Medtronic privacy notice
For medtronic.com and related sources within the United States
Last updated: October 2024
For medtronic.com and related sources within the United States
Last updated: October 2024
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 the United States.
Unless set out otherwise below, the Medtronic company responsible for processing your personal data is Medtronic Inc. (together “Medtronic,“ “we,” or “us”).
In this privacy notice, we will 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. Medtronic and some of its affiliates, including Medtronic Minimed™, and our international affiliates, also operate other websites.
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. It also 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 Ask HR.
This section describes how Medtronic uses your personal data to provide you with therapies and related services. Unless we need your personal data in order 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. The following situations are discussed in more detail below:
When you visit our websites or apps, we may collect and/or process your personal data (from your interaction with our sites) to learn more about how you use our site/app and services.
What personal data we obtain
How we use your data
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 setting and preferences.
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
How we use your data
You may make an inquiry, or require assistance or support, by contacting our customer service or support team by phone or email, or by using our “How to contact us” form, our chat tools, and automated communications assistants, 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.
How we use your data
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. Contact your medical institution or healthcare professional to learn more about their use of your data for the provision of medical treatment or care.
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, which may be obtained from your interactions with or submissions to our site, your account, your medical device’s registration or telemetry data, or from your healthcare provider(s), as well as from information you communicate to us or post on a public forum, include:
How we use your data
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:
How we use your data
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.
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).
When you visit our websites or apps, we may collect 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. While personal data collected through these technologies is not shared for money or other similar compensation, the use of these technologies may be considered personal data sharing under applicable law. The types of technologies, purposes of use, parties involved, and controls available to you, which may vary across our digital offerings, are detailed in our cookie policy.
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 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 from that interaction include:
How we use your data
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:
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.
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 a 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 from your participation include:
How we use your data
We will use your data to organize and facilitate the event/interview, and conduct our educational, promotional, and advertising activities.
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:
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.
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:
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 except if required for the purposes of the study.
If you’re a healthcare professional involved in our (clinical) research activities, the types of personal data we obtain or process about you include:
How we use your data
We will do so based on your consent or as required by applicable law in conducting research activities, for scientific research, or to ensure high standards of quality and safety of our products and services.
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.
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:
How we use your data
We will use your information — in an anonymized, de-identified or redacted form, where appropriate — in order to:
With the authorization of your medical institution, the data obtained as part of the services provided to your medical institution may be further used to support and improve those services, 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.
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, and for additional purposes for which you have provided your consent. You can choose to withdraw or withhold your consent. However, where your sensitive data is necessary to provide you with services, you will not be able to use those services.
We may ask that you, your caregiver, your account administration, or any individual authorized by you not to send or disclose any other personal data other than the data that we may ask you to provide.
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, we may use automated technologies (including recordings and auto-dialing), and 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 texting ”STOP” in reply to a text message or for marketing messages, signing into your Medtronic profile and updating your communication preferences.
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:
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.
For more information on Medtronic affiliates (including those affiliates to whom personal data may be transferred) please consult Exhibit 21 of the most recent annual 10-K filing, available at SEC Filings.
We will only 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 archived for 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, contact us as indicated in the “How to contact us” section below.
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.
How to exercise your rights. You or your authorized agent may exercise these rights at any time or contact us with any inquiries through the methods provided in the “How to contact us” section below.
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. This does not necessarily include, depending on applicable law in your jurisdiction, cases where a difference in price or services offered is reasonably related to the value provided by your data, or where you consent to participate in a voluntary loyalty or similar incentive program.
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, contact us using the information found in the “How to contact us” section.
United States of America
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. You can read the previous version of our privacy notice here.
If you would like to exercise your privacy rights or if you have any questions about this privacy notice you may contact us as follows:
General inquiries (all geographies): By email.
U.S. inquiries: By email via the general inquiries email address or phone: 866-639-6907. You may also send mail to our general-purpose corporate mailing address:
Medtronic, Inc.
710 Medtronic Parkway Northeast,
Fridley, Minnesota 55432-5603,
USA