Privacy Statement

When you visit our websites or apps, we may collect and/or process your personal data to learn more about how you use our site/app and services. 

• What personal data we obtain

o    Electronic device information includes identifiers associated with your devices, operating system type and characteristics.

o    Internet and network activity information includes internet protocol (IP) address, domain name, web browser characteristics, language preferences, navigation and your interactions with our site or app (such as the pages you visit, links you click and features you use, dates and times of access to our site/app, browsing history, search history, the pages that led or referred you to our site), and other information about your use of our site or app.  

o    Geolocation data includes location information based on your use of our site/app.

o    Certain information by automated means, including cookies and similar technologies, such as Flash cookies, local storage, web beacons and pixels, JavaScript, software development kits (SDKs) and device identifiers.

• How we use your data

o    To ensure our sites or apps operate correctly and secure logins work properly.  

o    Improve visitor experience and learn how they use our sites/apps and their features.

o    Provide you with enhanced functionality such as video content and show you targeted ads on other sites or social media channels

Depending on your location, some Cookies may require your consent. Click here to know more about our use of Cookies and how to manage your Cookie settings and preferences.

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We may collect and process your Personal Data to create and manage your account with us, or when you request information about therapies or related services.

• What personal data we obtain

o    Identification information, such as your name, user ID number, date of birth or age, phone number, email address, physical address, and mailing address. 

o    Location data, such as your country/region and language preference. 

o    Login credentials, such as your username/email address and password. 

o    Professional information of healthcare professional, such as your profession, your job title and your medical specialty, the name of the institution you work for and your professional email address.

• How we use your data

o    Create and manage your account, including to authenticate you and ensure account security. We’ll do so with your consent or based on a contractual relationship we have with you or to take steps at your request, before entering a contract.

We may further use your account information, together with the information collected through Medtronic’s products or services, to communicate with you and provide you with the products and services you requested, unless you have been notified that an alternative notice applies to such use. 

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You can request or order certain Medtronic products and services directly from us (e.g., in our e-shop).

• What personal data we obtain

If you order our products and services, the types of personal data we obtain or process about you include:

o    Your contact information, such as your name, email address or account data. In certain cases, you may choose to also provide us with your phone number (optional) if you want delivery service providers or our support team to be able to contact you via phone about your order.

o    Your shipping details, such as your shipping address and instructions.

o    Information about the product and service ordered; and

o    Where applicable, payment information, such as your billing address, account number, payment card details (including card number, expiration date and security code). Depending on the payment method, your information may be shared with a trusted payment service provider. That service provider may process your data for its own purposes (e.g., to monitor, prevent and detect fraud). Please read the privacy policy of the payment service provider to learn more on how they’ll use your data.

• How we use your data 

We will use your data as needed to fulfill our contractual obligations to provide you with the products and services you requested and to deliver the products ordered. Your payment details will also be used to protect against, identify and prevent fraud and, where applicable, to handle payment-related complaints or investigations, based on our legitimate interests to do so. With your consent, we may also keep your payment card details to facilitate future orders.

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As a manufacturer of medical devices, we are subject to regulatory obligations when we place (or make available or put into service) our products on the market. Compliance with those obligations require us to process personal data.

• What personal data we obtain

The types of personal data we obtain or process as a manufacturer of medical devices include:

o    Data allowing the indirect identification of the patient or person exposed to an adverse health event, such as age, year or date of birth, gender, weight, height, or identification number. 

o    Data relating to the identification of the product concerned, such as the type of product used, serial number, implant date. 

o    Any other information necessary for the assessment of an undesirable health event, such as professional life, health data, therapy data, consumption of tobacco, alcohol, drugs, life habit and behavior; and

o    Contact details of the person who made a complaint or notified us of an adverse health event, or of any health professional likely to provide details. 

• How we use your data 

o    Conduct health-vigilance related activities, manage adverse health events and handle product complaints. We’ll do so to ensure compliance with our legal obligations and with high standards of quality and safety of healthcare and medical devices.

The Medtronic entity responsible for processing your data for the above purposes is the manufacturer of your Medtronic product or the Medtronic affiliate responsible for placing it on the market as mentioned on the product, package label or instructions for use.

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We may collect and process your Personal Data to treat and care for your medical condition and device.

• What personal data we obtain 

o   Contact information. Name, email address, postal address, telephone number, geographic location, language, date of birth, communication preferences, and optional profile pictures and third-party login information.

o   Family information. Marital status, family and household contact, relationship, and health data, dates of birth and death, legal guardianship, emergency contact status and information, and names and contact information of authorized persons named by you. 

o   Your medical device, including device ID, telemetry, and model/serial number, device usage data, user-generated content, and product use data.

o   Your medical device treatment history, including implantation details.

o   Your medical record and history, including your conditions, general health status, disabilities, family medical history, sex/gender, age, prescriptions and medications, procedure information (including IDs, videos, duration, and dates), medical practitioners, and lab/telemetry results.

o   Your medical status, including vitals, symptoms, condition reports, image, and device telemetry/monitoring. 

o   Volunteered information, including communications you send to us or other data you choose to provide.

•  How we use your data

o   Recording your preferences, including for communications from us.

o   Registering your device. 

o   Communicating with you about your condition or treatment, including information about your condition, treatment, or device pre- and post-trial and permanent implant.

o   Monitoring your device, including for issues with and the efficacy of the device or your health or condition.

o   Communicating with you about your device, including notifications about device configuration and status, as well as safety or quality issues if they arise.

o   Servicing your device, including by updating or upgrading it, diagnosing and resolving issues, and optimizing its configuration. 

o   Improving our treatments, products, and services, such as through surveys about specific health conditions or device performance/feedback.

o   Fulfilling your requests for information from us.

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We may collect and process your Personal Data to treat and care for your medical condition and device.

• What personal data we obtain 

o   Contact information. Name, email address, postal address, telephone number, geographic location, language, date of birth, communication preferences, and optional profile pictures and third-party login information.

o   Family information. Marital status, family and household contact, relationship, and health data, dates of birth and death, legal guardianship, emergency contact status and information, and names and contact information of authorized persons named by you.

o   Your medical device, including device ID, telemetry, and model/serial number, device usage data, user-generated content, and product use data.

o   Your medical device treatment history, including implantation details.

o   Your medical record and history, including your conditions, general health status, disabilities, family medical history, sex/gender, age, prescriptions and medications, procedure information (including IDs, videos, duration, and dates), medical practitioners, and lab/telemetry results.

o   Your medical status, including vitals, symptoms, condition reports, image, and device telemetry/monitoring. 

o   Volunteered information, including communications you send to us or other data you choose to provide.

• How we use your data

o   Recording your preferences, including for communications from us.

o   Registering your device.

o   Communicating with you about your condition or treatment, including information about your condition, treatment, or device pre- and post- trial and permanent implant.

o   Monitoring your device, including for issues with and the efficacy of the device or your health or condition.

o   Communicating with you about your device, including notifications about device configuration and status, as well as safety or quality issues if they arise.

o   Servicing your device, including by updating or upgrading it, diagnosing and resolving issues, and optimizing its configuration. 

o   Improving our treatments, products, and services, such as through surveys about specific health conditions or device performance/feedback.

o   Fulfilling your requests for information from us

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We may collect, process, and disclose your Personal Data to coordinate and work with your care team to treat and care for your medical condition and device.

• What personal data we obtain 

o   Contact information. Name, email address, postal address, telephone number, geographic location, language, date of birth, communication preferences, and optional profile pictures and third-party login information.

o   Family information. Marital status, family and household contact, relationship, and health data, dates of birth and death, legal guardianship, emergency contact status and information, and names and contact information of authorized persons named by you. 

o   Your medical device, including device ID, telemetry, and model/serial number, device usage data, user-generated content, and product use data.

o   Your medical device treatment history, including implantation details.

o   Your medical record and history, including your conditions, general health status, disabilities, family medical history, sex/gender, age, prescriptions and medications, procedure information (including IDs, videos, duration, and dates), medical practitioners, and lab/telemetry results.

o   Your medical status, including vitals, symptoms, condition reports, image, and device telemetry/monitoring. 

o   Volunteered information, including communications you send to us or other data you choose to provide.

• How we use your data

Coordinating with your care team when you request an appointment with a health care practitioner who will be treating your condition or managing your device, including your implanting and continuing care physicians.

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You may make an inquiry, require assistance or support by contacting our customer service or support team by phone, email or by using our “How to Contact Us” form, our chatbots or other customer support tools.

• What personal data we obtain 

If you contact our customer and support services to make an inquiry or request support, the types of personal data we obtain or process about you include:

o    Identification and contact information, such as your name, title, email address, telephone number, address (as relevant). 

o    Location data, such as country/region.

o    Information about you that you submit in your request.

o    Any other information about you necessary for dealing with your request, including data relating to your device or health if you’re a patient.

o    Audio recordings and notes if we record the conversation, we have with you. 

• How we use your data

We will use your data to respond to you, provide you with required support, and follow up on your request, including, where applicable, ensuring compliance with our regulatory obligations and establishing, exercising, or defending ourselves from legal claims. 

We will use your data for the above reasons based on the following bases:

o    Our need to perform the contract we may have with you (if you are an existing customer), or to take pre-contractual steps at your request. 

o    Our legitimate interests, in particular in training our personnel, improving our services to you and defending our legal rights; or

o    Our need to comply with our legal obligations. 

We may also keep a record of the communications we have with you for evidentiary purposes and to train our personnel and improve the quality of our services. If you call us, you will be notified at the beginning of the call whether our conversation will be recorded.  

If we need to use sensitive information about you (e.g., health data) as part of your request, we will seek your explicit consent or we will do so as necessary to ensure high standards of quality and safety of our products.  

Please note that, in some circumstances, we may use your data to provide technical support on behalf of and in the name of your medical institution or healthcare professional. This is the case if the Medtronic product or service you use was provided to your medical institution or healthcare professional, as part of the services Medtronic provides to them. If that product or service requires technical support, we’ll use your data as directed by your medical institution and/or healthcare professional, as part of your medical treatment. Please contact your medical institution or healthcare professional to learn more on their use of your data for the provision of medical treatment or care.

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Based on what you directly submit to us through this website, or through information provided by your browsing session about your browser, network, application, or device, we collect:

• What personal data we obtain 

o    Any contact information you directly submit to us, including name, email address, and telephone number, 

o    Any other content posted or submitted by you (including your relationship to Medtronic that you indicate, the type of health care provider you are if applicable, stage of education or training, and areas of interest, 

o    Demographic information including country of residence, 

o    Preferences including preferred language, and

o    Session information and device and network identifiers including IP address.

• How we use your data 

o    Create and manage your account and maintain our services, 

o    Personalize content based on your interests,

o    Interact with you at your request,

o    Perform analytics and research,

o    Improve our products and services,

o    Perform quality assurance and complaint handling functions,

o    Detect, investigate, and respond to malicious and fraudulent activities, and

o    Debug and repair our products and services.

We will not sell or share this data for marketing purposes except as disclosed in our Cookie Policy.  If you choose to close your account, we will maintain copies of your information in our internal records, systems, and databases, in accordance with our data retention schedules. We will continue to treat your personal data in accordance with this Privacy Notice.

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You may visit our locations in order to interact with our personnel, to provide services or perform certain tasks.

• What personal data we obtain
  If you visit Medtronic locations, the types of personal data we obtain or process about you include:

            o    Your contact information and visit details, such as your name, signature and arrival/departure time and date, to enable                    you to access our premises and provide you with a badge as applicable

            o    Video recordings of you if we operate closed-circuit television (CCTV) systems in the location you visit

• How we use your data
  We will use this information for security and safety reasons, including ensuring the security of Medtronic personnel, property and assets, and complying with our internal security policies.

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From time to time, we may invite you to participate in a Medtronic survey to gather your feedback to help us determine customer satisfaction levels, identify areas of potential improvement or to carry out market research.

What personal data we obtain
To the extent possible, we will gather your feedback in an anonymous manner. In some cases, however, the survey may gather identifiable respondent information. In such instances, the types of the personal data we obtain or process about you includes:

• Identification/contact information, such as your name, email address, phone number
• Professional details (if you are a business customer), such as your employer’s details, specialty, professional experience, professional qualifications
• Opinions, views, or information you choose to provide us as part of your survey responses. If you’re a patient, this may include your age and information about your health, such as your medical condition, type of Medtronic product/services you are treated with, details of the medical procedure you underwent as a patient and your condition post such procedure.
• Where applicable, information collected by automated means (including cookies), such as your IP address, and survey metadata (e.g., the language you take the survey in, duration of your survey response, last date the survey was started)

How we use your data
We will use your personal data to conduct the survey, including to send it to you, allow you to submit your survey responses, prevent survey fraud, analyse the survey results, and improve or develop our products and services, accordingly. 

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In some circumstances, we process personal data to comply with applicable legal requirements and our policies, to perform auditing and other internal functions, or for litigation and dispute resolution purposes.

What personal data we obtain
When this is the case, the types of personal data we obtain or process about you include:

• Your identification and contact information
• Other information as is necessary and relevant to the particular case; e.g., in the event of an (internal) audit, information contained in documents and materials audited, or in the event of litigation, information gathered in the evidence necessary for the litigation

How we use your data
We will use your information — in an anonymized, de-identified or redacted form, where appropriate — in order to:

• Fulfil our contract with you when it is our legal duty
• Support and manage our therapies or related services by our service providers and/or business partners
• Manage our relationship with you and keep our records up to date
• Manage websites for healthcare professionals, account access support, verify your personal identity as needed for us to provide our therapies or related services, online support, and related services safely and lawfully
• Properly administer our business, therapies, or related services
• Enforce, establish, exercise, or defend our legal rights, including this privacy notice and other rules about use of our product or services
• Protect and secure websites, networks, systems, data, and services Medtronic provides to our customers
• Manage compliance with our policies, including conducting (internal) audits, investigations, or due diligence checks for the above reasons
• Understand how to improve our therapies or related services
• Comply with applicable legal requirements, regulations, court orders, or other legal processes

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