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This Privacy Statement tells you how we use information that we collect about you through this Medtronic website from countries in Europe, the Middle East, and Africa as well as any mobile sites, applications ( "apps"), widgets, conferences, events, electronic newsletters, communications or other services (collectively the "Services") that link to this Privacy Statement. This Privacy Statement does not apply to situations where we have notified you that an alternative privacy statement applies.
You should review the privacy statement posted on other Medtronic websites when you visit them. This website and this Privacy Statement are intended for individuals located in Europe, the Middle East, and Africa.
We intend to deal with your information in a manner that is fair and in line with your expectations and encourage you to read and consider the information provided in this Privacy Statement to confirm that is the case.
The information we receive, and how we use it, depends on what you do when visiting our website. We collect and use non-personal information (information that does not identify you personally) differently to your personal information.
Personal information is information that can specifically identify you, such as your:
We collect personal information about our users in two ways:
We may use the information that you have shared with us through this website and relevant Services (other than sensitive information, which is discussed separately below) for the following purposes:
Medtronic may also use your personal information to the extent necessary to achieve the following legitimate interests, so long as compatible with your rights and expectations of privacy:
Medtronic also has legal grounds to use your personal information:
Where required by law, we will ask you to "opt-in" or affirmatively consent to the processing of your personal data for a particular purpose. For example, where the law so requires, we will only send you newsletters if you have subscribed to them.
Some types of personal information are sensitive information. Sensitive information is personal information revealing or relating to your health (such as your device serial number, or the date of an implant), genetic or biometric data, your racial or ethnic origin, religious or philosophical beliefs, sex life or sexual orientation, political opinions or trade union membership.
Medtronic will only collect and process your sensitive information:
For example:
Non-personal information is information that cannot identify you or be tied to you in any way. Therefore the non-personal information that we collect through this website does not identify you as an individual person, and will not be linked to you. It may include information such as the following:
If you visit our website to read or download information, such as information about a health condition or about one of our products, we may collect certain non-personal information from your computer. This information is collected from your computer's web browser. If you only read or simply click to download information on our website, we do not collect or learn your name, e-mail address, home address, or any other personal information about you. For more information about how we use cookies to collect information about visitors to our website, please click here.
We are always looking for ways to better serve you and improve our products, services and website experience. We will use non-personal information from you to make this website more useful to visitors. We may also use non-personal information for other business purposes. For example, we may use non-personal information or aggregate non-personal information to:
Medtronic may wish to provide you with educational materials or other information about our products and services, as well as information about clinical trials or the products and services of others that might be of interest to you, based on the information you have shared with us and that we have collected through cookies or similar techniques regarding your use of Medtronic websites, social media and blogs. For more information on how we use cookies, and your choices in that regard, please click here.
We will ask you to "opt-in" or affirmatively consent to the use of your personal information for the purposes of such communications, in accordance with applicable laws.
If at any time you decide not to receive any educational, commercial or promotional information related to our products and services or regarding the products or services of our affiliates or service providers, please email us at the contact details listed below and mention “OPT-OUT” in the subject of your email. Alternatively, you may use the opt-out procedure provided in any relevant message you receive from us.
Please note that if you opt not to receive promotional messages from us, we may still continue to send you relevant information for other lawful purposes, such as to administer any account you may have with us, to respond to your requests, to execute agreements with you, or to provide you with information that Medtronic is required by law to provide, e.g. regarding product recalls.
From time to time, we may invite you to participate in a survey to determine customer satisfaction levels, identify areas of potential improvement or to carry out market research. We may send you a specific invite to participate in such a survey on the basis of our legitimate interests in conducting the survey, or on the basis of your prior “opt-in” consent to receive such communications, in accordance with applicable laws. You may opt-out of receiving any such future communications in the manner detailed in the section above.
The personal data that is collected for the purpose of the survey may include your email address (including country location), phone number, professional role & specialization, survey results, and any free-text message you may have written in the survey.
We process your personal information as part of the survey for carefully considered and specific business purposes which are in our legitimate interests and which we believe also often benefit you, based on our assessment that our legitimate interests do not override your freedom and data protection rights.
The business purpose of collecting your data is to reply to survey feedback you may have provided, specifically:
Medtronic will not share your personal information with a third-party except as described in this Privacy Statement.
In the ordinary course of business, we may share some personal information with Medtronic affiliates or third party companies that we hire to perform services or functions on our behalf.
For example, we may:
In all cases we will not share more information than is necessary, and we will not authorize any third parties to keep, disclose or use your information except to provide the requested services in line with the purposes set out above.
Please note that subject to applicable laws, we may disclose your personal information if we believe we are required to do so to comply with any law, regulation, court order, legal or government request. In the unlikely event that all or part of our business is acquired by a third party, your information may be transferred to the new corporate owner insofar as relevant to the business in question and subject to appropriate safeguards being in place.
In addition, we may use and disclose your personal information to third parties if necessary to:
In addition, please keep in mind that certain areas of our website may be interactive in nature, and allow you to post information that other users can see. If you do not wish to have information viewed publicly, please do not use those sections of the website.
In certain cases Medtronic may transmit personal information collected on this website to our affiliates or third party service providers in other countries, but only in furtherance of the purposes set out in this Privacy Statement. In cases where personal information is transmitted outside the jurisdiction where the you are located to other countries we will ensure that such transfer is done on the basis of approved legal mechanisms under applicable data protection laws, and with regulatory approval in circumstances where required by applicable data protection laws. For more information on the safeguards implemented by Medtronic please contact rs.privacyeurope@medtronic.com.
We will only keep your personal information for so long as necessary to fulfill the purposes for which we are allowed to use them, as set out in this Privacy Statement. For example, if you tell us that you no longer wish to receive a newsletter from us, we will immediately delete your email address from our mailing list. In case you participate in a program via our website we will delete the personal information provided as part of that program within a reasonable time after its completion (e.g. six months after completion will normally be considered reasonable unless we have lawful grounds to retain some of the information for longer (e.g. if necessary for validation or to comply with recordkeeping obligations)).
This Privacy Statement is published on July 19th, 2021. We recognize that data protection is an ongoing responsibility, so we will update this Privacy Statement in case we undertake new processing practices with your personal information or adopt new privacy policies. We encourage you to review this Privacy Statement each time you visit the website.
This website may contain links to other websites. Some of those websites may be operated by Medtronic affiliates, and some may be operated by third parties. This Privacy Statement does not apply to other websites, even other Medtronic websites. Therefore, whenever you leave this website we recommend that you review the privacy practices that apply to information you provide on other websites. We provide the links for your convenience, but we do not review, control, or monitor the privacy practices of websites operated by others. Neither are we are responsible for websites operated by third parties or your business dealings with them.
We care about protecting the online privacy of children. We will not intentionally collect any personal information (such as a child's name or e-mail address) from children under the age of 16 without the consent of someone holding parental responsibility. If you think that we have otherwise collected personal information from someone under the age of 16, please Contact Us.
Security is very important to us. We also understand that security is important to you. We use industry standard measures to protect your personal information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However no website or email transmission is 100% secure and we encourage you to therefore take special care in deciding what information you send or request via email, and take appropriate precautions such as keeping any usernames and passwords you use confidential.
Subject to applicable law, you may have the right to:
Please note that we may keep using aggregated data (statistics, trends), even after you request deletion of your personal information or withdraw your consent, as there may be no technical means available to isolate or identify the data elements to exclude.
You may also at any time, free of charge and without having to provide any justification, opt-out of any direct marketing campaigns and request to no longer receive any promotional material as described above.
Please note that the above rights are generally applicable to the Services offered to our customers in Europe but may be limited in some other jurisdictions according to applicable law. To exercise these rights, or for more information, please send an email to rs.privacyeurope@medtronic.com
Please note that in accordance with applicable laws, we may ask you to provide some proof of identity (such as a copy of your ID card or passport) before we can process your request.
In case you are not satisfied with our handling of your request you may contact the applicable Data Protection Authority.
The Services are facilitated and carried out by the Medtronic entity identified in contractual documentation or other documentation provided in connection with the Services.
Medtronic’s EU Headquarters is located at
Medtronic International Trading Sárl
Route du Molliau 31
CH - 1131 Tolochenaz
Switzerland
Medtronic’s CEMA Headquarters is located at
Medtronic META FZ-LLC
Dubai Knowledge Park Dubai,
Dubai 500638
UAE
Email rs.privacyeurope@medtronic.com