Legal Global Privacy Policy

ZimVie values your privacy and the protection of your personal data. This ZimVie Privacy Notice (“Notice”) explains how we collect, use, share, transfer, and process information collected from or about you (“Personal Data”) by any subsidiary or affiliate of ZimVie Inc. (collectively “ZimVie,” “we,” “our,” or “us”).

This Notice describes the types of Personal Data that ZimVie may collect or process, how we may use and disclose that Personal Data, and how you may exercise any rights you may have regarding our processing of your Personal Data. This Notice applies to Personal Data collected or processed by us online (through websites, applications, and otherwise), when we provide products or services to you, your doctor, hospital, medical treatment or scanning facility, or other healthcare provider (collectively, “Healthcare Provider,” which refers both to the Healthcare Provider institution, organization, or company, and individuals employed by or working for or with such organization), or your patients, and in other situations where you interact with us, including anywhere this Notice is posted or referenced (products, services, websites, and other systems will be referred to in this Notice as “Products and Services”). This Notice also applies to Personal Data that is collected or processed when you interact with us in-person, by telephone, or by mail.

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

If you provide Personal Data of anyone other than yourself, please note that you are responsible for complying with all applicable privacy and data protection laws prior to providing that information to ZimVie (including obtaining consent, if necessary and required).

The ZimVie 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 can be found in Appendix 1 to this Notice, and contact details can be found in the Contact Us section at the end of this Notice.

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 ZimVie (including obtaining consent, if necessary and required).

The ZimVie 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 can be found in Appendix 1 to this Notice, and contact details can be found in the Contact Us section at the end of this Notice.

Personal Data

“Personal Data” is any information that can be used to identify an individual or that we can link directly to an individual, such as name, address, email address, telephone number, credit card number, or health or treatment information, as applicable. Personal Data in some jurisdictions can include information that indirectly identifies a person – such as a unique number assigned to a patient by a Healthcare Provider, even absent other identifying information. Please note that, for patients, as described below, we often receive information about you from your Healthcare Provider.

Purposes for Processing Your Personal Data

Some examples of instances where we collect Personal Data include if you:

• Register for an account for one of our Products or Services;
• Sign up for newsletters or other informational or marketing materials;
• Participate in our events, conferences, or trainings, including surgery trainings and Product and Service demonstrations;
• Ask us a question by contacting us;
• Apply for employment with us;
• Interact with us as a customer, vendor, supplier, or business partner or an employee or representative of same, including if you provide information about your customers or patients;
• Respond to our surveys or questionnaires;
• Make a complaint to us or to our customers about us; or
• Purchase, use, or receive our Products or Services.

We will process any Personal Data we collect in accordance with applicable law and as explained in this Notice (unless, as explained above, one of our other policies or notices governs). In some circumstances, if you do not want to provide us with your information, certain Products and Services may be unavailable to you.

Below is a summary of how we collect, process, and use Personal Data and the potential recipients of your Personal Data. 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.

Categories of Personal Data We Collect

For each category of Personal Data listed below, we describe: 

• Examples of Personal Data Processed
• Sources of Personal Data
• Purpose of Processing Personal Data
• Legal Bases of Processing Personal Data
• Recipients of Your Personal Data

Identity and Contact Information

• Examples of Identity and Contact Information: First and last name, email address, postal address, phone number, job title, account username and password, IP address, and National Provider Identifier or state license number
• Sources: Directly from you, your Healthcare Provider, or your patients; from your devices; from our business partners
• Purpose: To provide you with our Products and Services; to communicate with you; to identify and authenticate you; to customize content for you; to detect security incidents; to protect against malicious or illegal activity; to ensure the appropriate use of our Products and Services; to improve our Products and Services; for short-term, transient use; for administrative purposes; for marketing, internal research, and development; and/or for quality assurance
• Legal Bases: For the purposes of our legitimate interests, including to support medical diagnosis and the provision of healthcare or treatment, and to ensure high standards of quality and safety of healthcare and medical devices; in the public interest; to comply with a legal obligation; to perform a contract; to protect vital interests; in circumstances where we have requested and received consent; and for other purposes that may be required or allowed by law*
• Recipients: ZimVie, our affiliates, subsidiaries, and related companies; Healthcare Providers; patients; and partners that assist us in providing the Products or Services or help us improve our marketing or administration**

Demographic Information

• Examples of Demographic Information: Age, gender, marital status, disability, and date of birth
• Sources: Directly from you, your Healthcare Provider, or your patients; from your devices; from our business partners
• Purpose: To provide you with our Products and Services; to communicate with you; to identify and authenticate you; to customize content for you; to detect security incidents; to protect against malicious or illegal activity; to ensure the appropriate use of our Products and Services; to improve our Products and Services; for short-term, transient use; for administrative purposes; for marketing, internal research, and development; and/or for quality assurance
• Legal Bases: For the purposes of our legitimate interests, including to support medical diagnosis and the provision of healthcare or treatment, and to ensure high standards of quality and safety of healthcare and medical devices; in the public interest; to comply with a legal obligation; to perform a contract; to protect vital interests; in circumstances where we have requested and received consent; and for other purposes that may be required or allowed by law*
• Recipients: ZimVie, our affiliates, subsidiaries, and related companies; Healthcare Providers; patients; and partners that assist us in providing the Products or Services or help us improve our marketing or administration**

Commercial and Financial Information

• Examples of Commercial and Financial Information: Transaction records, Products and Services purchased, obtained, or considered, request documentation, customer service records, financial transaction history, and financial account number
• Sources: Directly from you, your Healthcare Provider, or your patients; from your devices; from our business partners
• Purpose: To provide you with our Products and Services; to communicate with you; to identify and authenticate you; to customize content for you; to detect security incidents; to protect against malicious or illegal activity; to ensure the appropriate use of our Products and Services; to improve our Products and Services; for short-term, transient use; for administrative purposes; for marketing, internal research, and development; and/or for quality assurance
• Legal Bases: For the purposes of our legitimate interests, including to support medical diagnosis and the provision of healthcare or treatment, and to ensure high standards of quality and safety of healthcare and medical devices; in the public interest; to comply with a legal obligation; to perform a contract; to protect vital interests; in circumstances where we have requested and received consent; and for other purposes that may be required or allowed by law*
• Recipients: ZimVie, our affiliates, subsidiaries, and related companies; Healthcare Providers; and partners that assist us in providing the Products or Services or help us improve our marketing or administration**

Health Information

• Examples of Health Information: Information regarding your treatment, including your date of birth, sex/gender, treatment dates, medical history, and treatment information, patient-reported outcome measures (e.g., responses to questionnaires and surveys), X-rays, magnetic resonance imaging, medical scans, user activity, pictures and videos of treatment activities, therapy completion and use details, and communications with your Healthcare Provider and/or patient, including audio and/or video from telehealth sessions
• Sources: Directly from you, your Healthcare Provider, or your patients; from your devices; from our business partners
• Purpose: To provide you with our Products and Services; to communicate with you; to identify and authenticate you; to customize content for you; to detect security incidents; to protect against malicious or illegal activity; to ensure the appropriate use of our Products and Services; to improve our Products and Services; for short-term, transient use; for administrative purposes; for marketing, internal research, and development; and/or for quality assurance
• Legal Bases: For the purposes of our legitimate interests, including to support medical diagnosis and the provision of healthcare and treatment, for scientific or historical research or statistical purposes, and to ensure high standards of quality and safety of healthcare and medical devices; to protect vital interests; in circumstances where we have requested and received consent; and for other purposes that may be required or allowed by law*
• Recipients: ZimVie, our affiliates, subsidiaries, and related companies; Healthcare Providers; patients; and partners that assist us in providing the Products or Services or help us improve our marketing or administration**

Professional and Educational Information

• Examples of Professional and Education Information: Job title or position, employer, National Provider Identifier number, state medical license number, work skills, employment history, graduate degree, certification, specialized training, responses to surveys and questionnaires, and enrollment history for our education and training events
• Sources: Directly from you; from your devices; from our business partners
• Purpose: To provide you with our Products and Services; to communicate with you; to identify and authenticate you; to customize content for you; to detect security incidents; to protect against malicious or illegal activity; to ensure the appropriate use of our Products and Services; to improve our Products and Services; for short-term, transient use; for administrative purposes; for marketing, internal research, and development; and/or for quality assurance
• Legal Bases: For the purposes of our legitimate interests, including to support medical diagnosis and the provision of healthcare or treatment, and to ensure high standards of quality and safety of healthcare and medical devices; in the public interest; to comply with a legal obligation; to perform a contract; to protect vital interests; in circumstances where we have requested and received consent; and for other purposes that may be required or allowed by law*
• Recipients: ZimVie, our affiliates, subsidiaries, and related companies; Healthcare Providers; and partners that assist us in providing the Products or Services or help us improve our marketing or administration**

Technical Information

• Examples of Technical Information: Internet Protocol (IP) addresses, browser type, browser language, device type, advertising IDs associated with your device (such as Apple’s Identifier for Advertising (IDFA) or Android’s Advertising ID (AAID)), the date and time you use our Products and Services, Uniform Resource Locators, or URLs (i.e., website addresses) visited prior to arriving and after leaving our Products and Services, activity on our Products and Services and referring websites or applications, data collected from cookies or other similar technologies**, and geolocation information
• Sources: Directly from you; from your devices; from our business partners
• Purpose: To provide you with our Products and Services; to communicate with you; to identify and authenticate you; to customize content for you; to detect security incidents; to protect against malicious or illegal activity; to ensure the appropriate use of our Products and Services; to improve our Products and Services; for short-term, transient use; for administrative purposes; for marketing, internal research, and development; and/or for quality assurance
• Legal Bases: For the purposes of our legitimate interests, including to support medical diagnosis and the provision of healthcare or treatment, and to ensure high standards of quality and safety of healthcare and medical devices; in the public interest; to comply with a legal obligation; to perform a contract; to protect vital interests; in circumstances where we have requested and received consent; and for other purposes that may be required or allowed by law*
• Recipients: ZimVie, our affiliates, subsidiaries, and related companies; Healthcare Providers; and partners that assist us in providing the Products and Services or help us improve our marketing or administration**

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 consider Personal Data under data protection laws***
• Sources: Directly from you, your Healthcare Provider, or your patients; from your devices; from our business partners
• Purpose: To improve our Products and Services; for short-term, transient use; for administrative purposes; for marketing, internal research, and development; for quality assurance; and/or for our own purposes
• Legal Bases: We rely on the following purposes to anonymize personal data, after which time the data is no longer Personal Data under relevant data protection laws and does not require a legal bases for processing -- For the purposes of our legitimate interests, including to support medical diagnosis and the provision of healthcare and treatment, to ensure high standards of quality and safety of healthcare and medical devices, and for scientific or historical research or statistical purposes; in the public interest; to comply with a legal obligation; to perform a contract; to protect vital interests; in circumstances where we have requested and received consent; and for other purposes that may be required or allowed by law*

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. You acknowledge and understand that you have no expectation of privacy or confidentiality in the content you submit to Interactive Features over the Products and Services. Except when required to do so by applicable law, we assume no obligation to remove Personal Data you post on our Products and Services, and you disclose any Personal Data at your own risk.

Our Products or Services may contain links to other websites, applications, products, or services that are not owned or operated by ZimVie, such as social media websites and applications like Facebook and Twitter. 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.

Consistent with applicable laws and requirements, ZimVie has put in place physical, technical, and administrative safeguards designed to protect Personal Data from loss, misuse, alteration, theft, unauthorized access, and unauthorized disclosure.  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 websites, applications, Products and Services.

Your Rights Regarding Your Personal Information

Subject to applicable data protection law, you may have a right to some or all of the following with respect to your personal data:  request access to your Personal Data (including under GDPR Article 15); request that we rectify or erase your Personal Data (including under GDPR Articles 16 and 17);object to the processing of your Personal Data (including under GDPR Article 21); request that we restrict or block the processing of your Personal Data (including under GDPR Articles 21 and 22);provide your Personal Data directly to another, i.e., a right to data portability (including under GDPR Article 20);and when we previously obtained your consent, to withdraw consent to processing (including under GDPR Article 21).  Please refer to ZimVie’s supplemental Privacy Notices for your region.

To exercise these rights, please write to us at privacy.emea@zimvie.com or ZimVie, Attn: ZimVie Privacy Officer, 4555 Riverside Drive, Palm Beach Gardens FL 33410 USA.

You may also contact our Data Protection Officer for the European Union and the United Kingdom at privacy.emea@zimvie.com. For Germany, you may also contact our German Data Protection Officer at dpo.germany@zimvie.com.

If you are concerned about how your Personal Data is used, please email us or contact us. You may also have the right to lodge a complaint against us. To do so, contact your local data protection authority (if one exists in your country).

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. ZimVie has put in place safeguards, in accordance with applicable legal requirements, to protect your Personal Data irrespective of the standards in the country where your Personal Data may be transferred. This includes 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.

You may unsubscribe from any marketing or promotional emails. To do so, please email us at websupport@zimvie.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 will retain your Personal Data for as long as we maintain a relationship with you, your Healthcare Provider, or your patient and/or for as long as we provide a Product or Service to you or to customers that serve you, plus a reasonable period thereafter to fulfil the purposes described above. Retention periods may be extended if we are required to preserve your Personal Data in connection with litigation, investigations and court or administrative proceedings or if a longer retention period is required or permitted by applicable law. 

• 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. ZimVie 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.
• If you are a patient in the E.U., please note that this Notice is distinct from your clinician, hospital, health insurance or institution (“Healthcare Provider”) privacy notice, which describes how they use and disclose your Personal Data that they collect, as well as any other privacy practices they apply.

In accordance with their privacy notices, ZimVie receives data from your Healthcare Provider to allow for the proper development of the insurance relation between you and your insurer as permitted by law including minimum data in invoices and delivery notes.

Additionally, ZimVie receives data from your Healthcare Provider when they report product events that may disclose potential product’s defects / adverse effects including patient identifier, gender, age at the time of the event and weight, and information on ZimVie’s devices and products (i.e., number, type, date of use, characteristic, and adverse effects as the case may be). This information is codified by your Healthcare Provider.

The ZimVie subsidiary or affiliate with whom your Healthcare Provider is interacting with or who manages the processing of products events reporting or acts as a legal manufacturer of the product (see Appendix 1 for further details) will process the data to manage the reports and evaluate the event that disclosed the product’s defect / adverse effects. This processing is based on its legal obligations and, when shared with group entities, on our legitimate interest to adequately manage such reports (for instance, when transmitting such information for administrative purposes) for which the due balancing test has been done. We are entitled to process health data based on reasons of public interest related to the need to ensure high standards of quality and safety of medicinal products or medical devices. We may also disclose this data to the recipients described above (especially to ZimVie group companies as specified in the section related to “health information” in Information Collection of ZimVie Global Privacy Notice ).

Personal Data may be transferred outside the European Economic Area under the safeguards described in the section “Transfer of Personal Data Across National Borders”. The information will be retained following the criteria of the section “How Long Your Personal Information Will Be Retained” and particularly to comply with the purposes of the processing as described above.

You can exercise your data protection rights (including addressing the due data protection authority) as described in the section “Your Rights Regarding Your Personal Information” and you can contact the data protection officer at the addresses included in the section “Contact us”.

We may update this Notice from time to time without notice. As such, you should review this Notice periodically. We will indicate by the date below when this Notice was most recently updated. 

[1] “*Health Care Providers shall notify product incidents events using ZimVie Product Experience Report available in ZimVie portal ePER (zimvie.com). or contacting the local ZimVie representative or by email to emeacomplaints@zimvie.com”