Scope

This website and this Privacy Statement are intended for Singapore, Bangladesh, Indonesia, Malaysia, the Philippines, and Brunei audience.

For Australia and New Zealand: Please visit our ANZ Privacy Policy which applies to our interactions with you.

For Japan: Please visit our Japan Privacy Policy which applies to our interactions with you.

For South Korea: Please visit our South Korea Privacy Policy, which applies to our interactions with you.

For India: Please visit our India Privacy Policy, which applies to our interactions with you.

For Thailand: Please visit our Thailand Privacy Policy, which applies to our interactions with you.

For Vietnam: Please visit our Vietnam Privacy Policy, which applies to our interactions with you.

Introduction

This notice describes how Medtronic collects and uses information about you (“personal data”) in connection with the activities described below, including when you order Medtronic products and services, when you visit this website and Medtronic locations, when you contact Medtronic, or when you participate in Medtronic events, surveys, or clinical studies in Singapore, Bangladesh, Malaysia, the Philippines, and Brunei.

Unless otherwise stated below, the Medtronic company responsible for processing your personal data is the Medtronic entity in the country or region where you are located or with which you interact, including Medtronic International, Ltd., PT. Medtronic Indonesia, Medtronic Bangladesh Private Limited, Medtronic Malaysia Sdn. Bhd., or Medtronic Philippines, Inc.. In this Privacy Notice, these entities are collectively referred to as “Medtronic”, “we”, or “us”.

In this privacy notice, we’ll tell you what personal data we obtain about you, how we use that information, with whom we share it, what rights you have regarding your information, and how to contact us to exercise these rights.

This privacy notice does not apply when you have been notified that an alternative notice applies (for example on other Medtronic websites) or where Medtronic processes your personal data on behalf of your medical institution or healthcare professional in connection with your medical treatment. Your medical institution and/or healthcare professional is solely responsible for the processing of your personal data for the provision of your medical treatment and care. In addition, some sections of this notice only apply to certain geographies, as described further below. In such instance, your data is subject to your medical institution’s own data policies and privacy notices. When we obtain your data this way, we’ll use it only based on the instructions of your medical institution, unless we are required to do so to comply with our regulatory obligations, or your medical institution has authorized us to further use your data, as described below.

Our website may contain links to other apps or websites. Some of those websites or apps may be operated by our international affiliates, and some may be operated by third parties. This privacy notice does not apply to any other application or website, even if operated by Medtronic. When you leave our website, please read the privacy notice at each place you visit to see how that location processes your data. In addition, some sections of this privacy notice only apply to certain geographies, as described further below. This privacy notice does not apply to data processing activities specifically relating to current or former Medtronic employees or applicants – the relevant notice may be requested by contacting AskHR@Medtronic.com.

Personal data we collect and how we use it

This section describes how Medtronic uses your personal data (also known as your personal information in certain jurisdictions). Unless we need your personal data to comply with laws and regulations, you are not required to provide information to us but, if you choose not to do so, we may not be able to offer you certain services and related features, or to respond to requests that you may have.

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

  • Electronic device information includes identifiers associated with your devices, operating system type and characteristics.
  • 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.
  • Geolocation data includes location information based on your use of our site/app.
  • 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

  • To ensure our sites or apps operate correctly and secure logins work properly.
  • Improve visitor experience and learn how they use our sites/apps and their features.
  • 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. See our Cookie Policy to learn more about our use of cookies and how to manage cookie settings and preferences.

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When you create an account or register your device with us, we may collect and process your personal data to create and manage the account or to respond to your request for information about therapies or related services.

What personal data we obtain

  • Identification information, such as your name, user ID number, date of birth or age, phone number, email address, physical address, and mailing address.
  • Location data, such as your country/region and language preference.
  • Login credentials, such as your username/email address and password.
  • Information about your medical device, such as its identification/serial number(s), model and type, and other status information related to it.  
  • Professional information of healthcare professional account holder, 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

  • 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.
  • Together with the information collected through our products or services, we may communicate with you about 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:

  • 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.
  • Your shipping details, such as your shipping address and instructions.
  • Information about the product and service ordered; and
  • 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:

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

  • 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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You may make an inquiry, require assistance or support by contacting our customer service or support team by phone, email as listed in the How to Contact Us section, 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 from that interaction include the following:

  • Contact information you directly submit to us, including name, title, physical, postal, and email address, and telephone number
  • Medical device identifiers or information, including device serial number
  • Demographic information, including country of residence, date of birth, and age
  • Preferences including preferred language
  • Session information and device and network identifiers including IP address
  • Other information about you necessary for dealing with your request, including data relating to your device or health if you’re a patient
  • Recordings and notes if we record the conversation we have with you
  • Other content posted or submitted by you including your relationship to Medtronic that you indicate, the type of healthcare provider you are if applicable, stage of education or training, and areas of interest

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:

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

  • Any contact information you directly submit to us, including name, email address, and telephone number,
  • 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,
  • Demographic information including country of residence,
  • Preferences including preferred language, and
  • Session information and device and network identifiers including IP address.

How we use your data

  • Create and manage your account and maintain our services,
  • Personalize content based on your interests,
  • Interact with you at your request,
  • Perform analytics and research,
  • Improve our products and services,
  • Perform quality assurance and complaint handling functions,
  • Detect, investigate, and respond to malicious and fraudulent activities,
  • 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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We may use third party web analytical services including Adobe Analytics to gather user- and user cohort-level web portal use trend information.

What personal data we obtain

  • Identification and contact information, such as your name and email
  • Location data, such as country/region
  • Your provider information including physician’s email address
  • Technical connection and portal activity information such as IP address, time and date stamp, browser information, requested page, data about website use and pages visited.

How we use your data

We will use your data to learn about effective use of portal by the users, improve the user experience and design of the portal, improve our site and our service to you, and to optimize our content.

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You may send us a private or direct message via social media, or you may communicate about us or Medtronic products on social media (e.g., if you participate in our online communities, share a comment about a Medtronic product or if you tag Medtronic in your post).

What personal data we obtain

If you interact on social media with or about us, the types of personal data we obtain or process about you include:

  • Social media information, such as your social media username, profile picture, country.
  • Any information about you that is contained in your comments, posts, or other content about Medtronic that you share on social media services.

How we use your data

We will use your data to review or respond to your message or comments, and where applicable, to provide you with the required support and take any necessary follow-up actions.  If you communicate about us or our products, we will also use your data to gain a general understanding of what people are saying about us and our products. We’ll do so based on our legitimate interests, in particular in improving our products and services.

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We collect your personal data you provide when you interact with our services or communicate with our technical or online support systems, such as chatting with a bot provided on our website or sending messages to us using our services.

What personal data we obtain

  • Your contact information, such as name, email address, postal address, telephone number, geographic location, language, date of birth, age, implanted device serial number (if applicable), communication preferences, and optional profile pictures and third-party login information.
  • Demographic information including country of residence.

How we use your data

  • Allow users to participate in the services, including responding to your questions, concerns, requests, complaints, or comments.
  • Provide you with information on products, services, therapies, or suggestions you requested during the chat session.
  • Customize or improve the content, recommendations and offers that we display to you on the services.

We may collect aggregated information through our chat services using cookies and through other means as described in 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:

  • 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.
  • 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. We will do so as necessary for the purposes of Medtronic’s legitimate interests in ensuring the security of Medtronic personnel, property and assets and complying with our internal security policies.

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We may collect and process your personal data for research and development purposes, such as improving the quality, safety, and efficacy of devices, services, interfaces, and treatments.

What personal data we obtain

  • Your medical device, including device ID, telemetry, and model/serial number, device usage data, user-generated content, and product use data.
  • Your medical device treatment history, including implantation details.
  • Your device/networking information, including system generated user ID, system log including system events and error logs, machine data, system configuration, system generated procedure ID, device ID, other data collected during your interaction with our therapies or related services, and date and time stamps.

How we use your data

  • Analysis, including event and crash detection, repair, and improvement, and utilization and efficacy reviews.
  • Research, including activities resulting from that research such as developing and improving programs, therapies, related services, and content.

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You may wish to participate in one of our physical or virtual events (such as workshops, meetings, webinars or live broadcast events), or we may ask you to share your story, provide testimonial or take part in an interview about your treatment with a Medtronic product. 

In this case, we’ll need to process some personal data about you, as described below.

What personal data we obtain

If you participate in one of our events, testimonials or interviews, the types of personal data we obtain or process about you include:

  • Identification/contact information, such as your name (or a fictitious name to protect your privacy), email address, nationality, country.  
  • Personal details, such as dietary requirements, where applicable.
  • Professional information, such as your job type, title.
  • Product/service of interest to you, where applicable.
  • Health data, such as the medical condition treated by the Medtronic product (if you’re providing information as a patient);
  • Images, video and/or audio recordings of you, if our event/interview is filmed or recorded.

How we use your data

We will use your data to organize and facilitate the event/interview, and conduct Medtronic’s educational, promotional, and advertising activities. We will do so with your (explicit) consent, where required by applicable law (e.g., if the event is recorded and/or we obtain sensitive information such as your health data), or as otherwise necessary for the purposes of Medtronic’s legitimate interests in promoting and supporting Medtronic activities. 

The Medtronic entity responsible for processing your data for the above purposes is the Medtronic affiliate organizing the event/interview (in practice, the Medtronic business entity of the country where the event takes place).

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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 instance, the types of the personal data we obtain or process about you include:

  • 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.
  • 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, analyze the survey results, and improve or develop our products and services, accordingly, based on our legitimate interests to do so or with your consent, where required by applicable law.

The Medtronic entity responsible for the processing of your personal data for the above purposes is the Medtronic entity that sends you the survey, or the entity indicated in the survey questionnaire or notice provided to you at the time of data collection.

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We perform clinical activities, including clinical studies, clinical investigations, clinical surveys and other studies or research activities. In this context, we process personal data of participants to these activities, as well as personal data of healthcare personnel involved in such activities.

What personal data we obtain

The types of personal data we obtain or process this way will vary depending on the research activity, but this will generally include:

  • Information indirectly identifying participants in those research activities (such as age, or date of birth, place of birth, gender, country and department of residence, serial number or alphanumeric code excluding first and last name);
  • Where applicable, administrative data identifying participants that may be obtained by our service provider (such as first and last name, contact details, bank details) for very limited purposes, including to reimburse transport costs and/or to pay compensation.
  • Data concerning participants’ health, including vital status, and any other sensitive data, as relevant to the subject of the research activity (such as participants’ ethnic origin or data concerning their sexual life).
  • Dates relating to the conduct of the research activity (such as the date of inclusion);
  • Details of participants’ personal and professional life, such as family situation, current profession, business trips, consumption of tobacco, alcohol, drugs, lifestyle habits and behaviors, and any other relevant information.
  • Social security affiliation scheme/insurance.
  • Participation in other research activities.
  • Reimbursement of costs incurred by the participant.
  • Annual amount of compensation received.

For such activities, we typically have no access to directly identifiable information about patients as that information is kept confidential by the relevant healthcare professional.

If you’re a healthcare professional involved in our (clinical) research activities, the types of personal data we obtain or process about you include:

  • Identification data, such as name, gender, professional contact details, bank details.
  • Training and qualifications.
  • Other relevant details of professional life (e.g., professional curriculum);
  • If applicable, identification number in the directory of health professionals.
  • Amount of compensation and remuneration received.
  • Collaboration in research activities.
  • History of access, and connection to the medical data of participants in the research activities, where relevant.

How we use your data

We process your data in order to carry out research activities in the public interest, including to generate evidence to submit to health regulatory authorities in order to comply with our medical device manufacturer’s obligations, to assess the safety, performance and quality of our medical devices, and to develop and improve the safety and performance of these medical devices aiming at enhancing and improving healthcare.

We will do so based on our legitimate interests in conducting research activities, and for scientific research or to ensure high standards of quality and safety of our products, or with your consent as required by applicable law.

The Medtronic entity responsible for the processing of your personal data is the sponsor or Medtronic entity that determines the purposes of the clinical study or research project, as indicated in the clinical study or research documentation or in other relevant documentation provided by the healthcare professional in connection with the clinical or research activities you participate in.

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If you’re a patient, your medical institution and/or healthcare professional (your “Medical Institution”) may use Medtronic products and services as part of your medical treatment. In such instance, we may obtain information about you, including health data, as determined by your Medical Institution. We will use this information on behalf of your Medical Institution in order to provide the services requested by your Medical Institution. Please contact your Medical Institution or physician to learn more on the use of your data for the provision of your medical treatment and care. Medtronic is not responsible for this use. In such instance, your data is subject to your Medical Institution’s own data policies and privacy notices. 

When we obtain your data this way, we’ll use it only based on the instructions of your Medical Institution, unless we are required to do so to comply with our regulatory obligations, or your Medical Institution has authorized us to further use your data, as described below.

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

What personal data we obtain

  • 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.
  • 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.
  • Your medical device, including device ID, telemetry, and model/serial number, device usage data, user-generated content, and product use data.
  • Your medical device treatment history, including implantation details.
  • 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.
  • Your medical status, including vitals, symptoms, condition reports, image, and device telemetry/monitoring.
  • Volunteered information, including communications you send to us or other data you choose to provide.

How we use your data

  • Recording your preferences, including for communications from us.
  • Registering your device.
  • Communicating with you about your condition or treatment, including information about your condition, treatment, or device pre- and post- trial and permanent implant.
  • Monitoring your device, including for issues with and the efficacy of the device or your health or condition.
  • Communicating with you about your device, including notifications about device configuration and status, as well as safety or quality issues if they arise.
  • Servicing your device, including by updating or upgrading it, diagnosing and resolving issues, and optimizing its configuration.
  • Improving our treatments, products, and services, such as through surveys about specific health conditions or device performance/feedback.
  • 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

  • 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.
  • 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.
  • Your medical device, including device ID, telemetry, and model/serial number, device usage data, user-generated content, and product use data.
  • Your medical device treatment history, including implantation details.
  • 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.
  • Your medical status, including vitals, symptoms, condition reports, image, and device telemetry/monitoring.
  • 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.

Data you provide to us
We may ask that you, your caregiver, your account administrator, or any individual authorized by you not send or disclose any personal data other than the data that we ask you to provide using our therapies, related services, or otherwise to us.

Sensitive data use
Some of the data we collect, and use is considered sensitive under applicable laws, which may include, for example, health- and financial-related data and genetic/biometric data. Our collection and use of sensitive personal data is limited to that which is necessary to provide you with your requested services, including treating your condition.

You can choose to withdraw or withhold your consent, but, because your sensitive data is necessary to provide you with these services, you will not be able to use these services.

Secondary use of data
With the authorization of your Medical Institution, the data obtained as part of the services provided to your Medical Institution may be further used for Medtronic’s legitimate business purposes, including to improve and develop Medtronic products and services, to conduct benchmarking, business analytics or market research, to train and educate Medtronic personnel or healthcare professionals, or to support regulatory filings and the reimbursement of Medtronic products and services, based on Medtronic’s legitimate interests to do so.

For such purposes, your data will be used in a de-identified, aggregated or otherwise anonymized manner.

Telephonic contact.
By disclosing the phone number(s) you provide to Medtronic, we may contact those number(s), including via text, SMS, or voice call, for the transactional purposes defined in this Privacy Notice, as well as for responding to requests you make of Medtronic. If you provide an additional consent for marketing communications, Medtronic may then contact you by telephone for marketing, advertising, or offers of sale of Medtronic therapies or related services as well.

When making contact by telephone, Medtronic may use automated technologies (including recordings and auto-dialing), telephone, airtime, message, and data rates may apply. By providing your phone number(s) and/or consent(s), you certify that (a) you are age 13 and older, (b) the contact information you provide is yours, and (c) you authorize and consent to use of the information provided for Medtronic to contact you. Consent is not a condition for purchase or services. You may opt out of telephonic contact from Medtronic using automated technologies and for marketing communications at any time by (i) texting "STOP" in reply to a text message or (ii) for marketing messages, signing into your Medtronic profile and updating your communication preferences.

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When you use our healthcare professional education services, we may collect and use personal data to provide education, manage access, personalize learning, support events, and improve our services.

What personal data we obtain

  • Identification and contact information, such as your name, professional email address, phone number, country/region, preferred language, and account or registration details.
  • Professional information, such as your job title, healthcare profession, specialty, employer or medical institution, professional qualifications, and areas of interest.
  • Learning and event information, such as courses viewed or completed, event registrations, attendance, survey responses, learning preferences, knowledge or experience level, and requests for in-person training.
  • Technical and usage information, such as device and network identifiers, IP address, browser information, login activity, pages visited, content viewed, and interactions with education service features.
  • Communications and volunteered information, such as questions, feedback, comments, or other information you submit through forms, surveys, chats, or support channels.
  • Travel information, such as national ID or passport number, dietary and travel preferences, logistics and travel details, and expenses, where needed to organize or facilitate in-person training, events, or meetings.
  • Trainer or consultant information, such as basic identity information, contact details, professional activities and affiliations, professional qualifications, honoraria paid by Medtronic, and bank account information, if you are engaged by Medtronic to provide the services.
  • Images, video, and audio, such as photographs, video recordings, audio recordings, or image/audio/video transmitted through a platform. We will inform you if Medtronic intends to capture and record such personal data for further use.

How we use your data

  • Provide and manage your access to education services, including account administration, authentication, and service security.
  • Deliver educational content, courses, webinars, events, and related communications you request or register for.
  • Personalize your learning experience, including recommending relevant content based on your role, interests, knowledge, experience, or learning needs.
  • Coordinate digital or in-person training, events, or meetings, including trip logistics, travel arrangements, expense administration, and routing eligible requests to local Medtronic teams for follow-up.
  • Understand engagement with education services, measure learning effectiveness, perform analytics, and improve educational content, services, and user experience.
  • Administer contractual relationships with trainers or consultants engaged by Medtronic to provide the services, including payment of honoraria and related financial administration.
  • Respond to your questions, requests, feedback, or support needs.
  • Comply with applicable legal, regulatory, quality, and Medtronic policy obligations, and establish, exercise, or defend legal rights where necessary.

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We may collect and process your personal data for accounting and payment purposes.

What personal data we obtain

  • 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.
  • Health payer and claims information, including information on your provider, health condition and services rendered, health payer and your group, subscriber, account/member, and similar numbers or identifiers, claims history, financial assistance data, invoices, receipts, and payment information.

How we use your data

  • Submitting to your care provider or payer for payment for your health care services and products.
  • Accounting activities, including audits, investigations, insurance requirements, and general bookkeeping

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In some circumstances, we are obliged to 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, and any 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:

  • comply with applicable legal requirements, regulations, court orders or other legal processes.
  • comply with our policies.
  • establish, exercise or defend our legal rights.
  • conduct (internal) audits, investigations, or due diligence checks for the above reasons.

We will do so as necessary to comply with legal obligations to which we are subject in your country or region, or as needed to fulfil our legitimate interests, in particular in conducting business in compliance with all applicable laws and the highest ethical standards, protecting our rights or property; and asserting or defending legal claims, or with your consent where required by law.

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We may share relevant information and updates about our products and services, either via direct communication with you, or by using online advertisements. 

Direct Marketing Communications 

When we communicate with you directly to promote our product and service offerings (e.g., by email or phone), we will use your personal data to do so.

What personal data we obtain

The types of personal data we obtain or process about you to send you such communications include:

  • Information you have shared directly with us (e.g. when you complete a form to sign-up for such communications), such as your name,  email address and/or phone number, age and status as a patient or caregiver, or – if you are a business customer, your professional details;
  • Information that we have obtained through our interactions with you, such as expressions of interest you have made to our sales representatives;
  • Publicly available information about you (e.g. from the public website of the medical institution where you work);

Metadata collected from cookies or similar techniques, including to understand how you have interacted with our website and whether you have opened or clicked on the content in the emails that we have sent you). For more information on how we use cookies, and your choices in that regard, please click here.

How we use your data

We use such information to tailor our communications to your specific interests and preferred method of communication, to avoid sending you communications that are not of interest or for which you have not consented, and to follow up with you on the subjects that appear to be most relevant and useful for you. To this end, we may organize the data we obtain into interest-based groups.

We will ask you to "opt-in" or consent to the use of your personal data for the purposes of such communications, where required by applicable laws. You can decide at any time to stop such communications by using the opt-out procedure provided in the relevant message (e.g., clicking the unsubscribe link in our promotional emails), or alternatively by contacting us as specified in the “How to Contact Us” section below. 

If permitted by applicable law, we may rely on our legitimate interests to carry out some of the activities mentioned above.

Please note that if you choose to no longer receive promotional messages from us, we may still continue to send you relevant information for other lawful purposes, such as to administer any account or contract you may have with us, send you communications of an operational nature (e.g., planned outage or updates), respond to your requests and as required by law (e.g. in case of a product recall). The Medtronic entity responsible for processing your data for the above purposes is the Medtronic affiliate contacting you (in practice, the Medtronic business entity of the country or region where you are located).

Online Advertising 

From time to time, you may come across Medtronic ads online, including on social media platforms. Such ads are often presented to you based on your perceived interests, as gathered from your activities on social media or browsing the internet. 

What personal data we obtain and how we use it

Online advertising may be based on your search terms (in the case of ads on search engines) or user information on online platforms (such as the email address associated with your social media account, the country or professional interests selected on a social media platform).

In some instances, we will use your email address to show you ads for our products and services on social media platforms. To do so, we will provide – in a secure manner – your email address to the social media platform. The social media platform will then match your email address with the personal data (such as email addresses) you provided to them and use that information to show you Medtronic ads or include, exclude, or find similar platform users for a particular Medtronic advertisement. For more information on how social media platforms use your data, please refer to their privacy notices.

We may also place on our websites or apps advertising cookies or similar technologies that are made available by social media platforms or other third parties. If you visit our websites or apps and accept those advertising cookies and similar technologies, where required by law, then the information they collect (such as device identifiers and information on the pages visited) may also be used to display relevant ads for our products and our services on the social media platform or third party’s site and create interest-based profiles for advertising purposes. Often Medtronic itself will not actually receive identifiable data about you when such ads are displayed, but we may be able to further tailor our advertising to you depending on what ads you have already seen, and we can receive aggregated statistics on how many ads have been viewed and clicked on, etc.

We will rely on your consent for the use of your data for online advertising purposes (e.g., when you accept advertising cookies), or otherwise on our legitimate interest to do so where legally permissible. You should be able to configure your cookie settings on websites that use tracking cookies for advertising purposes. For more information on how Medtronic uses cookies, and how to configure your preferences on Medtronic websites, please see our Cookie Policy.

The Medtronic entity responsible for processing your information for the above purposes is the entity placing the advertisement (i.e., the Medtronic business entity in your country or region). For advertising on social media and other platforms, the platform provider itself will also have responsibility for how the advertising on its platform works. Please refer to the policies, privacy controls, and notices on the platform itself for more information on how advertising may be displayed to you, and your choices in this regard. 

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We maintain official accounts on third-party messaging platforms. When you interact with us through these platforms, we may process information associated with your profile (such as your display name, username, user ID, or other account identifiers), as well as any information or messages that you voluntarily provide. We process this information solely for the purpose of responding to your inquiries and communicating with you.

Please note that the messaging platform you use may also collect and use your information according to its own privacy practices. We encourage you to review the privacy policy of the platform to learn more about how it handles your personal data.

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Data sharing

In the ordinary course of business in carrying out the purposes described in this notice, we may share your personal data with certain categories of third parties, including:

Medtronic affiliated companies

Given the corporate structure of Medtronic and its affiliates, your personal data may be shared with other affiliates within the Medtronic group.

Service providers

Medtronic may share personal data with relevant third-party service providers, who act on our behalf to fulfill the activities noted in this privacy notice, including IT providers, providers of communication tools and customer relationship management systems, survey tool providers or platforms, event organization management tool providers, outsourced operations such as email automation tool providers, cloud hosting service providers, and contract management platform providers.

Health care providers and regulators: As described above, Medtronic may disclose personal data to your physician to coordinate or manage your health care and related services. This may also include other health care provider(s) who, at your request, become involved with the management of your care, online account, or related services. Medtronic may also disclose your personal data to support the daily activities related to health care and other health oversight agencies such as government agencies to support with audits, investigations, and inspections.

Business partners and other specialists

To the extent relevant to our website, the Medtronic app, or our websites, Medtronic may share personal data with external organizations with which it has partnered (such as research partners and partners in co-branded initiatives), established contractual protections or benefits from statutory protections, and with external specialists or professional advisors within a particular field (such as lawyers, consultants, tax advisors, auditors, specialist delivery providers, banks, payment service providers, and benchmarking agencies). In cases where those third parties are independently responsible for the processing of your personal data, their privacy notice will apply to their processing of your data.

For legal and other related interests: Medtronic may share personal data where it is:

  • Required by law
  • Required to disclose and/or share your personal data with regulatory, public, or governmental authorities to comply with any law, regulation, court order, legal or government request
  • Allowed or required by law for public health purposes, including reporting complaints and quality issues to medical device regulators
  • Needed to protect its own or others vital interests, including the safety of life and property, or for investigating illegal or malicious activities, where allowed by law
  • Needed to exercise or defend legal claims
  • It is believed that disclosure is necessary or appropriate to prevent physical or other harm or financial loss
  • Needed with its corporate affiliates, who have the same privacy requirements
  • Needed to fulfill corporate transactions (such as mergers, acquisitions, dissolutions, or divestitures), as well as with companies with whom Medtronic is working on a potential or pending corporate transaction.

Others, per your request: With your consent, we will share your personal data with any other parties you choose, such as your caregivers.

If we share your personal data with third parties, we will require them to sign a data processing agreement or include data protection clauses in the cooperation agreement before proceeding. This ensures that the company assumes the applicable privacy protection obligations and responsibilities.

International transfers

In some cases, Medtronic may transmit, or store personal data collected with affiliates, vendors, or sites in other countries. We will only transfer personal data as allowed by applicable law to further the purposes set out in this document. Where personal data is transferred to another country, we take administrative and technical measures to ensure adequate safeguards and protections are applied as provided for by applicable law. In cases where personal data is transmitted to other countries, we will ensure that safeguards equivalent to those required by applicable data protection laws are in place. For more information on the safeguards implemented by Medtronic, please contact us via email at rs.globaldataprivacyoffice@medtronic.com.

Data retention

We will keep your personal data for so long as necessary to fulfill the purposes for which we are allowed to use them, as set out in this privacy notice. Your data may be kept longer in order to take into account applicable statute of limitation periods, or as otherwise required by law. For more information on the retention of your personal data, please contact us as indicated in the How to Contact Us section below.

Your privacy rights

You may have some of the rights below relating to your personal data, depending on applicable laws. Additional information may be found in the Specific Jurisdictions section.

  • Access your personal data and confirm how your personal data is being processed
  • Transfer or obtain a copy in a structured, machine-readable, or portable format.
  • Correct or amend if it is incomplete, inaccurate, or outdated
  • Request deletion of your personal data, which in some cases may be fulfilled by restricting, obfuscating, de-linking, or deidentifying that data.
  • Restrict or limit excessive or unlawful processing, where the accuracy of the data is contested
  • Object to or opt-out of processing in circumstances where Medtronic claims a legitimate interest in its processing and where your rights outweigh those of Medtronic, such as where that data is used for direct marketing (including email or telephonic marketing)
  • Withdraw (or manage) consent where it is the basis for processing, which may include cases where the data is sensitive or on children. Where consent is revoked, we will not further process that data unless required or otherwise permitted by applicable law

Exercising your rights

How to exercise your rights. You or your authorized agent may exercise these rights at any time by completing the Privacy Rights Request form, or by calling us at 1-866-639-6907.

Process. We will first confirm that we have received your request. For rights requests, we are required to verify your identity, your right to access the information requested, and, as applicable, your authorized agent’s authority to act on your behalf. We may need to ask you for additional information that will help us do so, including government-issued IDs containing your name and address, utility bills containing that same information, and/or unique identifiers like usernames. We will only use that additional information in the verification process, and not for any other purpose.

After the validation of identity and authority (including if we do not receive that information), we will process your request and then contact you with our response to your request, including any data and reasons for rejection as applicable, within the time required by applicable law. If we need more time, we will notify you in accordance with applicable law.

Fees. We may charge a reasonable fee in some geographies to process or respond to your request only if allowed by applicable law, for instance if it is excessive, repetitive, or manifestly unfounded. If a fee is warranted, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Additional Options. Depending on your jurisdiction, you may have additional options if you are dissatisfied with our response:

  • You may internally appeal or contact our Data Protection Officer if you disagree with a decision we made about your rights. Please include a copy of or reference to the decision.
  • You may also complain to a data protection or regulatory authority if you have further concerns about our data practices or our response to a request. If you need information about which authority may apply to you depending on your location and circumstances, please contact us.
  • You will not be discriminated against for your exercise of your rights.

Children and personal data online

We do not intentionally collect personal data from children (as defined by applicable law) unless we have received verifiable consent (from the parent or the child, depending on the requirements of applicable law) unless a legal requirement or vital interest applies. If you believe we have collected personal data from a child, please contact us using the information found in the “How to contact us” section.

Special provision for specific jurisdictions

Philippines

Medtronic Philippines Data Privacy Registration Certificate 

Updates to this privacy notice

This privacy notice may be updated periodically to reflect changes in our personal data practices. We will indicate at the top of the privacy notice when it was most recently updated.

How to contact us

If you have any questions about this policy or our privacy practices, please contact us. You can write to our Data Protection Officer at rs.askdpo@medtronic.com

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