This Privacy Statement tells you how we protect and use information that we gather through Medtronic Mobile Applications (the “Application” or “App”). This Privacy Statement is intended for a global audience.
For users in Europe, please refer to the privacy statements specific to your geography that are referenced in your App.
This Privacy Statement was last revised on December 7, 2017. We may change the Privacy Statement at any time and for any reason.
Please read the End User Licensing Agreement (EULA) for your Application to understand the general rules about your use of the Application. Except as written in any other disclaimers, policies, terms of use, or other notices in an Application, this Privacy Statement and the EULA are the complete agreement between you and Medtronic with respect to your use of the Application.
INTRODUCTION
The Applications are owned and operated by Medtronic. Medtronic is the name we use to refer to our whole business, including Medtronic plc. and any of the companies that it controls, such as its subsidiaries and affiliates. When we use the words "we" or "our," we mean Medtronic. The information we receive, and how we use it, depends on what you do when using the Application.
We collect and use both personal information (information that is identifiable to you personally) and non-personal information about you through the application. Please see below for a definition of personal and non-personal information, and how Medtronic may use them.
WHAT IS PERSONAL INFORMATION?
Personal information is information we collect through the App that can specifically identify you. Examples of personal information include:
- First name
- Last name
- Geolocation information (where you are located at a point in time)
- Email address
- Phone number
- Your health condition
- Hospital/clinic name, address, and phone number
- Medical device serial number
- Implant date
- Model number
- Medical device name
- Mobile device identifiers, such as model number, manufacturer, serial number, or IMEI/MEID
HOW DOES MEDTRONIC COLLECT AND USE YOUR PERSONAL INFORMATION?
We may collect and use personal information from you through an App to provide you with access to the App. You may choose not to provide us with this information, but then you may not be able to access and utilize the App. In addition, we may collect and use your personal information:
- If you are a Patient, to transmit data to your Health Care Provider
- To provide services to you through the App
- To send you notifications
- To respond to your requests
- To develop records including records of your personal information
- To analyze how people use our App and to research, develop, and improve programs, products, services, and content
- To create a set of data that has only non-personal or de-identified information. In this case, we would remove your personal identifiers (your name, email address, biometric data, etc.) and we may treat it like other non-personal or de-identified information.
- To enforce this Privacy Statement and other rules about your use of the App
- To protect our rights or property
- To protect someone's health, safety, or welfare
- To comply with a law or regulation, court order or other legal process
DOES MEDTRONIC EVER SHARE PERSONAL INFORMATION WITH THIRD PARTIES?
Medtronic will not share your personal information collected from the App with an unrelated third party without your permission, except as described below. Medtronic may share personal information with any member of our corporate group, including parent companies, subsidiaries, and affiliates, for purposes that are consistent with those identified in this Privacy Statement.
In the ordinary course of business, we will share some personal information with companies that we hire to perform services or functions on our behalf. In all cases in which we share your personal information with a third party, we will only allow them to keep, disclose, or use your information to provide the services we asked them to provide. We will not sell, exchange, or publish your personal information, except in conjunction with a corporate sale, merger, dissolution, or acquisition.
We may be required to release your personal information in response to a court order, subpoena, search warrant, law, or regulation. We may cooperate with law enforcement authorities in investigating and prosecuting Application users who violate our rules or engage in behavior which is harmful to other users (or illegal). In addition, we may keep, disclose, and use your personal information in order to comply with U.S. FDA and other governmental guidance, directions, regulations, and laws.
We may disclose your personal information to third parties if we feel that the disclosure is necessary to:
- Enforce this Privacy Statement and the other rules about your use of the App
- Protect our rights or property
- Protect someone's health, safety, or welfare
- Comply with a law or regulation, court order, or other legal process
TRANSFERS BETWEEN COUNTRIES
- For China users: As part of a global company, please be aware that your personal information may be transferred to, stored, and processed in China or any other country in which Medtronic (including its Affiliated Companies), contractors or agents maintain facilities offshore. The countries to which we are likely to transfer personal information may include the United States, Singapore, Switzerland, the Philippines, and the Netherlands. By using the App, you consent to any transfer, processing, or storing of information outside China. Medtronic ensures that the use and disclosure of the personal information transferred is dealt with in accordance with this policy and the safeguards under PRC privacy laws.
- For Japan Users: Medtronic Japan may engage and delegate all or part of business operations including handling personal information to other Medtronic parties located outside of Japan to the extent it is necessary for achieving purposes of use described at Japan Privacy Policy. Medtronic Japan may also share personal information described at Japan Privacy Policy among other Medtronic parties located outside of Japan for purposes of use described at Japan Privacy Policy. In that case, Medtronic ensures that the use and disclosure of the personal information transferred or shared is dealt with in accordance with this policy and the safeguards under Japan Personal Information Protection law.
- For Australian and New Zealand users: As part of a global company, please be aware that your personal information may be transferred offshore. The countries to which we are likely to disclose personal information may include the United States, Singapore, Switzerland, the Philippines, and the Netherlands. Medtronic ensures that the use and disclosure of the personal information transferred is dealt with in accordance with this policy and the safeguards under ANZ privacy laws.
- For Canada Users: Medtronic is located outside of Canada, and may also use third-party service providers that are located outside of Canada. Accordingly, your personal information may be transmitted to, processed in, and stored within the United States and other foreign jurisdictions, and may be accessible to law enforcement or other authorities within those jurisdictions.
- For Latin America, Russia, Central Asian Users, and Middle East and North Africa Users: By accepting this, you are giving us authorization to receive, process, and use your personal information, including sensitive data, and also transfer the data out of your country to our affiliates and subsidiaries internationally, or third parties hired by Medtronic to manage the App.
WHAT IS NON-PERSONAL INFORMATION?
Non-personal information is information we collect through the Application that does not identify you as an individual. It may include information such as the following:
- The date and time you access our App
- The links within the App on which you click
- BuT status; Wi-Fi/Cell status
- Pages you visit on our mobile site, or within the App
- How you use this App
- App performance
WHAT DOES MEDTRONIC DO WITH NON-PERSONAL INFORMATION?
Because non-personal information cannot identify you, there are no restrictions on the ways that we can use or share non-personal information. We will use non-personal information to help us make the App more useful to users. We also will use non-personal information for other business purposes. For example, we may use non-personal information or aggregate non-personal information to:
- Create reports for internal use to develop programs, products, services, or content
- Customize the information or services that are of interest to you (including determine which features to show)
- Share it with third parties
WHAT ABOUT PRIVACY ON OTHER APPLICATIONS?
The Application may contain links to other apps or websites. Some of those websites or apps may be operated by Medtronic, and some may be operated by third parties. We provide the links for your convenience, but we do not review, control, or monitor the privacy practices of websites or apps operated by others. This Privacy Statement does not apply to any other application or website, even if operated by Medtronic. We are not responsible for the performance of applications or websites operated by third parties or for your business dealings with them. Therefore, whenever you leave the Application we recommend that you review each application or website's privacy practices and make your own conclusions regarding the adequacy of these practices.
DOES MEDTRONIC EVER COMMUNICATE DIRECTLY WITH USERS TO THE APPLICATION?
We may contact you periodically by email or text messages, if you agree to that.
COOKIES
Apps that link to, or connect with, websites may include cookies, pixel tags/web beacons, and similar technologies. This helps us to provide you with a good experience when you use the App or browse the websites, and also helps us to improve the App and our website. For further detailed information about cookies and the purposes for which we use them, please see the section of our website privacy policy that discusses cookies, above.
CHILDREN’S PRIVACY
We care about protecting the online privacy of children. We will not intentionally collect any personal information (such as a child's name or email address) from children under the age of 13. If you think that we have collected personal information from a child under the age of 13, please contact us. For Middle East and North Africa users, please notify us regarding children under the age of 18.
CALIFORNIA “DO NOT TRACK” DISCLOSURES
California law (CalOPPA) requires Medtronic to let you know how we respond to web browser "Do Not Track (DNT) signals." Because there currently is not an industry or legal standard for recognizing or honoring DNT signals, we do not honor Do Not Track requests at the time.
WHAT ABOUT APPLICATION SECURITY?
Security is very important to us. We also understand that security is important to you. We take reasonable steps to protect your personal information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. You should keep in mind that no online database or Internet transmission is ever 100% secure or error-free. You acknowledge that the App may not be password protected, and that you are responsible for maintaining the confidentiality and security of any of your data available via the App on your mobile device, by using an ID and password credentials for your mobile device.
HOW TO CONTACT MEDTRONIC
If you have questions or comments about this Privacy Statement, please use the Contact Us form on our App, or use the Contact Us form on our website.
You may use the Contact Us form on our Application to exercise your rights to access, rectify, update, and/or eliminate your personal information or ask for non-disclosure. Elimination may not be possible if it can cause damage to third parties or if preserving your personal information is required by any law or regulation.