Globus Medical Privacy Notice
Last Updated: September 2, 2024
This Privacy Notice describes how Globus Medical, Inc. and its affiliates and subsidiaries (collectively, “Globus Medical”) collect, use, share, and protect personal information gathered through the Globus Medical website (the “Site”) or other information gathering platforms Globus Medical may use (collectively “Services”), as well as through our offline interactions with you. In some cases, Globus Medical may issue more specific privacy notices for some products, services, or geographies.
This Privacy Notice does not pertain to NuVasive Clinical Services, NuVasive Japan, Globus Medical Japan, or The Better Way Back program. Please click the links provided to visit the privacy notices for these affiliates or programs:
- NuVasive Clinical Services: Notice of Privacy Practices
- NuVasive Japan ニューベイシブジャパン: Privacy Policy プライバシーポリシー
- Globus Medical Japan グローバスメディカル株式会社が、: Privacy Policy プライバシーポリシー
- The Better Way Back: Privacy Statement
Who We Are
Globus Medical is a global company with various offices, affiliates, and subsidiaries. Different Globus Medical entities may serve as the data controller (the entity responsible for processing your personal information) depending on the purpose for which Globus Medical processes your personal information and your geographic location.
Globus Medical’s Use of Personal Information
Globus Medical may collect, process, store, and share your personal information throughout the course of our relationship with you. The types of personal information we collect and the ways we use, store, and share that information depend on the nature and circumstances of our relationship with you.
Personal Information We Collect
- Identifiers such as your name, your postal addresses, email addresses, social networking website user account names, telephone numbers, or other addresses or numbers at which you can receive communications, your online or device identifiers, including your IP address, and your driver’s license number, passport number, national ID number, or other government identification number,
- Demographic information such as your age, citizenship status, military or veteran status, and, where permitted by local law and you choose to disclose it, your race or ethnicity,
- Commercial information such as information related to your purchasing, payment, and delivery history and habits,
- Internet or other electronic network and device activity such as information about your browsing behavior, search history, and interactions with our websites, emails, and advertisements, including data from cookies,
- Inferences regarding preferences and other characteristics such as our assessment of the types of products or services you may have an interest in,
- Audio, video, and pictures such as security footage from our facilities and recordings you may be included in when participating in our events, interacting with us, or providing your testimonial feedback,
- Professional or employment-related information such as information in your resume or CV, your job preferences, your job application profile, and, where permitted by local law, background check information and drug test results, and
- Health information including any disabilities for which you require accommodations. Where such services are available, Globus Medical may collect patient information from our healthcare provider customers for patient outcome-related benchmarking services, including patient ID number, diagnosis or condition, age, height, weight, gender, the Globus Medical product used, health history, and pre- and post-procedural health status and recovery progress. In the event of a patient safety concern or adverse event, we may collect the above patient information as well as additional information as required by law, including the patient’s name and adverse event details.
How We Collect Personal Information
- Information may be collected when you submit it to the Website or Globus Medical Platforms or interact with us. For example, when you submit a request for information or submit a request for Globus Medical to contact you. Globus Medical may also request optional information from you to support your use of the products and services,
- From the devices you use to access the Website or Globus Medical Platforms, which may provide information to us, including the model, operating system and version, the name of the domain from which you access the Internet, your Internet Protocol (“IP”) address, and other unique device identifiers. Globus Medical also collects device information like the date and time you access the Website or Globus Medical Platforms, which pages or portions of the Globus Medical Platforms you visit, the search terms you use, the links you click on, the browser you use, and your language preference. To collect much of this information, we use cookies and web analytics. Please see the section below titled Cookies and Analytics for more information,
- From our vendors and service providers, such as our web hosting providers, analytics providers, and advertisers, who may provide us information about you or your use of the Website or Globus Medical Platforms. You may also give us permission to access your information from services offered by third parties. The information we obtain from third parties depends on your relationship with those third parties and the third parties’ privacy policies,
- From our healthcare provider customers, where they provide a subset of patient information in support of patient outcome-related benchmarking, quality improvement, and comparative effectiveness analysis. Additionally, our customers may provide identified patient information for patient safety and adverse event reporting purposes as required by law, and
- From publicly available information, including the information you choose to post publicly on your social media pages.
How We Use Personal Information
Globus Medical may use the personal information we collect for the following purposes:
- To enter and fulfill business agreements with you.
- For order fulfillment, including payment processing, shipment, and returns.
- To provide customer service and respond to inquiries.
- To provide you with educational information, marketing, communications, and offers for products and services from Globus Medical and third parties.
- To plan and coordinate events, including to assist with the travel logistics arrangements associated with attending our events.
- To process job applications.
- To provide outcome-related benchmarking services to healthcare provider customers (US only).
- To solicit donations for and operate charitable medical missions.
- To monitor the safety and efficacy of Globus Medical products.
- For research, analysis, and product development.
- To conduct clinical research.
- To operate, maintain, and improve the Site and Services.
- To maintain the rights, safety, and security of Globus Medical, the Site and Services, our products, databases, and other technology assets.
- To detect, prevent, or otherwise address fraud, security, or technical issues.
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of a bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.
- To protect someone’s health, security, or welfare.
- To respond to law enforcement requests and as required by applicable law, court or other lawful order, or governmental regulations, including our transparency reporting obligations.
- As otherwise described to you at the time your personal information is collected, or with your consent, if not listed here.
How We Share Personal Information
Globus Medical may share your personal information with third parties for the following purposes:
- With service providers who perform a variety of services and functions for us, such as data storage, order fulfillment, and financial, legal, and marketing services. Your information will only be shared subject to an agreement with Globus Medical that permits the service provider to use your information only to provide the agreed services on our behalf,
- With our affiliates and subsidiaries who may use the personal information for the purposes described in this Privacy Notice,
- With researchers and academics who may use your information with your consent and in accordance with this Privacy Notice and applicable data protection laws,
- With a business transition partner in the event we go through a business transition such as a merger, acquisition by another company, bankruptcy, reorganization, or sale of all or a portion of Globus Medical’s assets,
- With law enforcement or governmental agencies to comply with a court order, law, or legal process, including to respond to any government or regulatory request,
- If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Globus Medical, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction, and
- With third parties for their independent use upon your request or with your prior authorization.
Cookies and Analytics
Cookies are text files stored on our Site’s servers and your web browser and are used by the Site to remember you for various purposes. To learn more about the cookies used on our Site, or to change or withdraw your consent for certain cookies at any time, please click the Cookie Settings link in the cookie notice banner or in the footer of the Site.
Like most other websites and services, Globus Medical uses cookies to help keep the Site stable, secure, and free of interruption. These cookies are essential to the proper functioning of our Site and cannot be disabled.
We also use website analytics services provided by Google Analytics and Hotjar, which may use cookies to collect information about your online activities for non-advertising purposes and provide us aggregated statistics about the usage of the Site. We use this aggregated data analysis to gain insights on user activity and improve the content and functionality of the website.
You can find more information about Google’s data protection practices and terms of use by visiting Google’s websites at https://www.google.com/analytics/terms/us.html and https://policies.google.com/privacy?hl=en. You can prevent Google from collecting and processing cookie-generated data relating to your use of a website by downloading and installing the browser plug-in available at the following link: http://tools.google.com/dlpage/gaoptout.
You may also alter your browser settings to block cookies. Browsers are different, so refer to instructions related to your browser to learn about cookie-related and other privacy and security settings that may be available. For more information on cookies and how to disable them, you can consult the information provided by visiting the Networking Advertising Initiative site at optout.networkadvertising.org and the Digital Advertising Alliance site at youradchoices.com.
Selling or Sharing Personal Information and Profiling
Globus Medical does not sell personal information for monetary or other valuable consideration. We also do not share personal information for behavioral advertising purposes, including cross-context behavioral advertising. We do not use sensitive personal information for inferring characteristics about individuals. Globus Medical does not use automated processing of personal information for profiling purposes.
Links to Third Party Sites
The Site may provide links to other web sites or resources over which Globus Medical does not have control (“External Web Sites”). Such links do not constitute an endorsement by Globus Medical of those External Web Sites. You acknowledge that Globus Medical is providing these links to you only as a convenience, and further agree that Globus Medical is not responsible for the content of such External Web Sites. Your use of External Web Sites is subject to the terms of use and privacy policies located on those External Web Sites. We encourage you to read the privacy policy of any web site that you visit before you provide any information to the operator of that web site.
Marketing Communications
At any time, you may choose not to receive marketing communications from Globus Medical by following the unsubscribe process described in the message or by contacting us at privacy@globusmedical.com. Where required, Globus Medical will obtain your opt-in consent prior to sending you marketing communications.
Please note that even if you unsubscribe from newsletters and promotional emails, we may still need to contact you for non-marketing purposes, such as with important transactional information about your account or your equipment.
Clinical Study Participants
If you participate in a Globus Medical-sponsored clinical trial, you will receive detailed information on the scope of personal information processing in your informed consent document. The information you are given for your specific trial controls your situation. In general, your data will be processed for the purpose of conducting the trial, applying for the approval of a new medical device product, and, if applicable, for other purposes as specified in the pertinent declaration of consent for the study. Anyone who views your identified personal information during a clinical trial is obligated by contract to hold this information in strict confidence.
Job Applicants
If you apply for a job with Globus Medical, we will use the personal information that you provide in your application, including any attachments sent, for the purpose of considering your candidacy for employment. If you have a social media profile, including a LinkedIn profile, Globus Medical may also process the data you choose to share on social media. In certain jurisdictions, where permitted by law, we may also conduct and process the results of background checks and drug tests on candidates.
The personal data we collect for recruitment include the following:
- Your personal contact details including your name, title, addresses, phone numbers, and email addresses,
- Any data you include in your resume, CV, or cover letter when applying to a position on our careers site,
- Any data you add to your candidate profile if you choose to create an account on our careers site,
- Your employment history, titles, certifications, and professional memberships,
- Your educational background,
- Your right to work documentation, such as proof of citizenship or visa information,
- Your references,
- Your compensation history,
- Any data you post publicly on your social media profiles, including LinkedIn,
- A copy of your driving license, Social Security number, or other government ID in jurisdictions where we conduct background checks,
- The results of any background checks conducted, including information about criminal convictions and offenses,
- The results of any drug tests conducted,
- Your employment preferences, including compensation expectations and location preferences,
- CCTV footage or other video and audio information obtained through electronic means when you visit a Globus Medical facility or participate in meetings with call or video recordings enabled,
- In jurisdictions where permitted, and with your consent, your racial and ethnic background for diversity metrics, and
- If an offer is extended, your compensation offer, start date, and location of employment or workplace.
Globus Medical uses this information to help us determine whether to offer you employment, for legal and administrative purposes, and to enable us to meet our legal and contractual obligations as a potential employer. We may also use personal data you voluntarily disclose in connection with compiling aggregate government labor statistics.
If you use our online job board hosted by Workday, your personal information will also be processed according to Workday’s privacy notice, found here: https://www.workday.com/en-us/privacy.html.
We only process this personal data where you have given your consent, where the processing is necessary for the efficient administration of your employment application, where the processing is necessary to comply with our legal obligations, or where the processing is in our legitimate interests as an employer if the processing does not interfere with your rights.
Your personal data may be shared with our affiliates or third-party processors that provide services for Globus Medical. Please see the “How We Share Personal Information” section above for more information about how we share personal data with our affiliates and third-parties. Please see the “Data Retention Period” and “Your Privacy Rights” sections below to learn about our retention practices and how to exercise your privacy rights. Depending on where you reside, your personal data may be transferred to other countries, including the United States. Please see the “International Data Transfers” section below for more information.
For applicants residing in the European Economic Area (EEA), we will retain your personal data for 1 year after the completion of your application process if your application is not successful. If your application is successful and you accept an offer of employment, we will retain your personal data for the period of your employment plus 6 additional years to fulfill our legal and business obligations.
Grant Applicants and Recipients
If you choose to apply for a corporate grant through the Globus Medical Corporate Grant webpage, we will use the personal information that you provide in your application to evaluate your application. This data includes your name and contact information, and grant application details, including any attachments sent for the purpose of considering your application. If you receive a corporate grant, Globus Medical may be required to include your personal information in applicable transparency reporting.
Charitable Donors and Volunteers
If you choose to donate to NuVasive Spine Foundation (“NSF”), we will use your name, contact information, and payment details to process your payment, send you a receipt with tax information, and attribute your donation within our systems. With your consent, we may also publish your name alongside your donation and contact you about future NSF activities. If you use our online donation portal hosted by Classy, your personal information will also be processed according to Classy’s privacy notice, found here: https://www.classy.org/terms/privacy/.
If you apply to be a medical volunteer for a medical mission, we will collect your name, contact information, languages, CV, medical credentials and licenses, professional references, and passport information. We will use this information to process your application, manage the volunteers on each mission, and book your travel for the mission.
If you apply to volunteer with NSF in a non-medical capacity, we will collect your name, contact information, languages, and relevant skills or interests that may benefit NSF. We will use this information to process your application, contact you about volunteering with NSF, and determine how your skills can best support NSF’s mission.
Third-Party Distributor and Agents
If you are engaging with Globus Medical as a third-party commercial distributor or agent, we will use the information you provide us and publicly available information about you to conduct due diligence to ensure compliance with applicable regulations, to maintain quality control, and to ensure that our partners are reputable and trustworthy.
Depending on certain risk factors, this due diligence may involve the processing of names, contact information, employment information, criminal records, financial information, and media and social media profiles of your business, your business’s executives, senior officers and/or beneficial owners, and their familial relations.
Legal Basis for Processing
Globus Medical will only process (i.e., use) your personal information when the law allows us to, that is, when we have a legal basis for processing.
We use your personal information in the following circumstances:
- Performance of a contract: where needed to perform a contract with you as a party or to take steps at your request before entering such a contract,
- Legal or regulatory obligation: where needed to comply with a legal or regulatory obligation that we are subject to,
- Legitimate interests: where necessary for our interests (or those of a third party), provided that your fundamental rights do not override such interests. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal information for our legitimate interests,
- Consent and explicit consent: where you provided your knowing and voluntary consent to processing your personal information,
- Public interests: where the processing is necessary to ensure high standards of quality and safety in healthcare and medical devices, or
- Vital interests: where the processing is necessary to protect the life or imminent safety of you or another individual, where no other legal basis applies.
Where Globus Medical processes your personal information for our legitimate interests, we do not use your personal information for activities where the impact to your interests overrides our interests.
We only rely on consent as the legal basis for processing your personal information where it is required by applicable local law (for instance, in relation to some of our electronic marketing or the processing of certain sensitive data). Where processing is based on consent, you have the right to withdraw your consent at any time without penalty. When you withdraw your consent, we will stop the data processing.
Purpose Limitation and Data Integrity
Globus Medical will only process personal information in a way that is compatible with and relevant to the purpose for which it was collected or authorized by you, or as we notify you if these purposes change. You have the right to object to or request that we restrict the processing of your personal information for such additional or new purposes. Globus Medical will take reasonable steps to ensure that personal information is accurate, complete, current, secure, and reliable for its intended use.
Data Retention Period
Globus Medical will keep your personal information for as long as is reasonably necessary for the purpose of the processing or as otherwise required by law. We retain personal information until it is no longer necessary for providing our products and services, fulfilling our contractual agreements with you, complying with applicable law, protecting Globus Medical’s rights and interests (e.g., where the retention is necessary for the establishment, exercise, or defense of legal claims), or otherwise needed for the purposes for which it was collected or processed.
Security
Globus Medical will take reasonable steps to ensure that personal information is accurate, complete, current, secure, and reliable for its intended uses. We employ procedural and technological security measures that are designed to protect your personal information from loss, unauthorized access, disclosure, alteration, or destruction. However, please remember that no method of transmission over the internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.
Your Privacy Rights
Some privacy laws provide certain rights to individuals regarding their privacy and their personal information. Globus Medical respects your rights concerning your personal information.
In accordance with applicable laws, you may have the right to:
- Request confirmation of whether Globus Medical processes your personal information,
- Request information about the entities with which Globus Medical has shared your personal information,
- Request to access, know, or receive a copy of your personal information,
- Request correction of inaccurate, incomplete, or out-of-date personal information,
- Object to Globus Medical’s processing of your personal information for direct marketing,
- Oppose or object, for reasons relating to your situation, to the processing of your personal information based on our legitimate interest, unless we provide compelling legitimate grounds for the processing which override your privacy interests,
- Request (under certain circumstances) the restriction of the processing of your personal information,
- Request to limit the use and disclosure of your sensitive personal information,
- Request the anonymization or deletion of your personal information, subject to certain limitations described below,
- Revoke your consent for the processing of your personal information and request the deletion of your personal information processed with your consent, and
- Lodge a complaint with the appropriate Data Protection Authority for your jurisdiction if you have concerns about our practices regarding the processing of personal information.
Exercising Your Rights
If you would like to exercise any of these rights, please contact us at our email: privacy@globusmedical.com.
Validating Your Identity and/or Authorization to Request
To protect you and your personal information, requests must:
- Provide sufficient information for us to reasonably verify you are the person or an authorized representative of the person whose personal information is the subject of the request, and
- Describe your request with sufficient detail for us to properly understand, evaluate, and respond to it.
If you use an authorized agent to submit a request on your behalf, we may verify both your and your agent’s identities as well as documentation authorizing your agent to act on your behalf. We will only use personal information collected during the verification process to verify your identity or your agent’s authority to make the request on your behalf.
Exceptions to Deletion Requests
If you request the deletion of your personal information, depending on the nature of the data, deletion may consist of erasing, aggregating, or anonymizing your information. After we receive and validate your request, we will delete and direct our service providers to delete your personal information, unless an exception applies. We may deny your deletion request, in whole or in part, if retaining the information is necessary for us or our service providers to:
- Complete the transaction for which we collected the personal information, provide a service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract with you,
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities,
- Debug to identify and repair errors that impair existing intended functionality,
- Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us or make other internal and lawful uses of that information that are compatible with the context in which you provided it, or
- Comply with a legal obligation, including maintaining a record of your request and our response.
Non-Discrimination
Globus Medical does not discriminate against individuals who exercise their rights under applicable law. We will not engage in the following in a discriminatory manner:
- Deny you goods or services,
- Charge you different prices or rates for goods or services, including through granting discounts and other benefits, or imposing penalties,
- Provide you with a different level or quality of goods or services, or
- Suggest that you may receive a different price, rate, or level of quality of goods or services.
International Data Transfers
At times, your personal information may be transferred to other Globus Medical affiliates, service providers, or systems in countries that may not offer a level of data protection equivalent to that in your country, including the United States. Where such transfers occur, Globus Medical complies with the cross-border data transfer and export control laws of the countries in which it operates.
Children’s Privacy
This Site is not intended for children under the age of 18. Globus Medical does not knowingly collect personal information via this Site from children under the age of 18. If Globus Medical becomes aware that we unconsciously collected such information, we will promptly delete and/or destroy it upon being made aware of the collection.
Some of Globus Medical’s medical devices and products are intended for children or minors. In such cases, Globus Medical collects minors’ personal information relating to the use of these products for the purposes described in this Privacy Notice and with the informed consent of a parent or legal guardian. If this consent is revoked, Globus Medical will cease the processing of and/or destroy or delete the child’s personal information in accordance with the terms of the informed consent and applicable law.
Privacy Notice Updates
Globus Medical may need to update this Privacy Notice on occasion. If we update this Privacy Notice, we will post the updated Privacy Notice on our Site and update the effective date at the top of the notice. We encourage you to regularly visit this Privacy Notice to ensure that you are aware of our current practices with respect to your personal information.
Questions / Data Protection Officer
If you have any questions regarding this Privacy Notice, please contact us via email at privacy@globusmedical.com.
Please contact our data protection officers if you have any further questions, suggestions, or requests regarding data protection at globusmedical_dpo@globusmedical.com.
Supplemental chart on personal information processing
| Data Category | Data sources | How we use this data | Third parties with whom we may share this data |
|---|---|---|---|
| Audio, Video, and Pictures |
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| Commercial or financial information |
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| Criminal Data |
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| Demographic information |
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| Education information |
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| Health information |
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| Identifiers |
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| Internet, network or device activity |
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| Preferences |
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| Professional or employment information |
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| Sensitive personal data |
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