fraudulent or illegal activity to ensure the appropriate use of our Products and Services to provide medical education to improve our Products and Services for short-term, transient use for administrative purposes for quality assurance for internal research and development to evaluate the effectiveness of and improve our Products and Services and to develop new products and services for quality assurance and to assist in training and development of our representatives in connection with adverse event and complaint tracking and reporting to procure third-party products and services, including to manage and satisfy related third-party contractual obligations for marketing, advertising and promotion, including to contact you regarding programmes, Products and Services, and topics that may be of interest or useful to you to comply with legal and regulatory obligations to generate surgeon- specific performance analytics relating to their patients’ pre-operative, intra-operative and post-operative insights and to further enable Healthcare Providers to compare aggregated, de-identified performance analytics across other Healthcare Providers – either regionally or globally. for preoperative planning	for the purposes of our legitimate interests for the purposes of medical diagnosis and the provision of healthcare or treatment to comply with legal or statutory obligations and to establish, exercise, or defend our legal claims and rights in preparation for or to perform a contract to protect vital interests or in the public interest for reasons of public health, including ensuring high standards of quality and safety of healthcare and medical devices for scientific or historical research or statistical purposes. In circumstances where we have requested and received consent, including for the use of certain Products and Services, and for other purposes that may be required or allowed by law*	Zimmer Biomet, our affiliates, subsidiaries and related companies Healthcare Providers your company/employer your patients your references and third parties that assist us in conducting background checks individuals or entities that you designate or instruct us to share your Personal Data with authorised representatives, family members and carers third parties who assist with fraud prevention, detection and mitigation third parties who assist with our information technology and security programmes and our loss prevention programmes Zimmer Biomet’s lawyers, auditors and consultants partners that assist us in providing the Products or Services or help us improve our marketing or administration Ethics committees External auditors Public authorities and governmental bodies
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 these types of Personal Data:	We obtain this Personal Data from:	We process this Personal Data for the following purposes:	We process this Personal Data under the following legal bases:	We may share this Personal Data with**:
Identity and Contact Information, such as: name and surname or unique pseudonym honorifics and titles, preferred form of address employer/company email address postal address phone number username or code and password^, security answers^ and user preferences contact information for related persons, such as authorised users of your account or designated representatives National Provider Identifier (NPI) number Social Security Number (SSN)^ signature Other Personal Information, such as: Age Preferred language gender marital status disability^ ethnicity^ date of birth Technical Information, such as: Internet Protocol (IP) addresses (which may identify your general geographic location or company) 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 and online behaviour while on our Products and Services and referring websites or applications, including forms and other information submitted, videos watched, your clicks on our site pages, and product descriptions read data collected from cookies or other similar technologies geolocation information**** Professional and Educational Information, such as: job title or position your employer, company with which you are associated, or principal working location National Provider Identifier (NPI) number State medical license number work skills employment history graduate degrees certifications professional memberships specialised training responses to surveys and questionnaires information from references background checks^ Anonymised / De identified Data Anonymised 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***	you directly your employer, company with which you are associated, or principal your references and third parties that assist us in conducting background checks those authorised to provide Personal Data on your behalf your devices our security systems (including CCTV) third parties that provide access to information you make available, such as social media companies companies conducting non-clinical research such as market research companies our business partners or other third parties that assist us in providing and improving our Products and Services and in hiring employees and contractors	to communicate with you to administer our relationship to send you updated, including with respect to updates on new employment opportunities to identify and authenticate you to detect security incidents to protect against malicious, fraudulent, or illegal activity for short-term, transient use for administrative purposes for internal research and development to evaluate the effectiveness or improve our Products and Services and to develop new products and services to procure third-party products and services, including to manage and satisfy related third-party contractual obligations for marketing, advertising and promotion, including to contact you regarding programmes, Products and Services, and topics that may be of interest or useful to you	for the purposes of our legitimate interests in preparation for or to perform a contract with you to comply with legal and regulatory obligations and to establish, exercise, or defend our legal claims and rights in circumstances where we have requested and received consent and for other purposes that may be required or allowed by law*	Zimmer Biomet, our affiliates, subsidiaries and related companies your references individuals or entities that you designate or instruct us to share your Personal Data with third parties who assist with fraud prevention, detection and mitigation third parties who assist with our information technology and security programmes and our loss prevention programmes third parties who assist us in hiring and conducting background checks. Zimmer Biomet’s lawyers, auditors and consultants partners that assist us in providing the Products or Services or help us improve our marketing or administration
Business Partners and Their Employees, Agents and Contractors We may process your Personal Data when you are a current or former business partner or an employee, agent, or contractor of a Zimmer Biomet business partner, including collaboration partners, key opinion leaders and vendors, suppliers of Zimmer Biomet.
We process these types of Personal Data:	We obtain this Personal Data from:	We process this Personal Data for the following purposes:	We process this Personal Data under the following legal bases:	We may share this Personal Data with**:
Identity and Contact Information, such as: name and surname or unique pseudonym honorifics and titles, preferred form of address employer/company email address postal address phone number username or code and password^, security answers^ and user preferences customer number company ID number such as account number National Provider Identifier (NPI) number signature Other Personal Information, such as: age gender marital status preferred language disability^ date of birth Technical information, such as: Internet Protocol (IP) addresses (which may identify your general geographic location or company) 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 and online behaviour while on our Products and Services and referring websites or applications, including forms and other information submitted, videos watched, your clicks on our site pages, and product descriptions read data collected from cookies or other similar technologies geolocation information**** Commercial and Financial Information, such as: Products and Services purchased, obtained, or considered request documentation customer service records financial transaction history financial account number bank account number and details^ other payment information tax identification number^ Professional and Educational Information, such as: job title or position your employer, company with which you are associated, or principal working location National Provider Identifier (NPI) number state medical license number work skills employment history graduate degrees certifications professional memberships specialised training responses to surveys and questionnaires enrolment and attendance history for our education and training events records of collaborations with Zimmer Biomet, such as consulting and other engagements information from references background checks^ Anonymised / De identified Data Anonymised 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***	you directly your employer, company with which you are associated, or principal your references and third parties that assist us with background checks your devices our security systems (including CCTV) third parties that provide access to information you make available, such as social media companies companies conducting non-clinical research such as market research companies business partners or other third parties that assist us in providing and improving our Products and Services Healthcare Providers clinical investigators and/or members of investigator teams patients	to provide you with our Products and Services to communicate with you to administer our relationship with your organisation to send you updates to identify and authenticate you to customise content for you and tailor your experience when using our Products and Services to detect security incidents to protect against malicious, fraudulent 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 internal research and development to evaluate the effectiveness of and improve our Products and Services and to develop new products and services for quality assurance and to assist in training and development of our representatives in connection with adverse event and complaint tracking and reporting for marketing, advertising and product promotion, including to contact you regarding programmes, Products and Services, and topics that may be of interest to procure third-party products and services, including to manage and satisfy related third-party contractual obligations to comply with legal and regulatory obligations	for the purposes of our legitimate interests for medical diagnosis and the provision of healthcare or treatment to comply with legal and regulatory obligations and to establish, exercise, or defend our legal claims and rights in preparation for or to perform a contract with you for reasons of public health, including ensuring high standards of quality and safety of healthcare and medical devices for scientific or historical research or statistical purposes in circumstances where we have requested and received consent and for other purposes that may be required or allowed by law*	Zimmer Biomet, our affiliates, subsidiaries and related companies Healthcare Providers patients your company / employer your references authorised legal representatives third parties who assist with fraud prevention, detection and mitigation third parties who assist with our information technology and security programmes and our loss prevention programmes third parties who assist us in hiring and conducting background checks. Zimmer Biomet’s lawyers, auditors and consultants partners that assist us in providing the Products or Services or help us improve our marketing or administration
Attendees and Participants at Zimmer Biomet Events We may process your Personal Data when you attend or participate in professional and educational events or conferences we sponsor or hold.
We process these types of Personal Data:	We obtain this Personal Data from:	We process this Personal Data for the following purposes:	We process this Personal Data under the following legal bases:	We may share this Personal Data with**:
Identity and Contact Information, such as: name and surname or unique pseudonym honorifics and titles, preferred form of address employer/company email address postal address phone number username or code and password^, security answers^ and user preferences contact information for related persons, such as authorised users of your account or designated representatives customer number company ID number such as account number National Provider Identifier (NPI) number signature Other Personal Information, such as: age gender marital status preferred language disability^ date of birth Video, Audio and Recorded Information, such as: still images video (including via CCTV) Technical Information, such as: Internet Protocol (IP) addresses (which may identify your general geographic location or company) 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 and online behaviour while on our Products and Services and referring websites or applications including forms and other information submitted, videos watched, your clicks on our site pages and product descriptions read data collected from cookies or other similar technologies geolocation information**** Commercial and Financial Information, such as: Products and Services purchased, obtained, or considered bank account number and details^ request documentation financial transaction history financial account number^ other payment information tax identification number^ Professional and Educational Information, such as: job title or position your employer, company with which you are associated or principal working location National Provider Identifier (NPI) number State medical license number work skills employment history graduate degrees certifications specialised training responses to surveys and questionnaires enrolment history for our education and training events records of collaborations with Zimmer Biomet, such as consulting and other engagements Anonymised / De identified Data Anonymised 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***	you directly Healthcare Providers your employer, company with which you are associated, or principal those authorised to provide Personal Data on your behalf your devices our security systems (including CCTV) third parties that provide access to information you make available, such as social media companies companies conducting non-clinical research such as market research companies our business partners or other third parties that assist us in providing and improving our Products and Services	to register you for the event or conference and other attendance-related purposes to communicate with you to administer our relationship with your organisation to send you updates to identify and authenticate you to detect security incidents to protect against malicious, fraudulent, or illegal activity for short-term, transient use for administrative purposes for internal research and development to evaluate the effectiveness of and improve our Products and Services and to develop new products and services for marketing, advertising and promotion, including to contact you regarding programmes, Products and Services, and topics that may be of interest or useful to you to comply with legal and regulatory obligations	for the purposes of our legitimate interests in preparation for or to perform a contract with you to comply with legal and regulatory obligations and to establish, exercise, or defend our legal claims and rights for scientific or historical research or statistical purposes in circumstances where we have requested and received consent and for other purposes that may be required or allowed by law*	Zimmer Biomet, our affiliates, subsidiaries and related companies Healthcare Providers Your company/employer Other third parties attending the Event individuals or entities that you designate or instruct us to share your Personal Data with third parties who assist with fraud prevention, detection and mitigation third parties who assist with our information technology and security programmes and our loss prevention programmes Zimmer Biomet’s lawyers, auditors and consultants Partners that assist us in providing or improving our Events, Products and Services or help us improve our marketing or administration
Clinical Investigators and Members of Investigator Teams We may process your Personal Data if you are an existing or prospective clinical investigator or a member of an investigation team for a clinical study that Zimmer Biomet sponsors.
We process these types of Personal Data:	We obtain this Personal Data from:	We process this Personal Data for the following purposes:	We process this Personal Data under the following legal bases:	We may share this Personal Data with**:
Identity and Contact Information, such as: name and surname or unique pseudonym honorifics and titles, preferred form of address employer / company email address postal address phone number username or code and password^, security answers^ and user preferences contact information for related persons, such as authorised users of your account or designated representatives customer number company ID number such as account number National Provider Identifier (NPI) number Social Security Number (SSN)^ signature Other Personal Information, such as: age gender preferred language disability^ date of birth Visual, Audio and Recorded Information, such as: still images video (including via CCTV) voicemails recordings of your interactions with our Online Services, whether through email, SMS/text message, or chat pictures and videos of treatment activities Technical Information, such as: Internet Protocol (IP) addresses (which may identify your general geographic location or company) 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 and online behaviour while on our Products and Services and referring websites or applications, including forms and other information submitted, videos watched, your clicks on our site pages, and product descriptions read data collected from cookies or other similar technologies geolocation information**** Commercial and Financial Information, such as: bank account number and details^ customer service records financial transaction history financial account number^ other payment information Professional and Educational Information, such as: job title or position your employer, company with which you are associated, or principal working location National Provider Identifier (NPI) number state medical license number work skills employment history graduate degrees certifications specialised training responses to surveys and questionnaires enrolment history for our education and training events records of collaborations with Zimmer Biomet, such as consulting and other engagements information from references background checks^ Product Usage Information, such as: technical and surgical data (pre-, intra- and post-operative) derived from your use of certain Products or Services date and time you use our Products and Services, including the Products and Services used Anonymised / De identified Data Anonymised and/or de-identified 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***	you directly Healthcare Providers your employer, company with which you are associated, or principal your devices those authorised to provide Personal Data on your behalf your references and third parties that assist us in conducting background checks our security systems (including CCTV) third parties that provide access to information you make available, such as social media companies companies conducting non-clinical research such as market research companies business partners or other third parties that assist us in providing and improving our Products and Services patients other clinical investigators and/or members of investigator teams	to determine your suitability to the role to assist us with running the clinical trial to communicate with you to administer our relationship with your organisation to send you updates to identify and authenticate you to customise content for you and tailor your experience when using our Products and Services to detect security incidents to protect against malicious, fraudulent, 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 internal research and development to evaluate the effectiveness of and improve our Products and Services and to develop new products and services for quality assurance and to assist in training and development of our representatives in connection with adverse event and complaint tracking and reporting to procure third-party products and services, including to manage and satisfy related third-party contractual obligations to comply with legal and regulatory obligations	for the purposes of our legitimate interests in preparation for or to perform a contract with you to comply with legal and regulatory obligations and to establish, exercise, or defend our legal claims and rights to protect vital interests or in the public interest for reasons of public health, including ensuring high standards of quality and safety of healthcare and medical devices for scientific or historical research or statistical purposes in circumstances where we have requested and received consent and for other purposes that may be required or allowed by law*	Zimmer Biomet, our affiliates, subsidiaries and related companies Healthcare Providers other clinical investigators and/or members of investigator teams your company / employer your reference individuals or entities that you designate or instruct us to share your Personal Data with third parties who assist us in hiring and conducting background checks. third parties who assist with fraud prevention, detection and mitigation third parties who assist with our information technology and security programmes and our loss prevention programmes Zimmer Biomet’s lawyers, auditors and consultants Patients and their authorised representatives, family members and carers third parties that assist us in choosing clinical trial investigators partners that assist us in providing the Products or Services or help us improve our marketing or administration
Clinical Study Candidates We may process your Personal Data to determine whether you qualify for or would be interested in participating in a clinical trial and when you have been identified as a potential candidate for clinical studies sponsored by us. If you are a participant in a clinical study or clinical trial, you should receive a separate privacy notice regarding the Personal Data we process for those purposes. That privacy notice – and not this Notice – governs our processing of such Personal Data once you are chosen for and participating in a trial.
We process these types of Personal Data:	We obtain this Personal Data from:	We process this Personal Data for the following purposes:	We process this Personal Data under the following legal bases:	We may share this Personal Data with**:
Identity and Contact Information, such as: name and surname or unique pseudonym honorifics and titles, preferred form of address employer / company email address postal address phone number username or code and password^, security answers^ and user preferences contact information for related persons, such as authorised users of your account or designated representatives signature Other Personal Information, such as: age gender preferred language marital status disability^ ethnicity^ date of birth Visual, Audio and Recorded Information, such as: still images video (including via CCTV) voicemails recordings of your interactions with our Online Services, whether through email, SMS/text message, or chat Technical Information, such as: Internet Protocol (IP) addresses (which may identify your general geographic location or company) 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 and online behaviour while on our Products and Services and referring websites or applications, including forms and other information submitted, videos watched, your clicks on our site pages and product descriptions read^ data collected from cookies or other similar technologies geolocation information**** Health Information, such as: identification of pathologies/diseases^ areas of interest in medical research^ medical history and treatment information^ drug allergies^ health values taken, such as heart rate and blood pressure^ pregnancy status^ location data^ Commercial and Financial Information, such as: Products and Services purchased, obtained, or considered bank account number and details^ request documentation customer service records financial transaction history financial account number^ other payment information Anonymised / De identified Data Anonymised and/or de-identified 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***	you directly Healthcare Providers those authorised to provide Personal Data on your behalf your devices our security systems (including CCTV) third parties that provide access to information you make available, such as social media companies companies conducting non-clinical research such as market research companies business partners or other third parties that assist us in providing and improving our Products and Services clinical investigators and/or members of investigator teams	to determine your suitability and eligibility for participating in a clinical trial and to determine your interest in participating in a clinical trial to communicate with you to administer our relationship with you to send you updates to identify and authenticate you to customise content for you and tailor your experience when using our Products and Services to detect security incidents to protect against malicious, fraudulent, 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 internal research and development to evaluate the effectiveness of and improve our Products and Services and to develop new products and services for quality assurance and to assist in training and development of our representatives in connection with adverse event and complaint tracking and reporting for marketing, advertising and product promotion, including to contact you regarding programmes, Products and Services and topics that may be of interest or useful to you to comply with legal and regulatory obligations	for the purposes of our legitimate interests in preparation for or to perform a contract with you to comply with legal and regulatory obligations and to establish, exercise, or defend our legal claims and rights to protect vital interests or in the public interest for reasons of public health, including ensuring high standards of quality and safety of healthcare and medical devices for scientific or historical research or statistical purposes in circumstances where we have requested and received consent and for other purposes that may be required or allowed by law*	Zimmer Biomet, our affiliates, subsidiaries and related companies Healthcare Providers Clinical investigators and/or members of investigator teams individuals or entities that you designate or instruct us to share your Personal Data with partners that assist us in providing the Products or Services or help us improve our marketing or administration
Children Zimmer Biomet may process Personal Data of minors who are users of a Zimmer Biomet Product. In those instances, Zimmer Biomet seeks consent from the minor’s parents or legal guardians to process their Personal Data. Zimmer Biomet does not knowingly collect, maintain, disclose, or otherwise process Personal Data from minors below the age of 16 in other circumstances, including through Online Services or Interactions. The below relates solely to the use of Personal Data of children who are users of a Zimmer Biomet Product and whose parents or legal guardians have given consent.
We process these types of Personal Data:	We obtain this Personal Data from:	We process this Personal Data for the following purposes:	We process this Personal Data under the following legal bases:	We may share this Personal Data with**:
Identity and Contact Information, such as: name and surname or unique pseudonym honorifics and titles, preferred form of address email address postal address phone number username or code and password^, security answers^ and user preferences contact information for related persons, such as authorised users of your account or designated representatives Other Personal Information, such as: age gender preferred language disability^ ethnicity^ date of birth Visual, Audio and Recorded Information, such as: still images video (including via CCTV) recordings of your calls with our customer service representatives voicemails recordings of your interactions with our Online Services, whether through email, SMS/text message, or chat pictures and videos of treatment activities^ Technical Information, such as: Internet Protocol (IP) addresses (which may identify your general geographic location or company) 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 and online behaviour while on our Products and Services and referring websites or applications, including forms and other information submitted, videos watched, your clicks on our site pages and product descriptions read^ data collected from cookies or other similar technologies geolocation information**** Health Information, such as: identification of pathologies/diseases^ identification number associated with your Products ^ areas of interest in medical research^ treatment dates^ medical history and treatment information^ patient-reported outcome measures (for example, responses to questionnaires and surveys about your health or treatment) ^ DICOM, X-rays, magnetic resonance imaging and medical scans^ user activity^ therapy completion and use details^ communications with your Healthcare Provider, including audio, video, or other recordings from telehealth sessions^ drug allergies^ prescriptions and dosing^ health values taken, such as heart rate and blood pressure^ adverse event information^ health insurance information and other information on payment for healthcare services^ pregnancy status^ contact information for designated recipients of your health information location data^ pictures and videos of treatment activities^ patient ID number^ Commercial and Financial Information, such as Products and Services purchased, obtained, or considered Anonymised / De identified Data Anonymised and/or de-identified 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***	you directly Healthcare Providers Clinical investigators and/or members of investigator teams those authorised to provide Personal Data on your behalf your devices our security systems (including CCTV) third parties that provide access to information you make available, such as social media companies companies conducting non-clinical research such as market research companies business partners or other third parties that assist us in providing and improving our Products and Services	to provide you with our Products and Services to communicate with you to administer our relationship with you to send you updates to identify and authenticate you to detect security incidents to protect against malicious, fraudulent, 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 internal research and development to evaluate the effectiveness of and improve our Products and Services and to develop new products and services for quality assurance and to assist in training and development of our representatives to determine and verify Products and Services eligibility and coverage in connection with adverse event and complaint tracking and reporting to procure third-party products and services, including to manage and satisfy related third-party contractual obligations for marketing, advertising and product promotion, including to contact you regarding programmes, Products and Services, and topics that may be of interest or useful to comply with legal and regulatory obligations	for the purposes of our legitimate interests for medical diagnosis or to provide healthcare or treatment in preparation for or to perform a contract with you to comply with legal and regulatory obligations and to establish, exercise, or defend our legal claims and rights to protect vital interests or in the public interest for reasons of public health, including ensuring high standards of quality and safety of healthcare and medical devices for scientific or historical research or statistical purposes in circumstances where we have requested and received consent and for other purposes that may be required or allowed by law*	Zimmer Biomet, our affiliates, subsidiaries and related companies Healthcare Providers clinical investigators and/or members of investigator teams individuals or entities that you designate or instruct us to share your Personal Data with authorised representatives, family members and carers third parties who assist with fraud prevention, detection and mitigation third parties who assist with our information technology and security programmes and our loss prevention programmes Zimmer Biomet’s lawyers, auditors and consultants 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, merger, consolidation, corporate reorganisation, or transfer, to the buyer, assignee, or transferee; and, (2) government or regulatory officials, law enforcement, courts, public authorities, 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 de-identified. We will not attempt to re-identify you or anyone else from this de-identified data, and if we disclose it to third parties, we will require that they not attempt to re-identify you or anyone else from the de-identified data.

****Geolocation information may be either provided by you or collected automatically (see section ‘Marketing, Cookies and Analytics’). This information may include your IP address and/or geographic location (such as longitude, latitude, city, state, zip or postcode).

Selling and Sharing Your Personal Data

We allow certain third parties to collect information about the users of our Products and Services to provide valuable services to us, such as fraud detection and reporting, analytics and advertising services, including cross-contextual behavioural advertising. This may include sharing information about your interactions with our Products and Services, including information about videos you may watch in connection with our Products and Services and disease, treatment, Healthcare Provider, or other information searched for or viewed in connection with our Products and Services for the purposes of providing you with information and advertising related to your searches, queries, or other interactions with our Products and Services. These activities may be considered a ‘sale’ or ‘sharing’ under some laws. To opt-out of any sale or sharing of Personal Data, please contact us as described in the section below titled ‘Your Rights Regarding Your Personal Data’.

Marketing, Cookies and Analytics

To the extent permitted by law, including with your consent where required, we may engage in the following activities:

We may use your contact details to contact you to determine whether you would like to initiate a business relationship with us or to send you marketing emails. You may unsubscribe from any marketing or promotional emails. To do so, please email us at websupport@zimmerbiomet.com or use the unsubscribe mechanism offered in our marketing emails or other communications, as applicable. Please note that if you already have requested our Products or Services when you decide to withdraw consent, a short period of time may elapse before we can update your preferences and ensure that we honour your request.
We may collect Personal Data automatically through cookies and other technologies to provide functionality to our Products and Services; to recognise you across devices when using our Products and Services; in each case where this is justified under applicable data protection law for our legitimate business purposes or with consent, where required. These legitimate business purposes include evaluating information about the use of our Products and Services and identifying trends; developing or enhancing our Products and Services; providing an experience tailored to you when you use our Products and Services; effecting certain security controls; and, identifying the advertisements and offers we think may interest you so that we may display them to you when you use our Products and Services.
We may display advertisements to you regarding Products and Services that we believe are relevant to you based on your activities while using our Products or Services or on other web or digital properties. Such advertisements may be shown to you while you are using our Products or Services or while you are using the online services of others. We achieve this by using and allowing third parties (including social media companies) to use certain cookies, eTags, pixels, web beacons and other tracking technologies such as Google Analytics to track your activities while using our Products or Services or while using other online services. For more information about these activities and how to manage or opt out of them, please see our Cookie Notice or contact us.
We may make offers to you based on your activities or interactions with Zimmer Biomet that are not through online Products and Services (for example, regional offers based on the location of your office listed on order forms).
We also perform statistical analyses of the users of our Products and Services to improve the functionality, content, design and navigation of the Products and Services, and to market the Products and Services.

You may be able to opt out of or revoke your consent to, as applicable, receiving web-based personalised advertisements from companies who are members of the Network Advertising Initiative by going to http://optout.networkadvertising.org/?c=1 or participate in the Digital Advertising Alliance Self-Regulatory Programme by going to http://www.aboutads.info/.

Public Interactive Features of our Websites

To the extent we offer any public or group forums on our Products or Services, such as news feeds, blogs, message boards, or similar tools (‘Interactive Features’), the posts or comments you make may be public and viewed by others. You should use care before posting information about yourself, including Personal Data. Because these are public postings, you should have no expectation of privacy or confidentiality in the content you submit to Interactive Features in connection with the Products and Services. Your disclosure of any Personal Data through the Interactive Features is at your own risk. Based on your disclosure of Personal Data through the Interactive Features we may use anonymised and/or de-identified 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

Third Parties

Service Providers

Service providers or vendors (or processors) acting on our behalf must execute agreements requiring them to maintain confidentiality and to process Personal Data only to provide the services to us and in a way that aligns with this Notice, other applicable privacy notices and as explicitly permitted or required by applicable laws, rules and regulations.

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 and third-party data repositories such as data brokers.

Links to Other Websites

Our Products or Services may contain links to other websites, applications, products, or services that are not owned or operated by Zimmer Biomet, such as social media websites and applications like Facebook and Twitter. Such links do not imply an endorsement with respect to any third-party, any website, or the products or services provided thereby. You should carefully review the privacy policies and practices of other websites, products and services as we cannot control and are not responsible for privacy policies, notices, or practices of third-party websites, applications, products and services.

Safeguarding Information

Consistent with applicable laws and requirements, Zimmer Biomet has put in place physical, technical and administrative safeguards to protect Personal Data from loss, misuse, alteration, theft, unauthorised access and unauthorised disclosure, consistent with legal obligations and industry practices. However, as is the case with all websites, apps, products and services, we unfortunately are not able to guarantee security for data collected through our Products and Services. In addition, it is your responsibility to safeguard any passwords, identification or ID numbers, or similar individual information associated with your use of the Products and Services.

Your Rights Regarding Your Personal Data

Depending on where you live, you may have the following rights with respect to some or all of your Personal Data:

To exercise the rights described under the section above titled ‘Selling and Sharing Your Personal Data’;
To request information about whether and how we process your Personal Data;
to request access to and a copy of your Personal Data including to provide your Personal Data directly to another organisation (called, in some locations, a right to data portability) (including under GDPR Articles 15 and 20);
to request that we correct or update your Personal Data (including under GDPR Article 16);
to request that we delete your Personal Data (including under GDPR Article17);
to request that we restrict or block or to object to or opt-out of the processing of your Personal Data, including your sensitive Personal Data (including under GDPR Articles 18, 21 and 22), or to revoke your consent (including under GDPR Article 7);
to appeal the denial of a request; and
to lodge a complaint with the data protection authority in your jurisdiction.

To exercise these rights, appeal the denial of one of your requests, or make a complaint about how we process your Personal Data, please submit a request using the Privacy Request Form, write at privacy.global@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 the section ‘Contact Us’ and in Appendix 1 to this Notice.

Zimmer Biomet will not discriminate against you for exercising any of the rights described above, although we may not be able to continue to provide you with certain Products and Services or it may otherwise affect the way we are able to interact with you.

Please note that after receiving your request, we may require additional information from you or your authorised agent to honour your request and may deny your request if we cannot verify your identity or status. Please be aware that we may be unable to afford these rights to you under certain circumstances, such as if we are legally prevented from doing so.

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.

When we receive your Personal Data from others, including your Healthcare Provider, and process your Personal Data on their behalf, we may do so at their request and subject to their instructions. In that case, we do not have control over their privacy and security practices and processes. If your Personal Data has been submitted to us by a third-party, we may need to ask you to contact them directly or we may be able to contact them on your behalf. If we need you to contact them directly, we will let you know.

Transfer of Personal Data Across National Borders

Please be aware that Personal Data we collect and process may be transferred and maintained outside your state, province, country, or other jurisdiction, where the privacy laws may not be as protective as those in your location, including the United States. In particular, Zimmer Biomet may disclose Personal Data to the countries listed in Appendix 1, the list of data controllers. Zimmer Biomet has put in place lawful transfer mechanisms and appropriate safeguards, in accordance with applicable legal requirements, to protect your Personal Data, including but not limited to entering into agreements with third parties, such as service providers, to require them to adopt standards that ensure an equivalent level of protection for data as those we adopt.

Zimmer Biomet’s privacy practices, described in this Privacy Policy, comply with the APEC Cross Border Privacy Rules System. The APEC CBPR system provides a framework for organisations to ensure protection of personal information transferred among participating APEC economies. More information about the APEC framework can be found here: www.cbprs.org.

Click here to view our certification/verification status.

Special Note for Individuals Located in Japan

If you are located in Japan, the following sections also apply to you:

Joint Use of Personal Data

Zimmer Biomet may use your Personal Data jointly with any subsidiary or affiliate of Zimmer Biomet Holdings, Inc. as described here. Personal Data subject to joint use: The personal information indicated in ‘Personal Data, Collection, Purposes, Source and Recipients’. Range of joint users: Zimmer Biomet Holdings, Inc., and its subsidiaries and affiliates (please refer to Appendix 1 for the specific names of the subsidiaries and affiliates). Joint users’ purposes of use: The purposes described in ‘Personal Data, Collection, Purposes, Source and Recipients’. Party responsible for managing your Personal Data: Zimmer Biomet Holdings, Inc.

Acquisition of Personally Referable Information:

Zimmer Biomet may acquire personally referable information (for example, browsing history, purchase history, service usage history, OS and other device information, cookie IDs, advertising identifiers, IP addresses and other online identifiers) obtained from other companies, such as advertising companies, affiliates and companies that are related to advertising things such as DMP companies, as Personal Data by linking it to the Personal Data that Zimmer Biomet already possess and use such personally referable information in accordance with the purposes of use described in ‘Personal Data, Collection, Purposes, Source and Recipients’.

Additional Notes for Mainland China

Processing Method

Personal Data may be processed in various methods including, without limitation, collection, storage, use, transmission, provision, disclosure and deletion, as stipulated under the Personal Information Protection Law of China (the PIPL).

The necessity of processing your sensitive Personal Data and the impact it has on your rights and interests

Our processing of your sensitive Personal Data described herein is necessary for:

Providing Products and Service, and fulfilling other purposes described above in each different scenarios;
Performing accounting, audit, internal investigations and other internal reviews;
Complying with all applicable laws, legal processes and internal policies; and
Otherwise accomplishing our business purposes and objectives.

Our processing of your sensitive Personal Data will not impact on your individual rights and interests as described in Section ‘Your Rights Regarding Your Personal Information’ of this Notice. These rights may be limited by law and regulations for certain purposes, including for the establishment, exercise, or defence of legal claims. Our processing of your sensitive Personal Data will be limited to the minimal level that is necessary to accomplish specific purposes as described above, and will be subject to the physical, technical and organisational measures for special data protection in accordance with the PIPL and other applicable Chinese data protections laws and regulations.

Zimmer Biomet has conducted necessary security assessment and privacy impact assessment for cross-border transfer for the collection and processing of your sensitive Personal Data in accordance with relevant Chinese data protection laws and regulations.

EU-U.S. Data Privacy Framework

Zimmer Biomet Holdings, Inc., in addition to all U.S. entities listed in Appendix 1 except CD Laboratories, Inc., complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. Zimmer Biomet has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of Personal Data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF. Zimmer Biomet has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of Personal Data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles, the UK Extension to the EU-U.S. DPF, and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the DPF programme, and to view our certification, please visit https://www.dataprivacyframework.gov/.

Onward Transfer to Third Parties

Zimmer Biomet shall remain liable under the DPF Principles if its agent(s) processes Personal Data in a manner inconsistent with the DPF Principles, unless Zimmer Biomet proves that it is not responsible for the event giving rise to the damage.

Recourse, Enforcement and Liability

In compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, Zimmer Biomet commits to resolve DPF Principles-related complaints about our collection and use of your Personal Data. EU, UK and Swiss individuals with enquiries or complaints regarding our handling of Personal Data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF should first contact Zimmer Biomet at: privacy.global@zimmerbiomet.com.

In compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, Zimmer Biomet commits to refer unresolved complaints concerning our handling of Personal Data received in reliance on the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF to JAMS, an alternative dispute resolution provider based in the United States. If you do not receive timely acknowledgement of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit https://www.jamsadr.com/DPF-Dispute-Resolution for more information or to file a complaint. The services of JAMS are provided at no cost to you.

Individuals may, under certain conditions, invoke binding arbitration for complaints regarding DPF compliance not resolved by any of the above DPF mechanisms. For more information, please visit: https://www.dataprivacyframework.gov/framework-article/ANNEX-I-introduction.

The Federal Trade Commission has jurisdiction over Zimmer Biomet’s compliance with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF).

Marketing and Promotional Emails

You may unsubscribe from any marketing or promotional emails. To do so, please email us at websupport@zimmerbiomet.com or use the unsubscribe mechanism offered in our marketing emails or other communications, as applicable. Please note that if you already have requested our Products or Services when you decide to withdraw consent, a short period of time may elapse before we can update your preferences and ensure that we honour your request.

How Long Your Personal Data Will Be Retained

We generally retain Personal Data for as long as needed for the specific purpose or purposes for which it was collected or obtained and as outlined in this Notice. In some cases, we may be required to retain Personal Data for a longer period of time by law or for other necessary or required purposes. Whenever possible, we aim to de-identify or anonymise your Personal Data or otherwise remove some or all information that may identify you from records that we may need to keep for periods beyond the specified retention period. The criteria used to determine our retention periods include: (i) the length of time we have an ongoing relationship with you; (ii) whether there is a legal obligation to which we are subject that affects the length of time we need to keep your Personal Data; and (iii) whether retention is determined to be necessary for Zimmer Biomet due to limitation periods, litigation, or other legal or regulatory obligations. Zimmer Biomet takes reasonable steps to dispose of Personal Data upon the expiration of retention periods, taking into consideration these litigation, legal, or regulatory obligations.

Special Note to Patients in the United States

If you are a U.S. patient, please note that this Notice is distinct from your Healthcare Provider’s HIPAA Notice of Privacy Practices, which describes how your Healthcare Provider uses and discloses individually identifiable information about your health that it collects, as well as any other privacy practices it applies. Zimmer Biomet collects, uses and discloses Personal Data it receives on behalf of your Healthcare Provider in accordance with your Healthcare Provider’s HIPAA Notice of Privacy Practices.

Changes to This Privacy Notice

This privacy notice is effective as of the date last updated, as indicated below. We may update this Notice from time to time without notice. As such, you should review this Notice periodically. Your continued interactions with us and/or the use of our Products and Services subject to this Notice constitutes your agreement 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.global@zimmerbiomet.com or write to us at Zimmer Biomet, Attn: Global Privacy Officer, 345 East Main Street, Warsaw, IN 46580, United States. You may contact the data protection officer directly at dataprotectionofficer@zimmerbiomet.com.

For more contact details for your country of residence, please refer to Appendix 1 to this Notice.

Updated: July 2024

Appendix 1 – List of data controllers and contact details for data protection questions or to exercise your rights regarding your personal information

Country	Name	Address
Australia	Zimmer Biomet Pty Ltd	Level 3, 12 Narabang Way, Belrose, NSW, 2085, Australia
Austria	Zimmer Biomet Austria GmbH	Euro Plaza, Lehrbachgasse 13, 1120 Wien, Austria
Belgium	Zimmer Biomet BV	Park Lane A, Culliganlaan 2A, 1831 Diegem, Belgium
Brazil	WM World Medical Importacao e Exportacao Ltda.	Rua Do Rezende 189, Rio De Jeneiro- RJ, 20230 -050 Brazil
Brazil	Zimmer Biomet Brasil Ltda.	Rua Machado Bittencourt 361, 13º andar, Vila Clementino, CEP 04044-001 São Paulo, Brazil
Canada	ORTHOSoft ULC	75 Rue Queen #3300, Montreal, QC QC H3C, Canada
Canada	Zimmer Biomet Canada, Inc.	2323 Argentia Road, Mississauga, ON L5N 5N3, Canada
Chile	Biomet Chile S.A.	Av. Santa Clara, 085, piso 7, Huechuraba, Santiago, Chile
China	Beijing Montagne Medical Device Co., Ltd.	Building #1, No. 21 Boxing 6th Road, Beijing Economic-Technological Development Area, Beijing, 100176, People’s Republic of China
China	Changzhou Biomet Medical Device Co. Ltd.	No. 235, Chuangxin Avenue, Xin Bei District, , Changzhou, 213031, People’s Republic of China
China	Shanghai Biomet Business Consulting Co., Ltd	Unit 02-03, 42/F, No. 580, West Nanjing Road, Shanghai, People’s Republic of China
China	Zhejiang Biomet Medical Products Co. Ltd.	980, Shenli Road, Jinhua City, Zhejiang Province 321016, People’s Republic of China
China	Zimmer (Shanghai) Medical International Trading Co.	1/F, 129 North Fute Road, China (Shanghai) Pilot Free Trade Zone, 200131, People’s Republic of China
China	Zimmer (Shanghai) Medical International Trading Co., Ltd Beijing Branch	Unit 03-05, 12/F, Tower A, Borui Building, No. 26 North Road, East 3rd Ring, Chao Yang District Beijing, People’s Republic of China
Colombia	Zimmer Biomet Colombia S.A.S	Cra 7 # 123-35 Torre 123 Piso 7, Bogota D.C., Colombia
Costa Rica	Zimmer Biomet Centroamérica SA	Oficentro Ejecutivo La Sabana Torre 7, piso 3, San José, Costa Rica
Czech Republic	Zimmer Czech, s.r.o.	Na strži 2097/63, 140 00 Praha 4, Czech Republic
Denmark	Zimmer Biomet Denmark ApS	Herstedvang 12, 2620 Albertslund, Denmark
Finland	Zimmer Biomet Finland Oy	Bertel Jungin aukio 1, Espoo, 02600, Finland
France	Biomet France Sàrl	Plateau de Lautagne, 26000 Valence, France
France	MedTech SA	432 rue du Rajol, 34130 Mauguio, France
France	Zimmer Biomet France SAS	70, rue du Chanoît, 25600 Brognard, France
Germany	Biomet Deutschland GmbH	Gustav-Krone-Strasse 2, 14167 Berlin, Germany
Germany	Zimmer Biomet Deutschland GmbH	Max-Immelmann-Allee 12, 79427 Eschbach, Germany
Germany	Zimmer International Logistics GmbH	Max-Immelmann-Allee 12, 79427 Eschbach, Germany
Greece	ZIMMER BIOMET HELLAS TRADING AND INDUSTRIAL SINGLE MEMBER SOCIETE ANONYME OF MEDICAL AND PHARMACEUTICAL GOODS	Parnithos 44, 14452 Metamorphosi, Greece
Hong Kong	Zimmer Asia (HK) Limited	Unit 807-811, 8/F, Tins Enterprises Centre, 777 Lai Chi Kok Road, Kowloon, Hong Kong
India	Zimmer India Pvt Ltd	Vanijya Kunj, Enkay Towers, Unit No 6, 6th Floor, Udyog Vihar, Phase V, Gurgaon – 122016, Haryana, India
Ireland	Zimmer Orthopedics Manufacturing Ltd.	Arthur Cox Building, Earlsfort Terrace, Dublin 2, Ireland
Israel	Zimmer Biomet Medical Israel Limited	Ha’Eshel 1 St. Caesarea, Building B, P.O.B 3531, Tel Aviv, Israel
Italy	Zimmer Biomet Italia S.r.l.	Via SAN BOVIO 3, 20090 SEGRATE (MI), Italy
Japan	Zimmer Biomet G.K.	11-1, Shibakoen 2-chome, Minato-ku, Tokyo, Japan
Malaysia	Zimmer Medical (Malaysia) Sdn Bhd	Menara Symphony, 01-18, 18th Floor, No 5 Jalan Prof. Khoo Kay Kim, Seksyen 13, 46200 Petaling Jaya, Selangor Darul Ehsan, Malaysia
Mexico	Biomet Mexico S.A. de C.V.	Avenida Periferico Sur #4829-401, Colonia Parques del Pedregal, Zip Code 14010, Delegacion Tlalpan, Mexico City, Mexico
Netherlands	Biomet Global Supply Chain Center B.V.	Heerbaan 14, -40, 4817NL Breda, Netherlands
Netherlands	Zimmer Biomet Nederland B.V.	Hazeldonk 6530 4836LD Breda, Netherlands
New Zealand	OSSIS Corporation	Unit 7, 2 Barry Hogan Place, Riccarton, Christchurch 8041, New Zealand
New Zealand	Zimmer Biomet New Zealand Company	C/-Russell McVeagh, Level 30, Vero Centre, 48 Shortland Street, Auckland, New Zealand
Norway	Zimmer Biomet Norway AS	Luhrtoppen 2, 1470 LØRENSKOG, Norway
Poland	Zimmer Biomet Polska sp. z o.o.	Ul. Domaniewska 50 (Tulipan Hause) 02-672 Warszawa, Poland
Portugal	Zimmer Biomet Portugal Unipessoal, Lda	Edificio Amoreiras Square; Rua Carlos Alberto Mota Pinto, 17 – 3ºA, 1070-313 Lisboa, Portugal
Puerto Rico	Biomet Orthopedics Puerto Rico, Inc.	Los Frailes Industrial Park, 484 Calle E, Guaynabo, PR 00969-3454, Puerto Rico
Puerto Rico	Zimmer Manufacturing BV (Puerto Rico Branch)	Ochoa Building, 500 Calle de la Tanca, Suite 514, San Juan, PR, 00901, Puerto Rico
Romania	Zimmer Biomet Romania S.R.L.	Bucharest, District 6, 319L Splaiul Independenței, Paris Office Building (building A1), ground floor, Romania
Russia	Zimmer CIS Ltd.	Usachev st., 29-9, Moscow 119048, Russian Federation
Saudi Arabia	Zimmer Biomet Asel AlArabia Ltd	891 King Fahd Road, Alsalam Tower, Riyadh, Kingdom of Saudi Arabia
Saudi Arabia	Zimmer Biomet Regional Headquarters	7008 King Fahad Branch Road – Ar Rahmaniyah Dis. Unit No 101, Riyadh, Kingdom of Saudi Arabia
Singapore	Zimmer Pte Ltd	401 Commonwealth Drive, Haw Par Technocentre #06-03, Singapore 149598
Slovakia	Zimmer Slovakia s.r.o.	Mostová 2, 811 02 Bratislava, Slovak Republic
South Africa	Zimmer Biomet South Africa (Pty) Ltd.	Meersig 1, Constantia Boulevard, Constation Kloof, 1710 Roodepoort, South Africa
South Korea	Zimmer Biomet Korea Ltd.	4F/5F, Ilsin B/D, 98 Hannam-daero, Yongsan-gu, Seoul 04418, Korea
Spain	Zimmer Biomet Spain SLU	Metalurgia 32-34, 08038 Barcelona, Spain
Spain	Biomet Spain Orthopaedics, S.L.	C/ ISLAS BALEARES, 52, PARCELA 169 – POLÍGONO INDUSTRIAL “FUENTE DEL JARRO” – 46988 PATERNA (VALENCIA) Spain
Sweden	Zimmer Biomet Sweden AB	Hyllie Boulevard 34, 215 32 MALMÖ, Sweden
Switzerland	Zimmer GmbH	Zaehlerweg 4, 6300 Zug, Switzerland
Switzerland	Zimmer Surgical SA	chemin du Pré-Fleuri 3, 1228 Plan-les-Ouates, Switzerland
Switzerland	Zimmer Switzerland Manufacturing GmbH	Sulzerallee 8, 8404 Winterthur, Switzerland
Taiwan	Zimmer Biomet Taiwan Co., Ltd.	Floor 7, No. 35, Lane 11, North Guangfu Road, Songshan District, Taipei, Taiwan
Thailand	Zimmer Biomet (Thailand) Co., Ltd.	3, 2nd Floor Rajanakarn Building, South Sathorn Road, Yannawa, Sathorn, Bangkok 10120, Thailand
Turkey	Zimmer Biomet Tibbi Cihazlar Sanayi Ve Ticaret Anonim Şirketi	Via Tower İs Merkezi, Yasam Caddesi, Nergis Sk. No: 7/40-41-42-43 Kat: 18 Söğütözü, Ankara, Turkey
United Arab Emirates	Zimmer Gulf FZ-LLC.	Dubai Science Park (DSP) Towers – South – 8th Floor – Office No. 802S., United Arab Emirates
United Kingdom	Biomet UK Healthcare Ltd	Waterton Industrial Estate, Bridgend, Mid Glamorgan, CF31 3XA, United Kingdom
United Kingdom	Biomet UK Ltd	Waterton Industrial Estate, Bridgend, Mid Glamorgan, CF31 3XA, United Kingdom
United Kingdom	Zimmer Biomet UK Ltd.	Part Second Floor, Stella, Windmill Hill Business Park, Swindon, SN5 6NX, United Kingdom
United Kingdom	Zimmer Trustees Limited	Part Second Floor, Stella, Windmill Hill Business Park, Swindon, SN5 6NX, United Kingdom
United States	A&E Advanced Closure Systems, LLC	5206 Asbury Road, Farmingdale, NJ 07727, United States
United States	A&E Medical Corp.	5206 Asbury Road, Farmingdale, NJ 07727, United States
United States	Alto Development Corp.	5206 Asbury Road, Farmingdale, NJ 07727, United States
United States	Avitus Orthopaedics, Inc.	2nd Floor, 6 Armstrong Road, Shelton, CT 06484, United States
United States	Biomet Biologics, LLC	56 East Bell Drive, Warsaw IN 46582, United States
United States	Biomet Fair Lawn LLC	20-01 Pollitt Drive, Fair Lawn NJ 07410, United States
United States	Biomet, Inc.	56 East Bell Drive, Warsaw IN 46582, United States
United States	Biomet International, Inc.	56 East Bell Drive, Warsaw IN 46582, United States
United States	Zimmer Biomet Leasing LLC	251 Falls Drive, Wilmington, DE 19808, United States
United States	Biomet Manufacturing, LLC	56 East Bell Drive, Warsaw IN 46582, United States
United States	Biomet Microfixation, LLC	1520 Tradeport Drive, Jacksonville, FL 32218-2480, United States
United States	Biomet Orthopedics, LLC	56 East Bell Drive, Warsaw IN 46582, United States
United States	Biomet Sports Medicine, LLC	56 East Bell Drive, Warsaw IN 46582, United States
United States	Biomet Trauma, LLC	56 East Bell Drive, Warsaw IN 46582, United States
United States	Biomet US Reconstruction, LLC	56 East Bell Drive, Warsaw IN 46582, United States
United States	Cayenne Medical, Inc.	16597 N. 2nd Street, #101, Scottsdale, AZ 85260, United States
United States	CD Diagnostics, Inc.	650 Naamans Road, Suite 100, Claymont, DE 19703, United States
United States	CD Laboratories, Inc.	650 Naamans Road, Suite 100, Claymont, DE 19703, United States
United States	Citra Labs LLC	55 Messino Drive, Braintree, MA 02184-6783, United States
United States	Dornoch Medical Systems, Inc.	345 East Main Street, Warsaw, IN 46580, United States
United States	Embody, Inc.	100 Shockoe Slip Fl 2, Richmond, VA 23219, United States
United States	ETEX Corporation	12th Floor, 675 Massachusetts Ave., Cambridge, MA 02139, United States
United States	Interpore Cross International LLC	181 Technology Drive, Irvine, CA 92618, United States
United States	Jace Medical, LLC	2902 E. Saint Andrews Road S, Winona Lake, IN46590, United States
United States	LVB Acquisition Inc.	345 East Main Street, Warsaw, IN 46580, United States
United States	Medtech Surgical, Inc.	1520 Tradeport Drive, Jacksonville, FL 32218, United States
United States	ReLign Corporation	655 Campbell Technology Parkway, #275, Campbell, CA 95008, United States
United States	Synvasive Technology, Inc.	345 East Main Street, Warsaw, IN 46580, United States
United States	ZB EMEA US UK LLC	345 East Main Street, Warsaw, IN 46580, United States
United States	ZB Manufacturing, LLC	345 East Main Street, Warsaw, IN 46580, United States
United States	Zimmer Biomet Distribution LLC	345 East Main Street, Warsaw, IN 46580, United States
United States	Zimmer Caribe, LLC	345 East Main Street, Warsaw, IN 46580, United States
United States	Zimmer CEP USA, Inc.	345 East Main Street, Warsaw, IN 46580, United States
United States	Zimmer CV, Inc.	345 East Main Street, Warsaw, IN 46580, United States
United States	Zimmer Knee Creations, Inc.	345 East Main Street, Warsaw, IN 46580, United States
United States	Zimmer Production, Inc.	345 East Main Street, Warsaw, IN 46580, United States
United States	Zimmer Spine Next, Inc.	345 East Main Street, Warsaw, IN 46580, United States
United States	Zimmer Surgical, Inc.	6001 East Royalton Road, Suite 100, Broadview Heights, OH 44047, United States
United States	Zimmer Trabecular Metal Technology, Inc.	10 Pomeroy Road, Parsippany, NJ 07054, United States
United States	Zimmer US, Inc.	345 East Main Street, Warsaw, IN 46580, United States
United States	Zimmer, Inc.	345 East Main Street, Warsaw, IN 46580, United States
Vietnam	The Representative Office of Zimmer Pte Ltd in Hanoi City	1303, 13th Floor Hanoi Tower, 49 Hai Ba Trung St. Hoan Kiem Dist, Hanoi City, Vietnam

Kingdom of Saudi Arabia/United Arab Emirates

Welcome

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”) (as defined further below) by any subsidiary or affiliate of Zimmer Biomet Holdings, Inc. (collectively “Zimmer Biomet,” “we,” “our,” or “us”).

Purpose of this Privacy Notice

Some examples of instances where we collect Personal Data include:

Through online activities and services we offer (through this and other websites, web surveys, newsletters, applications, online messaging services or channels, including online “chats” with live individuals and artificial intelligence, social media, our telephone customer service centers, email or SMS/text messages, and otherwise) (“Online Services”);
Through your account and our products or services, whether provided directly to you or your patient, or if you are a patient, through 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);
In other situations where you interact with us, including but not limited to interacting with us by visiting our sites, offices, or our events (such as tradeshows and conferences) (“Events”) (our Online Service, Events, and other products and services are collectively referred to in this Notice as “Products and Services”).
Related to activities we undertake in recruiting participants for participation in clinical trials or activities related to identifying and contracting with study investigators and their staff;
In connection with adverse events, complaints, and reports;
When you interact with us in a professional capacity, for example, if you are a Healthcare Provider or an employee of a company we do business with or provide Products and Services to;
When we undertake employment recruiting activities; or
Anywhere this Notice is posted or referenced.

Personal Data, Collection, Purposes, Source and Recipients

Personal Data

“Personal Data” is any information – as electronically or otherwise recorded– that can be used to identify a specific 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.

Personal Data may include information considered sensitive in some jurisdictions, such as biometric information, genetic information, health information, financial account information, specific geolocation, ethnic or racial origin, information concerning your sex life or your sexual orientation, social security number, driver’s license number, state identification card number, passport number, and other similar information. Personal Data that could be considered sensitive Personal Data under applicable law is indicated with a caret (^) in the chart below.

The below table is a high-level summary of the types of Personal Data we may collect from you. Following that high-level summary is additional detail and information on how we collect, process, and use Personal Data and the potential sources and 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. The types of Personal Data we collect and disclose depends on your relationship with Zimmer Biomet. Not all of the categories listed in the following charts may apply to you. If the nature of your relationship with Zimmer Biomet changes, additional categories of Personal Data may also apply.

	Identity and Contact Information	Age, Gender and Other Characteristics	Video, Audio, and Recorded Information	Technical Information	Health Information	Commercial and Financial Information	Professional and Educational Information	Anonymized / De-Identified Data
Users of Online Services, Visitors to Our Websites and Physical Locations, and Senders of Inquiries	X^	X^	X	X	X^			X
Patients and Users of Medical Devices	X^	X^	X^	X^	X^	X^		X
Healthcare Providers	X^	X^	X	X		X^	X^	X
Employment and Apprenticeship Candidates	X^	X^	X	X			X^	X
Business Partners and Their Employees, Agents, and Contractors	X^	X^	X	X		X^	X^	X
Attendees and Participants at Zimmer Biomet Events	X^	X^	X	X	X^	X^	X	X
Clinical Investigators and Members of Investigator Teams	X^	X^	X	X		X^	X^	X
Clinical Study Candidates	X^	X^	X	X^	X^	X^	X	X
Children⁺	X^	X^	X^	X^	X^	X		X

Personal Data that may be considered sensitive is noted with a “^”.

Users of Online Services, Visitors to Our Websites and Physical Locations, and Senders of Inquiries We may process your Personal Data when you (1) visit, use, register for, and/or engage with our Online Services; (2) sign up for our newsletters or other informational or marketing materials; (3) submit inquiries to us both online (e.g., via email, via chatbot) or offline (e.g., by written letters); (4) contact our customer service centers through phone, email, SMS/text messages, chats, or otherwise; (5) complete a survey or other online questionnaire or form; and/or (6) participate in Events.
We process these types of Personal Data:	We obtain this Personal Data from:	We process this Personal Data for the following purposes:	We process this Personal Data under the following legal bases:	We may share this Personal Data with**:
Identity and Contact Information, such as: first and last name or unique pseudonym honorifics and titles, preferred form of address employer/company email address postal address phone number username or code and password^, security answers^, and user preferences contact information for related persons, such as authorized users of your account or designated representatives customer number company ID number such as account number National Provider Identifier (NPI) number Other Personal Information, such as: age gender preferred language marital status disability^ date of birth Video, Audio and Recorded Information, such as: still images video (including via CCTV) voicemails recordings of your interactions with our Online Services, including with our customer service, whether through phone, email, SMS/text message, or chat Technical Information, such as: Internet Protocol (IP) addresses (which may identify your general geographic location or company) 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 and online behavior while on our Products and Services and referring websites or applications, including forms and other information submitted, videos watched, your clicks on our site pages, and product descriptions read 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***	you directly those authorized to provide on your behalf such as your caregiver or authorized representative your devices our security systems (including CCTV) third parties that provide access to information you make publicly available, such as social media companies conducting non-clinical research such as market research companies business partners and other third parties that assist us in providing and improving our Products and Services	to provide you with our Products and Services to communicate with you to administer our relationship with your organization to send you updates to identify and authenticate you to customize content for you and tailor your experience when using our Products and Services to detect security incidents to protect against malicious, fraudulent 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, internal research, and development to evaluate the effectiveness of and improve our Products and Services and to develop new products and services for quality assurance and to assist in training and development of our representatives to determine and verify Products and Services eligibility and coverage in connection with adverse event and complaint tracking and reporting to procure third party products and services, including to manage and satisfy related third party contractual obligations for marketing, advertising, and promotion, including to contact you regrading programs, Products and Services, and topics that may be of interest or useful to you to comply with legal and regulatory obligations	for the purposes of our legitimate interests in preparation for or to perform a contract with you to comply with legal and regulatory obligations and to establish, exercise, or defend our legal claims and rights to facilitate the provision of healthcare or treatment for reasons of public health, including ensuring 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*	Zimmer Biomet, our affiliates, subsidiaries, and related companies Healthcare Providers your company / employer individuals or entities that you designate or instruct us to share your Personal Data with authorized representatives, family members, and caregivers third parties who assist with fraud prevention, detection, and mitigation third parties who assist with our information technology and security programs and our loss prevention programs Zimmer Biomet’s lawyers, auditors, and consultants partners that assist us in providing the Products or Services or help us improve our marketing or administration
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 these types of Personal Data:	We obtain this Personal Data from:	We process this Personal Data for the following purposes:	We process this Personal Data under the following legal bases:	We may share this Personal Data with**:
Identity and Contact Information, such as: first and last name or a unique pseudonym honorifics and titles, preferred form of address employer / company email address postal address phone number username or code and password,^ security answers^, and user preferences contact information for related persons, such as authorized users of your account or designated representatives Other Personal Information, such as: age gender preferred language marital status disability^ ethnicity^ date of birth Video, Audio and Recorded Information, such as: still images video (including via CCTV) recordings of your calls with our customer service representatives voicemails recordings of your interactions with our Online Services, whether through email, SMS/text message, or chat pictures and videos of diagnosis and treatment activities )^ Technical Information, such as: Internet Protocol (IP) addresses (which may identify your general geographic location or company) 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 and online behavior while on our Products and Services and referring websites or applications, including forms and other information submitted, videos watched, your clicks on our site pages, and product descriptions read^ data collected from cookies or other similar technologies geolocation information**** Health Information, such as: identification of pathologies/diseases^ identification number associated with your Products^ areas of interest in medical research^ treatment and surgery dates^ medical history and treatment information^ patient-reported outcome measures (e.g., responses to questionnaires and surveys about your health or treatment)^ DICOM images, X-rays, magnetic resonance imaging, and medical scans^ user activity^ therapy completion and use details^ communications with your Healthcare Provider, including audio video, or other recordings from telehealth sessions^ drug allergies, prescriptions and dosing ^ health values taken, such as heart rate and blood pressure, gait patterns or rhythms ^ adverse event information^ health insurance information and other information on payment for healthcare services^ pregnancy status^ contact information for designated recipients of your health information location data^ pictures and videos of diagnosis and treatment activities ^ patient ID number^ Commercial and Financial Information, such as: Products and Services purchased, obtained, or considered Bank account number and details^ request documentation customer service records financial transaction history financial account number^ other payment 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***	you directly Healthcare Providers those authorized to provide Personal Data on your behalf, such as your caregiver or authorized representative your devices our security systems (including CCTV) third parties that provide access to information you make available, such as social media companies conducting non-clinical research such as market research companies our business partners or other third parties that assist us in providing and improving our Products and Services Your use of Zimmer Biomet Products or Services	to provide you with our Products and Services to communicate with you to administer our relationship with you to send you updates to identify and authenticate you to detect security incidents to protect against malicious, fraudulent 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 to generate surgeon- specific performance analytics relating to their patients’ pre-operative, intra-operative, and post-operative insights and to further enable Healthcare Providers to compare aggregated, deidentified performance analytics across other Healthcare Providers – either regionally or globally. for internal research and development to evaluate the effectiveness of and improve our Products and Services and to develop new products and services to determine and verify Products and Services eligibility and coverage in connection with adverse event and complaint tracking and reporting to procure third party products and services, including to manage and satisfy related third party contractual obligations for marketing, advertising, and product promotion, including to contact you regarding programs, Products and Services, and topics that may be of interest or useful to you to comply with legal and regulatory obligations	for the purposes of our legitimate interests for medical diagnosis and the provision of healthcare or treatment to comply with legal and regulatory obligations and to establish, exercise or defend our legal claims or rights. in preparation for or to perform a contract to protect vital interests or in the public interest for reasons of public health, including ensuring high standards of quality and safety of healthcare and medical devices for scientific or historical research or statistical purposes in circumstances where we have requested and received consent, including from Patients directly for their use of certain Products or Services, and for other purposes that may be required or allowed by law*	Zimmer Biomet, our affiliates, subsidiaries, and related companies Healthcare Providers individuals or entities that you designate or instruct us to share your Personal Data with authorized representatives, family members, and caregivers third parties who assist with fraud prevention, detection, and mitigation third parties who assist with our information technology and security programs and our loss prevention programs Zimmer Biomet’s lawyers, auditors, and consultants third parties with your consent partners that assist us in providing the Products or Services or help us improve our marketing or administration
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 these types of Personal Data:	We obtain this Personal Data from:	We process this Personal Data for the following purposes:	We process this Personal Data under the following legal bases:	We may share this Personal Data with**:
Identity and Contact Information, such as: first and last name or unique pseudonym honorifics and titles, preferred form of address employer / company email address postal address phone number username or code and password^, security answers^, and user preferences contact information for related persons, such as authorized users of your account or designated representatives customer number company ID number such as account number National Provider Identifier (NPI) number Unique personal identifier signature Other Personal Information, such as: age gender preferred language marital status disability^ date of birth Video, Audio, and Recorded Information, such as: still images video (including via CCTV) recordings of your calls with our customer service representatives voicemails recordings of your interactions with our Online Services, whether through email, SMS/text message, or chat pictures and videos of treatment activities or training activities Technical Information, such as: Internet Protocol (IP) addresses (which may identify your general geographic location or company) 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)) Uniform Resource Locators, or URLs (i.e., website addresses) visited prior to arriving and after leaving our Products and Services activity and online behavior while on our Products and Services and referring websites or applications including forms and other information submitted, videos watched, your clicks on our site pages, browsing time, and product descriptions read data collected from cookies or other similar technologies geolocation information**** Commercial and Financial Information, such as: Products and Services purchased, obtained, or considered Bank account number and details^ request documentation customer service records financial transaction history financial account number^ other payment information tax identification number^ Professional and Educational Information, such as: job title or position your employer, company with which you are associated, or principal working location National Provider Identifier (NPI)number state medical license number work skills employment history graduate degrees certifications professional memberships specialized training responses to surveys and questionnaires enrollment and attendance history for our education and training events records of collaborations with Zimmer Biomet, such as consulting and other engagements information from references background checks Product Usage Information, such as: technical and surgical data (pre-, intra-, and post-operative) and performance metrics derived from your use of certain Products or Services date and time you use our Products and Services, including the Products and Services used user preferences purchasing tendencies 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***	you directly Healthcare Providers your employer, company with which you are associated, or principal third party data repositories your devices your references and third parties that assist us in conducting background checks our security systems (including CCTV) third parties that provide access to information you make available, such as social media companies companies conducting non-clinical research such as market research companies your patients clinical investigators and/or members of investigator teams the use of Zimmer Biomet Products or Services sales representatives imaging centers	to provide you with our Products and Services to communicate with you to administer our relationship with your organization to send you updates to identify and authenticate you to customize content for you and tailor your experience when using our Products and Services to detect security incidents to protect against malicious, fraudulent or illegal activity to ensure the appropriate use of our Products and Services to provide medical education to improve our Products and Services for short-term, transient use for administrative purposes for quality assurance for internal research, and development to evaluate the effectiveness of and improve our Products and Services and to develop new products and services for quality assurance and to assist in training and development of our representatives.in connection with adverse event and complaint tracking and reporting to procure third party products and services, including to manage and satisfy related third party contractual obligations for marketing, advertising, and promotion, including to contact you regarding programs, Products and Services, and topics that may be of interest or useful to you to comply with legal and regulatory obligations to generate surgeon- specific performance analytics relating to their patients’ pre-operative, intra-operative, and post-operative insights and to further enable Healthcare Providers to compare aggregated, deidentified performance analytics across other Healthcare Providers – either regionally or globally. for preoperative planning	for the purposes of our legitimate interests for the purposes of medical diagnosis and the provision of healthcare or treatment to comply with legal or statutory obligations and to establish, exercise, or defend our legal claims and rights in preparation for or to perform a contract to protect vital interests or in the public interest for reasons of public health, including ensuring high standards of quality and safety of healthcare and medical devices for scientific or historical research or statistical purposes. In circumstances where we have requested and received consent, including for the use of certain Products and Services, and for other purposes that may be required or allowed by law*	Zimmer Biomet, our affiliates, subsidiaries, and related companies Healthcare Providers your company/employer your patients your references and third parties that assist us in conducting background checks individuals or entities that you designate or instruct us to share your Personal Data with authorized representatives, family members, and caregivers third parties who assist with fraud prevention, detection, and mitigation third parties who assist with our information technology and security programs and our loss prevention programs Zimmer Biomet’s lawyers, auditors, and consultants partners that assist us in providing the Products or Services or help us improve our marketing or administration Ethics committees External auditors Public authorities and governmental bodies
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 these types of Personal Data:	We obtain this Personal Data from:	We process this Personal Data for the following purposes:	We process this Personal Data under the following legal bases:	We may share this Personal Data with**:
Identity and Contact Information, such as: first and last name or unique pseudonym honorifics and titles, preferred form of address employer/company email address postal address phone number username or code and password^, security answers^, and user preferences contact information for related persons, such as authorized users of your account or designated representatives National Provider Identifier (NPI) number Social Security Number (SSN)^ signature Other Personal Information, such as: Age Preferred language gender marital status disability^ ethnicity^ date of birth Technical Information, such as: Internet Protocol (IP) addresses (which may identify your general geographic location or company) 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 and online behavior while on our Products and Services and referring websites or applications, including forms and other information submitted, videos watched, your clicks on our site pages, and product descriptions read data collected from cookies or other similar technologies geolocation information**** Professional and Educational Information, such as: job title or position your employer, company with which you are associated, or principal working location National Provider Identifier (NPI) number State medical license number work skills employment history graduate degrees certifications professional memberships specialized training responses to surveys and questionnaires information from references background checks^ 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***	you directly your employer, company with which you are associated, or principal your references and third parties that assist us in conducting background checks those authorized to provide Personal Data on your behalf your devices our security systems (including CCTV) third parties that provide access to information you make available, such as social media companies companies conducting non-clinical research such as market research companies our business partners or other third parties that assist us in providing and improving our Products and Services and in hiring employees and contractors	to communicate with you to administer our relationship to send you updated, including with respect to updates on new employment opportunities to identify and authenticate you to detect security incidents to protect against malicious, fraudulent, or illegal activity for short-term, transient use for administrative purposes for internal research and development to evaluate the effectiveness or improve our Products and Services and to develop new products and services to procure third party products and services, including to manage and satisfy related third party contractual obligations for marketing, advertising and promotion, including to contact you regarding programs, Products and Services, and topics that may be of interest or useful to you	for the purposes of our legitimate interests in preparation for or to perform a contract with you to comply with legal and regulatory obligations and to establish, exercise, or defend our legal claims and rights in circumstances where we have requested and received consent and for other purposes that may be required or allowed by law*	Zimmer Biomet, our affiliates, subsidiaries, and related companies your references individuals or entities that you designate or instruct us to share your Personal Data with third parties who assist with fraud prevention, detection, and mitigation third parties who assist with our information technology and security programs and our loss prevention programs third parties who assist us in hiring and conducting background checks. Zimmer Biomet’s lawyers, auditors, and consultants partners that assist us in providing the Products or Services or help us improve our marketing or administration
Business Partners and Their Employees, Agents, and Contractors We may process your Personal Data when you are a current or former business partner or an employee, agent, or contractor of a Zimmer Biomet business partner, including collaboration partners, key opinion leaders, and vendors, suppliers of Zimmer Biomet.
We process these types of Personal Data:	We obtain this Personal Data from:	We process this Personal Data for the following purposes:	We process this Personal Data under the following legal bases:	We may share this Personal Data with**:
Identity and Contact Information, such as: first and last name or unique pseudonym honorifics and titles, preferred form of address employer/company email address postal address phone number username or code and password^, security answers^, and user preferences customer number company ID number such as account number National Provider Identifier (NPI) number signature Other Personal Information, such as: age gender marital status preferred language disability^ date of birth Technical information, such as: Internet Protocol (IP) addresses (which may identify your general geographic location or company) 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 and online behavior while on our Products and Services and referring websites or applications, including forms and other information submitted, videos watched, your clicks on our site pages, and product descriptions read data collected from cookies or other similar technologies geolocation information**** Commercial and Financial Information, such as: Products and Services purchased, obtained, or considered request documentation customer service records financial transaction history financial account number bank account number and details^ other payment information tax identification number^ Professional and Educational Information, such as: job title or position your employer, company with which you are associated, or principal working location National Provider Identifier (NPI) number state medical license number work skills employment history graduate degrees certifications professional memberships specialized training responses to surveys and questionnaires enrollment and attendance history for our education and training events records of collaborations with Zimmer Biomet, such as consulting and other engagements information from references background checks^ 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***	you directly your employer, company with which you are associated, or principal your references and third parties that assist us with background checks your devices our security systems (including CCTV) third parties that provide access to information you make available, such as social media companies companies conducting non-clinical research such as market research companies business partners or other third parties that assist us in providing and improving our Products and Services Healthcare Providers clinical investigators and/or members of investigator teams patients	to provide you with our Products and Services to communicate with you to administer our relationship with your organization to send you updates to identify and authenticate you to customize content for you and tailor your experience when using our Products and Services to detect security incidents to protect against malicious, fraudulent 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 internal research and development to evaluate the effectiveness of and improve our Products and Services and to develop new products and services for quality assurance and to assist in training and development of our representatives in connection with adverse event and complaint tracking and reporting for marketing, advertising, and product promotion, including to contact you regarding programs, Products and Services, and topics that may be of interest to procure third party products and services, including to manage and satisfy related third party contractual obligations to comply with legal and regulatory obligations	for the purposes of our legitimate interests for medical diagnosis and the provision of healthcare or treatment to comply with legal and regulatory obligations and to establish, exercise, or defend our legal claims and rights in preparation for or to perform a contract with you for reasons of public health, including ensuring high standards of quality and safety of healthcare and medical devices for scientific or historical research or statistical purposes in circumstances where we have requested and received consent and for other purposes that may be required or allowed by law*	Zimmer Biomet, our affiliates, subsidiaries, and related companies Healthcare Providers patients your company / employer your references authorized legal representatives third parties who assist with fraud prevention, detection, and mitigation third parties who assist with our information technology and security programs and our loss prevention programs third parties who assist us in hiring and conducting background checks. Zimmer Biomet’s lawyers, auditors, and consultants partners that assist us in providing the Products or Services or help us improve our marketing or administration
Attendees and Participants at Zimmer Biomet Events We may process your Personal Data when you attend or participate in professional and educational events or conferences we sponsor or hold.
We process these types of Personal Data:	We obtain this Personal Data from:	We process this Personal Data for the following purposes:	We process this Personal Data under the following legal bases:	We may share this Personal Data with**:
Identity and Contact Information, such as: first and last name or unique pseudonym honorifics and titles, preferred form of address employer/company email address postal address phone number username or code and password^, security answers^, and user preferences contact information for related persons, such as authorized users of your account or designated representatives customer number company ID number such as account number National Provider Identifier (NPI) number signature Other Personal Information, such as: age gender marital status preferred language disability^ date of birth Video, Audio, and Recorded Information, such as: still images video (including via CCTV) Technical Information, such as: Internet Protocol (IP) addresses (which may identify your general geographic location or company) 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 and online behavior while on our Products and Services and referring websites or applications including forms and other information submitted, videos watched, your clicks on our site pages, and product descriptions read data collected from cookies or other similar technologies geolocation information**** Commercial and Financial Information, such as: Products and Services purchased, obtained, or considered bank account number and details^ request documentation financial transaction history financial account number^ other payment information tax identification number^ Professional and Educational Information, such as: job title or position your employer, company with which you are associated or principal working location National Provider Identifier (NPI) number State medical license number work skills employment history graduate degrees certifications specialized training responses to surveys and questionnaires enrollment history for our education and training events records of collaborations with Zimmer Biomet, such as consulting and other engagements 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***	you directly Healthcare Providers your employer, company with which you are associated, or principal those authorized to provide Personal Data on your behalf your devices our security systems (including CCTV) third parties that provide access to information you make available, such as social media companies companies conducting non-clinical research such as market research companies our business partners or other third parties that assist us in providing and improving our Products and Services	to register you for the event or conference and other attendance-related purposes to communicate with you to administer our relationship with your organization to send you updates to identify and authenticate you to detect security incidents to protect against malicious, fraudulent, or illegal activity for short-term, transient use for administrative purposes for internal research and development to evaluate the effectiveness of and improve our Products and Services and to develop new products and services for marketing, advertising, and promotion, including to contact you regarding programs, Products and Services, and topics that may be of interest or useful to you to comply with legal and regulatory obligations	for the purposes of our legitimate interests in preparation for or to perform a contract with you to comply with legal and regulatory obligations and to establish, exercise, or defend our legal claims and rights for scientifiec or historical research or statistical purposes in circumstances where we have requested and received consent and for other purposes that may be required or allowed by law*	Zimmer Biomet, our affiliates, subsidiaries, and related companies Healthcare Providers Your company/employer Other third parties attending the Event individuals or entities that you designate or instruct us to share your Personal Data with third parties who assist with fraud prevention, detection, and mitigation third parties who assist with our information technology and security programs and our loss prevention programs Zimmer Biomet’s lawyers, auditors and consultants Partners that assist us in providing or improving our Events, Products and Services or help us improve our marketing or administration
Clinical Investigators and Members of Investigator Teams We may process your Personal Data if you are an existing or prospective clinical investigator or a member of an investigation team for a clinical study that Zimmer Biomet sponsors.
We process these types of Personal Data:	We obtain this Personal Data from:	We process this Personal Data for the following purposes:	We process this Personal Data under the following legal bases:	We may share this Personal Data with**:
Identity and Contact Information, such as: first and last name or unique pseudonym honorifics and titles, preferred form of address employer / company email address postal address phone number username or code and password^, security answers^, and user preferences contact information for related persons, such as authorized users of your account or designated representatives customer number company ID number such as account number National Provider Identifier (NPI) number Social Security Number (SSN)^ signature Other Personal Information, such as: age gender preferred language disability^ date of birth Visual, Audio, and Recorded Information, such as: still images video (including via CCTV) voicemails recordings of your interactions with our Online Services, whether through email, SMS/text message, or chat pictures and videos of treatment activities Technical Information, such as: Internet Protocol (IP) addresses (which may identify your general geographic location or company) 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 and online behavior while on our Products and Services and referring websites or applications, including forms and other information submitted, videos watched, your clicks on our site pages, and product descriptions read data collected from cookies or other similar technologies geolocation information**** Commercial and Financial Information, such as: bank account number and details^ customer service records financial transaction history financial account number^ other payment information Professional and Educational Information, such as: job title or position your employer, company with which you are associated, or principal working location National Provider Identifier (NPI) number state medical license number work skills employment history graduate degrees certifications specialized training responses to surveys and questionnaires enrollment history for our education and training events records of collaborations with Zimmer Biomet, such as consulting and other engagements information from references background checks^ Product Usage Information, such as: Technical and surgical data (pre-, intra-, and post-operative) derived from your use of certain Products or Services date and time you use our Products and Services, including the Products and Services used Anonymized / De-identified Data Anonymized and/or de-identified 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***	you directly Healthcare Providers your employer, company with which you are associated, or principal your devices those authorized to provide Personal Data on your behalf your references and third parties that assist us in conducting background checks our security systems (including CCTV) third parties that provide access to information you make available, such as social media companies companies conducting non-clinical research such as market research companies business partners or other third parties that assist us in providing and improving our Products and Services patients other clinical investigators and/or members of investigator teams	to determine your suitability to the role to assist us with running the clinical trial to communicate with you to administer our relationship with your organization to send you updates to identify and authenticate you to customize content for you and tailor your experience when using our Products and Services to detect security incidents to protect against malicious, fraudulent, 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 internal research and development to evaluate the effectiveness of and improve our Products and Services and to develop new products and services for quality assurance and to assist in training and development of our representatives in connection with adverse event and complaint tracking and reporting to procure third party products and services, including to manage and satisfy related third party contractual obligations to comply with legal and regulatory obligations	for the purposes of our legitimate interests in preparation for or to perform a contract with you to comply with legal and regulatory obligations and to establish, exercise, or defend our legal claims and rights to protect vital interests or in the public interest for reasons of public health, including ensuring high standards of quality and safety of healthcare and medical devices for scientific or historical research or statistical purposes in circumstances where we have requested and received consent and for other purposes that may be required or allowed by law*	Zimmer Biomet, our affiliates, subsidiaries, and related companies Healthcare Providers other clinical investigators and/or members of investigator teams your company / employer your reference individuals or entities that you designate or instruct us to share your Personal Data with third parties who assist us in hiring and conducting background checks. third parties who assist with fraud prevention, detection, and mitigation third parties who assist with our information technology and security programs and our loss prevention programs Zimmer Biomet’s lawyers, auditors, and consultants Patients and their authorized representatives, family members, and caregivers third parties that assist us in choosing clinical trial investigators partners that assist us in providing the Products or Services or help us improve our marketing or administration
Clinical Study Candidates We may process your Personal Data to determine whether you qualify for or would be interested in participating in a clinical trial and when you have been identified as a potential candidate for clinical studies sponsored by us. If you are a participant in a clinical study or clinical trial, you should receive a separate privacy notice regarding the Personal Data we process for those purposes. That privacy notice—and not this Notice— governs our processing of such Personal Data once you are chosen for and participating in a trial.
We process these types of Personal Data:	We obtain this Personal Data from:	We process this Personal Data for the following purposes:	We process this Personal Data under the following legal bases:	We may share this Personal Data with**:
Identity and Contact Information, such as: first and last name or unique pseudonym honorifics and titles, preferred form of address employer / company email address postal address phone number username or code and password^, security answers^, and user preferences contact information for related persons, such as authorized users of your account or designated representatives signature Other Personal Information, such as: age gender preferred language marital status disability^ ethnicity^ date of birth Visual, Audio, and Recorded Information, such as: still images video (including via CCTV) voicemails recordings of your interactions with our Online Services, whether through email, SMS/text message, or chat Technical Information, such as: Internet Protocol (IP) addresses (which may identify your general geographic location or company) 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 and online behavior while on our Products and Services and referring websites or applications, including forms and other information submitted, videos watched, your clicks on our site pages, and product descriptions read^ data collected from cookies or other similar technologies geolocation information**** Health Information, such as: identification of pathologies/diseases^ areas of interest in medical research^ medical history and treatment information^ drug allergies^ health values taken, such as heart rate and blood pressure^ pregnancy status^ location data^ Commercial and Financial Information, such as: Products and Services purchased, obtained, or considered bank account number and details^ request documentation customer service records financial transaction history financial account number^ other payment information Anonymized / De-identified Data Anonymized and/or de-identified 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***	you directly Healthcare Providers those authorized to provide Personal Data on your behalf your devices our security systems (including CCTV) third parties that provide access to information you make available, such as social media companies companies conducting non-clinical research such as market research companies business partners or other third parties that assist us in providing and improving our Products and Services clinical investigators and/or members of investigator teams	to determine your suitability and eligibility for participating in a clinical trial and to determine your interest in participating in a clinical trial to communicate with you to administer our relationship with you to send you updates to identify and authenticate you to customize content for you and tailor your experience when using our Products and Services to detect security incidents to protect against malicious, fraudulent, 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 internal research and development to evaluate the effectiveness of and improve our Products and Services and to develop new products and services for quality assurance and to assist in training and development of our representatives in connection with adverse event and complaint tracking and reporting for marketing, advertising, and product promotion, including to contact you regarding programs, Products and Services, and topics that may be of interest or useful to you to comply with legal and regulatory obligations	for the purposes of our legitimate interests in preparation for or to perform a contract with you to comply with legal and regulatory obligations and to establish, exercise, or defend our legal claims and rights to protect vital interests or in the public interest for reasons of public health, including ensuring high standards of quality and safety of healthcare and medical devices for scientific or historical research or statistical purposes in circumstances where we have requested and received consent and for other purposes that may be required or allowed by law*	Zimmer Biomet, our affiliates, subsidiaries, and related companies Healthcare Providers Clinical investigators and/or members of investigator teams individuals or entities that you designate or instruct us to share your Personal Data with partners that assist us in providing the Products or Services or help us improve our marketing or administration
Children Zimmer Biomet may process Personal Data of minors who are users of a Zimmer Biomet Product. In those instances, Zimmer Biomet seeks consent from the minor’s parents or legal guardians to process their Personal Data. Zimmer Biomet does not knowingly collect, maintain, disclose, or otherwise process Personal Data from minors below the age of 16 in other circumstances, including through Online Services or Interactions. The below relates solely to the use of Personal Data of children who are users of a Zimmer Biomet Product and whose parents or legal guardians have given consent.
We process these types of Personal Data:	We obtain this Personal Data from:	We process this Personal Data for the following purposes:	We process this Personal Data under the following legal bases:	We may share this Personal Data with**:
Identity and Contact Information, such as: first and last name or unique pseudonym honorifics and titles, preferred form of address email address postal address phone number username or code and password^, security answers^, and user preferences contact information for related persons, such as authorized users of your account or designated representatives Other Personal Information, such as: age gender preferred language disability^ ethnicity^ date of birth Visual, Audio, and Recorded Information, such as: still images video (including via CCTV) recordings of your calls with our customer service representatives voicemails recordings of your interactions with our Online Services, whether through email, SMS/text message, or chat pictures and videos of treatment activities^ Technical Information, such as: Internet Protocol (IP) addresses (which may identify your general geographic location or company) 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 and online behavior while on our Products and Services and referring websites or applications, including forms and other information submitted, videos watched, your clicks on our site pages, and product descriptions read^ data collected from cookies or other similar technologies geolocation information**** Health Information, such as: identification of pathologies/diseases^ identification number associated with your Products ^ areas of interest in medical research^ treatment dates^ medical history and treatment information^ patient-reported outcome measures (for example, responses to questionnaires and surveys about your health or treatment)^ DICOM, X-rays, magnetic resonance imaging, and medical scans^ user activity^ therapy completion and use details^ communications with your Healthcare Provider, including audio, video, or other recordings from telehealth sessions^ drug allergies^ prescriptions and dosing^ health values taken, such as heart rate and blood pressure^ adverse event information^ health insurance information and other information on payment for healthcare services^ pregnancy status^ contact information for designated recipients of your health information location data^ pictures and videos of treatment activities^ patient ID number^ Commercial and Financial Information, such as: Products and Services purchased, obtained, or considered Anonymized / De-identified Data Anonymized and/or de-identified 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***	you directly Healthcare Providers Clinical investigators and/or members of investigator teams those authorized to provide Personal Data on your behalf your devices our security systems (including CCTV) third parties that provide access to information you make available, such as social media companies companies conducting non-clinical research such as market research companies business partners or other third parties that assist us in providing and improving our Products and Services	to provide you with our Products and Services to communicate with you to administer our relationship with you to send you updates to identify and authenticate you to detect security incidents to protect against malicious, fraudulent, 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 internal research and development to evaluate the effectiveness of and improve our Products and Services and to develop new products and services for quality assurance and to assist in training and development of our representatives to determine and verify Products and Services eligibility and coverage in connection with adverse event and complaint tracking and reporting to procure third party products and services, including to manage and satisfy related third party contractual obligations for marketing, advertising, and product promotion, including to contact you regarding programs, Products and Services, and topics that may be of interest or useful to comply with legal and regulatory obligations	for the purposes of our legitimate interests for medical diagnosis or to provide healthcare or treatment in preparation for or to perform a contract with you to comply with legal and regulatory obligations and to establish, exercise, or defend our legal claims and rights to protect vital interests or in the public interest for reasons of public health, including ensuring high standards of quality and safety of healthcare and medical devices for scientific or historical research or statistical purposes in circumstances where we have requested and received consent and for other purposes that may be required or allowed by law*	Zimmer Biomet, our affiliates, subsidiaries, and related companies Healthcare Providers clinical investigators and/or members of investigator teams individuals or entities that you designate or instruct us to share your Personal Data with authorized representatives, family members, and caregivers third parties who assist with fraud prevention, detection, and mitigation third parties who assist with our information technology and security programs and our loss prevention programs Zimmer Biomet’s lawyers, auditors, and consultants 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, merger, consolidation, corporate reorganization, or transfer, to the buyer, assignee, or transferee; and, (2) government or regulatory officials, law enforcement, courts, public authorities, 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. We will not attempt to reidentify you or anyone else from this de-identified data, and if we disclose it to third parties, we will require that they not attempt to reidentify you or anyone else from the de-identified data.

**** Geolocation information may be either provided by you or collected automatically (see section “Marketing, Cookies, and Analytics”). This information may include your IP address and/or geographic location (such as longitude, latitude, city, state, and/or zip code).

Selling and Sharing Your Personal Data

We allow certain third parties to collect information about the users of our Products and Services to provide valuable services to us, such as fraud detection and reporting, analytics, and advertising services, including cross-contextual behavioral advertising. This may include sharing information about your interactions with our Products and Services, including information about videos you may watch in connection with our Products and Services and disease, treatment, Healthcare Provider, or other information searched for or viewed in connection with our Products and Services for the purposes of providing you with information and advertising related to your searches, queries, or other interactions with our Products and Services. These activities may be considered a “sale” or “sharing” under some laws. To opt-out of any sale or sharing of Personal Data, please contact us as described in the section below titled “Your Rights Regarding Your Personal Data”.

Marketing, Cookies, and Analytics

To the extent permitted by law, including with your consent where required, we may engage in the following activities:

We may use your contact details to contact you to determine whether you would like to initiate a business relationship with us or to send you marketing emails. You may unsubscribe from any marketing or promotional emails. To do so, please email us at websupport@zimmerbiomet.com or use the unsubscribe mechanism offered in our marketing emails or other communications, as applicable. Please note that if you already have requested our Products or Services when you decide to withdraw consent, a short period of time may elapse before we can update your preferences and ensure that we honor your request.
We may collect Personal Data automatically through cookies and other technologies to provide functionality to our Products and Services; to recognize you across devices when using our Products and Services; in each case where this is justified under applicable data protection law for our legitimate business purposes or with consent, where required. These legitimate business purposes include evaluating information about the use of our Products and Services and identifying trends; developing or enhancing our Products and Services; providing an experience tailored to you when you use our Products and Services; effecting certain security controls; and, identifying the advertisements and offers we think may interest you so that we may display them to you when you use our Products and Services.
We may display advertisements to you regarding Products and Services that we believe are relevant to you based on your activities while using our Products or Services or on other web or digital properties. Such advertisements may be shown to you while you are using our Products or Services or while you are using the online services of others. We achieve this by using, and allowing third parties (including social media companies) to use certain cookies, eTags, pixels, web beacons, and other tracking technologies such as Google Analytics to track your activities while using our Products or Services or while using other online services. For more information about these activities and how to manage or opt out of them, please see our Cookie Notice or contact us.
We may make offers to you based on your activities or interactions with Zimmer Biomet that are not through online Products and Services (for example, regional offers based on the location of your office listed on order forms).
We also perform statistical analyses of the users of our Products and Services to improve the functionality, content, design, and navigation of the Products and Services, and to market the Products and Services.

You may be able to opt out of or revoke your consent to, as applicable, receiving web-based personalized advertisements from companies who are members of the Network Advertising Initiative by going to http://optout.networkadvertising.org/?c=1 or participate in the Digital Advertising Alliance Self-Regulatory Program by going to http://www.aboutads.info/.

Public Interactive Features of our Websites

To the extent we offer any public or group forums on our Products or Services, such as newsfeeds, blogs, message boards, or similar tools (“Interactive Features”), the posts or comments you make may be public and viewed by others. You should use care before posting information about yourself, including Personal Data. Because these are public postings, you should have no expectation of privacy or confidentiality in the content you submit to Interactive Features in connection with the Products and Services. Your disclosure of any Personal Data through the Interactive Features is at your own risk. Based on your disclosure of Personal Data through the Interactive Features we may use anonymized and/or de-identified 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

Third Parties

Service Providers

Service providers or vendors (or processors) acting on our behalf must execute agreements requiring them to maintain confidentiality and to process Personal Data only to provide the services to us and in a way that aligns with this Notice, other applicable privacy notices, and as explicitly permitted or required by applicable laws, rules, and regulations.

Combination of Data

Links to Other Websites

Our Products or Services may contain links to other websites, applications, products, or services that are not owned or operated by Zimmer Biomet, such as social media websites and applications like Facebook and Twitter. Such links do not imply an endorsement with respect to any third party, any website, or the products or services provided thereby. You should carefully review the privacy policies and practices of other websites, products, and services as we cannot control and are not responsible for privacy policies, notices, or practices of third party websites, applications, products, and services.

Safeguarding Information

Consistent with applicable laws and requirements, Zimmer Biomet has put in place physical, technical, and administrative safeguards to protect Personal Data from loss, misuse, alteration, theft, unauthorized access, and unauthorized disclosure, consistent with legal obligations and industry practices. However, as is the case with all websites, applications, products, and services, we unfortunately are not able to guarantee security for data collected through our Products and Services. In addition, it is your responsibility to safeguard any passwords, identification or ID numbers, or similar individual information associated with your use of the Products and Services.

Your Rights Regarding Your Personal Data

Depending on where you live, you may have the following rights with respect to some or all of your Personal Data:

To exercise the rights described under the section above titled “Selling and Sharing Your Personal Data”;
To request information about whether, and how, we process your Personal Data
to request access to and a copy of your Personal Data including to provide your Personal Data directly to another organization (called, in some locations, a right to data portability) (including under GDPR Articles 15 and 20);
to request that we correct or update your Personal Data (including under GDPR Article 16);
to request that we delete your Personal Data (including under GDPR Article17);
to request that we restrict or block or to object to or opt-out of the processing of your Personal Data, including your sensitive Personal Data (including under GDPR Articles 18, 21 and 22), or to revoke your consent (including under GDPR Article 7);
to appeal the denial of a request; and
to lodge a complaint with the data protection authority in your jurisdiction.

Please note that after receiving your request, we may require additional information from you or your authorized agent to honor your request and may deny your request if we cannot verify your identity or status. Please be aware that we may be unable to afford these rights to you under certain circumstances, such as if we are legally prevented from doing so.

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.

When we receive your Personal Data from others, including your Healthcare Provider, and process your Personal Data on their behalf, we may do so at their request and subject to their instructions. In that case, we do not have control over their privacy and security practices and processes. If your Personal Data has been submitted to us by a third party, we may need to ask you to contact them directly or we may be able to contact them on your behalf. If we need you to contact them directly, we will let you know.

Transfer of Personal Data Across National Borders

Zimmer Biomet’s privacy practices, described in this Privacy Policy, comply with the APEC Cross Border Privacy Rules System. The APEC CBPR system provides a framework for organizations to ensure protection of personal information transferred among participating APEC economies. More information about the APEC framework can be found here: www.cbprs.org.

Click here to view our certification/verification status.

Special Note for Individuals Located in Japan

If you are located in Japan, the following sections also apply to you:

Joint Use of Personal Data

Zimmer Biomet may use your Personal Data jointly with any subsidiary or affiliate of Zimmer Biomet Holdings, Inc. as described here. Personal Data subject to joint use: The personal information indicated in “Personal Data, Collection, Purposes, Source and Recipients”. Range of joint users: Zimmer Biomet Holdings, Inc., and its subsidiaries and affiliates (please refer to Appendix 1 for the specific names of the subsidiaries and affiliates). Joint users’ purposes of use: The purposes described in “Personal Data, Collection, Purposes, Source and Recipients”. Party responsible for managing your Personal Data: Zimmer Biomet Holdings, Inc.

Acquisition of Personally Referable Information:

Zimmer Biomet may acquire personally referable information (for example, browsing history, purchase history, service usage history, OS and other device information, cookie IDs, advertising identifiers, IP addresses, and other online identifiers) obtained from other companies, such as advertising companies, affiliates, and companies that are related to advertising things such as DMP companies, as Personal Data by linking it to the Personal Data that Zimmer Biomet already possess and use such personally referable information in accordance with the purposes of use described in “Personal Data, Collection, Purposes, Source and Recipients”.

Additional Notes for Mainland China

Processing Method

The necessity of processing your sensitive Personal Data and the impact it has on your rights and interests

Our processing of your sensitive Personal Data described herein is necessary for:

Providing Products and Service, and fulfilling other purposes described above in each different scenarios;
Performing accounting, audit, internal investigations and other internal reviews;
Complying with all applicable laws, legal processes, and internal policies; and
Otherwise accomplishing our business purposes and objectives.

Our processing of your sensitive Personal Data will not impact on your individual rights and interests as described in Section “Your Rights Regarding Your Personal Information” of this Notice. These rights may be limited by law and regulations for certain purposes, including for the establishment, exercise, or defense of legal claims. Our processing of your sensitive Personal Data will be limited to the minimal level that is necessary to accomplish specific purposes as described above, and will be subject to the physical, technical, and organizational measures for special data protection in accordance with the PIPL and other applicable Chinese data protections laws and regulations.

EU-U.S. Data Privacy Framework

Zimmer Biomet Holdings, Inc., in addition to all U.S. entities listed in Appendix 1 except CD Laboratories, Inc., complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. Zimmer Biomet has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of Personal Data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF. Zimmer Biomet has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of Personal Data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles, the UK Extension to the EU-U.S. DPF, and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the DPF program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

Onward Transfer to Third Parties

Recourse, Enforcement, and Liability

In compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF, Zimmer Biomet commits to resolve DPF Principles-related complaints about our collection and use of your Personal Data. EU, UK, and Swiss individuals with inquiries or complaints regarding our handling of Personal Data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF should first contact Zimmer Biomet at: privacy.global@zimmerbiomet.com.

In compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF, Zimmer Biomet commits to refer unresolved complaints concerning our handling of Personal Data received in reliance on the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF to JAMS, an alternative dispute resolution provider based in the United States. If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit https://www.jamsadr.com/DPF-Dispute-Resolution for more information or to file a complaint. The services of JAMS are provided at no cost to you.

The Federal Trade Commission has jurisdiction over Zimmer Biomet’s compliance with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF).

Marketing and Promotional Emails

How Long Your Personal Data Will Be Retained

We generally retain Personal Data for as long as needed for the specific purpose or purposes for which it was collected or obtained, and as outlined in this Notice. In some cases, we may be required to retain Personal Data for a longer period of time by law or for other necessary or required purposes. Whenever possible, we aim to de-identify or anonymize your Personal Data or otherwise remove some or all information that may identify you from records that we may need to keep for periods beyond the specified retention period. The criteria used to determine our retention periods include: (i) the length of time we have an ongoing relationship with you; (ii) whether there is a legal obligation to which we are subject that affects the length of time we need to keep your Personal Data; and (iii) whether retention is determined to be necessary for Zimmer Biomet due to limitation periods, litigation, or other legal or regulatory obligations. Zimmer Biomet takes reasonable steps to dispose of Personal Data upon the expiration of retention periods, taking into consideration these litigation, legal, or regulatory obligations.

Special Note to Patients in the United States

If you are a U.S. patient, please note that this Notice is distinct from your Healthcare Provider’s HIPAA Notice of Privacy Practices, which describes how your Healthcare Provider uses and discloses individually identifiable information about your health that it collects, as well as any other privacy practices it applies. Zimmer Biomet collects, uses, and discloses Personal Data it receives on behalf of your Healthcare Provider in accordance with your Healthcare Provider’s HIPAA Notice of Privacy Practices.

Changes to This Privacy 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.global@zimmerbiomet.com or write to us at Zimmer Biomet, Attn: Global Privacy Officer, 345 East Main Street, Warsaw, IN 46580, United States. You may contact the data protection officer directly at dataprotectionofficer@zimmerbiomet.com.

For more contact details for your country of residence, please refer to Appendix 1 to this Notice.

Updated: July 2024

Appendix 1 – List of data controllers and contact details for data protection questions or to exercise your rights regarding your personal information

Country	Name	Address
Australia	Zimmer Biomet Pty Ltd	Level 3, 12 Narabang Way, Belrose, NSW, 2085, Australia
Austria	Zimmer Biomet Austria GmbH	Euro Plaza, Lehrbachgasse 13, 1120 Wien, Austria
Belgium	Zimmer Biomet BV	Park Lane A, Culliganlaan 2A, 1831 Diegem, Belgium
Brazil	WM World Medical Importacao e Exportacao Ltda.	Rua Do Rezende 189, Rio De Jeneiro- RJ, 20230 -050 Brazil
Brazil	Zimmer Biomet Brasil Ltda.	Rua Machado Bittencourt 361, 13º andar, Vila Clementino, CEP 04044-001 São Paulo, Brazil
Canada	ORTHOSoft ULC	75 Rue Queen #3300, Montreal, QC QC H3C, Canada
Canada	Zimmer Biomet Canada, Inc.	2323 Argentia Road, Mississauga, ON L5N 5N3, Canada
Chile	Biomet Chile S.A.	Av. Santa Clara, 085, piso 7, Huechuraba, Santiago, Chile
China	Beijing Montagne Medical Device Co., Ltd.	Building #1, No. 21 Boxing 6th Road, Beijing Economic-Technological Development Area, Beijing, 100176, People’s Republic of China
China	Changzhou Biomet Medical Device Co. Ltd.	No. 235, Chuangxin Avenue, Xin Bei District, , Changzhou, 213031, People’s Republic of China
China	Shanghai Biomet Business Consulting Co., Ltd	Unit 02-03, 42/F, No. 580, West Nanjing Road, Shanghai, People’s Republic of China
China	Zhejiang Biomet Medical Products Co. Ltd.	980, Shenli Road, Jinhua City, Zhejiang Province 321016, People’s Republic of China
China	Zimmer (Shanghai) Medical International Trading Co.	1/F, 129 North Fute Road, China (Shanghai) Pilot Free Trade Zone, 200131, People’s Republic of China
China	Zimmer (Shanghai) Medical International Trading Co., Ltd Beijing Branch	Unit 03-05, 12/F, Tower A, Borui Building, No. 26 North Road, East 3rd Ring, Chao Yang District Beijing, People’s Republic of China
Colombia	Zimmer Biomet Colombia S.A.S	Cra 7 # 123-35 Torre 123 Piso 7, Bogota D.C., Colombia
Costa Rica	Zimmer Biomet Centroamérica SA	Oficentro Ejecutivo La Sabana Torre 7, piso 3, San José, Costa Rica
Czech Republic	Zimmer Czech, s.r.o.	Na strži 2097/63, 140 00 Praha 4, Czech Republic
Denmark	Zimmer Biomet Denmark ApS	Herstedvang 12, 2620 Albertslund, Denmark
Finland	Zimmer Biomet Finland Oy	Bertel Jungin aukio 1, Espoo, 02600, Finland
France	Biomet France Sàrl	Plateau de Lautagne, 26000 Valence, France
France	MedTech SA	432 rue du Rajol, 34130 Mauguio, France
France	Zimmer Biomet France SAS	70, rue du Chanoît, 25600 Brognard, France
Germany	Biomet Deutschland GmbH	Gustav-Krone-Strasse 2, 14167 Berlin, Germany
Germany	Zimmer Biomet Deutschland GmbH	Max-Immelmann-Allee 12, 79427 Eschbach, Germany
Germany	Zimmer International Logistics GmbH	Max-Immelmann-Allee 12, 79427 Eschbach, Germany
Greece	ZIMMER BIOMET HELLAS TRADING AND INDUSTRIAL SINGLE MEMBER SOCIETE ANONYME OF MEDICAL AND PHARMACEUTICAL GOODS	Parnithos 44, 14452 Metamorphosi, Greece
Hong Kong	Zimmer Asia (HK) Limited	Unit 807-811, 8/F, Tins Enterprises Centre, 777 Lai Chi Kok Road, Kowloon, Hong Kong
India	Zimmer India Pvt Ltd	Vanijya Kunj, Enkay Towers, Unit No 6, 6th Floor, Udyog Vihar, Phase V, Gurgaon – 122016, Haryana, India
Ireland	Zimmer Orthopedics Manufacturing Ltd.	Arthur Cox Building, Earlsfort Terrace, Dublin 2, Ireland
Israel	Zimmer Biomet Medical Israel Limited	Ha’Eshel 1 St. Caesarea, Building B, P.O.B 3531, Tel Aviv, Israel
Italy	Zimmer Biomet Italia S.r.l.	Via SAN BOVIO 3, 20090 SEGRATE (MI), Italy
Japan	Zimmer Biomet G.K.	11-1, Shibakoen 2-chome, Minato-ku, Tokyo, Japan
Malaysia	Zimmer Medical (Malaysia) Sdn Bhd	Menara Symphony, 01-18, 18th Floor, No 5 Jalan Prof. Khoo Kay Kim, Seksyen 13, 46200 Petaling Jaya, Selangor Darul Ehsan, Malaysia
Mexico	Biomet Mexico S.A. de C.V.	Avenida Periferico Sur #4829-401, Colonia Parques del Pedregal, Zip Code 14010, Delegacion Tlalpan, Mexico City, Mexico
Netherlands	Biomet Global Supply Chain Center B.V.	Heerbaan 14, -40, 4817NL Breda, Netherlands
Netherlands	Zimmer Biomet Nederland B.V.	Hazeldonk 6530 4836LD Breda, Netherlands
New Zealand	OSSIS Corporation	Unit 7, 2 Barry Hogan Place, Riccarton, Christchurch 8041, New Zealand
New Zealand	Zimmer Biomet New Zealand Company	C/-Russell McVeagh, Level 30, Vero Centre, 48 Shortland Street, Auckland, New Zealand
Norway	Zimmer Biomet Norway AS	Luhrtoppen 2, 1470 LØRENSKOG, Norway
Poland	Zimmer Biomet Polska sp. z o.o.	Ul. Domaniewska 50 (Tulipan Hause) 02-672 Warszawa, Poland
Portugal	Zimmer Biomet Portugal Unipessoal, Lda	Edificio Amoreiras Square; Rua Carlos Alberto Mota Pinto, 17 – 3ºA, 1070-313 Lisboa, Portugal
Puerto Rico	Biomet Orthopedics Puerto Rico, Inc.	Los Frailes Industrial Park, 484 Calle E, Guaynabo, PR 00969-3454, Puerto Rico
Puerto Rico	Zimmer Manufacturing BV (Puerto Rico Branch)	Ochoa Building, 500 Calle de la Tanca, Suite 514, San Juan, PR, 00901, Puerto Rico
Romania	Zimmer Biomet Romania S.R.L.	Bucharest, District 6, 319L Splaiul Independenței, Paris Office Building (building A1), ground floor, Romania
Russia	Zimmer CIS Ltd.	Usachev st., 29-9, Moscow 119048, Russian Federation
Saudi Arabia	Zimmer Biomet Asel AlArabia Ltd	891 King Fahd Road, Alsalam Tower, Riyadh, Kingdom of Saudi Arabia
Saudi Arabia	Zimmer Biomet Regional Headquarters	7008 King Fahad Branch Road – Ar Rahmaniyah Dis. Unit No 101, Riyadh, Kingdom of Saudi Arabia
Singapore	Zimmer Pte Ltd	401 Commonwealth Drive, Haw Par Technocentre #06-03, Singapore 149598
Slovakia	Zimmer Slovakia s.r.o.	Mostová 2, 811 02 Bratislava, Slovak Republic
South Africa	Zimmer Biomet South Africa (Pty) Ltd.	Meersig 1, Constantia Boulevard, Constation Kloof, 1710 Roodepoort, South Africa
South Korea	Zimmer Biomet Korea Ltd.	4F/5F, Ilsin B/D, 98 Hannam-daero, Yongsan-gu, Seoul 04418, Korea
Spain	Zimmer Biomet Spain SLU	Metalurgia 32-34, 08038 Barcelona, Spain
Spain	Biomet Spain Orthopaedics, S.L.	C/ ISLAS BALEARES, 52, PARCELA 169 – POLÍGONO INDUSTRIAL “FUENTE DEL JARRO” – 46988 PATERNA (VALENCIA) Spain
Sweden	Zimmer Biomet Sweden AB	Hyllie Boulevard 34, 215 32 MALMÖ, Sweden
Switzerland	Zimmer GmbH	Zaehlerweg 4, 6300 Zug, Switzerland
Switzerland	Zimmer Surgical SA	chemin du Pré-Fleuri 3, 1228 Plan-les-Ouates, Switzerland
Switzerland	Zimmer Switzerland Manufacturing GmbH	Sulzerallee 8, 8404 Winterthur, Switzerland
Taiwan	Zimmer Biomet Taiwan Co., Ltd.	Floor 7, No. 35, Lane 11, North Guangfu Road, Songshan District, Taipei, Taiwan
Thailand	Zimmer Biomet (Thailand) Co., Ltd.	3, 2nd Floor Rajanakarn Building, South Sathorn Road, Yannawa, Sathorn, Bangkok 10120, Thailand
Turkey	Zimmer Biomet Tibbi Cihazlar Sanayi Ve Ticaret Anonim Şirketi	Via Tower İs Merkezi, Yasam Caddesi, Nergis Sk. No: 7/40-41-42-43 Kat: 18 Söğütözü, Ankara, Turkey
United Arab Emirates	Zimmer Gulf FZ-LLC.	Dubai Science Park (DSP) Towers – South – 8th Floor – Office No. 802S., United Arab Emirates
United Kingdom	Biomet UK Healthcare Ltd	Waterton Industrial Estate, Bridgend, Mid Glamorgan, CF31 3XA, United Kingdom
United Kingdom	Biomet UK Ltd	Waterton Industrial Estate, Bridgend, Mid Glamorgan, CF31 3XA, United Kingdom
United Kingdom	Zimmer Biomet UK Ltd.	Part Second Floor, Stella, Windmill Hill Business Park, Swindon, SN5 6NX, United Kingdom
United Kingdom	Zimmer Trustees Limited	Part Second Floor, Stella, Windmill Hill Business Park, Swindon, SN5 6NX, United Kingdom
United States	A&E Advanced Closure Systems, LLC	5206 Asbury Road, Farmingdale, NJ 07727, United States
United States	A&E Medical Corp.	5206 Asbury Road, Farmingdale, NJ 07727, United States
United States	Alto Development Corp.	5206 Asbury Road, Farmingdale, NJ 07727, United States
United States	Avitus Orthopaedics, Inc.	2nd Floor, 6 Armstrong Road, Shelton, CT 06484, United States
United States	Biomet Biologics, LLC	56 East Bell Drive, Warsaw IN 46582, United States
United States	Biomet Fair Lawn LLC	20-01 Pollitt Drive, Fair Lawn NJ 07410, United States
United States	Biomet, Inc.	56 East Bell Drive, Warsaw IN 46582, United States
United States	Biomet International, Inc.	56 East Bell Drive, Warsaw IN 46582, United States
United States	Zimmer Biomet Leasing LLC	251 Falls Drive, Wilmington, DE 19808, United States
United States	Biomet Manufacturing, LLC	56 East Bell Drive, Warsaw IN 46582, United States
United States	Biomet Microfixation, LLC	1520 Tradeport Drive, Jacksonville, FL 32218-2480, United States
United States	Biomet Orthopedics, LLC	56 East Bell Drive, Warsaw IN 46582, United States
United States	Biomet Sports Medicine, LLC	56 East Bell Drive, Warsaw IN 46582, United States
United States	Biomet Trauma, LLC	56 East Bell Drive, Warsaw IN 46582, United States
United States	Biomet US Reconstruction, LLC	56 East Bell Drive, Warsaw IN 46582, United States
United States	Cayenne Medical, Inc.	16597 N. 2nd Street, #101, Scottsdale, AZ 85260, United States
United States	CD Diagnostics, Inc.	650 Naamans Road, Suite 100, Claymont, DE 19703, United States
United States	CD Laboratories, Inc.	650 Naamans Road, Suite 100, Claymont, DE 19703, United States
United States	Citra Labs LLC	55 Messino Drive, Braintree, MA 02184-6783, United States
United States	Dornoch Medical Systems, Inc.	345 East Main Street, Warsaw, IN 46580, United States
United States	Embody, Inc.	100 Shockoe Slip Fl 2, Richmond, VA 23219, United States
United States	ETEX Corporation	12th Floor, 675 Massachusetts Ave., Cambridge, MA 02139, United States
United States	Interpore Cross International LLC	181 Technology Drive, Irvine, CA 92618, United States
United States	Jace Medical, LLC	2902 E. Saint Andrews Road S, Winona Lake, IN46590, United States
United States	LVB Acquisition Inc.	345 East Main Street, Warsaw, IN 46580, United States
United States	Medtech Surgical, Inc.	1520 Tradeport Drive, Jacksonville, FL 32218, United States
United States	ReLign Corporation	655 Campbell Technology Parkway, #275, Campbell, CA 95008, United States
United States	Synvasive Technology, Inc.	345 East Main Street, Warsaw, IN 46580, United States
United States	ZB EMEA US UK LLC	345 East Main Street, Warsaw, IN 46580, United States
United States	ZB Manufacturing, LLC	345 East Main Street, Warsaw, IN 46580, United States
United States	Zimmer Biomet Distribution LLC	345 East Main Street, Warsaw, IN 46580, United States
United States	Zimmer Caribe, LLC	345 East Main Street, Warsaw, IN 46580, United States
United States	Zimmer CEP USA, Inc.	345 East Main Street, Warsaw, IN 46580, United States
United States	Zimmer CV, Inc.	345 East Main Street, Warsaw, IN 46580, United States
United States	Zimmer Knee Creations, Inc.	345 East Main Street, Warsaw, IN 46580, United States
United States	Zimmer Production, Inc.	345 East Main Street, Warsaw, IN 46580, United States
United States	Zimmer Spine Next, Inc.	345 East Main Street, Warsaw, IN 46580, United States
United States	Zimmer Surgical, Inc.	6001 East Royalton Road, Suite 100, Broadview Heights, OH 44047, United States
United States	Zimmer Trabecular Metal Technology, Inc.	10 Pomeroy Road, Parsippany, NJ 07054, United States
United States	Zimmer US, Inc.	345 East Main Street, Warsaw, IN 46580, United States
United States	Zimmer, Inc.	345 East Main Street, Warsaw, IN 46580, United States
Vietnam	The Representative Office of Zimmer Pte Ltd in Hanoi City	1303, 13th Floor Hanoi Tower, 49 Hai Ba Trung St. Hoan Kiem Dist, Hanoi City, Vietnam