Statement of Privacy Principles

In this Statement of Privacy Principles, we describe how Medtronic processes personal information. Preservation of, and respect for, our customers', business colleagues and vendors', and patients' trust is critical to our continued success. We will always process personal information:

Confidentiality and fairly
Appropriately, according to the statements we make
Lawfully, in accordance with applicable data protection laws, directives, regulations and principles

Version: May 2018

May 2018–today

Introduction

Please read this privacy statement carefully

This Privacy Statement tells you how we use information that we collect about you through this Medtronic website operated by Medtronic Limited based in United Kingdom. This Privacy Statement does not apply to situations where we have notified you that an alternative privacy statement applies, nor does it apply to other Medtronic websites, including websites operated by other Medtronic affiliates, including Covidien. You should review the privacy statement posted on other Medtronic websites when you visit them. This website and this Privacy Statement are intended for a UK audience.

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.

What information do we collect about you?

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.

Your personal information

Personal information is information that can specifically identify you, such as your:

first and last name
address, telephone number, e-mail address or other contact information
medical device serial number
personal health information
date of birth or age
social media username or profile
interests and qualifications
IP (Internet Protocol) address when such address is associated with a specific user

We collect personal information about our users in two ways:

when you enter personal information on certain pages of the website. For example, you may fill out a registration form for a particular service, participate in a survey, or complete a contact form.
using automated means, specifically through cookies. Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the website. For more information about cookies, please click here.

How does Medtronic use personal information?

We may use the information that you have shared with us through this website (other than sensitive information, which is discussed separately below) for the following purposes:

to respond to your requests
to provide the services or information you request
to allow you to register certain products or services, or enhance their functionality
to resolve and track the status of any consumer and/or product or service issues
to manage our relationship with you and facilitate any necessary follow up (e.g. by storing relevant information and preferences for a reasonable amount of time)
to enter into, or perform a contract with you (e.g. in case you wish to order products or services from us)
to enable you to participate in our online communities, including social media and blogs
to contact you with information that might be of interest to you – see further the Marketing and Education section below
In other ways to which you consent

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:

for analytical purposes in order to research, develop and improve programs, products, services and content
to anonymize your information by removing any personal identifiers (your name, e-mail address, social security number, etc.) so that it may be used for other purposes. In this case, the anonymized information would no longer identify you and may be treated like other non-personal information. For more details please see the relevant section below.
to enforce this Privacy Statement and other rules about your use of this website
to protect our rights or property

Medtronic also has legal grounds to use your personal information:

as necessary to protect someone's health, safety or welfare; and
in order to comply with a law or regulation, court order or other legal process

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.

What is sensitive information?

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.

Will Medtronic treat sensitive information differently to other personal information?

Medtronic will only collect and process your sensitive information:

in ways for which you have given your explicit consent
to protect the vital interests of you or another person, in cases where your explicit consent cannot be given or reasonably requested
according to applicable laws which include suitable and specific measures to safeguard your fundamental rights and interests
where the processing is necessary for medical purposes and we are, under the circumstances, under a duty of confidentiality equivalent to the duty of confidentiality of a health professional
to establish, exercise, or defend a legal claim

For example:

We may collect sensitive information directly from you, when you voluntarily provide it to us for a particular purpose (e.g. when you contact us with a question or suggestion about our products and services);
We may also collect sensitive information about patients through healthcare professionals who we work with to provide therapy or technical support for our products or services to you;
We may collect sensitive information as required by European, and other governmental authorities in order to assure safe and effective use of our products and services;
We may collect sensitive information about participants who have explicitly consented to participate in clinical trials, studies, and other research initiatives.

Non-personal information

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:

the type of web browser software you use (for example, Internet Explorer)
the name of the domain from which you access the Internet
the Internet address of the website from which you linked directly to our website
the date and time you access our website
which pages you have visited on our website
he search terms you use
the links on which you click

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.

What does Medtronic do with non-personal information?

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:

create reports for internal use to develop programs, products, services or content
adapt or improve the information or services provided
share or sell information to third parties
provide information on how our site is used, such as "traffic statistics" and "response rates" to third parties

Direct marketing and educational materials

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.

Does Medtronic ever share personal information with third parties?

Medtronic will not share your personal information collected from this website 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:

use different vendors or suppliers to ship you products that you order on our website. In these cases, we provide the vendor with information to process your order such as your name and mailing address.
use a service provider to administer certain newsletter or informational mailings that you have signed up for, and provide access to your email address for this purpose.
use a third-party application or platform to allow us to manage and keep track of our communications with you.
use our company affiliates to provide services relating to your personal information e.g. we may store your information on a secure server based at our affiliate’s site in Europe or the United States. For more information on the circumstances in which we may transfer your information to other countries, please see the relevant section below.

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:

enforce this Privacy Statement and the other rules about your use of this website
protect our rights or property
protect someone's health, safety or welfare
comply with a law or regulation, court order or other legal process
investigate or take action in cases of suspected fraud or illegal activities

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.

Do we transfer personal information to other countries?

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 from Europe to other countries we will ensure that safeguards equivalent to those provided by European data protection laws are in place. For more information on the safeguards implemented by Medtronic please Contact Us.

How long will we keep your personal information for?

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).

What happens if the privacy statement changes?

This Privacy Statement was last revised on May 15, 2018. We may change this Privacy Statement at any time and for any reason. If we decide to make a significant change to our Privacy Statement, we will post a notice on the homepage of our website for a period of time after the change is made. We encourage you to review this Privacy Statement each time you visit the website.

What about privacy on other websites?

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.

Are there special rules about children's privacy?

We care about protecting the online privacy of children. We will not intentionally collect any personal information (such as a child's name or 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.

What about website security?

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.

Your rights

At any time, you may exercise your right to access, rectify and, as the case may be, erase, any personal information relating to you, or restrict the processing of your personal information, in compliance with applicable laws.

You also have the right at any time to object, based on your particular situation, to any use or processing of your personal information which we have based on our legitimate interests.

In case we are processing your personal information in an automated manner as part of a service to you or based on your consent then you also have the right to request a copy of your information in a structured, commonly used and machine-readable format (known as the right to “data portability”).

Such requests can be sent to rs.globaldataprivacyoffice@medtronic.com or in writing to Attn: Data Protection Officer, Building 9, Croxley Park, Watford, Herts, WD18 8WW, UK. Please note that we may ask you to provide proof of identity (such as a copy of your ID card or passport) before we can comply with your request.

If we have based our collection or use of your personal information on your consent then you also have the right to withdraw your consent at any time in the same way as it was given, or by sending a request in the above manner.

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.

In case you are not satisfied with our handling of your request you may contact the applicable Data Protection Authority. See further: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm

How to contact Medtronic

If you have questions or comments about this Privacy Statement, please Contact Us through our website or via the contact details listed in the Your Rights section above.

until May 2018

Who is Medtronic?

Medtronic is the name we use to refer to our whole business, including Medtronic, Inc., a corporation based in the United States of America, and any of the companies that it controls such as its subsidiaries and affiliates. When we use the words we or our, we mean Medtronic.

When do these privacy principles apply?

These Privacy Principles apply when we process personal information collected from nations in Europe. These Privacy Principles apply to data when we collect it directly from the person who the data identifies, and also when we collect data from one person (or company) that identifies another person. Therefore, when we use the word "you", "me", and "I" in this Statement of Privacy Principles, we mean the individual whose personal information we are processing, whether we collect that information directly from the individual or indirectly from someone else.

This statement of privacy principles does not apply when we process information

about our employees in the scope of their employment relationship with us
where we have given other disclaimers, policies, terms of use, or other notices indicating that this policy does not apply, or that a different policy or notice does apply
that does not identify you as an individual person, including to personal information (which we define below) that we have de-identified, so that it no longer can be used to identify you

What is data processing?

Data processing is any set of operations involving personal information, whether or not by automatic means, including collecting, using, disclosing, adapting, altering, correcting, retrieving, combining, blocking, erasing, transferring, destroying, recording, organizing, storing, and using personal information.

What is personal information?

Personal information is information relating to you that we can use to specifically identify you, such as your:

name
telephone number
e-mail address
date of birth
address
social security number or other national identifier
account number
Any other information that identifies or could identify you and relates to you

Some kinds of personal information are sensitive information. Sensitive information is defined below. In this Statement of Privacy Principles, when we use the phrase personal information, we include sensitive information unless we specifically state otherwise.

When and how does Medtronic collect personal information?

Medtronic may collect personal information in a variety of ways. For example:

In some places on our web sites you have the opportunity to send us personal information about yourself. For example, you may fill out a registration form, a survey or an e-mail form. You also may choose to allow us to personalize your visits to the web sites, in which case we will ask you for certain personal information to make your visits to our web sites more helpful to you. When this information is combined with the non-personal information that we collect through cookies, we will be able to tell that you have visited our web sites before.
We may collect personal information from you when you contact us for information, products, or services.
We may collect personal information about you in the course of engaging in commercial transactions with our customers, vendors, and other business contacts.

How does Medtronic process personal information?

We may process your personal information (other than sensitive information, which is discussed separately below):

to respond to your requests and enquiries
to perform a contract or for contract negotiations with or about you
to develop records, including records of your personal information
to contact you by mail (or in other ways with your permission) with information that might be of interest to you, including information about clinical trials and about products and services of ours and of others
for analytical purposes and to research, develop and improve programs, products, therapies, services and content
to remove your personal identifiers (your name, e-mail address, social security number, etc). In this case, you would no longer be identified as a single unique individual. Once we have de-identified information, it is non-personal information and is not subject to this Statement of Privacy Principles
to personalize your access to our web sites, for example, by telling you about new features that may be of interest to you
to enforce this Statement of Privacy Principles and otherwise protect our rights or property
to protect your vital interests or someone else's health, safety or welfare
to comply with a law or regulation, court order, or other legal obligation
for our other legitimate interests, unless such processing will unfairly prejudice your rights or freedoms
in other ways to which you consent

What is sensitive information?

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), your racial or ethnic origin, religious or philosophical beliefs, sex life, political affiliation, or trade union membership.

Will medtronic collect or process sensitive information any differently than other personal information?

Medtronic will only collect and process your sensitive information:

in ways for which you have given your explicit consent
to protect your vital interests, in cases where your explicit consent cannot be given or reasonably requested
according to national law
where the processing is necessary for medical purposes and we are, under the circumstances, under a duty of confidentiality equivalent to the duty of confidentiality of a health professional
to establish, exercise, or defend a legal claim

For example:

We may collect sensitive information about patients from our customers, vendors, or other business contacts when we provide therapy or technical support for our products or services to you
We may collect sensitive information about patients when we receive questions and suggestions about our products and services
We may collect sensitive information as required by the U.S. Food and Drug Administration, European, and other governmental authorities in order to assure safe and effective use of our products and services
We may collect sensitive information about participants in clinical trials, studies, and other research initiatives
We may collect sensitive information directly from you, when you voluntarily provide it to us

Will medtronic ever use personal information to contact me with marketing messages?

We may contact you periodically in person, by e-mail, by fax, by mail, or by telephone to provide information regarding programs, products, services and content that may be of interest to you, unless you advise us that you do not wish to receive marketing or market research communications from us. If applicable law requires that we receive your explicit consent before we send you certain types of marketing communications, we will only send you those types of communications after receiving your explicit consent.

What if i no longer wish to receive marketing messages from medtronic?

If you wish to stop receiving marketing or market research communications from us, or would like us to stop processing your personal information in any other way, you can contact us as described at the bottom of this Statement to let us know what types of communications you wish to stop receiving. In addition, if you have received, or in the future receive, an e-mail from us, each e-mail we send includes an easy, automated way for you to cease receiving e-mails from us.

Does medtronic ever share personal information with third parties?

Medtronic will not share your personal information with an unrelated third party without your permission, except as otherwise provided in this Statement of Privacy Principles.

In the ordinary course of business, we will share some personal information with companies that we hire to perform services or functions on our behalf. For example, we may use different vendors or suppliers to ship our products. In these cases, we provide the vendor or supplier with information to process your order such as your name and mailing address. In all cases in which we share your personal information with a third party, we will not authorize them to keep, disclose or use your information with others except for the purpose of providing the services we asked them to provide.

We will not sell, exchange or publish your personal information, except in conjunction with a corporate sale, merger, dissolution, or acquisition.

We may be legally compelled to release your personal information in response to a court order, subpoena, search warrant, law, or regulation. We may cooperate with law enforcement authorities in investigating and prosecuting web sites visitors who violate our rules or engage in behavior which is harmful to other visitors (or illegal).

We may disclose your personal information to third parties if we feel that the disclosure is necessary to:

enforce this Statement of Privacy Principles
protect our rights or property
protect someone's health, safety or welfare
comply with a law or regulation, court order, or other legal process

Will medtronic ever transfer personal information about me to countries other than the country where i am located?

Medtronic may transfer information out of the country in which it was collected to any country or territory in the European Economic Area and to any other country that is recognized by the European Union as having adequate privacy protections. We will transfer information to other areas only if:

the transfer is necessary for the performance of a contract between you and Medtronic or for pre-contractual measures taken in response to your request; or
if you consent to the transfer; or
if the data will be adequately protected in the other country, by contract or other protection

Medtronic has arrangements with all of its offices and affiliates that assure that personal information transferred among Medtronic companies is adequately protected, including transfers of personal information (which may include sensitive information) to Medtronic companies in the United States of America.

What happens if the statement of privacy principles changes?

If we decide to make a significant change to this Statement of Privacy Principles, we will describe any major changes in this section of the Statement. You can always find the most current copy of this Statement and its history on the website for your country, or contact us at the address below.

What about the security of personal information?

We use reasonable physical, administrative, and technical safeguards to protect your personal information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. We also restrict access to your personal information to those employees and contractors who need to know that information to do their jobs. You should keep in mind that no Internet transmission is ever 100% secure or error-free. In particular, e-mail sent to or from us may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail.

How long will Medtronic maintain my personal information?

We will not keep information for any longer than is required. In many cases, personal information must be kept for considerable periods of time in order to make it available as and when questions or disputes arise. Retention periods will be determined for each personal information that is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable opportunity.
We will continue to treat your personal information in accordance with this Statement of Privacy Principles so long as we retain it.

Are there any additional privacy principles relating to Medtronic web sites?

Links. Our web sites may contain links to web sites operated by other parties. We provide the links for your convenience, but we do not review, control, or monitor the privacy practices of web sites operated by others. We are not responsible for the performance of web sites operated by third parties or for your business dealings with them.

Our web sites also may contain links to other web sites operated by Medtronic. This Statement of Privacy Principles applies only to web sites for Medtronic companies located in Europe, and there may be slight variations in the Statement as posted in specific countries in Europe. Therefore, whenever you follow a link from this web site to another web site, even to another site operated by Medtronic, we recommend that you review that web site's privacy practices.

Cookies

Medtronic may use cookies on its web sites. Cookies are text files we place in the browser files of your computer when you visit. The cookies may be stored on your computer's hard drive. The information that we collect using cookies is non-personal information. You are always free to decline our cookies if your browser permits, but some parts of our web sites may not work properly for you if you do so. We will not allow third parties to place cookies on our web sites.

How to contact Medtronic

We strive to keep our records of your information accurate. If you ever notice that your information is not complete, accurate or current, or if you have questions or comments about this Statement of Privacy Principles, please contact us at:

Medtronic Africa
Waterfall Distribution Campus,
Cnr Bridal Veil Road & K101 Pretoria Main Road,
Midrand, Gaueng, 1685 |
South Africa
Office +2711 260 9300