Zimmer Biomet Privacy Policy

Thank you for visiting this website or mobile application, which is owned and operated by a subsidiary or affiliate of Zimmer Biomet Holdings, Inc. (collectively Zimmer Biomet, we, our, or us).  The Zimmer Biomet subsidiary or affiliate who owns and operates the website or mobile application that you are visiting is, where applicable, the data controller responsible for the collection and use of personal information and its contact details can be found at the end of this Policy. 

The Zimmer Biomet entities operating in Australia, New Zealand, China, Hong Kong, India, Japan, South Korea, Malaysia, Singapore, Taiwan and Thailand are subsidiaries of Zimmer Biomet Holdings, Inc. Zimmer Biomet is committed to protecting the privacy and confidentiality of the personal information (including health information and other sensitive information) that it collects and uses.

This Zimmer Biomet Privacy Policy (Policy) complies with the privacy laws applicable in each country listed above. Zimmer Biomet requires that all health care professionals and organisations doing business with us similarly adhere to those privacy laws.

This Policy explains how we manage the personal information that we collect, use and disclose; it also describes how you may contact us if you have any questions or complaints about your privacy or would like to access the personal information we hold about you.

If you provide personal information to us either via a Zimmer Biomet website or by any other means, whether printed or electronic, you agree to our handling, use and disclosure of that information in accordance with this Policy. If you do not want to provide us this information, please do not use these features of this website.

Different websites may be directed to consumers, healthcare professionals, those seeking employment with us or other users of our services.  Please carefully review this Policy. 

Information Collection

Personal Information

Personal Information (also referred to as Personal Data in some jurisdictions) is any information that can be used to identify you or that we can link to you, such as your name, address, email address, telephone number or credit card number, as applicable. Personal Information in some jurisdictions can even include information that indirectly identifies a person such as a unique number assigned to a patient by a medical facility or healthcare professional.  Sensitive Personal Information includes health information, (Sensitive Information).  We will process your Sensitive Information in accordance with applicable law and as explained in this Policy. If you provide us with your Personal Information through a Zimmer Biomet website or otherwise, we will treat it in accordance with this Policy.

We collect Personal Information about patients so that we can provide products and services to them.  Personal information is collected in relation to surgical procedures, such as the patient’s name, details of the patient’s treating health care practitioners, x-rays and clinical images of the patient, the type of procedure and the products used in order to capture accurate records of a patient’s implant or surgical history, as well as product traceability for product recall purposes.

We collect the business contact details, professional or practice details of surgeons and allied healthcare and administrative personnel to facilitate the supply and use of Zimmer Biomet products and services to or by surgeons, and to ensure traceability of products. We also use this information to assess the suitability of Zimmer Biomet education events and requests for grants and donations, and to carry out marketing activities, including our participation in and/or sponsorship of medical education events and distribution of educational materials, brochures, newsletters, and related marketing materials.

We collect Personal Information from other individuals, such as employees, contractors, students, job applicants, and service providers, to enable us to assess, work with or transact with them.  The Personal Information we may collect from those individuals may include: name, contact details, qualifications, education, financial details and employment history. In the case of our service providers, we may also collect other details as are necessary to enable us to comply with relevant anti-corruption laws and to minimise the risk of breach of those laws.

Occasionally, Zimmer Biomet may invite you to participate in a survey or poll, for example, to provide feedback on website content, services, or products. Your responses will be anonymous unless you choose to provide your contact details so that we can provide you with additional information regarding the survey.

 

Technical Information

When you visit our websites, we may also collect certain technical information relating to you, which your web browser automatically sends whenever you visit a website on the Internet or which is collected when you use a mobile application. Our servers automatically record this information, which may include your Internet Protocol (IP) address, browser type, browser language, device type, advertising IDs associated with your device (such as Apple’s Identifier for Advertising (IDFA) or Google’s Ad ID (AAID)), the date and time of your request, the information you request, the country from which you request information and Uniform Resource Locators, or URLs (i.e., website addresses) you visited prior to visiting and after leaving our websites.  Depending on your country and the specific information involved, this technical information may or may not be Personal Information.   

 

Cookies and Similar Tools

Like many websites, we use "cookies," web beacons and other technologies on our websites to help us serve you better, and to help us evaluate and improve the content or functions of our site. A cookie is a unique numeric code that we transfer to your computer so that we can keep track of your interests and/or preferences and, among other things, recognize you as a return visitor to our websites.  Web beacons are small pieces of code placed on our websites that allow us to obtain information about website usage.    

 

Common uses for cookies include:

  • Identifying visitors who have signed into a protected website to avoid users having to submit a user name and password for every page;
  • Keeping track of visitors' preferences regarding the content they would like to see and the format in which they would like to view it so they don't need to resubmit the preferences every time they visit the site;
  • Keeping track of which pages visitors request to make improvements to site content and navigation;
  • Engaging in analytics about how the Websites are used; and
  • Collecting information about visitors’ online activities over time and across different websites when they use the Websites.

If you prefer not to receive cookies from this website set your browser to refuse all cookies from this and other websites that you may visit. This will provide you with more control over the acceptance of cookies on your computer. However, it is possible that some portions of the websites will not function properly or may perform more slowly if you choose to reject cookies. By using our websites and not disabling cookies, you consent to their use for the described purposes.

For more information on our use of cookies, please see the Zimmer Biomet Websites Cookie Policy at www.zimmerbiomet.com/cookies-policy.html.

Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services (including behavioral advertising services) that you do not wish such operators to track certain of your online activities over time and across different websites.  While we might engage in such tracking, our websites do not support Do Not Track requests at this time.

 

Children’s Information

Zimmer Biomet does not knowingly collect, maintain, disclose or otherwise process Personal Information from minors below the age of 16 in the country where the minor resides without the permission of such minor’s parents or legal guardians.  This does not affect medical information about minors that a healthcare professional using one of our websites may provide in connection with our healthcare professional-directed products or services websites. 

We may combine any of the information we collect, whether Personal Information or not, with Personal Information such as demographic information that we may obtain from third parties. These third parties include healthcare professionals who may use our websites for patient-related products and services we make available to them in the course of their or our provision of treatment. 

How We Collect Your Personal Information

We collect certain Personal Information in a variety of ways, including: when you interact with us electronically or in person; when you access a Zimmer Biomet website; and when we provide our products and/or services to you. Occasionally we may need to collect Personal Information about you from a third party such as your surgeon or other treating health care practitioners, but we will only do so if you have given us your permission, or if we cannot reasonably obtain the information from you and we require the information for your care and treatment and/or for product traceability reasons, or if the law otherwise permits us to do so. We may also collect and use Personal Information available from public sources, as well as from private sources, where it is necessary to identify actual or potential customers or business partners.

If a third party provides to us Personal Information about you that we have not requested and we determine that we would not have been permitted to collect that information under relevant privacy laws, we will ordinarily destroy or de-identify the information.

We will own any Personal Information collected, whether directly or indirectly.

Using and Sharing the Information We Collect

We will use and disclose your Personal Information for the particular purpose for which we have collected it, as already set out in this Policy.

We also use and disclose Personal Information we collect in the following circumstances:

(i)            to provide products and services to customers;

(ii)           to facilitate the use of our products and services provided to or by surgeons and to ensure traceability of products when used in the treatment of patients;

(iii)          to improve our products and services;

(iv)          to promote and market our products and services to customers and/or surgeons;

(v)           to facilitate or improve our marketing and administration procedures;

(vi)          to consider applications for employment; and

(vii)         to comply with our legal obligations and/or internal good governance requirements.

We may share your Personal Information with our affiliates, subsidiaries and related companies as well as with third parties that assist us in providing products or services that you requested or for improving our marketing administration. We may disclose your Personal Information to other third parties in the following circumstances:

(i)            the third party was the original discloser of the Personal Information to us;

(ii)           to regulatory bodies or agencies, where we are legally obliged to do so;

(iii)          to private health funds in relation to the supply of products used during a surgical procedure for a patient;

(iv)          to law enforcement agencies, government agencies, courts or external advisers, where permitted or required by law;

(v)           to third parties that assist us in providing products or services you request or that facilitate or improve our marketing or administration procedures, where such disclosure is necessary for the delivery of the relevant products or services;

(vi)          to companies that help us evaluate the use of our websites and continue to improve our website content;

(vii)         to third parties that assist us with internal good governance or administration procedures, including recruitment or anti-corruption screening;

(viii)        in relation to a patient with a Zimmer Biomet implant, to a surgeon who is subsequently engaged by the patient for an opinion, a consultation, and/or a surgical procedure; or

(ix)          with your express consent or as otherwise authorised by you.

 

We do not sell any Personal Information that you provide to us.

To the extent that your Personal Information and your Sensitive Information is transferred out of the country where you live, such as to Zimmer Biomet companies in other countries, including in the United States, there may be different standards that apply to how your data may be used and protected. Zimmer Biomet has put in place appropriate safeguards in accordance with applicable legal requirements to ensure that your data is adequately safeguarded and protected irrespective of the country. This includes obtaining written assurances from any third party given access to your data so as to require them to adopt standards that ensure an equivalent level of protection for your data as that adopted by Zimmer Biomet. Should you wish to know more about how your Personal Information and Sensitive Information is protected please contact websupport@zimmerbiomet.com.

From time to time, we will provide aggregate statistics about our customers, sales, online traffic patterns and related information to reputable third parties who help us improve our business and services, but these statistics do not include any personally identifying information.  Anonymised or aggregated information may also be shared with third parties for other purposes, including the optimisation of your web browsing experience.

In the event that we sell, assign or transfer all or part of the Zimmer Biomet business or its assets, we may transfer information, including your Personal Information, to the buyer. However, the buyer, assignee, or transferee will be required to safeguard your Personal Information in a manner that is compliant with applicable law.  In such situations, your continued use of the website signifies your agreement to be bound by the Policy and other applicable terms of the subsequent owner or operator.

Legal Bases for Using Your Personal Information

There are different legal bases that we rely on to use your Personal Information, namely:

  • Performance of a Contract - The use of your Personal Information may be necessary to perform the contract that you have with us.  For example, where you work for us either as an employee or a service provider or apply for a job with us your Personal Information will be necessary in connection with your contract of employment or services agreement.  If you are a consumer or a user of our services we will use your Personal Information to carry out our obligations under the contract that we have with you. 
  • Consent – We will rely on your consent, which in some cases (and to the extent permitted by law) may be implied, to use (i) technical information such as cookie data and geolocation data as described in this Policy; and (ii) your Personal Information for marketing purposes where permitted by law.  Where we would like to use your Sensitive Information we will only do so with your explicit consent if required by law, unless we have an obligation under employment law.  You may withdraw your consent at any time by contacting us at the addresses at the end of this Policy.  We may obtain certain Personal Information and Sensitive Information about individuals through healthcare professional users of our products and services, in which case they are responsible for obtaining and handling any required consents or for having another legitimate basis for processing such information.  
  • Legitimate interests – we may use your Personal Information for our legitimate interests to improve our products and services and the content on our websites and for administrative purposes.

Interactive Features

To the extent we offer any public or group forums on our websites, 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 Information, online. You acknowledge and understand that you have no expectation of privacy or confidentiality in the content you submit to interactive features over the websites. We assume no obligation to remove Personal Information from postings on our websites and you disclose any Personal Information in your postings at your own risk.

Links to Other Websites

Our websites may contain links to other websites that are not owned or operated by Zimmer Biomet, such as social media websites like Facebook, Twitter or through other mechanisms such as email.  You should carefully review the privacy policies and practices of other websites, as we cannot control and are not responsible for privacy policies or practices of third-party websites.

Safeguarding Your Information

Consistent with applicable laws and requirements, Zimmer Biomet has put in place physical, electronic, and administrative safeguards to protect your Personal Information from loss, misuse, alteration, theft, unauthorized access, or unauthorised disclosure, consistent with legal obligations and industry practices.  We evaluate these safeguards on an ongoing basis to help minimise risks from new security threats as they become known. However, as is the case with all websites, we unfortunately are not able to guarantee security for data collected through our websites.

If you are providing any Sensitive Information or financial information to us through our websites, such as credit card details, please be sure that the computer you are using to do so has up-to-date anti-virus software in place, to minimise the risk of any access to your information before it reaches us.

We expect our employees and contractors who handle Personal Information to comply with all applicable privacy laws and we will take appropriate action in response to any breaches of the privacy laws.

Your Rights regarding Your Personal Information

You may request access to the Personal Information we hold about you by contacting us at the details set out below. You may access your Personal Information by viewing it or by requesting a copy of your Personal Information.

Zimmer Biomet takes reasonable steps to ensure that your Personal Data is accurate and up-to-date for the purposes for which it was collected. We encourage you to contact us to update or correct your information if it changes or if you believe that any information that we have collected about you is inaccurate. You can also ask us to erase, restrict or port your Personal Information and you may tell us if you object to our use of your Personal Information. Consistent with legal requirements and limitations, Zimmer Biomet will comply with reasonable requests to obtain a copy of Personal Information that we hold about you. To exercise your rights, please communicate with us via the contact details contained in the Contact Us section at the foot of this Policy. Please note that we will likely require additional information from you in order to honor the request and we may charge you for giving you access to your Personal Information in accordance with the fees and charges we are permitted to charge under the applicable laws.

Please note that in certain limited circumstances, as prescribed by relevant privacy laws, you may be refused access to your Personal Information (for example, if providing access would be unlawful or the Personal Information is subject to legal privilege). In these cases, we will provide you with a written explanation for our refusal to provide access.

If you are concerned about how your Personal Information is used, please email us or contact us at the address below.  Alternatively you have a right to complain to your local data protection authority (if one exists in your country).

Right to Unsubscribe

You may unsubscribe from our marketing or promotional emails. To do so, please email us at websupport@zimmerbiomet.com or use the unsubscribe mechanism offered in our marketing emails. Please note that if you have already requested products or services when you decide to withdraw consent, there may be a short period of time for us to update your preferences and ensure that we honour your request.

How long your Personal Information will be retained

We will retain your Personal Information for as long as reasonably necessary for legitimate business or legal purposes.  We will delete or permanently de-identify your Personal Information when it is no longer required for the purposes for which it was collected, or for legitimate business or legal purposes.

Changes to This Privacy Policy

As we continue to provide additional services and as the privacy laws evolve, it may be necessary to revise or update this Privacy Policy.  We may update this Policy from time to time with no notice to you. We encourage you to review this Privacy Policy from time to time so that you are familiar with any changes.  Please note that we use Personal Information in accordance with the privacy policy that was in effect at the time the information was collected.You may contact us by one of the methods set out below in order to obtain the latest copy of this Policy at any time.

Your continued use of our websites and online services constitutes your agreement to this Policy. 

Contact Us

You can contact Zimmer Biomet about a privacy related issue by phone, post or email as follows:

 

Country

Contact Number

Postal Address

Email address / Fax

Australia

 

+61 2 9950 5400

AUS Privacy Officer

Zimmer Pty Ltd

10 Narabang Way

Belrose, NSW, 2085

Australia

 

Privacy.Officer_AU@zimmerbiomet.com

 

New Zealand

+64 9 925 5200

NZ Privacy Officer

Level 3

210 Khyber Pass Rd

Grafton 1023

New Zealand

Privacy.Officer_NZ@zimmerbiomet.com

India

+91 124 4693500

India Privacy Officer

14th floor, Building No. 5B

DLF Cyber Terraces

DLF Cyber City, Gurgaon

122002, Haryana, India

 

 

DataPrivacy.India@zimmerbiomet.com

 

Japan

+81 3 6402 6617

Japan Privacy Officer

15F, Sumitomo Fudosan Shibakoen Tower

11-1, Shibakoen 2-chome

Minato-ku, Tokyo

 

jp.personalinfo@zimmerbiomet.com

Korea

+82 2 538 8111

Korea Privacy Officer

17 FL., Sung-Won Building

141 Samsung-dong,

Kangnam-ku

Seoul 135-090, Korea

 

kr.privacyinfo@zimmerbiomet.com

Malaysia

+65 6854 7222

 

Data Protection Officer

Zimmer Pte Ltd

315 Alexandra Road

#03-03 Sime Darby Business Centre

Singapore 159944

DPO.Singapore@zimmerbiomet.com

Singapore

China

Hong Kong

Taiwan

Thailand

 

Updated: October 2016

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