CALIFORNIA PRIVACY NOTICE

Arthrex, Inc. (the “Arthrex” or “we”) provides this California Privacy Notice (“Notice”) as a supplement to the information contained in Arthrex’s Global Privacy Notice and applies solely to all visitors, users and others who reside in the state of California. Arthrex has adopted this Notice to provide additional information to California residents related to their rights under the California Consumer Privacy Act of 2018 (“CCPA”), as modified by the California Privacy Rights Act of 2020 (“CPRA”), and any terms defined in the CCPA have the same meaning when used in this Notice. This Notice describes how and why we may collect and use your Personal Data as well as our practices during the past twelve (12) months.

Personal Data We Collect, Use and Disclose

Collection of Personal Data

Our website collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, with a particular consumer or device (“Personal Data”). Arthrex may obtain Personal Data directly from you (i.e., when you submit Personal Data to us) or indirectly from you (ie, through cookies and other tracking technologies used when you interact with our Site).

Arthrex may collect the following categories of Personal Data about you:

  • Personal Identifiers includes Personal Data that can be used to identify an individual, such as name, address, email address or other similar identifers
  • Personal Information includes Personal Data that is not publicly available and can be used to identify an individual, such as employment information, education information and other similar information
  • Commercial Information includes Personal Data that is related to an individual’s transactions, purchases and other commercial interactions with businesses, such as product preferences and other similar information
  • Internet or other electronic network activity information includes information about an individual’s online activities, such as browsing history, search history and interactions with our websites, applications or advertisements

Uses and Disclosures of Personal Data

Arthrex may use your Personal Data for reasons referenced in the “How We Use Personal Data” section of the Global Privacy Notice. In particular, Arthrex may use your Personal Data for one of the following:

  • To fulfill or meet the reason you provided the Personal Data (i.e., if you share your name and contact information to ask a question about an Arthrex product or service, we will use that Personal Data to respond to your inquiry).
  • To provide, support, personalize and develop our Website, products and services.
  • To provide you with marketing material.
  • To provide and analyze our services.
  • To help maintain the safety, security and integrity of our Website, products, services, databases and other technology assets, and business.
  • Improve customer experience with surveys, polls and online research to deliver content and product and service offerings relevant to your interests.
  • To create, maintain, customize and secure your account with us.
  • For testing, research, analysis and product development, including to develop and improve our Website, products, and services.
  • As described to you when collecting your Personal Data or as otherwise set forth in the CCPA.

Arthrex may disclose your Personal Data to Arthrex affiliates, service providers, to support business operations and to a third party for a business purpose. When such Personal Data is disclosed, Arthrex will enter into a contract that describes the purpose and requires the receipt to keep the Personal Data confidential and not use it for any purpose except as to perform the obligations of the contract.

We may disclose your Personal Data with the following categories of third parties:

  • Business partners
  • Consultants
  • Service providers
  • Law enforcement, government agencies, courts or other parties to protect ourselves, employees, to investigate fraud or as required by law, such as to comply with a subpoena or similar legal process
  • Any other third party with your prior consent

Arthrex retains your Personal Data while your account is active or as needed to provide you with products, services or relevant information. After such time, we may continue to retain and use your Personal Data, as necessary, to comply with our legal, regulatory and ethical obligations, resolve disputes, exercise our rights, conduct internal research, maintain records and enforce and comply with our agreements.

Personal Data does not include:

  • Publicly available information made available from government records, widely distributed media or by individuals.
  • De-identified or aggregated consumer information.
  • Information excluded from the CCPA scope, which may include:
  • Health or medical information covered by the Health Insurance Portability and Accountability Act (“HIPAA”) of 1996 and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data.
  • Personal Data covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach Billy Act (GLBA), California Financial Information Privacy Act (CFIPA and the Driver’s Privacy Protection Act of 1994).

California Privacy Rights

California residents may exercise their privacy rights with respect to their Personal Data as set forth below, subject to applicable exceptions.

Right to Know and Access. You have the right to know and access what Personal Data is being collected about you by Arthrex.

Right to Deletion. You may be entitled to request that we delete the Personal Data that we have collected from you. We will use commercially reasonable efforts to honor your request, in compliance with applicable laws. Please note, however, that we may need or be required to keep such Personal Data for our legitimate business purposes or to comply with applicable law.

Right to Limit the Processing of Sensitive Personal Data. You may be entitled to restrict the processing of your Sensitive Personal Data in certain circumstances.

Right to Correct. You may request that we correct Personal Data that we hold about you.

Right to Opt-Out of Sales and Sharing of Personal Data. Arthrex does not share your Personal Data. You may be entitled to opt out of the disclosure of your Personal Data to third parties for certain targeted advertising.

Right to Non-Discrimination. You have the right not to receive discriminatory treatment if you exercise the rights conferred to you by applicable privacy law.

Exercising Your Rights and Response Time

If you are a California resident and would like to exercise your privacy rights listed above, please contact us at privacy@arthrex.com or (866) 363.3096. You may designate an authorized representative to make a request to exercise your privacy rights for you. Your representative should use the same contact information to make any privacy rights request. Please note that we may separately verify your identity with you should a representative make a request on your behalf.

You may make a verifiable consumer request for access or data portability. The verifiable consumer request must provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Data and describe your request with sufficient detail that allows us to properly understand, evaluate and respond to such request.

We aim to respond to all requests within 45 calendar days after receiving the request. We will inform you if our response takes longer.

Changes to Our Privacy Notice

Arthrex periodically evaluates its privacy policies and procedures to implement improvements and refinements. Therefore, Arthrex reserves the right to modify or amend this Privacy Notice at any time and for any reason. When this Privacy Notice is amended, Arthrex will revise the “last updated” date at the bottom of this page.

Please review this Privacy Notice periodically and especially before you provide personally identifiable information to us. For material changes to this Notice, Arthrex will notify individuals by placing a notice on this page. Your continued use of the Site after any changes to this Privacy Notice indicates your agreement with the terms of the revised Privacy Notice.

If you would like to receive a copy of this Privacy Notice in an alternate format or language, please contact us at privacy@arthrex.com or (866) 363.3096.

Contact Information

If you have any questions or comments about this Privacy Notice, the ways in which Arthrex collects, uses and discloses your Personal Data as described above, your choices and rights regarding such use, or wish to exercise your rights under California law, please contact:

Email: Privacy@arthrex.com

Phone: (866) 363.3096

Postal Address: Arthrex, Inc.

                           Attn: Risk Management & Compliance

                           1370 Creekside Blvd.

                           Naples, Florida 34108