Supplemental Privacy Notice for California Residents

Last Update: 10/15/2024

This supplemental privacy notice for California residents (“notice”) describes how ZimVie and our group companies (“ZimVie”, “we”, “us”, and “our”) collect, use and disclose the personal information (as defined below) of California residents (“consumer” or “you”) when acting as a business. This notice applies to personal information collected by our websites, applications, services, and products (collectively “services”), and during routine offline business contact with you.  Terms in this Addendum are set out in addition to and from an integral part of the terms of the ZimVie Corporate Privacy Notice | ZimVie Americas (“Notice”).

We adopted this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”), the California Privacy Rights Act of 2020 effective January 1, 2023 (“CPRA”) and other California privacy laws. Any terms defined in the CCPA and CPRA have the same meaning when used in this notice.

IF YOU ARE NOT A CALIFORNIA RESIDENT, THIS NOTICE DOES NOT APPLY TO YOU. PLEASE REFER TO OUR MAIN CORPORATE Privacy Notice | ZimVie Americas INSTEAD.

In the context of this notice, personal information means information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal information does not include certain publicly available information, deidentified or aggregated consumer information, and other information excluded from the CCPA and CPRA, such as health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) or the California Confidentiality of Medical Information Act (CMIA), clinical trial data subject to the Common Rule. The CCPA and CPRA does not apply to information that is de-identified in accordance with the requirements for de-identification set forth in Section 164.514 of Part 164 of Title 45 of the Code of Federal Regulations and is derived from patient information that was originally collected, created, transmitted or maintained by an entity regulated by the Health Insurance Portability and Accountability Act, the Confidentiality of Medical Information Act, or the Federal Policy for the Protection of Human Subjects. Therefore, this notice also does not cover our licensing or disclosure of such information.

1.  Personal information we collect

Please refer to our Corporate Privacy Notice for a full description of the types of personal data that we collect (see “What types of personal information we process”) and how we share this data with third parties (see “Who will access your personal data”).

Our Corporate Privacy Notice also provides details about ZimVie’s responsibilities when handling your personal data (for example, see “How we secure your personal data”).

Your personal information is required to enable us to provide our service to you. If you do not provide the necessary personal information, it may delay or prevent us from providing services to you. You confirm that you are authorized to provide to us the personal information which we shall collect on your behalf. Where the personal information relates to your employees, agents, associates or family members, it is not reasonably practicable for us to provide to them the information set out in this notice. Accordingly, where appropriate, you are responsible for providing this information to any such person.

2.  Sharing your personal information

ZimVie shall adopt a reasonable standard of care to store and protect from disclosure of any personal information collected by limiting access to personal information and sensitive personal information to individuals on a ‘need to know’ basis. Our third-party service providers are subject to security and confidentiality obligations and are only permitted to process information for a specified, legitimate business purpose and in accordance with our instructions and applicable laws.

3.  Sharing your sensitive personal information

Sensitive personal information is a subset of personally identifiable information that requires greater security protections and standards of care in handling. Sensitive personal information, also known as “special categories of information”, is defined as information that if lost, compromised, or disclosed could result in substantial harm, embarrassment, inconvenience, or unfairness to an individual.

We do not use or disclose sensitive personal information other than to provide you our services as permitted by California law. ZimVie does not sell or share sensitive personal information for the purpose of cross-context behavioral advertising.

We collect sensitive personal information based on one or more of the following legal grounds:

  • You have given explicit consent to the collection for one or more specified purposes;
  • Where the collection of sensitive personal information is manifestly made public by you; and/or
  • Where the collection is necessary for exercise or defense of legal claims.

4.  Retention

We retain your personal information for only as long as necessary to provide you our services. We retain your personal information in accordance with our Records Retention Policy.

5.  Children

We do not knowingly collect or sell personal information from anyone under the age of 16. If you are under 16, please do not provide any personal information about yourself to us. If you believe that a child under 16 may have provided us personal information, please contact us at privacy.nam@zimvie.com.

6.  Your rights

California residents are afforded specific rights regarding their personal information. This section describes these rights and explains how to exercise them, subject to certain exceptions.

Right to know

You have the right to request that we disclose certain information to you about our collection, use and disclosure of your personal and sensitive information. This information includes:

• Categories of personal information we have collected about you

• Specific personal information we have collected about you

• Where we received your personal information from

• The business purpose for collecting or sharing your personal information

Right to deletion
You have the right to request that we delete personal information we collected about you, and to direct our service providers to delete it as well, subject to certain exceptions permitted by applicable California law.

Right to correction
You have the right to request that we correct your inaccurate personal information.

Right to opt out of sharing
ZimVie does not share your personal information with third parties for cross-context behavioral advertising.

Do not sell my personal information
ZimVie does not sell personal information as defined in applicable California law.

Do not share or disclose my sensitive personal information
You have the right to limit how your sensitive personal information is disclosed or shared with third parties, as defined in the CPRA.

Right to non-discrimination
You have the right to not be discriminated against for exercising any of your CCPA/CPRA rights.

Exercising your rights
To exercise your rights as described above, please submit a request using one of the following methods:

Upon receiving a request from you, we will first verify your identity by matching the information you provide (including your name, email address, and phone number) with what we have on file for you. We may ask you for additional information to verify your identity or to comply with your request.

You may use an authorized agent to make a request on your behalf. To designate an agent, you will need to provide a written and signed document by both you and the agent that authorizes the agent to act on your behalf or demonstrate power of attorney. You may also use a power of attorney. We will still require you to provide sufficient information to allow us to reasonably verify your identity and we may deny a request from an authorized agent that does not submit proof that they have been authorized by you to act on your behalf.

Response timing and format
We will respond to your request within 10 days of receipt and endeavor to respond to a verifiable consumer request within 45 days of receipt.  If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.

We will typically communicate with you in the same manner in which the request was received. Or, if you have an account with us, we may deliver our written response to that account.  The response we provide will also explain the reasons we cannot comply with a request, if applicable.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded and only as permitted by applicable California law.  If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

 

7.  Changes to our privacy notice

We reserve the right to amend this notice at our discretion and at any time. Any changes will be effective when we post the revised notice. This notice was last updated as of the effective date listed above. We encourage you to periodically review this page for the latest information on our privacy practices.

8.  How to contact us

If you have any questions or comments about this notice, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under the CCPA, please do not hesitate to contact us by submitting a request CA Privacy Request Form (zimvie.com), e-mailing us at privacy.nam@zimvie.com.